APPENDIX C1

Technical Support Document for the Development of the 

2007 Emission Inventories for Regional Air Quality Modeling 

in the Northeast/Mid-Atlantic Region Version 3.3 

(AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012) 

Bureau of Air Quality 

Department of Environmental Protection 
[This page intentionally left blank.] 
Technical Support Document 

for the 

Development of the 2007

Emission Inventory 

for Regional Air Quality Modeling 

in the Northeast / Mid-Atlantic Region 

Version 3.3 

Prepared for: 

Mid-Atlantic Regional Air Management Association (MARAMA) 

8600 LaSalle Road, Suite 636 

Towson, MD 21286 

(443) 901-1882 

January 23, 2012 

MARAMA Contract Agreement FY2011-004 

Submitted by 

AMEC Environment & Infrastructure SRA International, Inc. 

4021 Stirrup Creek Drive 652 Peter Jefferson Parkway 

Suite 100 Suite 300 

Durham, NC 27703 Charlottesville, VA 22911 

919 381-9900 571 499-0833
Acknowledgements 

This work was supported by funds provided to MARAMA by the U.S. Environmental Protection 

Agency under assistance agreement XA 97351101 – Regional Cooperation and Assistance for 

Clean Air Act Implementation and by MARAMA’s Memorandum of Agreement with the Ozone 

Transport Commission (OTC), which is funded by USEPA grant agreement XA973181 – 

Regional Haze Planning in the Northeast and Mid-Atlantic States (CFDA 66.034). 

About MARAMA 

The Mid-Atlantic Regional Air Management Association, Inc. is a voluntary, non-profit 

association of ten state and local air pollution control agencies. MARAMA's mission is to 

strengthen the skills and capabilities of member agencies and to help them work together to 

prevent and reduce air pollution in the Mid-Atlantic Region. MARAMA provides cost-effective 

approaches to regional collaboration by pooling resources to develop and analyze data, share 

ideas, and train staff to implement common requirements. 
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

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Table of Contents 

1.0 INTRODUCTION.................................................................................................................. 1

1.1 INVENTORY PURPOSE ................................................................................................ 1

1.2 POLLUTANTS ................................................................................................................ 2

1.3 SOURCE CATEGORIES ................................................................................................ 2

1.4 DATA FORMATS ........................................................................................................... 3

1.5 SUMMARY OF INVENTORY DEVELOPMENT PROCESS ............................................ 4

1.6 REPORT ORGANIZATION ............................................................................................. 4

2.0 ANNUAL 2007 INVENTORY FOR POINT SOURCES ......................................................... 6

2.1 INITIAL DATA SOURCES AND QA REVIEW .................................................................. 6

2.1.1 Initial State NIF Submittals ...................................................................................... 6

2.1.2 EPA CAMD Hourly Emissions Data ........................................................................ 7

2.2 PM AUGMENTATION .................................................................................................... 9

2.2.1 EGU PM Augmentation ..........................................................................................12

2.2.1.1 EGU Condensable Emission Factors .................................................................12

2.2.1.2 EGU Heat Input .................................................................................................14

2.2.1.3 EGU PM Emission Calculations .........................................................................14

2.2.2 NONEGU PM Augmentation ..................................................................................17

2.2.2.1 Initial QA and Remediation of PM Pollutants ......................................................17

2.2.2.2 Updating of PM Factor Ratios ............................................................................17

2.2.2.3 NonEGU PM Emission Calculations...................................................................18

2.3 EMISSION RELEASE POINT QA CHECKS...................................................................20

2.3.1 QA Checks and Gap-Filling for Location Coordinates ............................................20

2.3.2 QA Checks and Gap-Filling for Emission Release Parameters ..............................21

2.4 IDENTIFICATION OF EGUS AND NONEGUS ...............................................................26

2.5 VERSION 2 - STAKEHOLDER COMMENT AND RESPONSE .......................................26

2.5.1 Connecticut Response to Stakeholder Comments .................................................26

2.5.2 Maryland Response to Stakeholder Comments .....................................................27

2.5.3 Massachusetts Response to Stakeholder Comments ............................................28

2.5.4 New Jersey Response to Stakeholder Comments .................................................28

2.5.5 New York Response to Stakeholder Comments ....................................................30

2.5.6 Pennsylvania Response to Stakeholder Comments ...............................................30

2.5.7 Virginia Response to Stakeholder Comments ........................................................31

2.6 VERSION 2 - ADDITIONAL STATE-SPECIFIC UPDATES ............................................32

2.6.1 Connecticut ............................................................................................................32

2.6.2 Delaware ...............................................................................................................33

2.6.3 District of Columbia ................................................................................................33

2.6.4 Maine .....................................................................................................................33

2.6.5 Maryland ................................................................................................................33
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2.6.6 Massachusetts .......................................................................................................33

2.6.7 Maine .....................................................................................................................34

2.6.8 New Hampshire .....................................................................................................34

2.6.9 New Jersey ............................................................................................................34

2.6.10 Pennsylvania – Allegheny County ......................................................................34

2.6.11 Pennsylvania - Philadelphia ...............................................................................35

2.6.12 Rhode Island ......................................................................................................35

2.6.13 Vermont .............................................................................................................35

2.6.14 Virginia ...............................................................................................................35

2.7 VERSION 3 REVISIONS ...............................................................................................36

2.7.1 Emission Offsets ....................................................................................................36

2.8 ANNUAL 2007 POINT SOURCE EMISSION SUMMARY ...............................................36

3.0 HOURLY 2007 INVENTORY FOR LARGE POINT SOURCES ..........................................44

3.1 DATA SOURCES FOR HOURLY EMISSIONS ..............................................................44

3.1.1 2007 Annual Emission Inventory ............................................................................44

3.1.2 EPA CAMD Hourly Database .................................................................................44

3.1.3 Virginia Hourly Data for Distributed Generation Units ............................................45

3.1.4 Maryland Hourly Data for Six Month Reporters ......................................................45

3.2 METHODOLOGY FOR DEVELOPING HOURLY SMOKE FILES ..................................46

3.2.1 Conversion of Annual NIF Inventory to SMOKE ORL Format for PTINV ................46

3.2.2 PTHOUR Methodology for 12 Month Reporters .....................................................49

3.2.3 PTHOUR Methodology for 6 Month Reporters .......................................................50

3.2.4 PTHOUR Methodology for Maryland 6 Month Reporters .......................................51

3.2.5 PTHOUR Methodology for Virginia Distributed Generation Units ...........................52

3.2.6 QA of PTINV and PTHOUR Files ...........................................................................52

3.3 DEVELOPMENT OF HOURLY PROFILES FOR 6-MONTH REPORTING UNITS ..........53

3.3.1 Annual Profile Preparation .....................................................................................53

3.3.2 Non-Annual Profile Development ...........................................................................55

3.3.3 Issue for Consideration ..........................................................................................56

3.4 VERSION 2 - STATE AND STAKEHOLDER REVIEW ...................................................56

3.4.1 Massachusetts .......................................................................................................56

3.4.2 New York ...............................................................................................................56

3.4.3 Pennsylvania .........................................................................................................57

3.4.4 Virginia ..................................................................................................................57

3.5 VERSION 3 REVISIONS ...............................................................................................58

3.5.1 Massachusetts Stony Brook Energy Center NH3 Emissions ..................................58

4.0 ANNUAL 2007 INVENTORY FOR AREA SOURCES ........................................................59

4.1 AREA SOURCE CATEGORIES.....................................................................................59

4.2 USEPA AREA SOURCE DATA .....................................................................................64
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4.2.1 USEPA 2008 National Emission Inventory .............................................................65

4.2.2 EPA Residential Wood Combustion (RWC) Tool ...................................................65

4.2.3 EPA CMU Agricultural Ammonia Model .................................................................66

4.2.4 EPA SMARTFIRE Emissions Database .................................................................66

4.3 STATE-SPECIFIC DATA ...............................................................................................67

4.4 VERSION 2: STATE AND STAKEHOLDER REVIEW AND COMMENT .........................72

4.4.1 National Park Service Comments ..........................................................................72

4.4.2 Checks for Missing Categories, Double Counting, Outliers, and Differences 

between 2002 and 2007 Inventories ..................................................................................72

4.5 VERSION 3 REVISIONS ...............................................................................................73

4.5.1 Use of New USEPA Road Dust Equation...............................................................73

4.5.2 Use of MOVES Model to Estimate Stage II Emissions ...........................................74

4.5.3 Connecticut Changes for Fuel Combustion ............................................................75

4.5.4 Connecticut Revisions for AIM Coatings and Auto Refinishing ...............................76

4.5.5 District of Columbia Residential Wood Combustion ...............................................77

4.5.6 Maryland Degreasing VOC Emisions .....................................................................77

4.5.7 Massachusetts NH3 Emisions ...............................................................................77

4.5.8 New Jersey Bakeries and Auto Refinishing VOC Emisions ....................................77

4.5.9 New York VOC Emisions from Residential Wood Combustion ...............................77

4.5.10 Pennsylvania Industrial Coal Combustion ..........................................................77

4.5.11 Pennsylvania Residential Distillate Oil Combustion ............................................77

4.5.12 Virginia Industrial Coal Combustion ...................................................................77

4.5.13 Multiple States Open Burning and Commercial Cooking ....................................78

4.6 ANNUAL 2007 AREA SOURCE EMISSION SUMMARY ................................................78

5.0 ANNUAL 2007 INVENTORY FOR NONROAD SOURCES INCLUDED IN THE NONROAD 

MODEL .....................................................................................................................................87

5.1 NONROAD MODEL CATEGORIES ...............................................................................87

5.2 VERSION 2 INVENTORY DEVELOPMENT ..................................................................87

5.2.1 State Review of NMIM Meteorology Data and Fuel Characteristics .......................87

5.2.2 Update of NMIM Allocation Files for Population and Housing ................................88

5.2.3 State-Specific Data Incorporated in NMIM .............................................................89

5.2.3.1 Connecticut ........................................................................................................89

5.2.3.2 Delaware ...........................................................................................................89

5.2.3.3 Maryland ............................................................................................................90

5.2.3.4 New Hampshire .................................................................................................90

5.2.4 New Jersey ............................................................................................................90

5.2.4.1 New York ...........................................................................................................90

5.2.4.2 Pennsylvania .....................................................................................................91

5.2.5 NMIM Run Specification ........................................................................................91

5.2.6 State and Stakeholder Review of Version 2 ...........................................................92
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5.2.6.1 Connecticut ........................................................................................................92

5.2.6.2 New Jersey ........................................................................................................92

5.2.7 Removal of Airport Ground Support Equipment Emissions ....................................92

5.3 CHANGES MADE FOR VERSION 3 ..............................................................................92

5.4 SUMMARY OF NMIM MODELING RESULTS FOR 2007 ..............................................92

6.0 ANNUAL 2007 INVENTORY FOR NONROAD SOURCES –MARINE VESSELS, 

AIRPORTS, AND RAIL ..........................................................................................................102

6.1 COMMERCIAL MARINE VESSELS .............................................................................102

6.2 AIRPORTS (AIRCRAFT AND GROUND SUPPORT EQUIPMENT) .............................104

6.3 RAILROAD LOCOMOTIVES AND RAILYARDS ..........................................................106

6.4 STAKEHOLDER REVIEW AND COMMENT ................................................................107

6.5 VERSION 3 REVISIONS .............................................................................................107

6.5.1 New Jersey MAR Revisions .................................................................................107

6.5.2 Adjustment of Rail VOC Emissions ......................................................................108

6.6 SUMMARY OF MAR INVENTORY FOR 2007 .............................................................108

7.0 ANNUAL 2007 INVENTORY FOR ONROAD SOURCES.................................................116

7.1 OVERALL PROCESS TO DEVELOP THE ONROAD INVENTORY .............................116

7.2 MOVES MODEL RUN SPECIFICATIONS AND DOCUMENTATION ...........................116

7.3 SUMMARY OF ONROAD INVENTORY.......................................................................116

8.0 PREPARATION OF SMOKE MODEL FILES ...................................................................124

8.1 PREPARATION OF SMOKE EMISSION FILES ...........................................................124

8.1.1 Point Source SMOKE Emission Files ...................................................................124

8.1.2 Area Source SMOKE Emission Files ...................................................................125

8.1.3 Nonroad NMIM SMOKE Emission Files ...............................................................127

8.1.4 Nonroad MAR SMOKE Emission Files ................................................................127

8.1.5 Onroad SMOKE Emission Files ...........................................................................127

8.1.1 Biogenic SMOKE Emission Files .........................................................................127

8.1.1 SMOKE Emission Files for Areas Outside of the MANE-VU+VA Region .............127

8.2 REVIEW OF SMOKE AUXILIARY FILES .....................................................................127

8.2.1 SMOKE Speciation Files ......................................................................................128

8.2.2 SMOKE Spatial Allocation Files ...........................................................................128

8.2.3 SMOKE Temporal Allocation Files .......................................................................129

9.0 FINAL DELIVERABLES...................................................................................................131

10.0 REFERENCES................................................................................................................136
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List of Appendices 

Appendix A CAMD to NIF Crosswalk Aug12_2010.xls 

Appendix B Technical Memorandum - EFs for CPM from EGUs.doc 

Appendix C SCC_Control_Device_PM_Ratios.xls 

Appendix D Stack_SCC_Defaults.xls 

Appendix E VDEQ Conceptual Description for DG draft March 15, 2010.doc 

Appendix F NESCAUM 2007 2020 MOVES modeling 20111209 PM.doc 

Appendix G Stage_II_Controls.xlsx 

Appendix H MANEVU_VA SMOKE QA Memo 17Dec2010.doc 

List of Exhibits 

Exhibit 2.1 – PM Compound Descriptions 

Exhibit 2.2 – PM Compounds Reported in State Initial Submittals 

Exhibit 2.3 - Emission Factors Used to Estimate EGU Condensable PM Emissions 

Exhibit 2.4 – Cases and Steps Required to Augment EGU PM Emissions 

Exhibit 2.5 – Cases and Steps Required to Augment nonEGU PM Emissions 

Exhibit 2.6 - Stack Parameter Data Replacement Matrix 

Exhibit 2.7 – 2002 and 2007 Point Source CO Emissions by State 

Exhibit 2.8 – EGU and nonEGU 2007 Point Source CO Emissions by State 

Exhibit 2.9 – 2002 and 2007 Point Source NH3 Emissions by State 

Exhibit 2.10 – EGU and nonEGU 2007 Point Source NH3 Emissions by State 

Exhibit 2.11 – 2002 and 2007 Point Source NOx Emissions by State 

Exhibit 2.12 – EGU and nonEGU 2007 Point Source NOx Emissions by State 

Exhibit 2.13 – 2002 and 2007 Point Source PM10-PRI Emissions by State 

Exhibit 2.14 – EGU and nonEGU 2007 Point Source PM10-PRI Emissions by State 

Exhibit 2.15 – 2002 and 2007 Point Source PM25-PRI Emissions by State 

Exhibit 2.16 – EGU and nonEGU 2007 Point Source PM25-PRI Emissions by State 

Exhibit 2.17 – 2002 and 2007 Point Source SO2 Emissions by State 

Exhibit 2.18 – EGU and nonEGU 2007 Point Source SO2 Emissions by State 

Exhibit 2.19 – 2002 and 2007 Point Source VOC Emissions by State 
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Exhibit 2.20 – EGU and nonEGU 2007 Point Source VOC Emissions by State 

Exhibit 3.1 – SMOKE ORL Format for PTINV 

Exhibit 3.2 – SMOKE EMS-95 Traditional Foramt for Individual Hour-Specific Files 

Exhibit 3.3 – Example Application of Calculated Ratios for Actual 2007 by Month 

Exhibit 3.4 - Example SMOKE Profile for Monthly Distribution of New York Annual Emissions 

Using Heat Input 

Exhibit 3.5 - Example SMOKE profile for Adjusted Monthly Distribution of New York Seasonal 

Emissions Using Heat Input 

Exhibit 4.1 – Area Source Category Definitions 

Exhibit 4.2 – Values Contained in the DATA_SOURCE Field of the EM Table 

Exhibit 4.3 – Data Sources Generally Used by Each State for Each Area Source Category 

Exhibit 4.4 – Comparison of 2007 Paved Road Dust PM10 and PM2.5 Emission Estimates 

Exhibit 4.5 – Comparison of 2007 Vehicle Refueling Emissions using NMIM and MOVES 

Exhibit 4.6 – 2002 and 2007 Area Source CO Emissions by State 

Exhibit 4.7 – 2007 Area Source CO Emissions by Category and State 

Exhibit 4.8 – 2002 and 2007 Area Source NH3 Emissions by State 

Exhibit 4.9 – 2007 Area Source NH3 Emissions by Category and State 

Exhibit 4.10 – 2002 and 2007 Area Source NOx Emissions by State 

Exhibit 4.11 – 2007 Area Source NOx Emissions by Category and State 

Exhibit 4.12 – 2002 and 2007 Area Source PM10-PRI Emissions by State 

Exhibit 4.13 – 2007 Area Source PM10-PRI Emissions by Category and State 

Exhibit 4.14 – 2002 and 2007 Area Source PM25-PRI Emissions by State 

Exhibit 4.15 – 2007 Area Source PM25-PRI Emissions by Category and State 

Exhibit 4.16 – 2002 and 2007 Area Source SO2 Emissions by State 

Exhibit 4.17 – 2007 Area Source SO2 Emissions by Category and State 

Exhibit 4.18 – 2002 and 2007 Area Source VOC Emissions by State 

Exhibit 4.19 – 2007 Area Source VOC Emissions by Category and State 

Exhibit 5.1 – Gasoline Fuel Record Types Add to MySQL NCD Database 

Exhibit 5.2 – Sources of Population and Housing Data 

Exhibit 5.3 – 2002 and 2007 NMIM/NONROAD CO Emissions by State 

Exhibit 5.4 – 2007 NMIM Source CO Emissions by Category and State 

Exhibit 5.5 – 2002 and 2007 NMIM/NONROAD NH3 Emissions by State 
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Exhibit 5.6 – 2007 NMIM Source NH3Emissions by Category and State 

Exhibit 5.7 – 2002 and 2007 NMIM/NONROAD NOx Emissions by State 

Exhibit 5.8 – 2007 NMIM Source NOx Emissions by Category and State 

Exhibit 5.9 – 2002 and 2007 NMIM/NONROAD PM10-PRI Emissions by State 

Exhibit 5.10 – 2007 NMIM Source PM10-PRI Emissions by Category and State 

Exhibit 5.11 – 2002 and 2007 NMIM/NONROAD PM25-PRI Emissions by State 

Exhibit 5.12 – 2007 NMIM Source PM25-PRI Emissions by Category and State 

Exhibit 5.13– 2002 and 2007 NMIM/NONROAD SO2 Emissions by State 

Exhibit 5.14 – 2007 NMIM Source SO2 Emissions by Category and State 

Exhibit 5.15 – 2002 and 2007 NMIM/NONROAD VOC Emissions by State 

Exhibit 5.16 – 2007 NMIM Source VOC Emissions by Category and State 

Exhibit 6.1 – Data Sources for Commercial Marine Vessel Inventory 

Exhibit 6.2 – Data Sources for Airport Inventory 

Exhibit 6.3 – Data Sources for Railroad Locomotive and Railyard Inventory 

Exhibit 6.4 – 2002 and 2007 MAR CO Emissions by State 

Exhibit 6.5 – 2002 and 2007 MAR NH3 Emissions by State 

Exhibit 6.6 – 2002 and 2007 MAR NOx Emissions by State 

Exhibit 6.7 – 2002 and 2007 MAR PM10-PRI Emissions by State 

Exhibit 6.8 – 2002 and 2007 MAR PM25-PRI Emissions by State 

Exhibit 6.9 – 2002 and 2007 MAR SO2 Emissions by State 

Exhibit 6.10 – 2002 and 2007 MAR VOC Emissions by State 

Exhibit 7.1 – MOVES Modeling Approach by State 

Exhibit 7.2 – 2002 and 2007 Onroad CO Emissions by State 

Exhibit 7.3 – 2002 and 2007 Onroad NH3 Emissions by State 

Exhibit 7.4 – 2002 and 2007 Onroad NOx Emissions by State 

Exhibit 7.5 – 2002 and 2007 Onroad PM10-PRI Emissions by State 

Exhibit 7.6 – 2002 and 2007 Onroad PM25-PRI Emissions by State 

Exhibit 7.7 – 2002 and 2007 Onroad SO2 Emissions by State 

Exhibit 7.8 – 2002 and 2007 Onroad VOC Emissions by State 

Exhibit 8.1 – Comparison of 2007 Area Source Emissions With and Without the Application of 

the Fugitive Dust Transport Factor 
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Exhibit 9.1 – NIF Data and Emission Summary Files for the 2007 MANE-VU+VA Emission 

Inventory 

Exhibit 9.2 – SMOKE Files for the 2007 MANE-VU+VA Emission Inventory 
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Acronyms and Abbreviations 

Acronym Description

CAMD Clean Air Markets Division (USEPA)

CAP Criteria Air Pollutant

CEM Continuous Emission Monitoring 

CMV Commercial Marine Vessel

CO Carbon Monoxide 

EGU Electric Generating Unit

ERTAC Eastern Regional Technical Advisory Committee

FIPS Federal Information Processing Standard

GSE Ground Support Equipment

MANE-VU Mid-Atlantic/Northeast Visibility Union

MANE-VU+VA MANE-VU States plus Virginia

MAR Marine, Airport, Rail 

MARAMA Mid-Atlantic Regional Air Management Association

MOBILE6 USEPA model

MOVES Motor Vehicle Emissions Simulator

NAICS North American Industry Classification System code

NCD National County Database 

NEI National Emission Inventory

NESCAUM Northeast States for Coordinated Air Use Management

NH3 Ammonia

NIF3.0 National Emission Inventory Input Format Version 3.0

NMIM National Mobile Input Model

NOF3.0 National Emission Inventory Output Format Version 3.0

NONROAD USEPA model

NOx Oxides of nitrogen

OAQPS Office of Air Quality Planning and Standards (USEPA)

ORL One-record-per-line (SMOKE Format)

OTAQ Office of Transportation and Air Quality (USEPA)

PFC Portable Fuel Container

PM-CON Primary PM, Condensable portion only (all < 1 micron)

PM-FIL Primary PM, Filterable portion only

PM-PRI Primary PM, includes filterables and condensables

PM-PRI= PM-FIL + PM-CON

PM10-FIL Primary PM10, Filterable portion only

PM10-PRI Primary PM10, includes filterables and condensables, 

PM10- PRI = PM0-FIL + PM-CON
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Acronym Description

PM25-FIL Primary PM2.5, Filterable portion only

PM25-PRI Primary PM2.5, includes filterables and condensables

PM25-PRI= PM25-FIL + PM-CON

RWC Residential Wood Combustion

SEMAP Southeast Modeling, Analysis and Planning

SIC Standard Industrial Classification code

SIP State Implementation Plan

SCC Source Classification Code

S/L State/local

SMOKE Sparse Matrix Operator Kernel Emissions

SO2 Sulfur Dioxide

USEPA U.S Environmental Protection Agency

VISTAS Visibility Improvement State and Tribal Association of the Southeast 

VMT Vehicle Miles Traveled

VOC Volatile Organic Compounds
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1.0 INTRODUCTION 

This technical support document (TSD) explains the data sources, methods, and results for 

preparing the 2007 criteria air pollutant (CAP) and ammonia (NH3) emission inventory for 

the Northeast and Mid-Atlantic/Northeast region. The region includes the Mid-Atlantic / 

Northeast Visibility Union (MANE-VU) area plus Virginia. In this document, this region 

will be referred to as the MANE-VU+VA region. The MANE-VU+VA region includes 

Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New 

Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia. 

Local air planning agencies include Philadelphia and Allegheny County, Pennsylvania. 

1.1 INVENTORY PURPOSE 

The MANE-VU+VA regional inventory will be used to concurrently address national 

ambient air quality standard (NAAQS) requirements for the new ozone and fine particle 

ambient standards and to evaluate progress towards long-term regional haze goals. Similar 

pollutant emissions and atmospheric processes control chemical formation and transport of 

ozone, fine particles, and regional haze. Therefore, similar technical analyses are 

necessary to evaluate air quality benefits of emissions controls. The emissions inventory 

will support a single integrated, one-atmosphere air quality modeling platform to support 

State air quality attainment demonstrations. 

The U.S. Environmental Protection Agency (USEPA) has provided guidance on 

developing emission inventories to be used with models and other analyses for 

demonstrating attainment of air quality goals for ozone, fine particles, and regional haze 

(USEPA 2007a). According to the USEPA guidance, there are potentially two different 

base year emissions inventories. One is the base case inventory which represents the actual 

emissions for the meteorological period that is being modeled. This inventory is generally 

used for model performance evaluations. The second potential base year inventory is 

called the baseline inventory, which is generally used as the basis for projecting emissions 

to the future. The base case inventory may include day specific information (e.g. hourly 

continuous emission monitoring data for point sources) that USEPA considers 

inappropriate for using in future year projections. Therefore, the baseline inventory may 

need to replace the day specific emissions with average or “typical” emissions (for certain 

types of sources). For the 2007 MANE-VU+VA inventory, the base case and baseline 

inventories are one in the same. 
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1.2 POLLUTANTS 

The inventory includes annual emissions for carbon monoxide (CO), ammonia (NH3), 

oxides of nitrogen (NOx), particulate matter (PM), sulfur dioxide (SO2), and volatile 

organic compounds (VOC). The PM species in the inventory are categorized as: filterable 

and condensable particles with an aerodynamic diameter less than or equal to a nominal 10 

and 2.5 micrometers (i.e., PM10-PRI and PM25-PRI); filterable particles with an 

aerodynamic diameter less than or equal to a nominal 10 and 2.5 micrometers (i.e., PM10-

FIL and PM25-FIL); and condensable particles (PM-CON). Note that PM10-PRI equals 

the sum of PM10-FIL and PM-CON, and PM25-PRI equals the sum of PM25-FIL and 

PM-CON. 

1.3 SOURCE CATEGORIES 

Emission inventory data from five general categories are needed to support air quality 

modeling: stationary point-sources, stationary area-sources, on-road mobile sources, 

nonroad mobile sources (including aircraft, railroad, and marine vessels), and 

biogenic/geogenic emissions. These sectors are described as follows: 

Point Sources are individual facilities and are further subdivided by stack, 

emission unit (“point”), and emission process (“segment”). The point source data 

include source-specific information on the location of sources (e.g., 

latitude/longitude coordinates); stack parameters (stack diameter and height, exit 

gas temperature and velocity); type of emission process (Source Classification 

Code {SCC}); and annual emissions. Point sources were classified as electric 

generating units (EGUs) and non-electric generating units (nonEGUs). Most point 

source emissions data is certified by the facility and reported to the State agency or 

USEPA. 

Stationary Area Sources include sources that in and of themselves are small, but 

in aggregate may comprise significant emissions. Examples include emissions 

from small industrial/commercial facilities, residential heating furnaces, VOCs 

volatizing from house painting or consumer products, gasoline service stations, and 

agricultural fertilizer/pesticide application. Emissions were calculated using 

emission factors and activity data on a county and source category basis. 

On-road Mobile Source emissions include sources of air pollution from internal 

combustion engines used to propel cars, trucks, buses, and other vehicles on public 

roadways. Emissions were calculated by the Northeast States for Coordinated Air 
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Use Management (NESCAUM) using the USEPA Motor Vehicle Emission 

Simulator (MOVES) model in concert with vehicle miles traveled (VMT) data. 

Non-road Mobile Sources include internal combustion engines used to propel 

marine vessels, airplanes, and locomotives, or to operate equipment such as 

forklifts, lawn and garden equipment, portable generators, etc. For activities other 

than marine vessels, airplanes, and locomotives, the inventory was developed using 

the most current version of USEPA’s NONROAD model as embedded in the 

National Mobile Inventory Model (NMIM). Since the NONROAD model does not 

include emissions from marine vessels, airplanes, and locomotives, these emissions 

were estimated using the latest USEPA guidance or by groups such as the Eastern 

Regional Technical Advisory Committee (ERTAC). 

Biogenic emissions are emitted by natural sources, such as plants, trees, and soils. 

The sharp scent of pine needles, for instance, is caused by monoterpenes, which are 

VOCs. The USEPA developed estimates of biogenic emissions from vegetation for 

natural areas, crops, and urban vegetation. The USEPA estimates take into account 

the geographic variations in vegetation land cover and species composition, as well 

as seasonal variations in leaf cover. 

For all sectors, emissions data were compiled on an annual basis to represent 2007 actual 

emissions and meteorology. For certain large EGUs and nonEGUs, actual hourly 2007 

emissions data were adapted for use in the inventory. For sources with emissions 

estimated by NONROAD model, emissions were compiled as monthly total emissions. 

For sources included in the MOVES model, emissions will be compiled on an hourly basis. 

1.4 DATA FORMATS 

The annual mass emissions inventory files were prepared in the National Emissions 

Inventory (NEI) Output Format Version 3.0 (NOF 3.0). These annual emission inventories 

will be converted (through the emissions modeling process) from their original resolution 

(e.g., annual, county level) to input files for air quality models. These input files generally 

require emissions to be specified by model grid cell, hour, and model chemical species. 

The emission modelers in the MANE-VU+VA region are using the Sparse Matrix 

Operator Kernel Emissions (SMOKE) modeling system and data formats. Ancillary files 

(holding spatial, temporal, and speciation profile data) were prepared in SMOKE 

compatible format. Various spreadsheets summarizing emissions by county, sector, SCC, 

and pollutant were also prepared. 
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1.5 SUMMARY OF INVENTORY DEVELOPMENT PROCESS 

Work on Version 1 of the 2007 MANE-VU+VA inventory began in April 2009. 

Preparation of the consolidated inventory for point, area, onroad, and nonroad sources 

started with the inventories submitted by State and local (S/L) as well as input files needed 

by the NONROAD and MOVES models. For certain area and nonroad source categories, 

the S/L submittals were supplemented 2008 NEI data. In addition, the Carnegie Mellon 

Ammonia model was exercised to calculate agricultural ammonia emissions. Work 

products developed by ERTAC were used including the USEPA wood smoke tool and the 

Area Source emission factor harmonization project. 

The USEPA’s format and content quality assurance (QA) programs (and other QA checks 

not included in USEPA’s QA software) were run to identify format and/or data content 

issues (EPA, 2004). The Contractor worked with the S/L agencies and the staff of the MidAtlantic Regional Air Management Association (MARAMA) to resolve QA issues and 

augment the inventories to fill data gaps in accordance with the Quality Assurance Project 

Plan prepared for this project. 

Work on Version 2 began with a stakeholder review process. Version 1 inventory and 

summary files were provided for stakeholder review between October 2009 and August 

2010. Stakeholder comments were reviewed by the S/L agencies and revisions to the 

inventory files were made to incorporate stakeholder comments as approved by each S/L 

agency. Other corrections, revisions, or updates were supplied by the S/L agencies, which 

resulted in the publication of Version 2 of the 2007 inventory in February 2011 

(MARAMA 2011). 

Further revisions to the 2007 inventory were made in late 2011. The most significant 

changes were to use an improved emission estimation methodology for re-entrained road 

dust from paved roads, incorporate vehicle refueling emissions as calculated by MOVES, 

amd correct errors used in the NMIM modeling of nonroad emissions. Other revisions 

were made to correct minor errors or revisions to selected categories as identified by the 

S/L agencies. These revisons resulted in the publication of Version 3 of the 2007 

inventory in December 2011. 

1.6 REPORT ORGANIZATION 

This report documents the development of Version 1 of the 2007 inventory, as well as the 

revisions made during the Version 2 and Version 3 update cycles. Sections 2 and 3 of this 

TSD present the general and State-specific methods and data sources used to develop the 

MANE-VU+VA 2007 annual inventory for point sources and hourly emissions for large 
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point sources, respectively. Sections 4 through 7 present the methods and data used to 

develop the inventory for area sources, nonroad marine vessel/airport/locomotive sources, 

nonroad sources included in the NONROAD model, and onroad sources included in the 

MOVES model. Section 8 documents the inventory, temporal allocation, speciation, and 

spatial allocation modeling input files used for the MANE-VU+VA 2007 inventory for all 

sectors. Section 9 identifies the file names for all final deliverable products. References 

for the TSD are provided in Section 10.
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2.0 ANNUAL 2007 INVENTORY FOR POINT SOURCES 

2.1 INITIAL DATA SOURCES AND QA REVIEW 

The 2007 annual point source inventory was developed using the 2007 inventories that S/L 

agencies submitted to MARAMA and data from the USEPA’s Clean Air Markets Division 

(CAMD) hourly emissions database. 

2.1.1 Initial State NIF Submittals 

State and local (S/L) agencies prepared and submitted emission inventory files in the 

National Emissions Inventory (NEI) Input Format Version 3.0 (NIF 3.0). The NIF format 

includes eight tables: Transmittal (TR), Site (SI), Emission Unit (EU), Emission Release 

Point (ER), Emission Process (EP), Emission Period (PE), Emission (EM), and Control 

Equipment (CE). States were requested to submitted 2007 data for those major sources 

that they would normally submit to USEPA during the 3-year requirements of the 

Consolidated Emission Reporting Rule. All 13 MANE-VU+VA agencies submitted point 

source inventories to MARAMA. In addition, Allegheny and Philadelphia Counties in 

Pennsylvania each submitted their own point source inventories. 

Upon receipt of the NIF submittals, the Contractor performed an initial review of the S/L 

inventories with the following QA checks: 

EPA’s Basic Format and Content Checker tool was used to verify format and check 

for referential integrity and duplicate record issues. Only very minor issues were 

identified and were resolved by the Contractor without the need for S/L assistance. 

Facility-level comparisons were made between the MANE-VU/VISTAS Best and 

Final 2002 inventories and the S/L 2007 submittals to identify facilities included in 

the 2002 inventory but not in the 2007 inventory. For four S/L agencies (NY, PA, 

Allegheny and Philadelphia Counties), the number of facilities included in the 2007 

were far less than the number of facilities reported in 2002. These S/L agencies 

provided revised files with a lower facility emission cutoff level to ensure that all 

major sources were included in the 2007 inventory. S/L agencies were asked to 

review this list and confirmed that facilities not in the 2007 inventory were either 

closed or included in the area source inventory. 

Facility-level comparisons were made between the MANE-VU/VISTAS 2002 

inventories and the S/L 2007 submittals to identify facilities included in the 2007 

inventory but not in the 2002 inventory. S/L agencies verified the reasonableness 

of this list of sources. 
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Facility-level comparisons were made between the MANE-VU/VISTAS 2002 

inventories and the S/L 2007 submittals to identify facilities that were included in 

both the 2002 inventory and 2007 inventory. Facility-level emission changes were 

calculated, large differences between 2002 and 2007 emissions were flagged, and 

S/L agencies reviewed and confirmed the reasonableness of the emission changes 

between 2002 and 2007. 

Facility-level ammonia emissions were obtained from the USEPA 2007 Toxic 

Release Inventory (USEPA 2009a) and were compared to the ammonia emissions 

in the S/L agency submittal. S/L agencies reviewed the TRI data to ensure that 

large (> 100 tons per year) ammonia sources were included in the 2007 MANEVU+VA inventory. 

Following this initial QA review, these individual inventory files were consolidated into a 

single NIF database. S/L responses and updates to the inventory files resulting from the 

initial QA review are discussed later in this document. 

2.1.2 EPA CAMD Hourly Emissions Data 

The second source of data was the hourly emissions data reported to USEPA by facilities 

to comply with various provisions of the Clean Air Act. MARAMA downloaded the 2007 

CAMD annual inventory containing NOx and SO2 emissions, heat input data and other 

information from the CAMD web site in May 2009. 

MARAMA prepared an initial crosswalk file to match facilities and units in the CAMD 

inventory to facilities and units in the 2002 MANE-VU Version 3 inventory. In the CAMD 

inventory, the Office of Regulatory Information Systems (ORIS) identification (ID) code 

identifies unique facilities and the unit ID identifies unique boilers and internal combustion 

engines (i.e., turbines and reciprocating engines). MARAMA sent an Excel Workbook to 

each S/L agencies that contained an initial crosswalk with the ORIS ID and unit ID in the 

CAMD inventory matched to the state and county FIPS, state facility ID, and EU ID in the 

2002 MANE-VU Version 3 inventory. The crosswalk contained the annual 2007 NOx, 

SO2, and heat input (except for those units that are required to report for only 6 months, 

wherein the data were for the 6 month period). The crosswalk also included other 

information from the 2002 MANVEU inventory, including stack and location coordinates. 

Agencies reviewed and confirmed/corrected/supplemented the information in the 

crosswalk, provided annual 2007 emissions for the 6-month CAMD reporting units, and 

provided 2007 annual emissions for other CAPs and NH3. 

The crosswalk was provided to the Contractor who updated the crosswalk as follows: 
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In most of the S/L inventories, the state and county FIPS and state facility ID 

together identify unique facilities and the EU ID identifies unique boilers or 

internal combustion engines. However, in some of the S/L inventories, the 

emissions for multiple EUs were summed and reported under the same EU ID. To 

provide a better linkage between the CAMD data and the S/L inventories, the 

Contractor worked with States to establish the crosswalk at the EU ID / EP ID / ER 

ID. This effort resulted in a much better linkage between the CAMD and S/L 

inventories. 

In several cases, the EU ID / EP ID / ER ID identifiers in the 2002 MANVU 

inventory were changed in the 2007 S/L agency submittals. The Contractor worked 

with the S/L agencies to correct these broken linkages by updating the EU ID / EP 

ID /ER ID identifies as necessary. 

The Contractor downloaded the 2007 CAMD hourly inventory containing hourly 

NOx and SO2 emissions and heat input data from the CAMD website (USEPA 

2009b). The Contractor summed the hourly emissions to the annual level (or 6-

month level for 6-month reporting units) by emission unit. The summed hourly 

data was compared to the annual summary data, which matched in virtually all 

cases. This check was made because MARAMA is considering using the actual 

2007 hourly data rather than average temporal profiles in the next round of regional 

air quality modeling. 

As another QA check, the Contractor compiled a list of sources with EGU SCCs of 

1-01-xxx-xx and 2-01-xxx-xx in the State NIF tables that could not be linked to the 

CAMD table. States reviewed this list and verified that there are no large EGUs 

missing from the CAMD to NIF crosswalk. 

The Contractor prepared a CAMD-to-NIF crosswalk spreadsheet for each State. 

Aagencies were asked to review this list and verify that (1) the linkages are correct, (2) 

there are no large sources missing from the CAMD-to-NIF crosswalk, and (3) there are not 

discrepancies between the emissions reported to CAMD and the emissions reported in the 

SEMAP database. 

There are three types of possible linkages: 

CAMD facility has no match in NIF SI facility table. The emissions from these 

facilities reported to CAMD are small, and initially accounted for about 0.5% 

of the NOx and 0.07% of the SO2 emissions in the CAMD database. 
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CAMD unit could not be matched in NIF. The emissions from these facilities 

reported to CAMD were small, accounting for about 0.9% of the NOx and 

0.007% of the SO2 emissions in the CAMD database. Most of the units that 

could not be matched at the unit level are either peaking units or industrial 

sources such as paper mills or chemical plants. In addition, there were several 

instances where multiple CAMD units match to a single NIF record (i.e., units 

are grouped in the NIF tables but reported individually in the CAMD database). 

CAMD unit matches with a single NIF record or CAMD unit matches with 

multiple NIF records (in many cases, the NIF tables include multiple records 

for different fuel types). The emissions from these units reported to CAMD 

account for about 98.6% of the NOx and 99.9% of the SO2 emissions in the 

CAMD database. In most cases the sum of the emissions from the matching 

NIF records are generally very close to the CAMD unit level emissions; and 

S/L agencies verified that linkages were correct. 

As another QA check, the Contractor compiled a list of sources with EGU SCCs of 1-01-

xxx-xx and 2-01-xxx-xx in the S/L agency NIF tables that could not be linked to the 

CAMD CEM table to help resolve some of the linkage issues noted above. S/L agencies 

made significant efforts to improve the crosswalk between the CAMD identifiers and the 

S/L agency identifiers. Appendix A contains the current version of the crosswalk. 

2.2 PM AUGMENTATION 

PM compounds may be reported in several forms, as identified in Exhibit 2.1. Exhibit 2.2 

provides a count of the number of annual NIF EM table records in each agency’s NIF 

Submittal by type of PM compound. The PM augmentations process was necessary to 

gap-fill missing PM pollutant complements. For example, if a S/L agency provided only 

PM10-PRI emissions, the PM augmentation process filled in the PM25-PRI emissions. 

A second aspect of the PM augmentation process was to utilize improved condensable 

emission factors for EGUs. Condensable emissions were not calculated uniformly across 

all states in the MANE-VU region in the 2002 emissions inventory. Because of the need to 

model the effect of condensable emissions on regional haze and fine particles, MARAMA 

instructed the Contractor to use recently updated emission factors for condensable 

emissions from EGUs. 
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Exhibit 2.1 – PM Compound Descriptions 

Pollutant Code Pollutant Pollutant Description

PM-CON Primary PM

Condensable portion

only (all < 1 micron)

Material that is vapor phase at stack conditions, but which 

condenses and/or reacts upon cooling and dilution in the 

ambient air to form solid or liquid PM immediately after 

discharge from the stack.

PM-FIL Primary PM, Filterable

portion only

Particles that are directly emitted by a source as a solid or 

liquid at stack or release conditions and captured on the filter 

of a stack test train. 

PM-PRI Primary PM, includes

filterables and

condensables

PM-PRI=

PM-FIL + PM-CON

Particles that enter the atmosphere as a direct emission from 

a stack or an open source. It is comprised of two 

components: Filterable PM and Condensable PM.

PM10-FIL Primary PM10,

Filterable portion only

Particles with an aerodynamic diameter equal to or less than 

10 micrometers that are directly emitted by a source as a 

solid or liquid at stack or release conditions and captured on 

the filter of a stack test train.

PM10-PRI Primary PM10,

includes filterables and

condensables,

PM10- PRI =

PM0-FIL + PM-CON

Particles with an aerodynamic diameter equal to or less than 

10 micrometers that enter the atmosphere as a direct 

emission from a stack or an open source. It is comprised of 

two components: Filterable PM and Condensable PM. (As 

specified in § 51.15 (a)(2), These two PM components are 

the components measured by a stack sampling train such as

USEPA Method 5.)

PM25-FIL Primary PM2.5,

Filterable portion only

Particles with an aerodynamic diameter equal to or less than 

2.5 micrometers that are directly emitted by a source as a 

solid or liquid at stack or release conditions and captured on 

the filter of a stack test train.

PM25-PRI Primary PM2.5,

includes filterables and

condensables

PM25-PRI=

PM25-FIL + PM-CON

Particles with an aerodynamic diameter equal to or less than 

2.5 micrometers that enter the atmosphere as a direct 

emission from a stack or an open source. It is comprised of 

two components: Filterable PM and Condensable PM. (As 

specified in § 51.15 (a)(2), These two PM components are 

the components measured by a stack sampling train such as

USEPA Method 5.)
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Exhibit 2.2 – PM Compounds Reported in State Initial Submittals 

Number of Annual EM Records in Agency’s Initial NIF Submittal

Agency PM-CON PM-FIL PM-PRI PM10-FIL PM10-PRI PM25-FIL PM25-PRI

CT1--- --- --- 122 1,300 --- 5

DE 449 --- --- 886 756 734 699

DC 70 --- --- 70 70 70 70

ME --- 9 --- 1,150 --- 1,053 ---

MD 1,265 --- --- 3,543 3,750 3,040 2,477

MA --- --- 6 6,614 --- 5,930 ---

NH --- 463 --- 464 --- 461 ---

NJ --- --- 5,966 --- 5,848 --- ---

NY --- --- 1,220 --- 1,201 --- ---

PA --- --- --- --- 5,738 --- 3,949

Allegheny2434 881 --- 881 --- 836 ---

Philadelphia --- --- --- 1,178 27 351 21

RI 12 12 105 12 46 12 48

VT --- 64 --- --- --- --- ---

VA3--- --- --- 5,204 --- 3,302 ---

After reviewing the initial draft inventory that was posted in October, 2009, three agencies provided the 

following changes to their initial submittals. These changes are reflected in the record counts in the above 

table. The PM augmentation routine was re-executed to account for these changes. 

1) Connecticut indicated that the PM records in their original submittal for oil and coal-fired boilers 

should have been submitted as PM10-FIL and not PM10-PRI. All natural gas-fired units and oil-fired 

turbines were correctly reported as PM10-PRI. 

2) Allegheny County provided information on 31 additional facilities that were not included in their 

original submittal. 

3) Virginia indicated that all of the PM records in their original submittal used incorrect pollutant codes. 

Records in the original submittal designated as PM10-PRI should have been submitted as PM10-FIL, 

and PM25-PRI should have been PM25-FIL. 
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The PM augmentation process was divided into two components – the first applying to 

EGUs and the second to all other point sources. EGUs were identified as those units that 

supplied hourly data to USEPA’s CAMD database. Because of the differences in the 

augmentation process for EGUs and nonEGUs, each process is discussed separately in the 

following sections. The EGU process uses the updated condensable emission factors, 

while the nonEGU process is essentially the same process used in developing the 2002 

MANE-VU Version 3 inventory. 

2.2.1 EGU PM Augmentation 

The EGU PM augmentation process utilized the recently updated condensable emission 

factors for EGUs developed for MARAMA in 2008. Appendix B contains the technical 

memorandum describing how the emission factors were developed. The general process is 

to use the emission factors and heat input to calculate the PM-CON emissions, and then to 

perform the gap filling for compounds missing from the S/L submittal. 

2.2.1.1 EGU Condensable Emission Factors 

As described in Appendix B, two sets of emission factors were developed by 6-digit SCC 

corresponding to equipment type (boiler or IC engine) and fuel type. The first set is based 

on all available source tests, while the second set includes only source tests where nitrogen 

purging occurred. As described in more detail in Appendix B, in measuring condensable 

PM from combustion of fuels containing sulfur, it has been shown by USEPA that SO2 

collected in the impingers can be oxidized to sulfate and produce a variable sulfate artifact 

that results in overestimation of condensable emissions. In this example, if impingers are 

not purged with nitrogen, errors associated with the sulfate artifact may be inflated 

resulting in an overestimation of condensable PM emissions. 

Exhibit 2.3 shows the emission factors considered for use in estimating EGU condensable 

PM emissions. It shows the new emission factors developed using all available test data as 

well as the emission factors based only on those tests that utilized a nitrogen purge. In 

addition, emission factors are available from USEPA’s AP-42 emission factor document. 

The emission factors actually used in the augmentation process are highlighted in bold in 

Exhibit 2.3. Emission factors based on purged test were used where available; otherwise 

the emission factors based on all tests were used. Since Appendix B did not provide a 

condensable PM emission factors for residual oil, we used the AP-42 condensable PM 

emission factor for residual oil. 
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Exhibit 2.3 - Emission Factors Used to Estimate EGU Condensable PM Emissions 

Emission Factor (lbs/mmBtu)

SCC 

(6-digit) SCC (6-digit) Description MARAMA1 All Tests

MARAMA1 

Purged 

Tests Only

AP-422

1-01-001

1-02-001

Boiler / EGU / Anthracite Coal

Boiler / Industrial / Anthracite Coal

0.0084 --- ---

1-01-002 

1-02-002

1-03-002

Boiler / EGU / Bituminous/Sub-butuminous Coal

Boiler / Industrial / Bituminous/Subbit. Coal

Boiler / Commercial / Bituminous/Subbit. Coal

0.022 0.013 0.04 to 0.373 

depending 

on sulfur 

content

1-01-003 

1-02-003

Boiler / EGU / Lignite

Boiler / Industrial / Lignite

0.039 --- 0.014

1-01-004

1-02-004

Boiler / EGU / #6 Fuel Oil

Boiler / Industrial / #6 Fuel Oil

--- --- 0.01

1-01-005 

1-02-005

1-03-005

Boiler / Industrial / #2 Fuel Oil

Boiler / Commercial / #2 Fuel Oil

Boiler / EGU / #2 Fuel Oil

0.014 --- 0.00928

1-01-006 

1-02-006

1-03-006

Boiler / EGU / Natural Gas

Boiler / Industrial / Natural Gas

Boiler / Commercial / Natural Gas

0.00249 --- 0.00559

1-01-008 Boiler / EGU / Petroleum Coke 0.05 --- ---

2-01-001

2-01-009

2-02-009

IC Engine / EGU/ Fuel Oil

IC Engine / EGU/ Kerosene

IC Engine / Industrial / Kerosene

0.013 0.01 0.0072

2-01-002 

2-02-002

2-03-002

IC Engine / EGU / Natural Gas

IC Engine / Industrial/ Natural Gas

IC Engine / Commercial / Natural Gas

0.005 0.0015 0.0047

1) Source: Emissions Factors for Condensable Particulate Matter Emissions from Electric Generating 

Units ; memo dated August 20, 2008, from Arthur Werner (MACTEC) to Julie McDill (MARAMA). In 

accordance with USEPA guidance, CPM emissions determined from Method 202 tests that apply 

nitrogen purging are more reliable than results from tests where purging was not used. 

2) Source: AP 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point 

and Area Sources. 

3) Based on typical bituminous sulfur content range of 0.7 to 4.0 % by weight. 

4) Based on typical lignite sulfur content of 0.4 % by weight. 

5) Bolded numbers are the emission factors actually used to calculated condensable emissions. 

SCCs associated with CAMD units for which condensable emission factors were not available in the 

MARAMA report: 

1-01-009 Boiler / EGU / Wood or Bark Waste 

1-01-010 Boiler / EGU / LPG 

1-01-012 Boiler / EGU / Solid Waste 

1-01-013 Boiler / EGU / Liquid Waste 

1-02-009 Boiler / Industrial / Wood or Bark Waste 

1-02-010 Boiler / Industrial / LPG 

1-02-014 Boiler / CO Boiler / Natural or Process Gas 

3-05-007 Cement Manufacturing / Kilns 

3-06-002 Petroleum Refining / Catalytic Cracking Units 

3-06-012 Petroleum Refining / Fluid Coking Units 

3-90-001 In-process Fuel / Anthracite Coal 

3-90-012 In-process Fuel / Solid Waste 

3-99-999 Misc. Industrial Processes 
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While Appendix B only provides emission factors for electric generation SCCs (e.g., 1-01-

xxx-xx or 2-01-xxx-xx), a review of the S/L agency NIF submittals showed that several 

other SCCs were used by EGUs. These additional SCCs are highlighted in italics in 

Exhibit 3. Since these SCCs were associated with EGUs, it was assumed that emission 

factors would apply to these SCCs also. 

Note also that there were several other SCCs associated with EGUs for which condensable 

PM emission factors were not available. These SCCs are listed at the bottom of Exhibit 

2.3. No special effort was made to evaluate condensable emissions for these SCCs; rather, 

the State-supplied PM condensable emissions were used where available. 

2.2.1.2 EGU Heat Input 

In addition to the emission factors, the annual heat input in mmBtu/year by unit and fuel 

type is also needed to calculate condensable PM emissions. Heat input was available from 

two sources. The CAMD hourly database provides heat input, but there are two limitations 

for each use in this analysis. First, the heat input is reported at the unit level and does not 

provide a breakout of heat input for units using multiple fuels. Second, only a 6-month 

heat input value is provided for those units only required to report for six months. 

As an alternative to the CAMD heat input, the S/L NIF tables usually provide a fuel 

process annual throughput which can be used to calculate the heat input using the heating 

value of the fuel. By calculating the heat input using the NIF annual throughput, the 

annual heat input is available by fuel type for both 6-month and 12-month reporting units. 

Where NIF annual throughput was available, it was used to calculate the annual heat input 

which was then used to calculate condensable PM emissions. In cases where the S/L NIF 

tables do not provide an annual throughput, the CAMD heat input was assigned to the 

primary fuel type and used in the condensable PM emission calculations. 

2.2.1.3 EGU PM Emission Calculations 

In addition to calculating the condensable PM emissions, the EGU PM augmentation also 

gap-fills missing PM compounds. The gap-filling requires that the data be analyzed and 

separated into cases. The cases determine which math steps and ratios of PM terms will be 

applied. Exhibit 2.4 shows the various cases and the augmentation method that was 

applied. 
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Exhibit 2.4 – Cases and Required Steps to Augment EGU PM Emissions 

Case PM Reported Augmentation Methodology

1 --- None required; all PM compounds = 0

2 PM25-PRI PM-CON = HEAT_USED * EMIS_FACT

PM25-PRI = PM-CON (only if PM-CON > PM25-PRI)

PM25-FIL = PM25-PRI - PM-CON

PM10-FIL = PM25-FIL * F10_F25 ratio

PM10-PRI = PM-CON + PM10-FIL

3 PM10-PRI PM-CON = HEAT_USED * EMIS_FACT

PM10-PRI = PM-CON (only if PM-CON > PM10-PRI)

PM10-FIL = PM10-PRI - PM-CON

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PM-CON + PM25-FIL

4 PM25-PRI

PM10-PRI

PM-CON = HEAT_USED * EMIS_FACT

PM10-PRI = PM-CON (only if PM-CON > PM10-PRI)

PM25-PRI = PM-CON (only if PM-CON > PM25-PRI)

PM10-FIL = PM10-PRI - PM-CON

PM25-FIL = PM25-PRI - PM-CON

5 PM10-FIL PM-CON = HEAT_USED * EMIS_FACT

PM10-PRI = PM-CON + PM10-FIL

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PM-CON + PM25-FIL

6 PM10-FIL

PM25-FIL

PM-CON = HEAT_USED * EMIS_FACT

PM10-PRI = PM-CON + PM10-FIL

PM25-PRI = PM-CON + PM25-FIL

7 PM10-FIL

PM10-PRI

PM25-FIL

PM25-PRI

PM-CON = HEAT_USED * EMIS_FACT

8 PM-PRI PM-CON = HEAT_USED * EMIS_FACT

PM-PRI = PM-CON (only if PM-CON > PM-PRI)

PM-FIL = PM-PRI - PM-CON

PM10-FIL = PM-FIL * F10_FIL ratio

PM10-PRI = PM-CON + PM10-FIL

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PM-CON + PM25-FIL

9 PM-PRI

PM10-PRI

PM-CON = HEAT_USED * EMIS_FACT

PM10-PRI = PM-CON (only if PM-CON > PM10-PRI)

PM10-FIL = PM10-PRI - PM-CON

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PM-CON + PM25-FIL

10 PM-PRI

PM10-FIL

PM-CON = HEAT_USED * EMIS_FACT

PM10-PRI = PM-CON + PM10-FIL

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PM-CON + PM25-FIL
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Case PM Reported Augmentation Methodology

11 PM-FIL PM-CON = HEAT_USED * EMIS_FACT

PM10-FIL = PM-FIL * F10_FIL ratio

PM10-PRI = PM-CON + PM10-FIL

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PM-CON + PM25-FIL

12 PM-FIL

PM10-FIL

PM25-FIL

PM-CON = HEAT_USED * EMIS_FACT

PM10-PRI = PM-CON + PM10-FIL

PM25-PRI = PM-CON + PM25-FIL

13 PM-CON

PM10-FIL

PM25-FIL

PM10-PRI = PM10-FIL + PM-CON

PM25-PRI = PM25-FIL + PM-CON

14 PM-CON

PM10-FIL

PM10-PRI

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PMCON + PM25-FIL

15 PM-CON

PM10-FIL

PM10-PRI

PM25-FIL

PM25-PRI

None required; all PM compounds present

16 PM-CON

PM-PRI

None required; only one occurrence and emissions were trivial

17 PM-CON

PM-PRI

PM10-FIL

PM10-PRI

PM25-FIL

PM25-PRI

None required; all PM compounds present

18 PM-CON

PM-FIL

PM-PRI

PM10-FIL

PM10-PRI

PM25-FIL

PM25-PRI

None required; all PM compounds present
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

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2.2.2 NONEGU PM Augmentation 

The nonEGU PM augmentation process utilized the methodology developed for 

MARAMA for the 2002 MANE-VU Version 3 inventory. The steps in the PM 

augmentation process were as follows: 

Step 1: Initial QA and remediation of S/L provided PM pollutants; 

Step 2: Updating of PM factor ratios previously developed for MARAMA based on 

factors from the Factor Information and Retrieval (FIRE) Data System and the 

USEPA PM Calculator (Appendix C provides the PM ratio table by SCC and 

control device); 

Step 3: Implementation of the ratios developed in step 2.; and 

Step 4: Presentation of PM augmentation results to S/L agencies for review and 

comment. 

2.2.2.1 Initial QA and Remediation of PM Pollutants 

Before we ran the nonEGU PM augmentation process, we reviewed the data for 

inconsistencies. Inconsistent values were be replaced. The consistency checks and 

replacement actions were as follows: 

1. If PM10-PRI >0 and PM25-PRI > PM10-PRI (and PM10-FIL, PM25-FIL and PMCON are null or 0), then set PM25-PRI = PM10-PRI. 

2. If PM10-FIL > 0 and PM25-FIL > PM10-FIL (and PM10-PRI, PM25-PRI and PMCON are null or 0), then set PM25-FIL = PM10-FIL. 

3. If PM10-PRI >0 and PM10-FIL > PM10-PRI (and PM25-PRI, PM25-FIL and PMCON are null or 0), then set PM10-FIL = PM10-PRI. 

4. If PM25-PRI > 0 and PM25-FIL > PM25-PRI (and PM10-PRI, PM10-FIL and PMCON are null or 0), then set PM25-FIL = PM25-PRI. 

The consistency checks revealed very few occurrences of inconsistencies, and when 

inconsistencies did occur, the emission values were very small. As a result, S/L agencies 

were not asked to review this information and provide corrections because the 

inconsistencies did not involve significant emission sources. The replacement actions 

above were appropriate for an inventory used for regional air quality modeling. 

2.2.2.2 Updating of PM Factor Ratios 

The augmentation steps require the use of ratios developed from available emissions and 

particle size distribution data. These ratios are needed when only one PM term is available, 
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and two or more terms need to be augmented. Examples of how we used the PM ratios are 

shown below: 

PM-FIL × RatioCON/FIL = PM-CON 

PM-PRI × RatioCON/PRI = PM-CON 

PM-CON × RatioFIL/CON = PM-FIL 

PM-CON × RatioPRI/CON = PM-PRI 

For the MANE-VU 2002 inventory, a table of PM compound ratios was developed. The 

development of this table is documented in the TSD for the 2002 MANE-VU SIP Modeling 

Inventories, Version 3. The primary deliverable of this step of the process was the 

development of a table keyed by SCC, primary control device, and secondary control 

device. This table is called the SCC Control Device Ratios table (Reference Tables 

MANE-VU_PMAugmentation.mdb ). We updated this table to include SCC, primary 

control device, and secondary control device codes found in the 2007 inventory that were 

not contained in the 2002 MANE-VU inventory. Appendix C provides the PM ratio table 

by SCC and control device. 

2.2.2.3 NonEGU PM Emission Calculations 

The gap-filling requires that the data be analyzed and separated into cases. The cases 

determine which math steps and ratios of PM terms will be applied. Exhibit 2.5 shows the 

various cases and the augmentation method that was applied. 

After completing the calculations, the data was QA checked to ensure that the calculations 

resulted in consistent values for the PM complement. On a few occasions, the mix of ratio 

value and the pollutants and values provided by the S/L agency resulted in negative values 

when FIL was back-calculated. In this case the negative FIL value was set to zero and the 

PRI value was readjusted. In a few cases the appropriate combination of ratios, SCC, and 

control efficiencies were not available to calculate the PM10-PRI and PM25-PRI values. 

In these cases, PM10-PRI and PM25-PRI were set equal. 
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

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Exhibit 2.5 – Cases and Required Steps to Augment nonEGU PM Emissions 

Case PM Reported Augmentation Methodology

1 PM25-PRI PM-CON = PM25-PRI * CON_P25 ratio

PM25-FIL = PM25-PRI - PM-CON

PM10-FIL = PM25-FIL * F10_F25 ratio

PM10-PRI = PM-CON + PM10-FIL

2 PM10-PRI PM-CON = PM10-PRI * CON_P10 ratio

PM10-FIL = PM10-PRI - PM-CON

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PM-CON + PM25-FIL

3 PM25-PRI

PM10-PRI

PM-CON = PM10-PRI * CON_P10 ratio

PM10-FIL = PM10-PRI - PM-CON

PM25-FIL = PM25-PRI - PM-CON

4 PM10-FIL PM-CON = PM-CON * CON_F10 ratio

PM10-PRI = PM-CON + PM10-FIL

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PM-CON + PM25-FIL

5 PM10-FIL

PM25-FIL

PM-CON = PM10-FIL * CON_F10 ratio

PM10-PRI = PM-CON + PM10-FIL

PM25-PRI = PM-CON + PM25-FIL

6 PM10-FIL

PM10-PRI 

PM-CON = PM10-PRI - PM10-FIL

PM25-FIL = PM10-FIL * F25_F10 ratio

PM25-PRI = PM-CON + PM25-FIL

7 PM25-FIL PM-CON = PM25-FIL * CON_F25 ratio

PM10-FIL = PM25-FIL * F10-F25 ratio

PM10-PRI = PM-CON + PM10-FIL

PM25-PRI = PM-CON + PM25-FIL

8 PM10-FIL

PM10-PRI

PM25-FIL

PM25-PRI

PM-CON = PM25-PRI - PM25-FIL

9 PM-PRI PM-CON = PM-PRI * CON_PRI ratio

PM-FIL = PM-PRI - PM-CON

PM10-FIL = PM-FIL * F10_FIL ratio

PM10-PRI = PM-CON + PM10-FIL

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PM-CON + PM25-FIL

10 PM25-FIL

PM25-PRI

PMCON = PM25-PRI - PM25-FIL

PM10-FIL = PM25-FIL * F10_F25 ratio

PM10-PRI = PM-CON + PM10-FIL

11 PM-CON

PM10-FIL

PM25-FIL

PM10-PRI = PM-CON + PM10-FIL

PM25-PRI = PM-CON + PM25-FIL
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Case PM Reported Augmentation Methodology

12 PM-CON PM10-FIL = PM-CON * F10_CON ratio

PM25-FIL = PM10-FIL * F25_F10 ratio

PM10-PRI = PM-CON + PM10-FIL

PM25-PRI = PM-CON + PM25-FIL

13 PM-CON

PM10-FIL

PM10-PRI

PM25-FIL = PM10-FIL / F10_F25 ratio

PM25-PRI = PMCON + PM25-FIL

14 PM-CON

PM10-FIL

PM10-PRI

PM25-FIL

PM25-PRI

None required; all PM compounds present

15 PM-CON

PM-FIL

PM10-FIL = PM-CON / CON_F10 ratio

PM25-FIL = PM10-FIL / F10_F25 ratio

PM10-PRI = PM-CON + PM10-FIL

PM25-PRI = PM-CON + PM25-FIL

16 PM-CON

PM10-PRI

PM25-PRI

PM10-FIL = PM10-PRI - PM-CON

PM25-FIL = PM25-PRI - PM-CON

17 PM-FIL PM10-FIL = PM-FIL * F10_FIL ratio

PM_CON = PM10-FIL * CON_F10 ratio

PM25-FIL = PM10-FIL / F10_F25 ratio

PM10-PRI = PM-CON + PM10-FIL

PM25-PRI = PM-CON + PM25-FIL

2.3 EMISSION RELEASE POINT QA CHECKS 

Stack parameters are an important component of an emission inventory used for regional 

air quality modeling. Careful QA is required to ensure that the point source emissions are 

properly located both horizontally and vertically on the modeling grid. This section 

describes the procedures used to quality assure, augment, and where necessary, revise, 

stack parameters using standardized procedures to identify and correct stack data errors. 

These procedures were implemented within the NIF file itself, and are based on the QA 

procedures built into SMOKE that are designed to catch missing or out-of-range stack 

parameters. 

2.3.1 QA Checks and Gap-Filling for Location Coordinates 

Because air quality modeling strives to replicate the actual physical and chemical processes 

that occur in an inventory domain, it is important that the physical location of emissions be 

determined as accurately as possible. The emission release (ER) point record is used to 

report the location and relevant physical attributes of the emission release point. Location 
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coordinates must be reported to identify where emissions are released to the ambient air, 

via a stack or non-stack (e.g., fugitive release). For a non-stack, or fugitive release, 

coordinates may represent the general location where emissions are released. 

In the ER record, location data may be reported as x and y coordinates (X – Y) from either 

of two coordinate systems - Latitude / Longitude (LATLON), or Universal TransMercator 

(UTM). X - Y coordinates reported as Latitude and Longitude must be reported in the 

decimal degree format. X - Y coordinates reported as UTM Easting and UTM Northing, 

must be reported in kilometers. 

UTM data received from MARAMA was processed by the Contractor Team and converted 

to Latitude Measure and Longitude Measure in decimal degrees, as is required by the 

SMOKE emissions processing system. All conversions of UTM to LATLON were made 

using a spreadsheet1

developed by Professor Steven Dutch, School of Natural and Applied 

Sciences, University of Wisconsin - Green Bay. This spreadsheet tool allowed for batch 

conversion of UTM data to decimal degree format and was configured for WGS 84 

DATUM. While errors using this spreadsheet are typically a few meters, rarely 10 or 

more, the accuracy of the conversion is limited to the accuracy of the initial UTM data. 

Once conversions were made to LATLON decimal degrees, reasonableness checks were 

conducted on each release point relative to county centroids and min/max coordinates 

associated with the FIPS codes assigned to each stack. If a stack was located outside the 

western-, eastern-, northern- or southern-most boundary of the county (based on SMOKE’s 

county lat/lon file), the point was flagged for additional review. Flagged sources were then 

mapped with GIS software to determine their placement relative to the FIPS County 

associated with the stack. If a source was found to be outside of the county boundaries, it 

was identified for further review. 

2.3.2 QA Checks and Gap-Filling for Emission Release Parameters 

In preparing emissions for grid modeling, valid parameters for the physical characteristics 

of each release point (stack height, diameter, temperature, velocity, and flow) are necessary 

to correctly place facility release points and associated emissions into vertical layers for 

proper air quality modeling. The USEPA’s QA guidance for diagnosing stack parameter 

issues was generally applied to identify QA issues in the S/L point source inventories. The 

QA guidance involved diagnosing the correct assignment of the ERP type (i.e., stack or 

 

1

 http://www.uwgb.edu/dutchs/FieldMethods/UTMSystem.htm 
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

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fugitive), parameters with zero values, parameters not within the range of values specified 

in the USEPA’s QA procedures, and consistency checks (i.e., comparing calculated values 

against the values reported in the inventory). In many cases errors were caused by missing 

or zero values. 

The first step of our quality assurance (QA) involves review of the Emission Release Point 

Type. Using this type code, we used a routine to assess the validity of the stack 

parameters, to replace values if necessary, and to fill-in missing data points. We employed 

a routine that compared each emission release point parameter to a minimum and 

maximum range of values and when that parameter was missing or was found to exist 

outside of that range, we augmented the parameter. We also checked non-fugitive stack 

parameters for internal consistency between: 

stack height and diameter, and 

stack diameter, exit gas velocity, and exit gas flow rate. 

When internal consistency was not met, we provided replacement values for the 

parameters. 

The following steps summarize the process of finding and replacing missing, out-of-range, 

or internally inconsistent stack parameters.

Step 1: For fugitive emission release points, replace stack parameters 

For fugitive emission release points (ERPTYPE=01), we first compared the existing 

fugitive emission height against the following range thought to be representative of the 

minimum and maximum values allowable for most fugitive emission release points. 

Fugitive Release Height: 0.1 to 100 ft 

In all but one case, the fugitive release height was valid. For that one case, we set the 

fugitive release height to 100 feet. For all other cases, we kept the fugitive release height 

and replaced all other stack parameters with the defaulted values listed below. In some 

cases, the fugitive release height was blank but the S/L agency provided a stack height and 

we retained the S/L supplied stack height. In other cases, the S/L agency provided a 

temperature for the fugitive emissions and we retained the S/L supplied temperature. The 

following summarizes the procedure for filling in stack parameters for fugitive emission 

release points: 
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Stack Height: use fugitive release height, if valid; if fugitive release height not 

present and stack height provided, use the stack height; if neither fugitive release 

height or stack height not present, use 10 feet as the default. 

Stack Temperature: use temperature provided by S/L agency, if valid; otherwise 

used 72 oF. 

Stack Diameter: use 0.003 feet for fugitive sources 

Stack Velocity: 0.0003 feet per second for fugitive sources 

Stack Flow: use 0.0 cubic feet per second for fugitive sources 

Step 2: For non-fugitive emission release points, find and replace out-of-range or 

missing stack heights and temperatures 

For non-fugitive emission release points, we compared existing stack parameters against a 

set of the following ranges thought to be representative of the minimum and maximum 

values allowable for most emission release points. 

Stack Height: 0.1 to 1000 feet 

Stack Temperature: 50 to 1,800 oF 

Stack Diameter: 0.1 to 50 feet 

Missing or out-of range parameters were identified and evaluated. If not realistic, missing 

or out-of range parameters were replaced using the procedures described below. 

Stack Height: All stack heights were less than the maximum value of 1000 feet. 

Numerous stack heights were zero or missing, in which case the stack height was 

filled in using national default sets of physical parameter data based on the SCC. 

The stack parameter national default database is included as Appendix D. 

Stack Temperature: There were 30 records where the stack temperature exceeded 

1,800 oF. We reviewed the stack description table for these records, which 

indicated that most of these stacks were for flares or furnaces. We deemed the S/L 

supplied temperature data as plausible and retained the S/L provided value. There 

were 100 records where the stack temperature was less than 50 oF and not equal to 

0 oF or missing. We reviewed the stack description table for these records. Many 

of these stacks were for refrigerated tanks or other sources where the S/L supplied 

temperature data was deemed plausible. For example, a nylon manufacturing 

facility in Virginia emits thousands of tons of NOx in 2007. Most of the NOx is 
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emitted from a handful of fairly cold stacks, with exit gas temperatures generally 

ranging from 40-60 degrees. Rather than replace these S/L supplied values that 

seemed plausible with national defaults, we retained the S/L supplied data. Where 

the stack temperature was reported as 0 oF or missing, we replaced the stack 

temperature with the national default based on the SCC. 

Step 3: For non-fugitive emission release points, find and replace out-of-range or 

missing stack diameters, velocities, and flow rates 

First, we evaluated the stack diameter to determine if it was within the valid range of 0.1 to 

50 feet. There were 200 records where the stack diameter exceeded 50 feet. We reviewed 

the stack description table for these records. Most of these were large storage tanks, 

cooling towers, wastewater treatment ponds or area-type sources such as process 

equipment leaks. Based on this review, we deemed the S/L supplied diameter data as 

plausible and retained the S/L provided value. 

There were 66 records with missing stack diameters where both the velocity and flow rate 

were provided. For these records, the stack diameter was calculated using the following 

equation: 

Stack Diameter [ft] = SQRT ( 4 * Stack Flow [cu ft/sec] / (Stack Velocity [ft/sec] * π [Pi]))

For the remaining cases where the stack diameter was reported as zero or missing, we 

replaced the stack diameter with the national default based on the SCC. 

Next, the velocity and flow rate were evaluated. If the diameter, velocity and flow rate 

were all non-zero, we assessed internal consistency between diameter, velocity and flow 

rate using the following equation: 

Stack Flow [cu ft/sec] = (π [Pi] * (Stack Diameter [ft] / 2) ^ 2) * Stack Velocity [ft/sec] 

If the calculated and reported flow rates are within 10 % of one another, then internal 

consistency was assumed and no additional steps were taken. If the internal consistency 

was not met for velocity and flow rate, Exhibit 2.6 below provides details on the approach 

taken to correct missing, out-of-range values, or internally inconsistent values for velocity 

and flow rate based on different scenarios. Velocity and flow rate were augmented either 

by calculation or the use of national defaults by SCC when necessary. 
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Exhibit 2.6 - Stack Parameter Data Replacement Matrix 

(X = Data value present) 

Diameter Velocity Flow Rate Action

- X X 1. Calculate diameter using velocity and flow rate.

2. Check that calculated diameter is within range.

- - - 1. Replace diameter, velocity, and flow rate with 

national SCC default values.

- - X 1. Replace diameter, velocity, and flow rate with 

national SCC default values.

- X - 1. Replace diameter, velocity, and flow rate with 

national SCC default values.

X - - 1. Default velocity using national default sets.

2. Calculate flow rate using internal consistency 

formula.

X - X 1. Calculate velocity using internal consistency 

formula.

2. Check that calculated velocity is within range (less 

than 150 ft/sec).

A. If calculated velocity is not within range, 

then default all 3 parameters using national 

default sets.

X X - 1. Check that velocity is within range (less than 150 

ft/sec).

A. If velocity is within range, then:

> Calculate flow rate using internal 

consistency formula.

B. If velocity is not within range, then:

> Default all 3 parameters using national 

default sets.

X X X 1. Check that velocity is within range (less than 150 

ft/sec).

A. If velocity is within range and flow rate does 

not meet internal consistency for diameter, 

velocity and flow rate, then:

> Calculate flow rate using internal 

consistency formula.

B. If velocity is not within range, then:

> Calculate velocity using internal consistency 

formula.

> Check that calculated velocity is within 

range. If so, then default to calculated velocity.

> If calculated velocity is not within range, then 

default all 5 parameters using national default 

set.
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2.4 IDENTIFICATION OF EGUs AND NONEGUs 

In the past, point sources have been categorized as either EGUs or nonEGUs using a 

variety of schemes. The SCC, standard industrial classification code (SIC), and North 

American Industry Classification System (NAICS) code have been used to classify sources 

as either EGU or nonEGU. Another scheme that has been used is to classify as EGU 

sources that is required to report emissions to USEPA’s CAMD hourly emission database. 

For consistency in both reporting and projecting emissions to the future, the MANEVU+VA inventory using the following scheme for classifying point sources: 

CAMD EGU – these are units that report emissions to the USEPA CAMD hourly 

emission database and have been classified by States as EGUs; 

CAMD nonEGU - these are units that report emissions to the USEPA CAMD 

hourly emission database and have been classified by States as nonEGUs; and 

OTHER – all other nonEGU point sources and small EGU point sources not 

included in the above categories. 

Data elements were add to the NIF EP table to include the above classification scheme. 

This classification scheme was reviewed and approved by ERTAC. 

2.5 VERSION 2 - STAKEHOLDER COMMENT AND RESPONSE 

On October 6, 2009, MARAMA provided a notice to stakeholders of the opportunity to 

review the initial draft of the 2007 point source inventory data and documentation. 

Stakeholders were invited to review and comment on the draft 2007 inventory of air 

emissions from point sources to be used for regional air quality modeling. On October 20, 

MARAMA hosted a conference call that provided an opportunity for stakeholders to ask 

questions about the draft 2007 point source modeling inventory. Written comments were 

reviewed by the State inventory staff and MARAMA, and resulted in several changes to 

the draft documentation and inventory data. The changes requested by stakeholders and 

approved by the States are summarized in the following subsections. 

2.5.1 Connecticut Response to Stakeholder Comments 

Sikorsky Aircraft provided comments on roughly ten sources regarding the SO2, PM, and 

VOC emissions. The requested changes were very small (under a ton per year). 

Connecticut accepted Sikorsky Aircraft’s comments. 
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Covanta Energy commented that the annual NOx emissions for the Covanta Bristol Unit 

#1 (Facility ID 09003-0902, emission unit P0026) were abnormally low because of a 

temporary pilot test of a NOx emission control technology. Covanta requested that 2005 

emissions should be used since the 2007 actual emissions are not representative of 

previous or subsequent years. Since the 2007 inventory is being used for air quality 

modeling that will be tied to actual air quality data, Connecticut decided to use actual 2007 

emission values rather than 2005 values as requested by Covanta. Connecticut will 

consider this comment again during the development of the future year inventories to 

ensure that reasonable future year emissions are estimated. 

Hamilton Sundstrand commented that three emission units at its facility (Facility ID 

09003-8602, emission units P0038, P0079, and R0097) were permanently shut down in 

2008. Since the 2007 inventory is being used for air quality modeling that will be tied to 

actual air quality data, Connecticut decided to use actual 2007 emission values. 

Connecticut will consider this comment again during the development of the future year 

inventories to ensure that reasonable future year emissions are estimated. 

NRG Energy provided very minor revisions to the SO2, NOx, CO, VOC, PM and NH3 

emissions data for the Montville (Facility ID 09011-1505) and Norwalk (Facility ID 

09001-4214) facilities. Connecticut accepted these changes. 

2.5.2 Maryland Response to Stakeholder Comments 

NRG Energy requested a change to the VOC emissions for the Vienna Power Generating 

Station (Facility ID 019-0013, emission unit 4-0065). Maryland agreed to make the 

change, revising the VOC emissions from 0.9455 to 0.9641 tons per year. 

Transcontinental Gas Pipe Line Company commented that the inventory for its facility in 

Howard County (Facility ID 027-0223) has 12 internal combustion engines represented by 

one grouped emission unit, which gives the impression that there is one large source when 

there are actually 12 smaller units. Maryland did not change the inventory based on this 

comment since the 12 engines are nearly identical and identifying each engine individually 

is not needed for the 2007 modeling inventory. 

Covanta Energy requested changes to the stack parameters for the three units at the 

Montgomery County Resource Recovery Facility (Facility ID 031-1718). Maryland 

agreed to make those revisions. 
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2.5.3 Massachusetts Response to Stakeholder Comments 

Saint Gobain Containers requested minor changes to the annual emissions and stack 

parameters for its facility in Milford (Facility ID 25027-1200856). Massachusetts 

accepted the changes and the 2007 inventory was updated to reflect the stakeholder 

comments. 

Verallia formerly (Saint Gobain Containers) also provided comments on the 2007 PM2.5 

emissions for all sources and stated that they may not contain appropriate condensable 

emissions. The company did not provide revised estimates or suggestions for improving 

the estimates of condensable emissions. For facilities that did not report PM2.5 or 

condensable emissions, the PM2.5 or condensable emissions were calculated using the 

methodogy described in Section 2.2.2. MARAMA acknowledges that there is some 

uncertainty regarding the methodology, but lacking source-specific data the methodology 

is the best available technique at this time for filling in the missing PM2.5 or condensable 

emissions. 

Verallia formerly (Saint Gobain Containers) also indicated that stack flow rate data was 

missing for their plants in Massachusetts. The facilities facilities did have stack velocity 

data. This data gap was filled by calculating the flow rate using the stack diameter and the 

stack exit velocity. 

2.5.4 New Jersey Response to Stakeholder Comments 

RRI Energy provided updated emissions and stack data for several of its facilities, mostly 

minor changes to PM emission values and revisions to stack parameters. New Jersey 

agreed to make the revisions provided by RRI Energy. 

BASF identified that its plant in East Newark (Facility ID 34017-10419) was permanently 

shut down and did not operate in 2007. New Jersey agreed and the 2007 emissions were 

set to zero. 

Merck & Co., Inc indicated that its facility in Rahway, NJ (Facility ID 34039-41712) 

emitted 3.42 tons/yr of ammonia emissions from their boilers in 2007. New Jersey agreed 

and the ammonia emissions were added to the inventory. 

Georgia Pacific Gypsum LLC submitted updates for its Camden facility (Facility ID 

34007-51611) to correct the 2007 emissions based upon recent stack test data for board 

dryer U7 and process emissions factors from kettles U3, U4 and U5. Total PM2.5 

emissions were also updated using current AP-42 factors for the Gypsum industry. In 
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addition, the ammonia emissions were missing from the inventory. New Jersey agreed to 

make the requested changes. 

E.R. Squibb & Sons, LLC, requested changes to the ammonia and PM2.5 emissions for its 

facilities in Lawrenceville, NJ (Facility ID 34021-61052), New Brunswick, NJ (Facility ID 

34023-17739), and Hopewell (Facility ID 34021-61053). New Jersey agreed to make the 

requested changes. 

Schering Corporation supplied corrections to the ammonia emissions from its Kenilworth 

facility (Facility ID 34039-41806). New Jersey agreed to make the requested changes. 

ConocoPhillips Company provided revisions to ammonia and VOC emissions for the 

Bayway Refinery (Facility ID 34039-41805). They also provided revisions to selected 

SCCs for certain heaters, sulfur recovery units, truck loading activities, marine vessel 

loading activities, and emergency flares. ConocoPhillips also requested that certain parts 

of the refinery be modeled as area sources rather than point sources, and provided 

rectangular grid coordinates to define the area sources. While this change would be 

appropriate for a fence line modeling study, it cannot not be accommodated in a multiState regional air quality model since the SMOKE emission modeling system is not 

capable of handling area sources that are smaller than the air quality model grid cell. 

Therefore, this change was not made. 

Covanta Energy requested minor revisions to the ammonia and PM emissions at the Union 

County Resource Recovery Facility (Facility ID 34039-41814) and Warren Energy 

Resource Facility (Facility ID 34041-85455). New Jersey agreed to make those revisions. 

Air Engineering submitted comments on behalf of EF Kenilworth LLC (Facility ID 34029-

41741), requesting minor changes to PM emissions and revisions to stack parameters. 

New Jersey agreed to make the requested changes. 

Air Engineering submitted comments on behalf of Rowan University (Facility ID 34015-

55779), requesting adding ammonia emissions for its sources. New Jersey agreed to make 

the requested changes. 

Air Engineering submitted comments on behalf of The College of New Jersey (Facility ID 

34021-61008), requesting adding ammonia emissions for its sources and revisions to stack 

parameters. New Jersey agreed to make the requested changes. 

Actavis requested the addition of 0.13 tons per year of ammonia for their facility (Facility 

ID 34039-40295). New Jersey agreed to make the addition. 
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PSEG Power LLC requested changes to SCCs and stack parameters, as well as numerous 

minor changes to emission estimates, for its facilities in New Jersey. New Jersey agreed to 

make the revisions. PSEG also requested the units classified as “insignificant units” be 

excluded from the modeling inventory. New Jersey elected to keep the emissions from 

insignificant units in the inventory because the purpose of the inventory is to model all of 

the emissions actually emitted in 2007. 

MRPC/OEC-LES requested changes SCCs, ammonia and PM emissions, and stack 

parameters for its facility (Facility ID 34029-78901). New Jersey agreed to make the 

revisions. 

2.5.5 New York Response to Stakeholder Comments 

Covanta Energy provided updated PM emissions and stack data for several of its facilities, 

mostly minor changes to PM emission values and revisions to stack parameters. New 

York agreed to make the revisions provided by Covanta Energy. 

NRG Energy provided updated PM emissions and stack data for its facilities. NRG Energy 

also provided updated data for the individual turbine units at the Astoria Gas Turbine 

Power Plant (ORISID=55243). New York agreed to make the revisions provided by NRG 

Energy. NRG Energy also noted that baghouses are being installed at the Dunkirk and 

Huntley coal-fired plants. These changes were noted and will be accounted for in the 

future year inventories. 

2.5.6 Pennsylvania Response to Stakeholder Comments 

Covanta Energy requested changes to stack parameters at the Delaware Valley (Facility ID 

420450059), Lancaster County (Facility ID 420710145), Plymouth (420910295) and 

Harrisburg (Facility ID 420430017) facilities. Covanta also requested minor changes to 

the emission estimates at the Plymouth facility. Pennsylvania agreed to make those 

revisions. 

RRI Energy provided updated emissions and stack data for several of its facilities. The 

most notable change was a significant increase in PM emissions at several coal-fired units. 

Pennsylvania agreed to make the revisions provided by RRI Energy. 

Saint Gobain Containers requested minor changes to the annual emissions and stack 

parameters for its facility in Port Allegheny (Facility ID 420830006). Pennsylvania 

accepted the changes and the 2007 inventory was updated to reflect the stakeholder 

comments. 
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Verallia formerly (Saint Gobain Containers) also provided comments on the 2007 PM2.5 

emissions for all sources and stated that they may not contain appropriate condensable 

emissions. The company did not provide revised estimates or suggestions for improving 

the estimates of condensable emissions. For facilities that did not report PM2.5 or 

condensable emissions, the PM2.5 or condensable emissions were calculated using the 

methodogy described in Section 2.2.2. MARAMA acknowledges that there is some 

uncertainty regarding the methodology, but lacking source-specific data the methodology 

is the best available technique at this time for filling in the missing PM2.5 and condensable 

emissions. 

The National Lime Association requested changes to the PM emissions for four of their 

member facilities: Mercer Lime & Stone (Facility ID 420190021), Graymont/Pleasant Gap 

(Facility ID 420270003), Carmeuse Lime/Millard Lime (Facility ID 420750016), and 

OWB Refractories (Facility ID 421330007). Pennsylvania accepted the changes and the 

2007 inventory was updated to reflect the stakeholder comments. 

Magnesita Refractories (formerly LWB Refractories) provided minor revisions to stack 

data and PM emission estimates for the facility. Pennsylvania determined that no changes 

to the 2007 inventory were needed since the PM2.5 emissions were small (about 20 tons 

per year) and that PM2.5 emissions of this magnitude should not adversely impact the 

results of regional air quality modeling analyses using these inventories. 

Carmeuse Lime provided minor revisions to stack data and PM emission estimates for the 

facility. Pennsylvania determined that no changes to the 2007 inventory were needed since 

the PM2.5 emissions were small (about 10 tons per year) and that PM2.5 emissions of this 

magnitude should not adversely impact the results of regional air quality modeling 

analyses using these inventories. 

2.5.7 Virginia Response to Stakeholder Comments 

Virginia received comments from Covanta Energy and Transco requesting very minor 

changes to the emissions for their facilities (generally less than 0.1 ton change in 

emissions). Virginia decided not to make those changes because of the insignificant 

impact on the regional modeling inventory. 

BASF identified that its plant in Virginia is permanently shut down. Since it did operate in 

2007, the actual 2007 emissions will be used for the 2007 modeling. Emissions from the 

plant will be set to zero for future year inventories. 

Michigan Cogen Systems requested minor changes to stack parameters for their facility. 

Virginia approved the requested changes. 
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Virginia received revised stack parameters for about 20 units at the Chemical Lime 

Company’s Kimbalton Plant. Due to the location of this facility and the size of the 

emissions in 2007, Virginia determined that the recommended changes should not affect 

air quality modeling results for 2007. 

Virginia received comments from Carmeuse Natural Chemicals regarding the PM2.5 

emissions at two of its facilities in Virginia. Since the company did not provide PM2.5 

emissions to Virginia, the PM2.5 emissions were calculated using the methodogy 

described in Section 2.2.2. Virginia acknowledged that there is some uncertainty regarding 

the methodology, but lacking source-specific data the methodology is the best available 

technique at this time for filling in the missing PM2.5 emissions. Virginia determined that 

no changes to the 2007 inventory were needed since the PM2.5 emissions from these two 

kilns were small (less than 20 tons per year) and that PM2.5 emissions of this magnitude 

should not adversely impact the results of regional air quality modeling analyses using 

these inventories. 

2.6 VERSION 2 - ADDITIONAL STATE-SPECIFIC UPDATES 

Several States and local agencies provided revisions and updates following their review of 

the initial draft of the point source inventory posted in October, 2009. These changes are 

summarized in the following subsections. 

2.6.1 Connecticut 

During the review of the initial draft 2007 inventory, Connecticut identified several 

emission units with unexpectedly high emission values. Connecticut determined that its 

original submittal had emissions adjusted for rule effectiveness. Since the 2007 inventory 

is being used for air quality modeling that will be tied to actual air quality data, 

Connecticut decided to use actual 2007 emission values rather than values that had been 

artificially adjusted to account for rule effectiveness. The Contractor calculated the actual 

emissions for all units with a non-zero rule effectiveness value by backing out the rule 

effectiveness value. These actual emission values were supplied to Connecticut for review 

and approval. Connecticut recommended that the actual emissions calculated by the 

Contractor be used instead of the values originally supplied by Connecticut which included 

rule effectiveness. 

Connecticut indicated that some of the PM records in their original submittal used 

incorrect pollutant codes. Connecticut indicated that the PM records in their original 

submittal for oil and coal-fired boilers should have been submitted as PM10-FIL and not 

PM10-PRI. All natural gas-fired units and oil-fired turbines were correctly reported as 
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PM10-PRI. The PM augmentation routine described in Section 1.3 was re-executed for the 

coal- and oil-fired units. 

2.6.2 Delaware 

No revisions to the initial inventory were requested or made. 

2.6.3 District of Columbia 

The District of Columbia made revisions to the emission inventory for Benning Road 

(Facility ID 11001-0001). There are four emission units at the facility designated as Units 

1, 2, 15, and 16. Units 15 and 16 report emissions to USEPA’s CAMD CEM database, 

while units 1 and 2 do not. Units 1 and 2 were not included in the initial point source 

inventory. These two units were added to the inventory and increased facility-wide SO2 

emissions by about 100 tons per year and NOx emissions by 50 tons per year. Smaller 

increases were added for the other pollutants. 

2.6.4 Maine 

Maine provided a small correction to the SO2 emissions for the Maine Independence 

Station (Facility ID 2301900115). 

Maine provided small corrections to the SO2 and NOx emissions for Westbrook Energy 

Center (Facility ID 2300500193). Also there was an error in the cross-reference between 

the USEPA CAMD database and the State’s NIF database, which was corrected. 

2.6.5 Maryland 

No additional revisions beyond those requested by stakeholder were requested or made. 

2.6.6 Massachusetts 

An error in the PM augmentation routine was detected that incorrectly replaced Statereported PM25-FIL values. The Contractor reviewed the PM augmentation routine and 

identified the error that affected “Case 5” nonEGU PM25-FIL and PM25-PRI values. This 

error also affected numerous small sources in Massachusetts. The error was corrected and 

the State-reported PM25-FIL values were retained during the PM augmentation process 

and that the PM25-PRI values were correctly calculated using the State-reported PM25-

FIL value. 

Massachusetts identified errors in the ammonia emissions for 2007 for the Stony Brook 

Energy Center (25013-0420001) and New Bedford Energy (25005-1200634). 

Massachusetts provided corrected ammonia emission estimates for these two facilities. 

This change reduced ammonia emissions in Massachusetts by about 2,300 tons. 
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2.6.7 Maine 

Maine identified on error in the PM augmentation routine that incorrectly replaced Statereported PM25-FIL values. The Contractor reviewed the PM augmentation routine and 

identified the error that affected “Case 5” nonEGU PM25-FIL and PM25-PRI values. The 

error was corrected and the State-reported PM25-FIL values were retained during the PM 

augmentation process and that the PM25-PRI values were correctly calculated using the 

State-reported PM25-FIL value. 

2.6.8 New Hampshire 

An error in the PM augmentation routine was detected that incorrectly replaced Statereported PM25-FIL values. The Contractor reviewed the PM augmentation routine and 

identified the error that affected “Case 5” nonEGU PM25-FIL and PM25-PRI values. This 

error also affected numerous small sources in New Hampshire. The error was corrected 

and the State-reported PM25-FIL values were retained during the PM augmentation 

process and that the PM25-PRI values were correctly calculated using the State-reported 

PM25-FIL value. 

2.6.9 New Jersey 

New Jersey identified numerous emission units that were inadvertently missing from their 

initial submittal. Most of these units were flagged as “insignificant units” or “non-source 

fugitive” sources in New Jersey’s data system and were excluded during the initial 

conversion to NIF tables. New Jersey subsequently identified these “unmatched” units and 

submitted pertinent data for inclusion in the 2007 modeling inventory. The Contractor 

added these units and emissions to the NIF database. The emissions added to the inventory 

from these units were about: 60 tpy of CO, 50 tpy of NOx, 672 tpy of PM10-PRI,257 tpy 

of PM25-PRI, 5 tpy of SO2, and 1,477 tpy of VOC. 

Ammonia emissions were missing from New Jersey’s initial submittal. New Jersey 

supplied the missing ammonia emissions, which added about 845 tpy of NH3 to the point 

source inventory. 

2.6.10 Pennsylvania – Allegheny County 

Allegheny County’s initial 2007 submittal included only the five “very large” sources that 

were submitted to USEPA for the 2007 NEI. After the release of the initial version of the 

point source inventory in October, 2009, the agency provided a second submittal with an 

addition 31 facilities. The second submittal was subjected to the QA and PM 

augmentation procedures described previously in Sections 1.2 and 1.3 of this report. 
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2.6.11 Pennsylvania - Philadelphia 

Philadelphia provided the following revisions to the initial draft inventory: 

Boiler #3 at Sunoco Chemical Frankford Plant (Facility ID 4210101551 and 

emission point 052) was linked to CAMD ORIS ID 880007 and boilerID 52. 

VOC emissions at Cardone Industries (Facility ID 4210103887) were increased 

from 75.96 to 143.98 tons per year. 

2.6.12 Rhode Island 

Rhode Island revised the emissions for Providence Metallizing Co. (Facility ID 

44007AIR1230 and emission point 2). All emissions for this emission point were changed 

to zero for 2007. 

2.6.13 Vermont 

No revisions to the initial inventory posted in October 2009 were requested or made. 

2.6.14 Virginia 

After the release of the initial version of the point source inventory in October, 2009, the 

agency provided a second submittal with a number of additional distributed generation 

units. The second submittal was subjected to the QA and PM augmentation procedures 

described previously in Sections 1.2 and 1.3 of this report. A flag was added to the EP 

table to identify the distributed generation units for both the units in Virginia’s original 

submittal as well as the new units. 

Virginia indicated that all of the PM records in their original submittal used incorrect 

pollutant codes. Records in the original submittal designated as PM10-PRI should have 

been submitted as PM10-FIL, and PM25-PRI should have been PM25-FIL. The PM 

augmentation routine described in Section 1.3 was re-executed after changing all PM10-

PRI to PM10-FIL and all PM25-PRI to PM25-FIL. 

Virginia revised the PM data for the Mirant Potomac River Generating Station (SiteID: 

51-510-00003) using 2007 condensable test data using the test method with the nitrogen 

purge to replace the emission factors previously applied by the Contractor. 

Virginia requested that the plantID for the Dominion Leesburg Compressor Station be 

changed from 51-107-71978 to 51-107-01016.

Virginia requested that the plantID for the Transcontinental Gas Pipeline Station 175 be 

changed from 51-065-40789 to 51-065-00016.
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Virginia’s review of stack test data Greif Packaging LLC (51-009-00022) showed an 

incorrect emissions factor applied in 2007. The 2007 emissions factor for CO was 54 lbs 

CO/ton processed. The test factor was 5.6 lbs CO/ton processed. The 2007 data was 

corrected using the lower emissions factor. 

2.7 VERSION 3 REVISIONS 

2.7.1 Emission Offsets 

Mulitple states (CT, MA, MD, NH and NJ) added county level records account for account 

emission reduction credits (ERCs) issued to stationary sources pursuant to state regulation. 

States provided ERCs on a county-by-county basis. Fictitious facilities with an identifier 

of “OFFSET99999” were created for each county using SCC 23-99-000-000 

(miscellaneous industrial processes: not elsewhere classified) Stack data were developed 

that assumed that emissions were released at the county centroid with an assumed release 

height of 10 feet. For the 2007, ERC emissions were set to zero since the banked 

emissions were not actually emitted in 2007. The ERCs will be included in the future year 

inventories and air quality modeling analysis. 

2.8 ANNUAL 2007 POINT SOURCE EMISSION SUMMARY 

Exhibits 2.7 to 2.20 present State-level summaries of 2002 and 2007 annual point source 

emissions by pollutant and compare 2007 annual emissions from CAMD EGUs, CAMD 

nonEGUs, and OTHER point sources. The 2002 emissions are those that were developed 

previously for Version 3 of the MANE-VU and the VISTAS best-and-final inventory for 

Virginia. 

For most States and pollutants, point source emissions have decreased from 2002 to 2007. 

Notable exceptions are substantial increases in PM10-PRI and PM25-PRI emissions in 

Maryland, Pennsylvania, and Virginia. These increases are primarily due to a better 

representation of condensable emissions in the 2007 inventory, especially for coal-fired 

power plants. New data provided by these States confirm that condensable emissions were 

underreported in the 2002 inventory. 

In 2007, CAMD EGUs accounted for about 88% of SO2 emissions, 62% of NOx, 51% of 

PM10-PRI, and 54% of PM25-PRI emissions. Non-CAMD reporting sources accounted 

for 94% of VOC and 82% of CO emissions in 2007. 
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Exhibit 2.7 – 2002 and 2007 Point Source CO Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 4,053 3,679 -9%

Delaware 9,766 7,753 -21%

District of Columbia 248 311 25%

Maine 17,005 14,483 -15%

Maryland 99,032 81,770 -17%

Massachusetts 21,641 10,108 -53%

New Hampshire 2,725 3,164 16%

New Jersey 12,300 10,548 -14%

New York 66,427 66,357 0%

Pennsylvania 121,524 101,440 -17%

Rhode Island 2,234 1,653 -26%

Vermont 1,078 2,146 99%

Virginia 70,688 70,353 0%

428,721 373,765 -13%

Exhibit 2.8 – EGU and nonEGU 2007 Point Source CO Emissions by State 
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Exhibit 2.9 – 2002 and 2007 Point Source NH3 Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 0 0 

Delaware 196 94 -52%

District of Columbia 4 0 -100%

Maine 845 665 -21%

Maryland 305 137 -55%

Massachusetts 1,578 647 -59%

New Hampshire 74 128 73%

New Jersey 0 918 

New York 1,861 2,417 30%

Pennsylvania 1,388 2,379 71%

Rhode Island 58 74 28%

Vermont 0 0 

Virginia 3,230 1,830 -43%

9,539 9,289 -3%

Exhibit 2.10 – EGU and nonEGU 2007 Point Source NH3 Emissions by State 
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Exhibit 2.11 – 2002 and 2007 Point Source NOx Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 12,923 10,061 -22%

Delaware 16,345 15,628 -4%

District of Columbia 780 789 1%

Maine 19,939 17,746 -11%

Maryland 95,369 74,890 -21%

Massachusetts 48,607 23,628 -51%

New Hampshire 9,759 7,441 -24%

New Jersey 51,593 30,088 -42%

New York 118,978 83,033 -30%

Pennsylvania 297,379 258,379 -13%

Rhode Island 2,764 1,444 -48%

Vermont 787 811 3%

Virginia 147,300 112,938 -23%

822,523 636,876 -23%

Exhibit 2.12 – EGU and nonEGU 2007 Point Source NOx Emissions by State 
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Exhibit 2.13 – 2002 and 2007 Point Source PM10-PRI Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 1,617 1,350 -17%

Delaware 4,217 3,465 -18%

District of Columbia 161 59 -63%

Maine 7,289 4,896 -33%

Maryland 9,046 19,322 114%

Massachusetts 5,852 5,604 -4%

New Hampshire 3,332 1,925 -42%

New Jersey 6,072 7,642 26%

New York 10,392 9,507 -9%

Pennsylvania 40,587 49,745 23%

Rhode Island 300 189 -37%

Vermont 304 146 -52%

Virginia 17,211 19,203 12%

106,380 123,053 16%

Exhibit 2.14 – EGU and nonEGU2007 Point Source PM10-PRI Emissions by State 
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Exhibit 2.15 – 2002 and 2007 Point Source PM25-PRI Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 1,283 1,242 -3%

Delaware 3,666 3,107 -15%

District of Columbia 132 53 -60%

Maine 5,787 3,852 -33%

Maryland 5,054 15,682 210%

Massachusetts 4,161 4,864 17%

New Hampshire 2,938 1,663 -43%

New Jersey 4,779 6,821 43%

New York 7,080 5,999 -15%

Pennsylvania 20,116 32,460 61%

Rhode Island 183 140 -23%

Vermont 267 114 -57%

Virginia 12,771 14,888 17%

68,217 90,885 33%

Exhibit 2.16 – EGU and nonEGU 2007 Point Source PM25-PRI Emissions by State 
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Exhibit 2.17 – 2002 and 2007 Point Source SO2 Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 15,988 7,971 -50%

Delaware 73,744 43,088 -42%

District of Columbia 963 612 -36%

Maine 23,711 17,248 -27%

Maryland 290,929 305,383 5%

Massachusetts 106,960 63,229 -41%

New Hampshire 46,560 45,258 -3%

New Jersey 61,217 40,703 -34%

New York 294,729 152,751 -48%

Pennsylvania 995,175 1,028,056 3%

Rhode Island 2,666 1,516 -43%

Vermont 905 322 -64%

Virginia 305,106 243,048 -20%

2,218,653 1,949,185 -12%

Exhibit 2.18 – EGU and nonEGU 2007 Point Source SO2 Emissions by State 
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Exhibit 2.19 – 2002 and 2007 Point Source VOC Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 4,907 1,590 -68%

Delaware 4,755 3,489 -27%

District of Columbia 69 59 -14%

Maine 5,319 5,022 -6%

Maryland 6,187 4,986 -19%

Massachusetts 8,350 4,557 -45%

New Hampshire 1,599 916 -43%

New Jersey 16,547 10,526 -36%

New York 11,456 10,891 -5%

Pennsylvania 37,323 28,965 -22%

Rhode Island 1,928 970 -50%

Vermont 1,097 395 -64%

Virginia 43,906 35,618 -19%

143,443 107,984 -25%

Exhibit 2.20 – EGU and nonEGU 2007 Point Source VOC Emissions by State 
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3.0 HOURLY 2007 INVENTORY FOR LARGE POINT SOURCES 

The sources included in the hourly inventory include those that report hourly emissions to 

USEPA’s CAMD database as required by market-based regulatory programs including the 

USEPA Acid Rain and NOx Budget Trading Programs. In Virginia, the hourly inventory 

also includes distributed generation (DG) units. These Virginia units are mainly internal 

combustion engines that participate in a demand-response program. The hourly SO2, 

NOx, and heat input data were used to prepare SMOKE files for modeling that used actual 

2007 hourly emissions data. 

3.1 DATA SOURCES FOR HOURLY EMISSIONS 

The 2007 hourly point source inventory was developed using the 2007 annual emissions 

inventory developed as discussed in Section 2 of this report, data from the USEPA’s 

CAMD hourly emissions database, hourly emissions data provided by the Virginia 

Department of Environmental Quality (VDEQ), and hourly emissions data for 6-month 

reporting units provided by the Maryland Department of the Environment (MDE). 

3.1.1 2007 Annual Emission Inventory 

As described in Section 2 of this TSD, S/L agencies prepared and submitted emission 

inventory files in the NIF format. A crosswalk was developed to match facilities and units 

in the USEPA CAMD hourly database to units in the 2007 Version 1 annual inventory. 

This process is necessary because the data submitted by the S/L agencies and data 

submitted by companies to CAMD do not use the same facility or boiler/unit identifiers to 

identify a particular unit. The crosswalk matched a unit in the NIF annual inventory (using 

the State, County, PlantID, PointID, StackID and SegmentID) with its counterpart in the 

USEPA CAMD hourly database (using the ORISID and BoilerID). As previously 

discussed in Section 2, the final version of the crosswalk is included as Appendix A in this 

TSD. Complete documentation of the development of the annual inventory and crosswalk 

table can be found in Section 2 of this report. 

3.1.2 EPA CAMD Hourly Database 

The second source of data was the hourly emissions data reported to USEPA by facilities 

to comply with various provisions of the Clean Air Act. Affected facilities are required to 

report hourly emissions of NOx and SO2, as well as other operational parameters such as 

hourly emission rate, gross load and heat input. Some units are required to submit hourly 

emissions data for both NOx and SO2 for the entire 12 month reporting period. Other 

units are required to submit hourly emissions data only for NOx for the entire 12 month 

reporting period. Still other units are required to submit hourly emissions data only for 
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NOx for the 6 month ozone season. Finally, there are a very small number of units that 

reported hourly emissions for a 9-month period. The USEPA CAMD hourly database is 

subjected to extensive QA/QC by both USEPA and the reporting facilities.

For this analysis, we used the “Part 75 Prepackaged Data Sets - hourly emissions data 

formatted for use with the Sparse Matrix Operator Kernel Emissions (SMOKE) modeling 

system”. The 2007 hourly data was obtained from the USEPA Clean Air Markets web site 

(USEPA 2009c). 

3.1.3 Virginia Hourly Data for Distributed Generation Units 

The third set of data came from VDEQ. Distributed generation units are mainly internal 

combustion engines that participate in a demand-response program. These are small units, 

each usually no more than two or three megawatts in capacity, and they generally run on 

distillate fuel oil. These units are not required to report hourly emissions to USEPA’s 

CAMD. Most are permitted for well below 100 tons of NOx emissions annually and do 

not run frequently. Annual emissions of NOx are usually not very large from these units. 

However, ozone season daily emissions estimates from previous ozone SIPs show that 

facilities that have one or more of these types of units can be quite significant NOx 

emitters when examined on an ozone season daily basis. 

In past modeling efforts, these units were either not included in the emission inventory, or 

if they were included, were modeled using the SMOKE default temporal profile for the 

given SCC. To improve the hourly temporal allocation for these units, VADEQ undertook 

a substantial effort to develop hourly emission profiles using 2007 operations data obtained 

from utilities for their demand response programs as well as other facility-specific data. 

These data were used to create a 2007 profile for when these units generally operated. 

VDEQ used these generic profiles to prepare SMOKE PTHOUR files for each DG unit 

listed in the annual emissions inventory. 

Complete documentation of the data sources and methods used by VDEQ is included as 

Appendix E - VDEQ Conceptual Description for DG draft Feb 25, 2010.doc. 

3.1.4 Maryland Hourly Data for Six Month Reporters 

The final set of data came from the Maryland Department of the Environment (MDE). 

MDE filled in the non-ozone season hourly emissions data for certain units that only 

reported ozone season hourly emissions to USEPA CAMD. MDE identified facilities 

which reported only 6 months worth of data to CAMD and submitted requests to these 

facilities for the missing 6 months of data. MDE provided the values in a CAMDformatted table similar to the Part 75 Prepackaged Data Set format. 
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3.2 METHODOLOGY FOR DEVELOPING HOURLY SMOKE FILES 

SMOKE requires two input files for processing hourly point source emissions: 

PTINV File. This file contains annual emissions data, stack parameters, 

geographic coordinates, and other information. This file can be in Inventory Data 

Analyzer (IDA), Emission Modeling System-95 (EMS-95), or one-line-per record 

(ORL) format. The ORL format from SMOKE Version 2.6 was selected for this 

project and is shown in Exhibit 3.1. 

PTHOUR File. This file contains the hour-specific data. This file can be in either 

EMS-95 format or Continuous Emissions Monitoring (CEM) format. The SMOKE 

Version 2.6 EMS-95 traditional format was selected for this project and is shown in 

Exhibit 3.2. 

The following subsections describe how the PTINV ORL annual emissions file and the 

PTHOUR EMS-95 hour-specific emission files were created. 

3.2.1 Conversion of Annual NIF Inventory to SMOKE ORL Format for PTINV 

The 2007 annual inventory was developed in NIF format. Flags were added to the NIF EP 

table to indicate whether a unit was matched to a CAMD hourly unit or a Virginia DG unit. 

Matching units in the NIF file were converted to SMOKE PTINV ORL format. To 

facilitate QA of files and summarization of emissions, six different ORL files were created 

for the following types of sources: 

Annual emissions for units that reported hourly to USEPA CAMD for the entire 12 

months of 2007; 

Ozone season emissions for units that reported to USEPA CAMD for either 6 or 9 

months of 2007 (except for 6 month reporting units in Maryland); 

Non-ozone season emissions for units that reported to USEPA CAMD for either 6 

or 9 months of 2007 (except for 6 month reporting units in Maryland); 

Units that reported hourly to USEPA CAMD for the either 6 or 9 months of 2007 

in Maryland; 

Units that are classified as distributed generation units by VDEQ; and 

All other units (these are not associated with the hourly PTHOUR files); temporal 

allocation for these units will be accomplished using the standard SMOKE V2.6 

temporal allocation profiles. 

The ORL files were quality assured to conform to the SMOKE PTINV ORL format and to 

prevent double counting of emissions. 
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Exhibit 3.1 – SMOKE ORL Format for PTINV 

Position Name Type Description

A FIPS Int Five digit FIPS code for state and county (required)

B PLANTID Char Plant Identification Code (15 characters maximum) 

(required; this is the same as the State Facility 

Identifier in the NIF)

C POINTID Char Point Identification Code (15 characters maximum) 

(required; this is the same as the Emission Unit ID in 

the NIF)

D STACKID Char Stack Identification Code (15 characters maximum) 

(recommended; this is the same as the Emissions 

Release Point ID in the NIF) 

E SEGMENT Char DOE Plant ID (15 characters maximum) 

(recommended; this is the same as the Process ID 

in the NIF)

F PLANT Char Plant Name (40 characters maximum) 

(recommended)

G SCC Char Ten character SCC (required)

H ERPTYPE Char Emissions release point type (2 characters 

maximum); indicates type of stack (not used by 

SMOKE)

01 = fugitive 

02 = vertical stack 

03 = horizontal stack 

04 = goose neck 

05 = vertical with rain cap 

06 = downward-facing vent 

I SRCTYPE Char Source type (not used)

J STKHGT Real Stack Height (ft) (required)

K STKDIAM Real Stack Diameter (ft) (required)

L STKTEMP Real Stack Gas Exit Temperature (°F) (required)

M STKFLOW Real Stack Gas Flow Rate (ft3/sec) (optional; 

automatically calculated by Smkinven from velocity 

and diameter if not given in file) 

N STKVEL Real Stack Gas Exit Velocity (ft/sec) (required)

O SIC Int Standard Industrial Classification Code 

(recommended)

P MACT Char Maximum Available Control Technology Code (6 

characters maximum) (optional)

Q NAICS Char North American Industrial Classification System 

Code (6 characters maximum) (optional)
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Position Name Type Description

R CTYPE Char Coordinate system type (1 character maximum) 

(required)

L = Latitude/longitude 

S XLOC Real X location (required); Longitude (decimal degrees) 

T YLOC Real Y location (required); Latitude (decimal degrees) 

U UTMZ Int UTM zone (not used)

V CAS Char Pollutant CAS number or other code (16 characters 

maximum) (required; this is called the pollutant code 

in the NIF)

W ANN_EMIS Real Annual Emissions (tons/year) (required)

X AVD_EMIS Real Average-day Emissions (tons/average day) (not 

used )

Y CEFF Real Control Efficiency percentage (give value of 0-100) 

(recommended, if left blank, SMOKE default is 0)

Z REFF Real Rule Effectiveness percentage (give value of 0-100) 

(recommended, if left blank, SMOKE default is 100)

AA CPRI Int Primary Control Equipment Code (not used by 

SMOKE)

BB CSEC Int Secondary Control Equipment Code (not used by 

SMOKE)

CC NEI_UNIQUE_ID Char For units that report hourly emissions to CAMD, this 

field contains a code to indicate how frequently the 

unit operated in 2007 (i.e., <15%, 15-50%, or >50% 

of available hours)

For Virginia DG units, this field contains the 

descriptor “VA DG”.

For units that do not have an association in the 

PTHOUR file, this field contains the descriptor 

“NonHourly”.

DD ORIS_FACILITY_CODE Char DOE Plant ID (generally recommended, and 

required if matching to hour-specific CEM data)

EE ORIS_BOILER_ID Char Boiler Identification Code (recommended)

Fields not currently used by SMOKE Version 2.6 after field position EE have been excluded from 

the ORL file to reduce file size. 
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Exhibit 3.2 – SMOKE EMS-95 Traditional Format for Individual Hour-Specific Files 

Position Name Type Description

1-2 STID Int State FIPS Code (required)

3-5 CYID Int County FIPS Code (required)

6-20 FCID Char Facility ID (a.k.a. plant ID) (required)

21-32 SKID Char Point ID (required)

33-44 DVID Char Stack ID (required)

45-56 PRID Char Segment ID (required)

57-61 POLID Char Pollutant name (required)

62-69 DATE Char Date in MM/DD/YY format. Years less than 70 are treated as 

century 2000 (required)

70-72 TZONNAM Char Time zone name associated with emissions data. Valid 

entries are GMT, ADT, AST, EDT, EST, CDT, CST, MDT, 

MST, PDT, and PST. (required) 

73-79 HRVAL1 Real Hourly emissions for hour 1 (short tons/hour) (required)

80-86 HRVAL2 Real Hourly emissions for hour 2 (short tons/hour) (required)

87-93 HRVAL3 Real Hourly emissions for hour 3 (short tons/hour) (required)

...

234-240 HRVAL24 Real Hourly emissions for hour 24 (short tons/hour) (required)

241-248 DAYTOT Real Daily emissions total (short tons/day)

249 Blank Blank Blank 

250-259 SCC Char SCC (required).

261-276 DATNAM Char Blank

3.2.2 PTHOUR Methodology for 12 Month Reporters 

For units that reported hourly data to USEPA CAMD for the entire 12 months of 2007, the 

annual emissions in the PTINV ORL files were allocated to specific hours using the actual 

NOx, SO2, and heat input-based hour-specific data in the USEPA CAMD database. This 

ensured that the annual emission values provided by the S/L agencies were maintained and 

distributed to specific hours using actual 2007 hourly data. 

The methodology for creating the PTHOUR files is as follows. First, hourly SO2 and NOx 

mass and heat input values in the USEPA CAMD database were summed for each unit to 
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create annual values. Next, annual emission records in the ORL file were matched to a 

corresponding hourly CAMD unit using the crosswalk file. The hourly values in the 

PTHOUR file were calculated using the following equations, depending on the pollutant: 

Hourly NOx emissions 

Hourly PTHOUR NOx emissions = annual ORL NOx emissions * hourly CAMD NOx emissions 

 CAMD summed annual NOx emissions

Hourly SO2 emissions for units with non-zero SO2 emissions in the CAMD database 

Hourly PTHOUR SO2 emissions = annual ORL SO2 emissions * hourly CAMD SO2 emissions 

 CAMD summed annual SO2 emissions

Hourly SO2 emissions for units with zero SO2 emissions in the CAMD database 

Hourly PTHOUR SO2 emissions = annual ORL SO2 emissions * annual factor 

Where annual factor = hourly CAMD heat input / annual summed CAMD heat input 

Hourly emissions for other pollutants (CO, NH3, PM10-PRI, PM25-PRI, VOC) 

Hourly PTHOUR POLL emissions = annual ORL POLL emissions * annual factor 

Where annual factor = hourly CAMD heat input / annual summed CAMD heat input 

If CAMD heat input data are not available, the steam load was used instead, if available, 

followed by gross load as a last resort. 

3.2.3 PTHOUR Methodology for 6 Month Reporters 

About 15 percent of the units in the 2007 CAMD hourly database only reported data for 

the ozone season, i.e., the second and third quarters, as allowed by their reporting 

requirements. These units are referred to as 6-months units in this document. Two 

separate PTINV ORL files were created – one for the 6-month ozone season and one for 

the 6-month non-ozone season. The CAMD hourly data for these units were used to 

develop ozone season PTINV and PTHOUR files. For the non-ozone season, a PTINV file 

was created and was used with re-adjusted SMOKE temporal profiles to develop hourly 

emissions for the non-ozone season. 

The CAMD hourly database for 6-month units contains NOx emissions, heat input and 

other parameters for the 6 month period. The CAMD hourly data for April through 

September was used directly and was summed to calculate the ozone season NOx 

emissions. To calculate the non-ozone season NOx emissions, total CAMD NOx 

emissions for a 6-month unit was subtracted from the annual NOx emissions of the 

corresponding unit in the S/L supplied NIF database. In some cases, the 6-month NOx 
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emissions in the CAMD database were greater than the annual emissions in the S/L NIF 

database. For those cases, non-ozone season emissions were set to zero. 

Ozone season emissions of other pollutant are not available from the CAMD database. 

These emissions were estimated based on a ratio of ozone season NOx emissions to annual 

NOx emissions. This ratio was applied to the annual emissions from the NIF database. To 

calculate the non-ozone season emissions for the other pollutants, the total ozone season 

emissions for the 6-month unit was subtracted from the annual emissions reported for that

unit in the S/L supplied NIF database. The PTHOUR files for the ozone season were 

created as follows. First, hourly NOx mass and heat input values in the USEPA CAMD 

database were summed for each unit to create ozone season values. Next, ozone season 

emission records in the ORL file were matched to the hourly CAMD unit using the 

crosswalk file. Hourly emissions were calculated using the following equations: 

Hourly NOx emissions 

Hourly PTHOUR NOx emissions = 6-month ORL NOx emissions * hourly CAMD NOx emissions 

 CAMD summed 6-month NOx emissions

Hourly emissions for other pollutants (CO, NH3, PM10-PRI, PM25-PRI, SO2, VOC) 

Hourly PTHOUR POLL emissions = annual ORL POLL emissions * annual factor 

Where annual factor = hourly CAMD heat input / 6-month summed CAMD heat input 

If CAMD heat input data are not available, the steam load was used instead, if available, 

followed by gross load as a last resort. 

Hourly data for the non-ozone season was developed using the methodology discussed in 

Section 3.4 of this TSD. 

3.2.4 PTHOUR Methodology for Maryland 6 Month Reporters 

MDE identified facilities that only reported 6 months of data to CAMD and requested data 

from those facilities for the 6 months outside of the ozone season. MDE manually entered 

hourly values into a CAMD-formatted table similar to the Part 75 Prepackaged Data Set 

format for the following units. 

Plant Name ORIS UNITS

Constellation Perryman 1556 CT1, CT2, CT3, CT4

Constellation Riverside 1559 CT6

Constellation Westport 1560 CT5

Mirant Chalk Point 1571 GT2, SMECO

Mirant Morgantown 1573 GT3, GT4, GT5, GT6
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The PTHOUR files for the Maryland 6-month reporters were created as described here. 

First, hourly SO2 and NOx mass and heat input in the MDE hourly database were summed 

for each unit to create annual totals. Next, annual emission records for all pollutants in the 

ORL file were matched to the hourly records using the crosswalk file. Hourly emissions in 

the PTHOUR file were calculated using the following equations, depending on the 

pollutant: 

Hourly NOx emissions 

Hourly PTHOUR NOx emissions = annual ORL NOx emissions * hourly MDE NOx emissions 

 MDE summed annual NOx emissions

Hourly SO2 emissions for units with SO2 emissions in the MDE database 

Hourly PTHOUR SO2 emissions = annual ORL SO2 emissions * hourly MDE SO2 emissions 

 MDE summed annual SO2 emissions

Hourly SO2 emissions for units without SO2 emissions in the MDE database 

Hourly PTHOUR SO2 emissions = annual ORL SO2 emissions * annual factor 

Where annual factor = hourly MDE heat input / annual summed MDE heat input 

Hourly emissions for other pollutants (CO, NH3, PM10-PRI, PM25-PRI, VOC) 

Hourly PTHOUR POLL emissions = annual ORL POLL emissions * annual factor 

Where annual factor = hourly MDE heat input / annual summed MDE heat input 

If MDE heat input data are not available, the steam load was used instead, if available, 

followed by gross load as a last resort. 

3.2.5 PTHOUR Methodology for Virginia Distributed Generation Units 

Complete documentation of the data sources and methods used by VDEQ is included as 

Appendix E - VDEQ Conceptual Description for DG draft Feb 25, 2010.doc. 

3.2.6 QA of PTINV and PTHOUR Files 

A number of QA activities were undertaken to ensure that the PTINV and PTHOUR files 

were complete, consistent with the 2007 NIF annual inventory, and did not double count 

any emission source. Specific QA steps included: 

The ORL annual emission files were quality assured to conform to the SMOKE 

PTINV ORL format and match the values reported in the original NIF file. 

The PTHOUR files were quality assured to conform to the SMOKE PTHOUR 

EMS-95 traditional format, the sum of emissions in the PTHOUR file equals the 
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ORL annual emissions, the number of hourly data records equals 8760, the number 

of days equals 365, and that all pollutants were included in the PTHOUR file. 

These QA checks verified that the original NIF annual values and the annual sum of the 

hourly values matched. 

3.3 DEVELOPMENT OF HOURLY PROFILES FOR 6-MONTH 

REPORTING UNITS 

Since some CAMD units only report data for the ozone season, there was a need for a set 

of actual 2007 hourly temporal profiles to be used in simulating hourly emissions for these 

units in non-ozone season months. The following subsections describe the steps taken by 

Alpine Geophysics in preparing this file. 

3.3.1 Annual Profile Preparation 

The 2007 hourly CEM data was obtained from CAMD’s “Data and Maps” website for 

each State in the MANE-VU+VA region. Using these data, we filtered the individual 

source list within each State to only those units reporting each hour of the year (i.e., 8,760 

hours of data). This ensured that the resulting profiles are not influenced by units which 

only report during summertime months for ozone season programs. 

For this filtered source list, we summed three variables: total NOx and SO2 mass and heat 

input as reported in these hourly files at both a State monthly and a State total basis. For 

each of the three variables, monthly distribution ratios were calculated by dividing each 

State’s monthly sum by their total annual sum as shown in Equation 1 below. 

Equation 1. Monthly ratio calculation. 

Monthly Ratio State, Var = Monthly Sum State, Var / Annual Sum State, Var 

Where, 

Var = CEM-based variable of SO2, NOx or heat input 

Exhibit 3.3 provides an example calculation for this step, both in tabular and graphical 

format. 

The resulting ratios were normalized for each variable to provide SMOKE with the 

monthly distribution factors necessary to process annual emissions into a monthly result. 

An example monthly profile using the data from Exhibit 3.3 is shown in Exhibit 3.4. 
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Exhibit 3.3 – Example Application of Calculated Ratios for Actual 2007 by Month 

Actual Reported Value Sums [2007] Calculated Ratios

State Month SO2 Mass NOx Mass Heat Input SO2 NOx

Heat 

Input

NY Jan 22,423,391 10,809,292 60,408,685 0.1046 0.0942 0.0809

NY Feb 29,299,033 12,448,052 67,590,104 0.1366 0.1084 0.0905

NY Mar 21,364,883 10,327,432 63,106,554 0.0996 0.0900 0.0845

NY Apr 16,454,881 9,221,500 55,568,488 0.0767 0.0803 0.0744

NY May 12,855,963 8,198,597 53,421,346 0.0600 0.0714 0.0715

NY Jun 14,525,239 9,282,277 65,577,304 0.0677 0.0809 0.0878

NY Jul 16,311,783 10,372,119 74,182,361 0.0761 0.0904 0.0993

NY Aug 17,757,143 11,156,733 82,322,615 0.0828 0.0972 0.1102

NY Sep 15,809,719 8,879,373 63,553,452 0.0737 0.0773 0.0851

NY Oct 15,055,032 7,390,952 55,149,951 0.0702 0.0644 0.0738

NY Nov 14,471,865 7,561,984 47,280,729 0.0675 0.0659 0.0633

NY Dec 18,092,057 9,155,587 58,804,999 0.0844 0.0798 0.0787

NY Total 214,420,988 114,803,899 746,966,587 1.0000 1.0000 1.0000

2007 CEM-Based Temporal Profiles

New York

0.0000

0.0200

0.0400

0.0600

0.0800

0.1000

0.1200

0.1400

0.1600

01 02 03 04 05 06 07 08 09 10 11 12

Month Relative Distribution

SO2

NOX

Heat Input
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Exhibit 3.4 - Example SMOKE profile for monthly distribution of New York annual 

emissions using heat input. 

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total

Monthly 

Ratio 0.0809 0.0905 0.0845 0.0744 0.0715 0.0878 0.0993 0.1102 0.0851 0.0738 0.0633 0.0787 1.0000

Monthly 

Profile 809 905 845 744 716 878 994 1103 851 739 633 788 10005

The profile in the above table can then be associated to the profile cross-reference lookup 

either by State, State-SCC or some other combination allowing each non-CEM (PTHOUR) 

reporting unit to have annual emissions allocated. Existing day of week and diurnal 

profiles from the EPA CHIEF website were used to allocate emissions to finer smaller time 

periods within each month. 

3.3.2 Non-Annual Profile Development 

A number of units were identified which require monthly distribution for timeframes 

outside of the ozone season (when these units are not required to report CEMs). The 

monthly profiles described in 3.3.1 were modified for use with these units. To account for 

emissions at these sources not included in prepared hourly (PTHOUR) SMOKE input files, 

the monthly profiles were zeroed out during the months when hourly CAMD emissions 

were reported. Concurrently, the TOTAL profile sum was adjusted to accurately reflect 

the ratio of month to total distribution. An example of this adjustment is shown with 

highlight in Exhibit 3.5. 

Exhibit 3.5 - Example SMOKE profile for adjusted monthly distribution of New York 

seasonal emissions using heat input. 

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total

Monthly 

Ratio 0.0809 0.0905 0.0845 0.0744 0.0715 0.0878 0.0993 0.1102 0.0851 0.0738 0.0633 0.0787 1.0000

Monthly 

Profile 809 905 845 744 716 878 994 1103 851 739 633 788 10005

Adjusted 

Profile 809 905 845 0 0 0 0 0 0 739 633 788 4719
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3.3.3 Issue for Consideration 

In the USEPA CAMD files only a few CAMD 6-month units reported emissions in April 

2007. As a result, the April hourly CAMD data was not used in MARAMA’s simulation. 

Instead, an adjusted profile for five month operation was prepared and used for these 

sources. 

3.4 VERSION 2 - STATE AND STAKEHOLDER REVIEW 

On March 15, 2010, MARAMA invited States and stakeholders to review and comment on 

the draft 2007 hourly inventory of air emissions from point sources. States and 

stakeholders were provided a 4-week comment period. Written comments were reviewed 

by the State inventory staff and MARAMA, and resulted in several changes to the draft 

documentation and inventory data. The changes requested by stakeholders and approved 

by the States are summarized in the following subsections. 

3.4.1 Massachusetts 

Massachusetts commented that the majority of the Massachusetts facilities reviewed the 

CAMD-to-NIF crosswalk and indicated they found no major errors. Some facilities 

expressed concern that several dual fuel units appeared to have their total NOx emissions 

doubled, reported separately for both oil and gas. The Contractor reviewed the database 

and verified that no double counting of emissions occurs. For multiple-fuel units, the 

Appendix A spreadsheet matches each CAMD record to ALL fuel records in the NIF 

database, making it appear that the CAMD emissions are counted more than once. 

MARAMA will use the NIF emissions from State database in regional modeling and the 

hourly data from the matching CAMD unit to allocate NIF emissions to hourly data for 

modeling. Emissions will not be double counted for units using multiple fuels. 

3.4.2 New York 

NRG Energy identified an issue with the hourly emissions for those units in the NIF 

database when multiple units exhaust from a common stack. In NY’s database, multiple 

units are represented by a single emission unit, whereas in the CAMD database each unit is 

represented individually. That is why there is a CAMD BLR6ID with no equivalent NIF 

labels in Appendix A. The Contractor discussed the issue with NRG and devised a 

solution for the Huntley and Dunkirk Steam Generating Stations by adding emissions units 

to the NIF tables in cases where there are combined stacks. Annual emissions in the NIF 

database will be apportioned to each unit based on annual heat input from the USEPA 

CAMD database. This will allow a proper match to the hourly data for each Unit and 
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ensure that the proper CAMD hourly emissions were used in developing the PTHOUR 

files for the units at these two facilities. 

New York State also worked to improve the linkages between the NIF annual emissions 

and the CAMD hourly emissions. Not all cases could be resolved, and New York is 

continuing to review the data. 

3.4.3 Pennsylvania 

RRI Energy commented that they agree with the approach for calculating hourly emissions 

as described in Section 3.3 of this report. 

3.4.4 Virginia 

Virginia reviewed the data in the hourly files and provided three updates needed for the 

VA cross reference between NIF and CAMD information. These updates do not affect 

large emission units, but they were made to make the cross reference as correct as possible, 

as follows: 

For ORIS CODE 55439, NIF ID 51-065-00021, facility name Tenaska Virginia 

Generating Station was added to CAMD Boiler ID CTGDB1 with the NIF 

identifier Stack 1, Point 1, Segment 2. This stack point segment was left out of the 

cross reference and represents the emissions from the duct burner on this turbine. 

For ORIS CODE 55439, NIF ID 51-065-00021, facility name Tenaska Virginia 

Generating Station was added to CAMD Boiler ID CTGDB3 with the NIF 

identifier Stack 3, Point 9, Segment 2. This stack point segment was left out of the 

cross reference and represents the emissions from the duct burner on this turbine. 

For ORIS CODE 52089, NIF ID 51-071-00062, facility name Duke Energy 

Generation Services of Narrows was deleted for the NIF identifier Stack 1, Point 1, 

Segment 3 from CAMD Boiler ID BLR007. This stack point segment represents 

the emissions from the ash handling system for the boilers, and the emissions 

would be better represented by generic profiles rather than CAMD profiles. 

Virginia also commented that some facilities have empty date stamps (i.e., MM/DD/YY 

field is listed as “xx/xx/xxEST“ where x is blank space). For example, in 12 month units 

files, 51-033-00040 and 51-065-00021 combined have either 21 or 39 lines with empty 

date stamps. Similarly, in 6 month units files, 09-009-6614 (in New Haven, Connecticut) 

have 6 or 12 lines without date stamps. The Contractor identified errors in the CAMD to 

NIF crosswalk that caused this situation to occur. Fixing the CAMD to NIF crosswalk 

resolved all occurrences of this problem. 
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3.5 VERSION 3 REVISIONS 

3.5.1 Massachusetts Stony Brook Energy Center NH3 Emissions 

Massachusetts identified errors in the ammonia emissions for 2007 for the Stony Brook 

Energy Center (25013-0420001) and New Bedford Energy (25005-1200634). 

Massachusetts provided corrected ammonia emission estimates for these two facilities. 

This change reduced ammonia emissions in Massachusetts by about 2,300 tons. 

New Bedford Energy does not report hourly emissions to CAMD, so no changes to the 

PTHOUR files were needed for this source. 

The Stony Brook Energy Center has three units that are 12-month CAMD reporters and 

two units that are 5-month CAMD reporters. The PTHOUR monthly files for 5-month and 

12-month reporters were revised to provide corrected NH3 emissions for the Stony Brook 

units. 
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4.0 ANNUAL 2007 INVENTORY FOR AREA SOURCES 

4.1 AREA SOURCE CATEGORIES 

Area sources are relatively small sources of air pollutants that are diffused over a wide 

geographical area. They include sources that individually are insignificant, but in 

aggregate may comprise significant emissions. Examples are emissions from home 

heating systems, house painting, consumer products usage, and small industrial or 

commercial operations that are not permitted as point sources. There are 356 individual 

area source categories in the MANE-VU+VA inventory, categorized by a 10-digit SCC. 

Major grouping (categories at the 7-digit SCC) included in the area source inventory are 

shown in Exhibit 4.1. 

The USEPA has develops area source emission estimation methodologies and estimates for 

the NEI on a three-year cycle, and inventories are available for 2002, 2005, and 2008 

(USEPA 2010a). 

For many categories, unless specifically instructed otherwise by the States, the Contractor 

used the most recent data from USEPA. These sources included ammonia emissions from 

livestock and fertilizers which came from a recent application of the Carnegie Mellon 

University (CMU) ammonia model to produce 2007 emissions and output from a version 

of the Residential Wood Combustion (RWC) model developed by USEPA and run with 

updated 2007 data to produce emission estimates for that source category. In addition, a 

number of States requested that the Contractor include USEPA data on wildfire emissions 

developed as part of USEPA’s SMARTFIRE system. 

In the following sections, we describe the data that was available from USEPA and that 

was used for categories where States did not submit data. Next we describe the State data 

submittals that were used to override the USEPA data. We summarize the ultimate source 

of the area source data that each State decided to use for each source category. Finally, we 

present a State-level summary of emissions by pollutant. 

Exhibit 4.1 – Area Source Category Definitions

7-Digit SCC 7-Digit SCC Description

21-01-001 Stationary Fuel; Electric Utility; Anthracite Coal

21-01-002 Stationary Fuel; Electric Utility; Bituminous/Sub-butuminousSub-butuminous Coal

21-01-004 Stationary Fuel; Electric Utility; Distillate Oil

21-01-005 Stationary Fuel; Electric Utility; Residual Oil

21-01-006 Stationary Fuel; Electric Utility; Natural Gas

21-02-001 Stationary Fuel; Industrial; Anthracite Coal
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7-Digit SCC 7-Digit SCC Description

21-02-002 Stationary Fuel; Industrial; Bituminous/Sub-butuminous Coal

21-02-004 Stationary Fuel; Industrial; Distillate Oil

21-02-005 Stationary Fuel; Industrial; Residual Oil

21-02-006 Stationary Fuel; Industrial; Natural Gas

21-02-007 Stationary Fuel; Industrial; Liquified Petroleum Gas (LPG)

21-02-008 Stationary Fuel; Industrial; Wood

21-02-011 Stationary Fuel; Industrial; Kerosene

21-03-001 Stationary Fuel; Commercial/Institutional; Anthracite Coal

21-03-002 Stationary Fuel; Commercial/Institutional; Bituminous/Sub-butuminous Coal

21-03-004 Stationary Fuel; Commercial/Institutional; Distillate Oil

21-03-005 Stationary Fuel; Commercial/Institutional; Residual Oil

21-03-006 Stationary Fuel; Commercial/Institutional; Natural Gas

21-03-007 Stationary Fuel; Commercial/Institutional; Liquified Petroleum Gas (LPG)

21-03-008 Stationary Fuel; Commercial/Institutional; Wood

21-03-011 Stationary Fuel; Commercial/Institutional; Kerosene

21-04-001 Stationary Fuel; Residential; Anthracite Coal

21-04-002 Stationary Fuel; Residential; Bituminous/Sub-butuminous Coal

21-04-004 Stationary Fuel; Residential; Distillate Oil

21-04-006 Stationary Fuel; Residential; Natural Gas

21-04-007 Stationary Fuel; Residential; Liquified Petroleum Gas (LPG)

21-04-008 Stationary Fuel; Residential; Wood

21-04-009 Stationary Fuel; Residential; Firelog

21-04-011 Stationary Fuel; Residential; Kerosene

22-94-000 Mobile Sources; Paved Roads; All Paved Roads

22-96-000 Mobile Sources; Unpaved Roads; All Unpaved Roads

23-01-000 Industrial Processes; Chemical Manufacturing: SIC 28; All Processes

23-01-030 Industrial Processes; Chemical Manufacturing: SIC 28; Process Emissions from Pharmaceutical 

23-02-002 Industrial Processes; Food and Kindred Products: SIC 20; Commercial Cooking – Charbroiling

23-02-003 Industrial Processes; Food and Kindred Products: SIC 20; Commercial Cooking – Frying

23-02-040 Industrial Processes; Food and Kindred Products: SIC 20; Grain Mill Products

23-02-050 Industrial Processes; Food and Kindred Products: SIC 20; Bakery Products

23-02-070 Industrial Processes; Food and Kindred Products: SIC 20; Fermentation/Beverages

23-02-080 Industrial Processes; Food and Kindred Products: SIC 20; Miscellaneous Food and Kindred Prods

23-07-030 Industrial Processes; Wood Products: SIC 24; Millwork, Plywood, and Structural Members

23-07-060 Industrial Processes; Wood Products: SIC 24; Miscellaneous Wood Products

23-08-000 Industrial Processes; Rubber/Plastics: SIC 30; All Processes

23-09-100 Industrial Processes; Fabricated Metals: SIC 34; Coating, Engraving, and Allied Services

23-11-010 Industrial Processes; Construction: SIC 15 - 17; Residential

23-11-020 Industrial Processes; Construction: SIC 15 - 17; Industrial/Commercial/Institutional

23-11-030 Industrial Processes; Construction: SIC 15 - 17; Road Construction

23-25-000 Industrial Processes; Mining and Quarrying: SIC 14; All Processes

23-25-020 Industrial Processes; Mining and Quarrying: SIC 14; Crushed and Broken Stone
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7-Digit SCC 7-Digit SCC Description

23-25-030 Industrial Processes; Mining and Quarrying: SIC 14; Sand and Gravel

23-90-008 Industrial Processes; In-process Fuel Use; Wood

23-99-000 Industrial Processes; Industrial Processes: NEC; Industrial Processes: NEC

23-99-010 Industrial Processes; Industrial Refrigeration; Refrigerant Losses

24-01-001 Solvent Utilization; Surface Coating; Architectural Coatings

24-01-002 Solvent Utilization; Surface Coating; Architectural Coatings - Solvent-based

24-01-003 Solvent Utilization; Surface Coating; Architectural Coatings - Water-based

24-01-005 Solvent Utilization; Surface Coating; Auto Refinishing: SIC 7532

24-01-008 Solvent Utilization; Surface Coating; Traffic Markings

24-01-015 Solvent Utilization; Surface Coating; Factory Finished Wood: SIC 2426 thru 242

24-01-020 Solvent Utilization; Surface Coating; Wood Furniture: SIC 25

24-01-025 Solvent Utilization; Surface Coating; Metal Furniture: SIC 25

24-01-030 Solvent Utilization; Surface Coating; Paper: SIC 26

24-01-040 Solvent Utilization; Surface Coating; Metal Cans: SIC 341

24-01-045 Solvent Utilization; Surface Coating; Metal Coils: SIC 3498

24-01-050 Solvent Utilization; Surface Coating; Miscellaneous Finished Metals: SIC 34 - (341 + 3498)

24-01-055 Solvent Utilization; Surface Coating; Machinery and Equipment: SIC 35

24-01-060 Solvent Utilization; Surface Coating; Large Appliances: SIC 363

24-01-065 Solvent Utilization; Surface Coating; Electronic and Other Electrical: SIC 36 - 363

24-01-070 Solvent Utilization; Surface Coating; Motor Vehicles: SIC 371

24-01-075 Solvent Utilization; Surface Coating; Aircraft: SIC 372

24-01-080 Solvent Utilization; Surface Coating; Marine: SIC 373

24-01-085 Solvent Utilization; Surface Coating; Railroad: SIC 374

24-01-090 Solvent Utilization; Surface Coating; Miscellaneous Manufacturing

24-01-100 Solvent Utilization; Surface Coating; Industrial Maintenance Coatings

24-01-102 Solvent Utilization; Surface Coating; Industrial Maintenance Coatings

24-01-103 Solvent Utilization; Surface Coating; Industrial Maintenance Coatings

24-01-200 Solvent Utilization; Surface Coating; Other Special Purpose Coatings

24-01-990 Solvent Utilization; Surface Coating; All Surface Coating Categories

24-15-000 Solvent Utilization; Degreasing; All Processes/All Industries

24-15-005 Solvent Utilization; Degreasing; Furniture and Fixtures (SIC 25): All Processes

24-15-010 Solvent Utilization; Degreasing; Primary Metal Industries (SIC 33): All Processes

24-15-020 Solvent Utilization; Degreasing; Fabricated Metal Products (SIC 34): All Processes

24-15-025 Solvent Utilization; Degreasing; Industrial Machinery and Equipment (SIC 35): All Processes

24-15-030 Solvent Utilization; Degreasing; Electronic and Other Elec. (SIC 36): All Processes

24-15-035 Solvent Utilization; Degreasing; Transportation Equipment (SIC 37): All Processes

24-15-040 Solvent Utilization; Degreasing; Instruments and Related Products (SIC 38): All Processes

24-15-045 Solvent Utilization; Degreasing; Miscellaneous Manufacturing (SIC 39): All Processes

24-15-050 Solvent Utilization; Degreasing; Transportation Maintenance Facilities (SIC 40-45): All Processes

24-15-055 Solvent Utilization; Degreasing; Automotive Dealers (SIC 55): All Processes

24-15-060 Solvent Utilization; Degreasing; Miscellaneous Repair Services (SIC 76): All Processes

24-15-065 Solvent Utilization; Degreasing; Auto Repair Services (SIC 75): All Processes
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7-Digit SCC 7-Digit SCC Description

24-15-100 Solvent Utilization; Degreasing; All Industries: Open Top Degreasing

24-15-130 Solvent Utilization; Degreasing; Electronic and Other Elec. (SIC 36): Open Top Degreasing

24-15-200 Solvent Utilization; Degreasing; All Industries: Conveyerized Degreasing

24-15-230 Solvent Utilization; Degreasing; Electronic and Other Elec. (SIC 36): Conveyerized Degreasing

24-15-300 Solvent Utilization; Degreasing; All Industries: Cold Cleaning

24-15-360 Solvent Utilization; Degreasing; Auto Repair Services (SIC 75): Cold Cleaning

24-20-000 Solvent Utilization; Dry Cleaning; All Processes

24-20-010 Solvent Utilization; Dry Cleaning; Commercial/Industrial Cleaners

24-25-000 Solvent Utilization; Graphic Arts; All Processes

24-25-010 Solvent Utilization; Graphic Arts; Lithography

24-25-020 Solvent Utilization; Graphic Arts; Letterpress

24-25-030 Solvent Utilization; Graphic Arts; Rotogravure

24-25-040 Solvent Utilization; Graphic Arts; Flexography

24-30-000 Solvent Utilization; Rubber/Plastics; All Processes

24-40-000 Solvent Utilization; Misc. Industrial; All Processes

24-40-020 Solvent Utilization; Misc. Industrial; Adhesive (Industrial) Application

24-60-000 Solvent Utilization; Misc. Non-industrial: Consumer and Commercial; All Processes

24-60-100 Solvent Utilization; Misc. Non-industrial: Consumer and Commercial; All Personal Care Products

24-60-200 Solvent Utilization; Misc. Non-industrial: Consumer and Commercial; All Household Products

24-60-400 Solvent Utilization; Misc. Non-industrial: Consumer and Commercial; All Automotive Aftermarket 

24-60-500 Solvent Utilization; Misc. Non-industrial: Consumer and Commercial; All Coatings and Related 

24-60-600 Solvent Utilization; Misc. Non-industrial: Consumer and Commercial; All Adhesives and Sealants

24-60-800 Solvent Utilization; Misc. Non-industrial: Consumer and Commercial; All FIFRA Related Products

24-60-900 Solvent Utilization; Misc. Non-industrial: Consumer and Commercial; Miscellaneous Products

24-61-020 Solvent Utilization; Misc. Non-industrial: Commercial; Asphalt Application: All Processes

24-61-021 Solvent Utilization; Misc. Non-industrial: Commercial; Cutback Asphalt

24-61-022 Solvent Utilization; Misc. Non-industrial: Commercial; Emulsified Asphalt

24-61-023 Solvent Utilization; Misc. Non-industrial: Commercial; Asphalt Roofing

24-61-200 Solvent Utilization; Misc. Non-industrial: Commercial; Adhesives and Sealants

24-61-800 Solvent Utilization; Misc. Non-industrial: Commercial; Pesticide Application: All Processes

24-61-850 Solvent Utilization; Misc. Non-industrial: Commercial; Pesticide Application: Agricultural

24-61-870 Solvent Utilization; Misc. Non-industrial: Commercial; Pesticide Application: Non-Agricultural

24-65-000 Solvent Utilization; Misc. Non-industrial: Consumer; All Products/Processes

24-65-800 Solvent Utilization; Misc. Non-industrial: Consumer; Pesticide Application

25-01-011 Storage and Transport; Petroleum and Petroleum Product Storage; Residential PFCs

25-01-012 Storage and Transport; Petroleum and Petroleum Product Storage; Commercial PFCs

25-01-030 Storage and Transport; Petroleum and Petroleum Product Storage; 

25-01-050 Storage and Transport; Petroleum and Petroleum Product Storage; Bulk Terminals

25-01-055 Storage and Transport; Petroleum and Petroleum Product Storage; Bulk Plants

25-01-060 Storage and Transport; Petroleum and Petroleum Product Storage; Gasoline Service Stations

25-01-080 Storage and Transport; Petroleum and Petroleum Product Storage; Airports : Aviation Gasoline

25-01-090 Storage and Transport; Petroleum and Petroleum Product Storage; 
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7-Digit SCC 7-Digit SCC Description

25-01-995 Storage and Transport; Petroleum and Petroleum Product Storage; All Storage Types

25-05-020 Storage and Transport; Petroleum and Petroleum Product Transport; Marine Vessel

25-05-030 Storage and Transport; Petroleum and Petroleum Product Transport; Truck

25-05-040 Storage and Transport; Petroleum and Petroleum Product Transport; Pipeline

25-30-010 Storage and Transport; Bulk Materials Storage; Commercial/Industrial

26-01-000 Waste Disposal; On-site Incineration; All Categories

26-01-010 Waste Disposal; On-site Incineration; Industrial

26-01-020 Waste Disposal; On-site Incineration; Commercial/Institutional

26-01-030 Waste Disposal; On-site Incineration; Residential

26-10-000 Waste Disposal; Open Burning; All Categories

26-10-030 Waste Disposal; Open Burning; Residential

26-10-040 Waste Disposal; Open Burning; Municipal (collected from residences, parks,other for central burn)

26-20-000 Waste Disposal; Landfills; All Categories

26-20-030 Waste Disposal; Landfills; Municipal

26-30-010 Waste Disposal; Wastewater Treatment; Industrial

26-30-020 Waste Disposal; Wastewater Treatment; Public Owned

26-30-050 Waste Disposal; Wastewater Treatment; Public Owned

26-40-000 Waste Disposal; TSDFs; All TSDF Types

26-60-000 Waste Disposal; Leaking Underground Storage Tanks; Leaking Underground Storage Tanks

26-80-001 Waste Disposal; Composting; 100% Biosolids (e.g., sewage sludge, manure, mixtures)

26-80-002 Waste Disposal; Composting; Mixed Waste (e.g., a 50:50 mixture of biosolids and green wastes)

28-01-000 Misc. Area Sources; Agriculture Production - Crops; Agriculture – Crops

28-01-001 Misc. Area Sources; Agriculture Production - Crops; 

28-01-002 Misc. Area Sources; Agriculture Production - Crops; 

28-01-500 Misc. Area Sources; Agriculture Production - Crops; Agricultural Field Burning - whole field 

28-01-700 Misc. Area Sources; Agriculture Production - Crops; Fertilizer Application

28-05-001 Misc. Area Sources; Agriculture Production - Livestock; Beef cattle - finishing / dry-lots

28-05-002 Misc. Area Sources; Agriculture Production - Livestock; Beef cattle production composite

28-05-003 Misc. Area Sources; Agriculture Production - Livestock; Beef cattle - finishing / pasture/range

28-05-007 Misc. Area Sources; Agriculture Production - Livestock; Poultry production - layers with dry mgmt

28-05-008 Misc. Area Sources; Agriculture Production - Livestock; Poultry production - layers with wet mgmt

28-05-009 Misc. Area Sources; Agriculture Production - Livestock; Poultry production – broilers

28-05-010 Misc. Area Sources; Agriculture Production - Livestock; Poultry production – turkeys

28-05-018 Misc. Area Sources; Agriculture Production - Livestock; Dairy cattle composite

28-05-019 Misc. Area Sources; Agriculture Production - Livestock; Dairy cattle - flush dairy

28-05-020 Misc. Area Sources; Agriculture Production - Livestock; Cattle and Calves Waste Emissions

28-05-021 Misc. Area Sources; Agriculture Production - Livestock; Dairy cattle - scrape dairy

28-05-022 Misc. Area Sources; Agriculture Production - Livestock; Dairy cattle - deep pit dairy

28-05-023 Misc. Area Sources; Agriculture Production - Livestock; Dairy cattle - dry-lot/pasture dairy

28-05-024 Misc. Area Sources; Agriculture Production - Livestock; 

28-05-025 Misc. Area Sources; Agriculture Production - Livestock; Swine production composite

28-05-026 Misc. Area Sources; Agriculture Production - Livestock; 
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7-Digit SCC 7-Digit SCC Description

28-05-027 Misc. Area Sources; Agriculture Production - Livestock; 

28-05-028 Misc. Area Sources; Agriculture Production - Livestock; 

28-05-030 Misc. Area Sources; Agriculture Production - Livestock; Poultry Waste Emissions

28-05-035 Misc. Area Sources; Agriculture Production - Livestock; Horses and Ponies Waste Emissions

28-05-039 Misc. Area Sources; Agriculture Production - Livestock; Swine production - ops with lagoons 

28-05-040 Misc. Area Sources; Agriculture Production - Livestock; Sheep and Lambs Waste Emissions

28-05-045 Misc. Area Sources; Agriculture Production - Livestock; Goats Waste Emissions

28-05-047 Misc. Area Sources; Agriculture Production - Livestock; Swine production - deep-pit house 

28-05-053 Misc. Area Sources; Agriculture Production - Livestock; Swine production - outdoor 

28-06-010 Misc. Area Sources; Domestic Animals Waste Emissions; Cats

28-06-015 Misc. Area Sources; Domestic Animals Waste Emissions; Dogs

28-07-020 Misc. Area Sources; Wild Animals Waste Emissions; Bears

28-07-025 Misc. Area Sources; Wild Animals Waste Emissions; Elk

28-07-030 Misc. Area Sources; Wild Animals Waste Emissions; Deer

28-07-040 Misc. Area Sources; Wild Animals Waste Emissions; Birds

28-10-001 Misc. Area Sources; Other Combustion; Forest Wildfires

28-10-003 Misc. Area Sources; Other Combustion; Cigarette Smoke

28-10-005 Misc. Area Sources; Other Combustion; Managed Burning, Slash (Logging Debris)

28-10-010 Misc. Area Sources; Other Combustion; Human Perspiration and Respiration

28-10-014 Misc. Area Sources; Other Combustion; Prescribed Burning

28-10-015 Misc. Area Sources; Other Combustion; Prescribed Forest Burning

28-10-020 Misc. Area Sources; Other Combustion; Prescribed Rangeland Burning

28-10-025 Misc. Area Sources; Other Combustion; Charcoal Grilling - Residential 

28-10-030 Misc. Area Sources; Other Combustion; Structure Fires

28-10-035 Misc. Area Sources; Other Combustion; Firefighting Training

28-10-050 Misc. Area Sources; Other Combustion; Motor Vehicle Fires

28-10-060 Misc. Area Sources; Other Combustion; Cremation

28-10-090 Misc. Area Sources; Other Combustion; Open Fire

28-30-000 Misc. Area Sources; Catastrophic/Accidental Releases; All Catastrophic/Accidental Releases

28-30-010 Misc. Area Sources; Catastrophic/Accidental Releases; Transportation Accidents

28-70-000 Misc. Area Sources; ; 

4.2 USEPA AREA SOURCE DATA 

USEPA emissions inventories and emission estimation tools were used to create a 

preliminary version of the 2007 area source inventory. States reviewed the data available 

from USEPA and made a determination on a category by category basis of whether the 

USEPA data was acceptable for their State. This section describes the data and tools 

available from USEPA. 
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4.2.1 USEPA 2008 National Emission Inventory 

Prior to preparation of the 2008 inventory, USEPA, in consultation with ERTAC, revised 

the recommended emission factors and estimation methods for many area source 

categories, as listed below. The goal was to provide standardized emission calculations 

and related documentation across states. These were used by USEPA’s contractor to 

develop 2008 emission estimates for fifteen area source categories to support development 

of the 2008 National Emission Inventory (NEI). In general, county-level criteria and HAP 

pollutant emissions were estimated at the SCC level. In most cases, activity data was 

collected for 2008. In cases where 2008 activity data did not exist, data from the most 

recent year available was used, as reported in the documentation. 

Agriculture Production - Livestock 

Asphalt Paving 

Aviation Gasoline Distribution 

Commercial Cooking 

Construction Dust 

Commercial/Institutional Fuel Combustion 

Fertilizer Application 

Gasoline Distribution 

Industrial Fuel Combustion 

Open Burning 

Road Dust 

Publicly Owned Treatment Works (POTW) 

Residential Heating 

Solvent Usage - Surface Coatings 

Solvent Usage - Other 

The emission factors from the ERTAC process and the resulting 2008 emissions developed 

by USEPA were available for State use in this 2007 inventory development process 

(USEPA 2010a). 

4.2.2 EPA Residential Wood Combustion (RWC) Tool 

EPA worked with a group of State, local, and regional planning organization 

representatives to develop a new methodology for estimating RWC emissions (USEPA 

2010b). USEPA developed a Microsoft Access Tool to allow S/L agencies to calculate 

annual emissions from RWC sources. The new methodology: 1) accounts for appliances 

not included in the old methodology (e.g., outdoor hydronic heaters); 2) makes the 

methodology easier for States to input location-specific knowledge; and 3) updates many 

of the assumptions made to calculate emissions (for example, the percent conventional 

versus USEPA certified wood stoves). 
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EPA updated the RWC tool with 2007 population data and provided it to States to review 

the input parameters, including county populations, appliance profiles, burn rates, density 

of cordwood by county, appliance populations, and emission factors by SCC. The only 

changes that were made to the model itself were for Vermont, which provided updated 

burn rates and other appliance populations. The Contractor reran the revised 2007 RWC 

tool for all states. The results of this run are included in the inventory with the exception 

of New Jersey. New Jersey revised certain model inputs, re-ran the RWC tool on their 

own, and provided the Contractor with the resulting NIF files. 

4.2.3 EPA CMU Agricultural Ammonia Model 

In preparation for the 2008 NEI, USEPA used the Carnegie Mellon University (CMU) 

Ammonia Model to generate an ammonia emission inventory for the continental United 

States based on 2007 activity levels. No significant change was made to the emission 

factors in the model. The primary sources of ammonia are two agricultural operations: 

Livestock refers to domesticated animals intentionally reared for the production of 

food, fiber, or other goods or for the use of their labor. The definition of livestock 

in this category includes beef cattle, dairy cattle, ducks, geese, goats, horses, 

poultry, sheep, and swine. 

Fertilizer refers to any nitrogen-based compound, or mixture containing such a 

compound, that is applied to land to improve plant fitness. 

The Contractor obtained from USEPA a recent run of the CMU model for 2007 and 

provided it to the States for their review (USEPA 2010c). The USEPA data provided to 

MARAMA included emissions for livestock and fertilizer application. The CMU model is 

also capable of estimating ammonia emissions from non-domestic animals (deer, bear, etc.) 

and domesticated pets (dogs and cats) as well as other things such as human perspiration. 

However, none of these sources were included in the runs of the CMU model that EPA 

provided to MARAMA. Thus, unless a State supplied emission estimates for those 

categories, they were not included in the 2007 inventory. 

4.2.4 EPA SMARTFIRE Emissions Database 

SMARTFIRE is an algorithm and database system developed and built within a 

geographic information system (GIS) framework that combines multiple sources of fire 

information and reconciles them into a unified data set (SONOMA 2009). SMARTFIRE 

data sources include satellite fire detects and ground reports of fire incidents for various 

wild land management agencies. SMARTFIRE was developed by the USDA Forest 

Service AirFire Team and Sonoma Technology, Inc. under a grant from NASA. 
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SMARTFIRE interfaces with the BlueSky framework to estimate daily, location-specific 

fire emissions. 

The Contractor obtained from USEPA a file of 2007 annual, county-level emissions data 

for wild land fires as calculated using the SMARTFIRE methodology. The Contractor 

provided the inventory and documentation to States for their review and consideration. 

4.3 STATE-SPECIFIC DATA 

States reviewed the documentation and resulting emission files for each USEPA estimation 

methodology. Each State made a decision of whether to accept the USEPA inventory (NEI 

2008, RWC tool results, CMU ammonia model results, SMARTFIRE results) or to 

develop their own emission estimates for these categories. Based on state choices, the 

Contractor initiated collection of the State supplied data. Generally states provided their 

data in NIF3.0 format; however some data was provided in spreadsheets in a State-specific 

format or in the new EIS Emissions format. Where necessary, data was converted to NIF 

format, filling in as many NIF fields as possible with state-supplied data. 

State submitted emission files were augmented using USEPA data as directed by the 

States. Where 2008 NEI data were used to fill missing categories in the 2007 MANE 

VU+VA inventory, no growth adjustment was made to the emissions. This is because 

States felt that activity in 2008 to 2007 was similar due to the economic downturn. 

The emissions data is housed in NOF formatted files, which provide additional fields at the 

end of each table to identify the data source and revision date. Those data elements 

provide a the data lineage for each source category, thus improving the overall inventory 

quality assurance (QA). The values in the DATA_SOURCE field in the EM table are 

shown in Exhibit 4.2. Exhibit 4.3 summarizes the data sources used for each MARAMA 

State and major source category. 
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Exhibit 4.2 – Values Contained in the DATA_SOURCE Field of the EM Table

EM Table DATASOURCE Value Description of Data Source

2005NEIv2 

All of the records are for CT, which used this value in their 

submittal to the Contractor – data taken directly by CT from the 

2005 NEI version 2

2008NEI Emissions based on USEPA’s 2008 NEI using the USEPA data 

and methodologies described in Section 4.2.1 of this TSD

EPA Emissions based on USEPA’s 2008 NEI using the USEPA data 

and methodologies described in Section 4.2.1 of this TSD

EPA NEI05 

Emissions based on USEPA’s 2005 NEI as a gap-filling 

measure where 2007 data were not available from State or

USEPA

EPA RWC Mo Emissions based on USEPA’s Residential Wood Combustion 

model 

EPA/Ratio 

PM emissions were generated using USEPA-supplied emission 

values and ratios of condensable to PM-PRI or other ratios as 

necessary to complete the PM spectrum of pollutants 

EPA-CMU Emissions based on USEPA’s 2007 run of the CMU ammonia 

model

MARAMA02BY 

Emissions based on MARAMA’s 2002 Version 3 area source 

inventory as a gap-filling measure where 2007 data were not 

available from the State or USEPA

MARAMA2009 

Emissions based on MARAMA’s 2009 Version 3 area source 

inventory as a gap-filling measure where 2007 data not 

available from State or USEPA

MOVES Vehicle refueling emissions calculated by NESCAUM using the 

MOVES model in the inventory mode

NEI0508INT Emissions were linearly interpolated for 2007 based on values 

in the 2005 NEI and the 2008 NEI

NEI08CTMOD 

All of the records are for CT, which used this value in their 

submittal to the Contractor – these records were based on the 

2008 NEI data modified by CT air quality staff

SEMAP07 Emissions for Virginia are based on SEMAPs 2007 area source 

inventory

State MOVES Vehicle refueling emissions calculated by the state using the 

MOVES model in the inventory mode

State RWC Emissions for New Jersey based on NJ-specific application of

USEPA’s Residential Wood Combustion model

State Emissions were provided directly by the State and represent 

actual 2007 emissions

StateRatio 

PM emissions were generated using State-supplied emission 

values and ratios of condensable to PM-PRI or other ratios as 

necessary to complete the PM spectrum of pollutants
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

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Exhibit 4.3 – Data Sources Generally Used by Each State for Each Area Source Category

SCC4 Description CT DE DC ME MD MA NH NJ NY PA RI VT VA

2101 Fuel Comb. / 

Utility n/a n/a n/a n/a n/a n/a n/a n/a State n/a n/a n/a n/a

2102 Fuel Comb. / 

Industrial State State State n/a n/a State State State State State State State State

2103 Fuel Comb. / 

Commercial State State State State State State State State State State State State State

2104 Residential 

Other Fuels State State State State State State State State State State EPA State /USEPA State

2104 Residential 

Wood Comb.

EPA 

RWC State EPA RWC State State EPA RWC State State RWC State State EPA RWC

EPA 

RWC

EPA 

RWC

2294 Paved Road 

Dust State State State State State State State State State State State State State

2296 Unpaved Road 

Dust EPA n/a State State State EPA EPA State EPA EPA EPA State EPA

2302 Food & Kindred 

Products EPA State State State State State EPA State State State EPA EPA State /USEPA

2311 Construction EPA State State State State n/a State /

USEPA State EPA EPA EPA EPA EPA

2325 Mining & 

Quarrying State n/a n/a State n/a EPA NEI05

EPA 

NEI05 State MARAMA 09

EPA 

NEI05 n/a EPA NEI05 State

2399 Industrial 

Refrigeration State n/a n/a n/a n/a n/a n/a State n/a n/a n/a n/a n/a

2401 Surface 

Coating EPA State State State State State State State State State EPA EPA State

2415 Degreasing EPA State State State State State State State State State EPA EPA State

2420 Dry Cleaning EPA State State n/a State State EPA State n/a State EPA EPA State

2425 Graphic Arts EPA State State State State State State State State State EPA EPA State
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SCC4 Description CT DE DC ME MD MA NH NJ NY PA RI VT VA

2440 Industrial 

Adhesives 2005NEI State n/a State State State n/a State MARAMA 09 n/a n/a n/a n/a

2460 

Consumer/Comm 

Products

EPA State State State State State State State n/a State EPA EPA State

2461 Road Asphalt 2005NEI State State State State State State State State State State EPA State

2465 Consumer 

Products n/a n/a n/a n/a n/a n/a n/a n/a State n/a n/a n/a n/a

2501 Portable Fuel 

Containers

NEI0508 

INT State State n/a State EPA EPA State State State State EPA EPA

2501 Gas Stations 

Stage 1 2008NEI State State State State State State State EPA State State State State

2501 Gas Stations 

Stage 2 MOVES MOVES MOVES MOVES MOVES MOVES MOVES MOVES StateMOVES

State

MOVES MOVES MOVES StateMOVES

2501 Aviation Gas 

Stage 1/2 EPA State State State State State n/a State n/a n/a EPA State EPA

2505 Tank Truck 

Transport 2008NEI State State State State State n/a State EPA State State State State

2610 Open Burning EPA State State State State EPA State State EPA State /

USEPA EPA EPA EPA

2620 Landfills State State n/a State State State State State State n/a n/a n/a n/a

2630 Wastewater 

Treatment EPA State State State State State State State State State EPA EPA EPA

2660 Leaking 

Underground Tanks State State n/a State State State State State n/a n/a n/a n/a State

2680 Composting State n/a n/a State n/a n/a State State n/a n/a n/a n/a n/a

2801 Agriculture 

Tilling State State n/a State State State State State n/a EPA NEI05

EPA 

NEI05 State State
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

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SCC4 Description CT DE DC ME MD MA NH NJ NY PA RI VT VA

2801 Agriculture 

Field Burning n/a n/a n/a State n/a n/a n/a State n/a n/a n/a n/a n/a

2801 Agriculture 

Fertilizer

EPA 

CMU State n/a EPA CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA

CMU

EPA 

CMU

2805 Agriculture 

Livestock

EPA 

CMU State n/a EPA CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

EPA 

CMU

2810 Forest Wildfires n/a State n/a State State State n/a State State EPA n/a State SEMAP 

07

2810 Prescribed 

Fires n/a State State State State n/a n/a State State n/a n/a n/a SEMAP 07

2810 Structure Fires State State State State State State State State State n/a n/a State State

Note: this table provides a general indication of the data source used for each major source category. Refer to the NIF EM table for a comprehensive listing of the 

Data Source for each individual county/SCC/pollutant. 
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4.4 VERSION 2: STATE AND STAKEHOLDER REVIEW AND COMMENT 

The draft MS Access area source files were provided to States and stakeholders for review 

and comment. Within the Access database three queries were provided to allow the States 

to summarize emissions by State, county, SCC and pollutant to assist with the review. 

States and stakeholders provided comments and changes for incorporation and/or change. 

The following subsections describe the comments received and other QA activities 

performed that were ultimately incorporated into the final area source inventory. 

4.4.1 National Park Service Comments 

The only comments received from outside stakeholders came from the National Park 

Service (NPS). The NPS requested that the documentation be updated to more clearly 

identify the data sources used by each State for each category. Exhibits 4.2 and 4.3 were 

prepared in response to this request. Note that Exhibit 4.2 provides only a general 

indication of the data source used for each major source category. Reviewers are directed 

to the NOF EM table for a comprehensive listing of the Data Source used for each 

individual county/SCC/pollutant record. The NPS also commented on the large 

differences in emissions from some categories between 2002 and 2007. These differences 

were evaluated and are addressed in Section 4.4.3 and 4.5 of this TSD. 

4.4.2 Checks for Missing Categories, Double Counting, Outliers, and Differences 

between 2002 and 2007 Inventories 

As shown previously in Exhibit 4.3, a variety of data sources and methods are used by 

States to develop the 2007 inventory. The potential exists for categories to be 

inadvertently omitted, double counted (for example by including both State-specific and 

USEPA estimates), or to have a large per-capita or per-employee variation from State-toState. 

To guard against omission or double counting, the Contractor and MARAMA prepared a 

series of SCC level summary reports and manually reviewed them to determine potentially 

missing source categories. Among the reports were the following: 

“SCC in both 2002 and 2007” compares emissions by State and SCC for SCCs 

contained in both the 2002 and 2007 inventories. 

“2002 SCCs NOT in 2007” contains the SCCs that were in the 2002 inventory, but 

not in the first draft of the 2007 inventory. 

“2007 SCCs NOT in 2002” contains the SCCs that were in the 2007 inventory, but 

not in the 2002 inventory. 
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There are both increases and decreases in emissions between 2002 and 2007 depending 

upon the State and pollutant. In order to better understand these differences, we also 

prepared charts to graphically depict the major differences between the 2002 and 2007 area 

source inventories. Finally 4-digit SCC summaries were prepared to identify gaps. 

States were asked to review these QA reports and provide responses to fill in gaps or 

address potentially anomalous emission estimates. Several instances were found where a 

State did not have emissions for a relatively important source category in the draft 2007 

inventory. Examples are several SCCs related to PM emissions from construction, 

agricultural tilling and mining & quarrying operations. These gaps were brought to the 

attention of the affected States for resolution. In some cases, States provided data for the 

missing categories or advised the Contractor to fill in the gap using available data from 

existing USEPA or MARAMA inventories. In other cases, States indicated that emissions 

from the missing categories were small and determined that the effort to fill the missing 

category gap was not justified. 

We reviewed SO2 and NOx emissions by State from industrial, commercial/institutional, 

and residential fuel combustion. Since the OTC is considering additional control measures 

for the industrial/commercial/institutional fuel combustion category, these values were 

closely scrutinized. Pennsylvania showed a dramatic increase in emissions from 2002 to 

2007 for both SO2 and NOx for the industrial fuel combustion category. New York 

showed a substantial decrease in both the industrial and commercial/institutional categories 

from 2002 to 2007. Pennsylvania provided updated estimates for Version 3 of the 

inventory. New York did not provide an explanation of the possible reason for the 

differences, and no changes to the 2007 values were made. 

A comparison of 2002 and 2007 VOC emissions by State for three types of solvent 

evaporation categories revealed that two States – Maine and New York – appear to have 

double-counted VOC emissions for this category using two different SCCs (24-60-xxx-xx 

and 24-65-xxx-xx). Maine and New York reviewed the issue and provided updates to 

eliminate the double counting issue. 

4.5 VERSION 3 REVISIONS 

4.5.1 Use of New USEPA Road Dust Equation 

In January 2011, USEPA issued a new methodology (USEPA 2011) for developing 

emission factors for re-entrained particulate matter from vehicles traveling over a paved 

surface such as a road or parking lot. The new methodology was not used in Version 2 of 

the MANE-VU+VA 2007 inventory as it was not finalized in time. 
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This January 2011 version of the paved road emission factor equation only estimates 

particulate emissions from suspended road surface material. Particulate emissions from 

vehicle exhaust, brake wear, and tire wear are now estimated separately using USEPA's 

MOVES model. This approach eliminates possible double counting of emissions resulting 

from use of the previous version of the equation in this section and MOVES to estimate 

particulate emissions from vehicle traffic on paved roads. 

All states (except Maine) submitted revised paved road emission estimates using the new 

methodology for Version 3 of the 2007 MANE-VU+VA inventory. Exhibit 4.4 compares 

the 2007 PM10 and PM2.5 emissions using the new and previous methodology. PM10 

emissions are lower using the new methodology, while PM2.5 emissions are higher. 

Exhibit 4.4 –2007 Paved Road Dust PM10 and PM2.5 Emission Estimates 

State

PM10-PRI PM25-PRI

Version2

(tons/yr)

Version 3 

New Method

(tons/yr)

Version2

(tons/yr)

Version 3 

New Method

(tons/yr)

Connecticut 16,085 6,722 688 1,680

Delaware 10,217 4,556 724 1,143

District of Columbia 1,841 819 81 201

Maine* 16,536 16,536 1,665 1,665

Maryland** 12,813 13,798 3,160 3,387

Massachusetts 32,748 27,392 1,622 6,724

New Hampshire 8,821 7,985 524 1,960

New Jersey 38,210 19,914 1,142 4,979

New York 95,075 46,348 5,818 11,376

Pennsylvania 92,927 46,806 6,114 11,489

Rhode Island 4,387 3,833 204 941

Vermont 11,326 5,659 979 1,389

Virginia 50,827 29,637 2,966 7,275

Total 391,814 230,004 25,690 54,207

* Maine did not provide paved road emissions using the new method. 

** Maryland used a draft version of the new AP-42 method for Version 2.

4.5.2 Use of MOVES Model to Estimate Stage II Emissions 

States elected to use the Stage II emissions as calculated by the MOVES model, and to 

include those emissions in the area source sector emission summaries. Stage II emissions 

result from the refueling of motor vehicles at gasoline service stations. NESCAUM, PA, 

NY, and VA each executed the MOVES model in inventory mode to calculate vehicle 

refueling emissions. The MOVES estimates were used instead of the estimates provided 
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by states for Version 2 of the inventory. The MOVES estimates are not included in the 

onroad sector summaries or modeling files so that the emissions will not be double 

counted. Exhibit 4.5 compares the Stage II VOC emissions in the 2008 NEI to the 

emissions calculated using the MOVES model. VOC emissions are higher using MOVES 

in some states, lower in others. Appendix F contains NESCAUM’s documentation of the 

MOVES modeling. Appendix G contains the VOC control efficiencies by county used in 

the MOVES modeling for displacement losses and for spillage losses. 

Exhibit 4.5 –Stage II Refueling VOC Emissions for 2007 Using NMIM and MOVES 

State

NEI2008 

(tons/yr)

2007 Version 3 

Using

MOVES

(tons/yr)

Connecticut 483 286

Delaware 284 294

District of Columbia 71 52

Maine 809 709

Maryland 1,933 2,132

Massachusetts 980 807

New Hampshire 412 419

New Jersey 2,287 2,500

New York 7,604 8,787

Pennsylvania 5,313 6,581

Rhode Island 178 180

Vermont 128 122

Virginia 4,464 5,569

Total 24,947 28,437

4.5.3 Connecticut Changes for Fuel Combustion 

Connecticut provided updated 2007 emission estimates for non-wood fuel combustion for 

the residential, commercial/institutional and industrial source categories. Connecticut 

previously relied on USEPA’s 2005 NEI-v2 (commercial/institutional and industrial) and 

USEPA’s 2008 NEI (residential) for these categories. Prompted by reviews provided by 

MARAMA, Connecticut subsequently discovered that USEPA’s inventory assumed a 

2.25% sulfur level for residual fuel oil compared to a CT regulatory maximum of 1.0% 

sulfur. In addition, Connecticut could not verify whether USEPA’s 2005 NEI-v2 adjusted 

its area source estimates to avoid double counting of point sources. As a result, 

Connecticut has decided to use emission estimates from its draft-2005 periodic emissions 

inventory (PEI) for the non-wood fuel combustion portions of the three cited categories. 
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The draft-2005 PEI includes only CO, VOC and NOx emissions, so fuel use values were 

multiplied by USEPA emission factors obtained from the 2008 NEI to calculate estimates 

of annual SO2 and PM2.5 emissions. Emissions for 2005 are assumed to be representative 

of 2007, with no growth adjustments. 

Connecticut identified errors in the Version 2 inventory that were corrected in Version 3. 

The CO emissions for residential distillate oil combustion were incorrectly reported as 

winter season emissions instead of annual emissions. Version 2 emissions for residential, 

commercial/institutional, and industrial kerosene combustion were based on NEI 2008 

values. Connecticut indicated that kerosene emissions in the state are included under the 

distillate oil category. Emissions for the kerosene combustion SCCs were set to zero in 

Version 3 to avoid double counting of emissions. For a few SCCs, the sum of the PM10-

FIL and PM-CON emissions did not equal the PM10-PRI emissions, and the sum of the 

PM25-FIL and PM-CON emissions did not equal the PM25-PRI emissions. Revisions to 

the PM10-PRI and PM25-PRI emissions were made to correct the error. 

4.5.4 Connecticut Revisions for AIM Coatings and Auto Refinishing 

Version 2 of the 2007 inventory for AIM coatings was based on USEPA 2008 NEI values, 

which accounted for the implementation of the OTC model rule for AIM coatings in 

Connecticut. Since Connecticut’s AIM rule did not go into place in time to produce 2007 

reductions, the 2008 NEI values for those SCCs were increased for the Version 3 

inventory. The emission factor used to calculate emissions was changed from 2.41 to 3.02 

lbs/person to reflect the absence of reductions from the CT AIM rule in 2007. 

Version 2 of the 2007 inventory for industrial maintenance coatings was based on USEPA 

2008 NEI values, which accounted for the implementation of the OTC model rule for AIM 

coatings in Connecticut. Since Connecticut’s AIM rule did not go into place in time to 

produce 2007 reductions, the 2008 NEI values for those SCCs were increased for the 

Version 3 inventory. The emission factor used to calculate emissions was changed from 

0.15 to 0.96 lbs/person to reflect the absence of reductions from the CT AIM rule in 2007. 

Version 2 of the 2007 inventory for auto refinishing coatings was based on USEPA 2008 

NEI values, which did not account for the implementation of the OTC model rule for 

mobile equipment repair and refinishing in Connecticut. A rule similar to the OTC rule 

was in place in Connecticut in April 2006. Since Connecticut’s auto refinishing rule was 

in place prior to 2007, the 2008 NEI values for those SCCs were reduced for the Version 3 

inventory. The emission factor used to calculate emissions was changed from 89 to 55 

lbs/employee to reflect the 38 percent reduction in VOC emissions from the Connecticut 

auto refinishing rule in 2007. 
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4.5.5 District of Columbia Residential Wood Combustion 

Emissions for residential wood combustion in the District of Columbia were missing from 

Version 2 of the 2007 MANE-VU+VA area source inventory. These emissions were 

originally estimated using the USEPA RWC tool, but were inadvertently left out of the 

2007 inventory. The 2007 emissions calculated by the USEPA RWC tool were added. 

4.5.6 Maryland Degreasing VOC Emisions 

Maryland provided revised estimates for VOC emissions for the degreasing category. 

4.5.7 Massachusetts NH3 Emisions 

Massachusetts added NH3 emissions from humans (SCC 28-10-010-000), cats (SCC 28-

06-010-000), and dogs (SCC 28-06-015-000) that were missing in Version 2. 

4.5.8 New Jersey Bakeries and Auto Refinishing VOC Emisions 

New Jersey revised the VOC emissions for bakeries and auto refinishing. 

4.5.9 New York VOC Emisions from Residential Wood Combustion 

New York revised the CO and VOC emissions for all residential wood combustion SCCs. 

4.5.10 Pennsylvania Industrial Coal Combustion 

Pennsylvania revised the industrial coal emissions for SCCs 2102001000 and 2102002000. 

This revision was accomplished using one of the two new preferred methods of point 

subtraction based on activity throughputs (coal usage). The revised activity method is 

performed by subtracting the point source coal usage from the state coal usage totals, and 

then calculating the area source emissions, which is a more accurate calculation estimate. 

4.5.11 Pennsylvania Residential Distillate Oil Combustion 

Pennsylvania’s original submittal for SO2 emissions for residential distillate oil were 

incorrectly underreported by a factor of 100. This error was corrected in Version 3. 

4.5.12 Virginia Industrial Coal Combustion 

Virginia identified an error in the Version 2 emissions from industrial coal combustion 

(SCC=21-02-002-000) resulting from a misinterpretation of activity data from the Energy 

Information Administration. Virginia now believes that all industrial coal combustion is 

accounted for in the point source inventory. All emissions for this SCC were zeroed out 

for all counties in Virginia. 
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4.5.13 Multiple States Open Burning and Commercial Cooking 

USEPA updated their emissions estimates for the 2008 NEI in August, 2011. Several 

states relied on the USEPA estimates for use in the 2007 MANE-VU+VA inventory. 

These revisions included: 

For commercial cooking (SCCs 23-02-002-xxx and 23-02-003-xxx), USEPA added 

emission factors for PM-CON and emissions for PM25-PRI were recalculated. 

For open burning (26-10-000-100, 26-10-000-400, 26-10-000-500, 26-10-030-

000), USEPA updated per capita waste generation and recalculated emissions. 

Emissions for states using the USEPA estimates were updated to reflect these changes. 

4.6 ANNUAL 2007 AREA SOURCE EMISSION SUMMARY 

Overall, estimated area source emissions decreased from 2002 to 2007 in the region for all 

pollutants. Area source emissions are generally a product of both activity and emission 

factors. Changes in both activity and emission factors occurred between 2002 and 2007 

for several categories resulting in changes in emission estimates. 

Exhibit 4.6 summarizes 2002 and 2007 area source CO emissions by State. Exhibit 4.7 

presents the 2007 CO emissions by State and major source category. Most States show a 

significant reduction in CO area source emissions between 2002 and 2007. The District of 

Columbia, Rhode Island and Vermont show increases. Regionwide, area source emissions 

of CO are estimated to be 33% lower in 2007 than was estimated in 2002. Most of the area 

source CO emissions result from residential wood combustion and open burning, and the 

emission estimation methods used for these categories changed between 2002 and 2007. 

Therefore, the substantial changes in CO emissions from 2002 to 2007 are primarily due to 

different emission estimation methodologies used for the 2002 and 2007 inventories. 

Exhibit 4.8 summarizes 2002 and 2007 area source NH3 emissions by State. Exhibit 4.9 

presents the 2007 NH3 emissions by State and major source category. Most States show a 

reduction in NH3 area source emissions between 2002 and 2007, except for the District of 

Columbia, which show substantial percentage increase. It should be noted that the 

magnitude of NH3 emissions in the District are very small in comparison to regional 

emissions, and the large percentage increase is insignificant in the context of regional air 

quality modeling. Regionwide, area source emissions of NH3 are estimated to be 15% 

lower in 2007 than was estimated in 2002. Nearly all area source NH3 emissions result 

from agricultural livestock and fertilizer categories which were calculated by USEPA 

using the CMU ammonia model. Reductions in animal populations and fertilizer usage 

between 2007 and 2002 are the reason for the change. 
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Exhibit 4.10 summarizes 2002 and 2007 area source NOx emissions by State. Exhibit 4.11 

presents the 2007 NOx emissions by State and major source category. Most States show 

decreases between 2002 and 2007, except for Pennsylvania and Vermont, which show 

increases. Regionwide, area source emissions of NOx are estimated to be 28% lower in 

2007 than was estimated in 2002. Nearly all area source NOx emissions are from the 

industrial, commercial, and residential (non-wood fuel) categories. 

Exhibit 4.12 summarizes 2002 and 2007 area source PM10-PRI emissions by State. 

Exhibit 4.13 presents the 2007 PM10-PRI emissions by State and major source category. 

Regionwide, area source emissions of PM10-PRI are estimated to be 29% lower in 2007 

than was estimated in 2002. PM10-PRI emissions are attributable to the paved/unpaved 

road dust, construction activity, mining & quarrying, and agricultural tilling categories. 

Changes in the emission calculation methodology for road dust from paved roads accounts 

for a substantial portion of the decrease. 

Exhibit 4.14 summarizes 2002 and 2007 area source PM25-PRI emissions. Exhibit 4.15 

presents the 2007 PM25-PRI emissions by State and major source category. Regionwide, 

area source emissions of PM25-PRI are estimated to be 19% lower in 2007 than was 

estimated in 2002. PM25-PRI emissions result from residential wood combustion, 

paved/unpaved road dust, construction activity, mining & quarrying, and open burning 

categories. Changes in the emission calculation methodology for road dust from paved 

roads and residential wood combustion accounts for a substantial portion of the changes. 

Exhibit 4.16 summarizes 2002 and 2007 area source SO2 emissions by State. Exhibit 4.17 

presents the 2007 SO2 emissions by State and major source category. Most States show 

decreases between 2002 and 2007, except for Connecticut and Pennsylvania, which show 

increases. Regionwide, area source emissions of SO2 are estimated to be 42% lower in 

2007 than was estimated in 2002. Nearly all area source SO2 emissions are from the 

industrial, commercial, and residential (non-wood fuel) categories. 

Exhibit 4.18 summarizes 2002 and 2007 area source VOC emissions by State. Exhibit 

4.19 presents the 2007 VOC emissions by State and major source category. All States 

show substantial reductions in VOC emissions from 2002 to 2007. Regionwide, area 

source emissions of VOC are estimated to be 45% lower in 2007 than was estimated in 

2002. Part of the difference can be explained by post-2002 control measures for 

architectural coatings, consumer products, degreasing and portable fuel containers. But, as 

was discuss for CO emissions, part of the difference is due to differences in the 

methodologies used to estimate emissions from residential wood combustion. 
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Exhibit 4.6 – 2002 and 2007 Area Source CO Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 70,198 41,496 -41%

Delaware 14,052 8,266 -41%

District of Columbia 2,300 5,488 139%

Maine 109,223 50,496 -54%

Maryland 141,179 74,188 -47%

Massachusetts 137,496 79,226 -42%

New Hampshire 79,647 39,677 -50%

New Jersey 97,657 77,687 -20%

New York 356,254 205,055 -42%

Pennsylvania 266,935 217,079 -19%

Rhode Island 8,007 15,419 93%

Vermont 43,849 51,109 17%

Virginia 155,873 132,098 -15%

1,482,669 997,285 -33%

Exhibit 4.7 – 2007 Area Source CO Emissions by Category and State 

(tons/year) 
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Exhibit 4.8 – 2002 and 2007 Area Source NH3 Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 5,318 4,421 -17%

Delaware 13,278 12,382 -7%

District of Columbia 14 183 1188%

Maine 8,747 5,736 -34%

Maryland 25,835 26,006 1%

Massachusetts 18,809 13,791 -27%

New Hampshire 2,158 1,500 -30%

New Jersey 17,572 15,736 -10%

New York 67,422 45,693 -32%

Pennsylvania 79,911 72,569 -9%

Rhode Island 883 625 -29%

Vermont 9,848 8,013 -19%

Virginia 43,905 43,394 -1%

293,699 250,049 -15%

Exhibit 4.9 – 2007 Area Source NH3 Emissions by Category and State 

(tons/year) 
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Exhibit 4.10 – 2002 and 2007 Area Source NOx Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 12,689 12,422 -2%

Delaware 2,608 2,237 -14%

District of Columbia 1,644 1,547 -6%

Maine 7,360 6,656 -10%

Maryland 15,678 10,312 -34%

Massachusetts 34,281 20,252 -41%

New Hampshire 10,960 4,737 -57%

New Jersey 26,692 24,175 -9%

New York 98,803 72,053 -27%

Pennsylvania 47,591 47,545 0%

Rhode Island 3,886 3,469 -11%

Vermont 3,208 3,996 25%

Virginia 51,418 19,056 -63%

316,817 228,458 -28%

Exhibit 4.11 – 2007 Area Source NOx Emissions by Category and State 

(tons/year) 
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Exhibit 4.12 – 2002 and 2007 Area Source PM10-PRI Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 48,281 30,577 -37%

Delaware 13,039 10,499 -19%

District of Columbia 3,269 4,873 49%

Maine 168,953 54,445 -68%

Maryland 95,060 72,454 -24%

Massachusetts 192,860 148,756 -23%

New Hampshire 43,329 27,742 -36%

New Jersey 61,601 39,140 -36%

New York 369,595 272,674 -26%

Pennsylvania 391,897 287,998 -27%

Rhode Island 8,295 11,361 37%

Vermont 56,131 47,993 -14%

Virginia 237,577 183,341 -23%

1,689,886 1,191,853 -29%

Exhibit 4.13 – 2007 Area Source PM10-PRI Emissions by Category and State 

(tons/year) 
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Exhibit 4.14 – 2002 and 2007 Area Source PM25-PRI Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 14,247 10,606 -26%

Delaware 3,204 3,031 -5%

District of Columbia 805 1,542 91%

Maine 32,774 12,526 -62%

Maryland 27,318 19,789 -28%

Massachusetts 42,083 30,438 -28%

New Hampshire 17,532 8,623 -51%

New Jersey 19,350 18,299 -5%

New York 87,155 63,906 -27%

Pennsylvania 74,925 73,514 -2%

Rhode Island 2,064 3,896 89%

Vermont 11,065 13,106 18%

Virginia 43,989 44,102 0%

376,510 303,378 -19%

Exhibit 4.15 – 2007 Area Source PM25-PRI Emissions by Category and State 

(tons/year) 
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Exhibit 4.16 – 2002 and 2007 Area Source SO2 Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 12,419 16,083 30%

Delaware 1,588 1,144 -28%

District of Columbia 1,336 1,241 -7%

Maine 13,149 9,812 -25%

Maryland 12,393 5,960 -52%

Massachusetts 25,488 19,859 -22%

New Hampshire 7,072 5,283 -25%

New Jersey 10,744 8,811 -18%

New York 130,409 70,044 -46%

Pennsylvania 63,679 66,584 5%

Rhode Island 4,557 3,897 -14%

Vermont 4,088 3,752 -8%

Virginia 105,890 17,098 -84%

392,812 229,569 -42%

Exhibit 4.17 – 2007 Area Source SO2 Emissions by Category and State 

(tons/year) 
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Exhibit 4.18 – 2002 and 2007 Area Source VOC Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 87,302 57,253 -34%

Delaware 15,520 9,482 -39%

District of Columbia 6,432 5,568 -13%

Maine 100,621 31,966 -68%

Maryland 120,254 64,429 -46%

Massachusetts 155,557 85,870 -45%

New Hampshire 65,371 22,343 -66%

New Jersey 167,882 98,121 -42%

New York 507,291 195,976 -61%

Pennsylvania 240,785 176,781 -27%

Rhode Island 31,402 24,214 -23%

Vermont 23,266 14,108 -39%

Virginia 172,989 142,218 -18%

1,694,670 928,330 -45%

Exhibit 4.19 – 2007 Area Source VOC Emissions by Category and State 

(tons/year) 
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5.0 ANNUAL 2007 INVENTORY FOR NONROAD SOURCES 

INCLUDED IN THE NONROAD MODEL 

5.1 NONROAD MODEL CATEGORIES 

The USEPA’s NONROAD model estimates emissions from equipment such as 

recreational marine vessels, recreational land-based vehicles, farm and construction 

machinery, lawn and garden equipment, aircraft ground support equipment (GSE) and rail 

maintenance equipment. This equipment is powered by diesel, gasoline, compressed 

natural gas or liquefied petroleum gas engines. 

The National Mobile Inventory Model (NMIM) was developed by USEPA to estimate 

county-level emissions for certain types of nonroad equipment. NMIM uses the current 

version the NONROAD model. The NMIM national county database contains monthly 

input data to reflect county specific fuel parameters and temperatures. Most of the work 

associated with executing NMIM involved updating the NMIM county database with 

State-specific information. For this analysis, we used the NMIM2008 software (version 

NMIM20090504), the NMIM County Database (version NCD20090531), and 

NONROAD2008a (July 2009 version) as a starting point (USEPA 2009d). Changes were 

made to the NCD20090531 based on State review. 

5.2 VERSION 2 INVENTORY DEVELOPMENT 

The following subsections describe how Version 2 of the inventory was prepared. 

5.2.1 State Review of NMIM Meteorology Data and Fuel Characteristics 

The Contractor obtained from USEPA the National County Database (NCD20090531) for 

use as a starting point for preparing the modeling data sets. NCD20090531contains the 

2007 year-specific meteorology data set that USEPA used to calculate 2007 emissions in 

addition to fuel revisions for years 2006-2011. These fuel values are updates to those in 

the 2007 USEPA NMIM run which used NCD20090327. It was decided to use 

NCD20090531 as a starting point for development of the NONROAD input files for the 

2007 modeling inventory. NCD20090531 was made available for state comment. 

Several States commented on fuel characteristics data and changes were made to the 

underlying MySQL database to incorporate those changes into the model. These included 

changes to Reid Vapor Pressure, sulfur and oxygenate fractions. Where changes were 

made, the Contractor created new gasoline types and IDs using the NMIM MySQL NCD 

database default entries as a starting point. Only information related to criteria pollutant 

emission calculations was changed. Information related to air toxics that was contained in 
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

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the initial default fuel characteristic tables was not adjusted. Thus the fuel types created 

for the NMIM modeling should NOT be used for air toxics modeling. To further separate 

the data in the fuel characteristics tables from other modeling efforts, the Contractor 

created a separate NCD for use exclusively for this modeling effort. 

Exhibit 5.1 shows the number of added gasoline fuel record types added to the “gasoline” 

table in the MySQL NCD database. The total number of added fuel records was 118 new 

gasoline types. These records were given GasolineID values of 4462 to 4479 inclusive. 

Exhibit 5.1 – Gasoline Fuel Record Types Add to MySQL NCD Database

State Number of revised 

gasoline records

CT 10

MD 48

NH 15

NJ 20

NY 25

Although records were added for NY, they were not used since NY performed their own 

NONROAD modeling (see below). 

5.2.2 Update of NMIM Allocation Files for Population and Housing 

Several NONROAD categories use housing unit or population data to allocate the 

emissions to the county level from State calculations. States identified some discrepancies 

in the housing and population data contained in the NONROAD model and requested that 

the Contractor update the allocation files for those categories. As a consequence, the 

Contractor obtained 1 and 2 unit housing information and updated 2007 population 

estimates. Data were obtained from the sources listed in Exhibit 5.2. : 

Exhibit 5.2 – Data Sources for Population and Housing Data

Source Type Data Source

2007 Population Data Source http://www.census.gov/popest/counties/CO-EST2008-01.html

Total Housing Data Source http://www.census.gov/popest/housing/HU-EST2007-CO.html

1 yr - 1 and 2 Unit Housing 

Data

2007 American Community Survey 1-Year Estimates

3 yr - 1 and 2 Unit Housing 

Data

B25024. UNITS IN STRUCTURE - Universe: HOUSING UNITS 

Data Set: 2005-2007 American Community Survey 3-Year 

Estimates, Survey: American Community Survey

Three sources for the housing unit data were required to evaluate all counties within the 

region. Census data are frequently withheld when the data reporting can lead to disclosure 
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of confidential business information or due to incomplete survey response. For the 1 and 2 

unit housing data, the predominant source was the 1 year 1 and 2 unit housing data. If that 

was unavailable due to either confidentiality issues or lack of survey response, then the 3 

year data was used by determining an average value for the three year period. Finally if no 

data were available for the 3 year 1 and 2 unit housing information, total housing unit data 

were utilized. The revised housing unit data affected the allocation of residential lawn and 

garden equipment. Revised allocation files for all MARAMA States (except NY) were 

developed and utilized in the NMIM modeling for this category. 

For the population data, the latest county estimates of population were obtained from the 

Census Bureau. These estimates were available for all counties within the MARAMA 

region. Again, revised allocation files were developed for all States within the MARAMA 

region with the exception of NY. These revised allocation files applied to railroad 

maintenance equipment and AC/refrigeration equipment. 

A revised population allocation file was prepared for NH as part of this effort, but those 

data were not obtained from the Census Bureau. The NH population data were provided 

by NH and were obtained from the "2007 Population Estimates of New Hampshire Cities 

and Towns", New Hampshire Office of Energy and Planning, June 2008.” Those data 

were used in lieu of the Census Bureau data. 

In addition, Pennsylvania provided changes to the values for 1 and 2 unit housing for 2007. 

The source of these data was not cited. 

5.2.3 State-Specific Data Incorporated in NMIM 

In addition to the global updates to the housing and population allocation files in the 

MARAMA region, several States submitted additional information used to update the 

underlying data used to calculate emissions from nonroad sources. The data submitted and 

the updates resulting from these submittals are discussed below by State. 

5.2.3.1 Connecticut 

Connecticut only provided updated information related to the gasoline characteristics. No 

additional changes were submitted. 

5.2.3.2 Delaware 

Delaware provided revised values for several additional allocation files beyond those for 

population and housing units. Data for 2005 were submitted and updated files were 

developed for the following allocation categories: golf courses, recreational marine vessels, 

snow blowers, number of wholesale establishments, landscaping employees, and 
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manufacturing employees. In addition, Delaware also submitted data on the engine 

populations for 2005 for the following recreational marine vessels: 

2282005010 2-Str Outboard 

2282005015 2-Str Personal Water Craft 

2282010005 4-Str Inboard/Sterndrive 

2282020005 Dsl - Inboard 

2282020010 Dsl - Outboard 

The updated population values for 2005 were added to the corresponding file for the 

NONROAD model and were used for the 2007 runs. Because of the way NONROAD 

handles missing data, if data for 2007 are not found, the most current data (in this case 

2005) are used to assist in determining a 2007 value. 

5.2.3.3 Maryland 

Maryland only provided information to update the gasoline characteristics. No additional 

changes were submitted. 

5.2.3.4 New Hampshire 

As indicated above, New Hampshire provided State-specific population data from their 

own data source for their counties for use in preparing the population allocation files. A 

revised population allocation file was prepared for NH as part of this effort, but those data 

were not obtained from the Census Bureau. The NH population data were provided by NH 

and were obtained from the "2007 Population Estimates of New Hampshire Cities and 

Towns", New Hampshire Office of Energy and Planning, June 2008. Those data were 

used in lieu of the Census Bureau data. 

5.2.4 New Jersey 

New Jersey provided revised gasoline characteristics values as well as NONROAD 

equipment population data with revised data on equipment population values for Airport 

Ground Support Equipment. In addition, NJ provided revised human population data for 

2002, 2005, 2010, 2015 and 2020. These data (along with the 2007 data generated from 

the Census Bureau) were added to the NJ population allocation file. 

5.2.4.1 New York 

New York opted to not have the Contractor calculate emissions using NMIM for their 

State. Instead, NY calculated their own emissions for the nonroad category and submitted 

the output files to the Contractor for post processing. The output files submitted by NY 

were monthly output runs from the NONROAD model for each county. The Contractor 
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simply post-processed these files to combine emissions and throughput values for each 

county into an annual emissions number. Summary annual files were submitted to NY by 

the Contractor for approval. No other work on the NY emissions was performed by the 

Contractor. 

5.2.4.2 Pennsylvania 

Pennsylvania provided revised data for the 1 and 2 unit housing information for 2007. 

Those data were used in lieu of the Census Bureau data for 2007 in the allocation file. The 

source of these data was not cited. 

5.2.5 NMIM Run Specification 

The run specifications for each NMIM run were developed on a State-by-State basis. The 

settings for each specification panel within the NMIM model are detailed below. 

Description: A short descriptive term for the run was entered for each State specific 

run. 

Geography: The “county” option was selected for each State specific run. All 

counties within a State were selected for the run. 

Time: On the time panel, the year 2007 was selected in the drop down box and 

added to the year selections area. The Use Yearly Weather Data check box was 

also selected. Every month in the Months check box area was selected. 

Vehicles/Equipment: Only the nonroad vehicle/equipment area was selected. All 

fuels and all vehicle types were selected for each State run. 

Fleet: No selections or information was entered in this panel. 

Pollutants: All criteria pollutants (with HC reported as VOC) were selected except 

for CO2. Exhaust PM10 and PM2.5 were also selected. 

Advanced features: Only the server and database were selected in this panel. 

Output: Under the Geographic Representation panel the County selection was 

made. In the General Output area, a new database was selected on the server for 

the output. 

All added external files for use in each State run were placed in the external files directory 

of the NCD. Entries for all external files included were added to the countynrfiles table of 

the NCD. 
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5.2.6 State and Stakeholder Review of Version 2 

The Contractor completed the NMIM modeling runs in October of 2009. The results were 

made available to States and Stakeholders for review and comment. Based on the 

comments received, the following issues were addressed, and in some cases, changes were 

made to the 2007 nonroad inventory for sources included in NMIM. 

5.2.6.1 Connecticut 

Connecticut requested several changes to the NMIM inputs, which were incorporated into 

a new 2007 NMIM run. Connecticut indicated that the RFG areas were not applied to 

counties correctly. RVP values were modified by a small amount to reflect USEPA RFG 

sample averages for the appropriate mapping of Connecticut counties to RFG areas. 

Connecticut identified discrepancies in the RFG average sulfur values for 2007 and 

provided updated values. Connecticut also provided updated values for the calculated 

oxygen weight percents for ethanol. 

5.2.6.2 New Jersey 

New Jersey identified a very minor issue with the fuels data used for the 2007 NMIM runs. 

After considering the insignificant impact it would have on the emission totals, they agreed 

the fuels data used in the original NMIM run were adequate. 

5.2.7 Removal of Airport Ground Support Equipment Emissions 

The NMIM/NONROAD model includes emissions from airport ground support 

equipment. As discussed in detail in Section 6 of this TSD, emissions from airport ground 

support equipment is also included in USEPA’s aircraft inventory that was prepared using 

the Federal Aviation Administration’s Emissions and Dispersion Modeling System 

(EDMS). Correspondence with USEPA indicated that USEPA considers the emissions 

calculated by EDMS to be better than those calculated by NONROAD. For this reason, all 

emissions calculated by NMIM/NONROAD for airport ground support equipment were 

removed from the inventory to avoid double counting emissions. 

5.3 CHANGES MADE FOR VERSION 3 

Two main modifications were made to the nonroad inventory for 2007 for version 3 of the 

inventory. First, Virginia and New York requested that their emissions be recalculated 

using the information developed for the MARAMA States. The Virginia reruns were 

performed for all categories except for ground support equipment and for recreational 

marine vessels. Those values replaced the SEMAP supplied values used in versions prior 

to version 3. As indicated above, New York had originally provided data from 
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NONROAD model runs that they performed separately. For this version of the inventory, 

New York emissions were calculated using NMIM runs set up using the same criteria as 

those for other states in earlier versions of the inventory. Both New York and Virginia 

were provided with the opportunity to review fuel characteristics prior to their runs. Only 

Virginia made changes to the fuels, however the only changes that were made were to 

assign alternative default fuels for gasoline powered engines to counties. The fuel 

characteristics were not modified from the NMIM defaults, only the fuel IDs associated 

with a particular county/month combination were changed to another default fuel. Those 

changes were instituted in the NCD developed specifically for MARAMA. Default values 

for diesel, LPG and CNG were maintained for Virginia. New York did not request any 

changes to the default values. In addition, the revisions made to the housing population 

allocation files were instituted for both states. 

The second change was to modify the recreational marine vessel populations for all states 

except Vermont and Maine. A revised population file was prepared for Virginia but not 

utilized in the version 3 runs. Virginia used the NMIM default engine population for 

recreational marine vessels for version 3 runs. The revised population data were provided 

by the National Marine Manufacturers Association (NMMA). Total state populations for 

each of the three major categories contained in the NONROAD model (outboard, 

inboard/sterndrive and personal watercraft) were provided for each state. Because the 

population files used by the NONROAD model (and thus NMIM) were configured with 

population values for various horsepower categories, AMEC determined the fraction of the 

total for each marine vessel type in each horsepower category from the NONROAD 

default population files. These fractions were then used to allocate the total state 

population obtained from NMMA to the various horsepower categories. 

The only exception to this was that some states added in data for sailboats to the NMMA 

data. The sailboat populations were split among two of the default NONROAD categories. 

In addition, New Hampshire provided their own revised population file. Their population 

data were provided by the New Hampshire DMV and is not from NMMA. 

5.4 SUMMARY OF NMIM MODELING RESULTS FOR 2007 

Exhibits 5.3 to 5.9 present State-level summaries that compare 2002 and 2007 annual 

emissions for NMIM/NONROAD sources (excluding airport ground support equipment) 

from Version 3 of the MARAMA inventory. The 2002 emissions are those that were 

developed previously for Version 3 of the MANE-VU and the VISTAS best-and-final 

inventory for Virginia. Note that previous versions of this document had emissions for 
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Virginia derived from VISTAS/SEMAP NMIM results. For this document the Virginia 

data is from NMIM runs made consistent with the MARAMA approach. 

For most States and pollutants, emissions from NMIM/NONROAD sources decreased 

from 2002 to 2007. 

CO emissions generally decreased by 15-30% in all States, in part due to turnover 

to newer, cleaner engines. 

NH3 emissions showed increases from 2002 to 2007 for all states except 

Connecticut and New Jersey which showed modest decreases. 

Emissions of NOx, PM10-PRI, and PM25-PRI generally decreased by 9-20% from 

2002 to 2007, with some States showing slightly higher or slight lower decreases. 

For SO 

2

, emissions decreased by 40-50% in all States except New Hampshire and 

Rhode Island. 

VOC emissions decreased between 5-35% over the same time period. 

In addition, the estimated decrease in emissions was due to differences in the versions of 

the NONROAD model that were used to develop the 2002 and 2007 inventories. The new 

version of the model (NONROAD 2008a) used for the 2007 inventory accounts for new 

exhaust and evaporative emission controls, and predicts substantially less HC and CO, and 

somewhat less NOx and PM emissions than earlier versions of NONROAD with use of 

comparable scenario inputs. NH3 was relatively unaffected by the new NONROAD 

version.
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Exhibit 5.3 – 2002 and 2007 NMIM/NONROAD CO Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 274,388 181,817 -34%

Delaware 65,954 55,173 -16%

District of Columbia 18,775 14,319 -24%

Maine 148,555 131,319 -12%

Maryland 424,777 297,832 -30%

Massachusetts 448,399 324,793 -28%

New Hampshire 128,572 90,461 -30%

New Jersey 692,548 445,302 -36%

New York 1,219,168 911,813 -25%

Pennsylvania 903,168 719,517 -20%

Rhode Island 71,573 54,028 -25%

Vermont 61,732 52,497 -15%

Virginia 582,895 415,093 -29%

5,040,503 3,693,965 -27%

Exhibit 5.4 – 2007 NMIM CO Emissions by Category and State 

(tons/year) 
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Exhibit 5.5 – 2002 and 2007 NMIM/NONROAD NH3 Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 17 16 -1%

Delaware 5 6 13%

District of Columbia 2 3 9%

Maine 11 13 11%

Maryland 28 29 4%

Massachusetts 28 28 0%

New Hampshire 9 10 11%

New Jersey 43 40 -8%

New York 79 83 5%

Pennsylvania 55 60 9%

Rhode Island 4 5 15%

Vermont 5 5 12%

Virginia 42 45 5%

328 342 4%

Exhibit 5.6 – 2007 NMIM NH3 Emissions by Category and State 

(tons/year) 
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Exhibit 5.7 – 2002 and 2007 NMIM/NONROAD NOx Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 17,897 16,056 -10%

Delaware 5,798 4,998 -14%

District of Columbia 3,066 2,788 -9%

Maine 8,229 7,439 -10%

Maryland 27,789 25,726 -7%

Massachusetts 30,047 26,471 -12%

New Hampshire 8,150 8,562 5%

New Jersey 43,515 36,345 -16%

New York 78,601 72,271 -8%

Pennsylvania 62,265 55,362 -11%

Rhode Island 4,564 4,388 -4%

Vermont 4,170 3,743 -10%

Virginia 40,788 41,325 1%

334,878 305,475 -9%

Exhibit 5.8 – 2007 NMIM NOx Emissions by Category and State 

(tons/year) 
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Exhibit 5.9 – 2002 and 2007 NMIM/NONROAD PM10-PRI Emissions by State 

(tons/year) 

STATE 2002 2007 Change

Connecticut 1,713 1,412 -18%

Delaware 570 476 -17%

District of Columbia 298 242 -19%

Maine 1,204 1,151 -4%

Maryland 3,119 2,600 -17%

Massachusetts 2,887 2,384 -17%

New Hampshire 947 846 -11%

New Jersey 4,285 3,377 -21%

New York 8,332 7,059 -15%

Pennsylvania 6,281 5,623 -10%

Rhode Island 403 367 -9%

Vermont 518 482 -7%

Virginia 4,901 4,128 -16%

35,459 30,146 -15%

Exhibit 5.10 – 2007 NMIM PM10-PRI Emissions by Category and State 

(tons/year) 
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Exhibit 5.11 – 2002 and 2007 NMIM/NONROAD PM25-PRI Emissions by State 

(tons/year) 

STATE 2002 2007 Change

Connecticut 1,578 1,343 -15%

Delaware 525 453 -14%

District of Columbia 288 234 -19%

Maine 1,135 1,080 -5%

Maryland 2,870 2,473 -14%

Massachusetts 2,659 2,268 -15%

New Hampshire 872 799 -8%

New Jersey 3,951 3,213 -19%

New York 7,670 6,715 -12%

Pennsylvania 5,784 5,346 -8%

Rhode Island 371 349 -6%

Vermont 477 455 -5%

Virginia 4,665 3,933 -16%

32,844 28,660 -13%

Exhibit 5.12 – 2007 NMIM PM25-PRI Emissions by Category and State 

(tons/year) 
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Exhibit 5.3 – 2002 and 2007 NMIM/NONROAD SO2 Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 1,377 802 -42%

Delaware 513 266 -48%

District of Columbia 341 196 -43%

Maine 772 416 -46%

Maryland 2,569 1,436 -44%

Massachusetts 2,428 1,377 -43%

New Hampshire 673 441 -34%

New Jersey 3,525 1,905 -46%

New York 6,961 3,957 -43%

Pennsylvania 5,292 2,972 -44%

Rhode Island 335 211 -37%

Vermont 368 202 -45%

Virginia 3,982 2,284 -43%

29,136 16,464 -43%

Exhibit 5.14 – 2007 NMIM SO2 Emissions by Category and State 

(tons/year) 
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Exhibit 5.15 – 2002 and 2007 NMIM/NONROAD VOC Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 33,519 20,721 -38%

Delaware 7,531 7,157 -5%

District of Columbia 2,053 1,324 -36%

Maine 30,741 29,880 -3%

Maryland 53,035 35,160 -34%

Massachusetts 54,836 35,676 -35%

New Hampshire 22,238 17,108 -23%

New Jersey 81,900 47,521 -42%

New York 155,463 114,935 -26%

Pennsylvania 99,241 86,397 -13%

Rhode Island 7,699 6,721 -13%

Vermont 10,520 10,339 -2%

Virginia 53,487 55,135 3%

612,262 468,074 -24%

Exhibit 5.16 – 2007 NMIM VOC Emissions by Category and State 

(tons/year) 
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6.0 ANNUAL 2007 INVENTORY FOR NONROAD SOURCES –

MARINE VESSELS, AIRPORTS, AND RAIL 

The Contractor estimated 2007 base year emissions for the Marine Vessel, Airports, and 

Rail (MAR) categories using USEPA/ERTAC data, USEPA/ERTAC data revised or 

augmented with state supplied data; or State supplied data. Data for each MAR category 

was obtained from USEPA and ERTAC for use as a default data set. The USEPA and 

ERTAC data, developed to support the 2008 inventory, was provided to states for review. 

State inventory personnel determined which of the above approaches was appropriate for 

their state. MARAMA coordinated the collection of supplemental or replacement data 

from states. The sections below describe the default data sources as well as the 

modifications received from states for each inventory segment. 

6.1 COMMERCIAL MARINE VESSELS 

For commercial marine vessels, data was obtained from USEPA 2008 NEI (USEPA 

2010d). Initial draft database files were provided to the Contractor by USEPA for 

Category 1 and 2 CMV and for Category 3 CMV. The Category 1 and 2 database 

contained emissions for both ports and underway vessels. 

The Category 3 database included tables containing emissions from approach, interport, 

port and RSZ. This database includes emissions from CMV operation within 12 nautical 

miles of shore. Emissions beyond the 12 nautical mile boundaries are not included in this 

inventory, but will be provided by USEPA to emission modelers in SMOKE format for 

inclusion in air quality modeling. These tables were matched to GIS ArcInfo shape files 

for use in plotting emissions. 

Several MARAMA States indicated that they had CMV emissions that they preferred over 

those provided by USEPA. However, these emissions were only available in NIF area 

source file format (county/SCC summary level) and not spatially allocated. Thus for 

consistency, the Contractor summarized the emissions from USEPA to the county/SCC 

level and input that data into a database format. In late December 2009, USEPA provided 

the Contractor with a final version of the CMV emissions summarized at the county/SCC 

level. The file was a Microsoft Access database (2008CMVCntySummary.mdb). That 

database contained a summary table containing the State/county FIPS code, the SCC, 

pollutant code and 2008 annual emissions (in tons). The Contractor used that database to 

update the NIF format database for those MARAMA States that had indicated that they 

wished to use the USEPA data. The USEPA 2008 NEI data was used directly for 2007. 
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No changes were made to the 2008 data for 2007 (i.e., the 2007 emissions were assumed to 

be equal to 2008). 

Four States (CT, DC, RI, VA) used the USEPA NEI data for all CMV categories. Virginia 

supplemented the USEPA CMV data by adding military vessels to the inventory. VT 

indicated that they wanted to use USEPA data but no CMV emissions were in the USEPA 

database for VT. Six States (DE, ME, MA, NH, NJ and PA) supplied State specific data 

for all categories. Maryland used USEPA NEI data for diesel CMV and State-specific data 

for residual CMV. New York used State-specific data for diesel CMV and upstate residual 

CMV, and USEPA NEI data for seven counties in the New York City metro area. 

Note that NY included VOC emissions from lightering operations in the CMV inventory 

using SCC 22-80-002-000. Delaware included VOC emissions from lightering operations 

in the point source inventory. No other State has significant lightering operations. 

Exhibit 6.1 indicates the data source by State and SCC for the emissions in the MARAMA 

2007 base year inventory for CMV. 

Exhibit 6.1 – Data Sources for Commercial Marine Vessel Inventory 

State

22-80-002-100

Diesel

Port

22-80-002-200

Diesel

Underway

22-80-003-100

Residual

Port

22-80-003-200

Residual

Underway

22-83-000-000

All Fuels

Military

CT EPA EPA EPA EPA n/a

DE State State State State n/a

DC n/a EPA n/a EPA n/a

ME State State State State n/a

MD EPA EPA State State n/a

MA State* State* State State n/a

NH State State State State n/a

NJ State State State State n/a

NY State State State / EPA State / EPA n/a

PA State State State State n/a

RI EPA EPA EPA EPA n/a

VT n/a n/a n/a n/a n/a

VA EPA EPA EPA EPA State

* MA used different SCCs that the other States for diesel CMV to identify Harbor vessels, fishing 

vessels, military vessels, port operations, and underway operation. 
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6.2 AIRPORTS (AIRCRAFT AND GROUND SUPPORT EQUIPMENT) 

For airport emissions, states either used their own data or a database developed by USEPA 

to support the 2008 NEI (USEPA2010e). The USEPA database was developed on an 

airport by airport basis. Data files provided included: 

EIS facility site ID 

State facility site ID Facility site name 

State and county FIPS code Source classification code 

Pollutant code 

Airport emissions and 

The sum of landing and take offs (LTOs). 

In addition, a database containing geographic information on each facility (latitude and 

longitude) along with operational information related to LTOs but contained no emissions 

data. 

For States that used the USEPA inventory the USEPA 2008 NEI airport data was 

summarized at the county/SCC level to provide a starting point. The remaining States 

provided NIF format county/SCC level files. Once the initial inventory was compiled it 

was formatted in NIF format and the resultant database was provided to the States for 

review and comment. Changes resulting from States comments were made to the initial 

inventory. 

Exhibit 6.2 indicates by State and SCC which components of the inventory came from 

different data sources. In those instances where the data source is listed as “EPA”, the data 

are taken directly from the 2008 NEI. 2008 data were used directly to represent 2007 

emissions. No changes to the 2008 data were applied for the 2007 base year inventory. 

Exhibit 6.2 also indicates that for a number of States, the emission estimates represent 

blended sources. For example, several of the States providing their own data only 

provided emission estimates for aircraft emissions but not emissions for ground support 

equipment (GSE) or auxiliary power units (APUs). For those States, 2008 USEPA NEI 

data were added to the inventory to provide those estimates. Those States were DE and 

ME. MD provided State supplied GSE/APU emissions but without a break down of the 

GSE emissions by fuel type. In addition, NY provided EDMS output files for all aircraft 

and GSE/APU emissions from each individual airport. Those emissions also had GSE 

emissions as a single value without an indication of the fuel type of the equipment. In both 

cases (NY and MD), the fuel type ratios used in the USEPA NEI were used to divide GSE 

emissions by fuel type. Those ratios were: 
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SCC SCC Level Two Fraction

2265008005 Off-highway Vehicle Gasoline, 4-Stroke 0.1686

2267008005 LPG 0.0165

2268008005 CNG 0.0131

2270008005 Off-highway Vehicle Diesel 0.8017

Finally, while Exhibit 6.2 indicates that most of VA’s emissions were derived from 

USEPA data, military aircraft operations emissions were provided by VA and were added 

to the USEPA data. However because these data were added as individual airports in 

counties where there were already emissions, when the data were summarized the data 

source was maintained as USEPA since the majority of emissions were derived from the 

USEPA inventory. 

For Version 3, the only changes were to use a revised airport inventory for New Jersey. 

Exhibit 6.2 – Data Sources for Airport Operations Inventory 

State

2265, 2267,

2268, 2270

GSE

2275001xxx

Military

2275020xxx

Commercial

2275050xxx

General 

Aviation

2275060xxx

Air Taxi

2275070xxx

APUs

CT State State State State State State

DE EPA State State State State EPA

DC n/a n/a n/a State n/a n/a

ME EPA State State State State EPA

MD State and 

EPA State State State State State and EPA

MA EPA EPA EPA EPA EPA EPA

NH State State State State State n/a

NJ State State State State State State 

NY State n/a State State n/a State

PA EPA EPA EPA EPA EPA EPA

RI EPA EPA EPA EPA EPA EPA

VT EPA EPA EPA EPA EPA EPA

VA EPA EPA EPA EPA EPA EPA
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6.3 RAILROAD LOCOMOTIVES AND RAILYARDS 

The ERTAC 2008 inventory for railroad locomotives and rail yards was provided to 

MANEVU+VA States for review to determine if the inventory should be included in the 

2007 base year emission inventory (ERTAC 2010a, ERTAC 2010b). The ERTAC rail 

inventory included three categories of locomotive emissions: Class I line-haul, Class I rail 

yard switchers, and Class II/III short line and regional railroads. The original files 

provided to the Contractor for the ERTAC inventory included several spreadsheets. There 

spreadsheets were: 

1. EmissionsByCounty_Round61.xls (county level Class I line haul emissions) 

2. EmissionsByState_Round61.xls (State level Class I line haul emissions) 

3. R-1 Fuel Use Data Summary 20072.xls (line haul fuel use data for 2007) 

4. Rail-Class_II_III_revised 4-20-2010.xls (Class II and III county level emissions by 

rail line, along with link, mileage, and fuel usage information) 

The data in the Class II and III spreadsheet was summarized by county and converted into 

NIF format. The Class I emissions were also converted into NIF format. Both Class I and 

Class II/III emissions were reported as hydrocarbons (HC). These emissions were 

converted to VOC emissions by multiplying the HC emissions by a factor of 1.053 

(USEPA 2009e) for all states except Maryland, where a factor of 1.0478 was used. In 

addition, all 2008 emissions were assumed to equal 2007 emissions. 

Three States (PA, VA and VT) used the ERTAC data directly without modification for the 

three categories included in the ERTAC inventory (Class I Line Haul, Class II/III Line 

Haul, Yard/Switcher Locomotives). New Jersey used the ERTAC Class I data and Statesupplied data for Class II/III and Yard locomotives. New York used the ERTAC yard 

locomotive data and State-supplied data for Class I and Class II/III. All other States made 

changes to the 2008 ERTAC inventory, either to add/modify included sources or to revise 

emission values to 2007 values. 

ERTAC did not develop emission estimates for Line Haul Passenger (AMTRAK) or Line 

Haul Commuter locomotives. Six States (CT, DC, MD, NY, PA, and VA) provided 

emission estimates for AMTRAK diesel locomotives. Note that the AMTRAK northeast 

corridor line uses electric powered locomotives, so there are no emissions from diesel 

AMTRAK locomotives in DE, NJ, RI, and MA. Seven States (CT, DC, MD, MA, NJ, 

NY, and PA) provided emission estimates for diesel commuter locomotives in their State. 
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Exhibit 6.3 provides a breakdown by State and SCC of the data sources for emissions from 

railroads and rail yards. Once the draft inventory was prepared the NIF database was 

provided to the MARAMA States for review. Only minor corrections were made to the 

database prior to submittal for stakeholder review and comments. 

Exhibit 6.3 – Data Sources for Railroad Locomotive and Railyard Inventory 

State

2285002006

Line Haul 

Class I Ops

2285002007

Line Haul 

Class II/III Ops

2285002008

Line Haul 

Passenger

2285002009

Line Haul 

Commuter

2285002010

Yard 

Locomotives

CT State State State State State

DE State State n/a n/a State

DC State n/a State State State

ME n/a State n/a n/a State

MD State State State State State

MA State State n/a State State

NH n/a State n/a n/a n/a

NJ EPA / ERTAC State n/a State State

NY State State State State EPA / ERTAC

PA EPA / ERTAC EPA / ERTAC State State EPA / ERTAC

RI State State n/a n/a State

VT EPA / ERTAC EPA / ERTAC n/a n/a n/a

VA EPA / ERTAC EPA / ERTAC State n/a EPA / ERTAC

6.4 STAKEHOLDER REVIEW AND COMMENT 

Draft inventory data files and documentation for MAR sources was posted on the 

MARAMA website in August 2010 for stakeholder review. No comments on the MAR 

inventory were received. 

6.5 VERSION 3 REVISIONS 

6.5.1 New Jersey MAR Revisions 

Following the completion of Version 2 of the 2007 MANE-VU+VA inventory in February 

2011, New Jersey provided several revisions to the MAR inventory, as follows: 
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developed a new airport inventory using the FAA’s EDMS; 

provided revised emission estimates for all commercial marine vessel categories; 

allocated GSE emissions calculated by EDMS to four fuel types (gasoline, LPG, 

CNG, and diesel) using the apportionment factors listed in Section 6.2. Previously 

in Version 2, all GSE fuel use was assigned to diesel engines. The revisions did 

not change the total GSE emissions, simply distributes the EDMS emissions over 

the four GSE fuel types. 

6.5.2 Adjustment of Rail VOC Emissions 

It was discovered that the ERTAC-reported rail emissions for VOC were actually 

hydrocarbon emissions. For locomotive engines, USEPA estimated that VOC emissions 

can be assumed to be equal to 1.053 times the hydrocarbon emissions (USEPA2009e). 

This adjustment was not made to the rail inventory developed by ERTAC. The ERTAC 

inventory assumed that VOC emissions equal hydrocarbon emissions. Some states (DE, 

NH, RI) made this adjustment in the rail inventories that were used in Version 2. The 

remaining states did not make the adjustment and the Version 2 VOC emissions were 

multiplied by 1.053 to generated revised emissions for Version 3. Maryland made a partial 

adjustment in Version 2, and specified that a factor of 1.0478 should be used to adjust 

6.6 SUMMARY OF MAR INVENTORY FOR 2007 

Exhibits 6.4 to 6.10 compare the 2002 and 2007 emissions by State and pollutant for MAR 

sources. The 2002 emissions are those that were developed previously for Version 3 of the 

MANE-VU and the VISTAS best-and-final inventory for Virginia. It is likely that many 

of the differences between the 2002 and 2007 emissions are due to changes in the emission 

estimation methodologies for CMV, airports, and railroads. 

CO emissions are primarily from aircraft and GSE engines used at airports. CMV is the 

largest sector for NOx emissions, but there are also substantial NOx emissions from 

airports and railroad locomotives. SO2 emissions are primarily from the CMV category. 

All three sectors also generate PM and VOC emissions. 
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Exhibit 6.4 – 2002 and 2007 MAR CO Emissions by State (tons/year) 

Marine Vessels Airports Rail Locomotives

STATE 2002 2007 Change 2002 2007 Change 2002 2007 Change

CT 603 1,077 79% 1,565 4,659 198% 362 184 -49%

DE 1,138 554 -51% 1,575 1,625 3% 144 75 -48%

DC 1 1 1% 0 14 n/a 73 73 0%

ME 376 522 39% 4,487 32,879 633% 69 188 173%

MD 431 2,795 548% 11,575 10,265 -11% 789 700 -11%

MA 1,231 1,473 20% 11,294 15,495 37% 748 646 -14%

NH 169 89 -47% 2,031 2,089 3% 71 88 24%

NJ 1,424 1,619 14% 29,375 21,878 -26% 580 665 15%

NY 1,790 3,475 94% 11,895 17,403 46% 1,551 3,061 97%

PA 1,111 1,294 16% 24,799 26,540 7% 3,359 2,987 -11%

RI 0 522 n/a 1,424 1,739 22% 55 15 -73%

VT 0 0 n/a 521 2,420 365% 20 72 262%

VA 1,082 3,735 245% 11,873 22,009 85% 1,186 2,701 128%

9,356 17,155 83% 112,414 159,016 41% 9,007 11,456 27%
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Exhibit 6.5 – 2002 and 2007 MAR NH3 Emissions by State (tons/year) 

Marine Vessels Airports Rail Locomotives

STATE 2002 2007 Change 2002 2007 Change 2002 2007 Change

CT 0 3 n/a 0 0 n/a 0 1 n/a

DE 0 0 n/a 0 0 n/a 0 0 n/a

DC 0 0 n/a 0 0 n/a 0 0 n/a

ME 0 0 n/a 0 0 n/a 0 0 n/a

MD 0 8 n/a 0 0 n/a 0 0 n/a

MA 0 0 n/a 0 0 n/a 0 2 n/a

NH 0 0 n/a 0 0 n/a 0 0 n/a

NJ 0 8 n/a 0 0 n/a 0 2 n/a

NY 0 2 n/a 0 0 n/a 0 0 n/a

PA 0 13 n/a 0 0 n/a 0 9 n/a

RI 0 1 n/a 0 0 n/a 0 0 n/a

VT 0 0 n/a 0 0 n/a 0 0 n/a

VA 0 9 n/a 0 0 n/a 0 8 n/a

0 44 n/a 0 0 n/a 0 23 n/a
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Exhibit 6.6 – 2002 and 2007 MAR NOx Emissions by State (tons/year) 

Marine Vessels Airports Rail Locomotives

STATE 2002 2007 Change 2002 2007 Change 2002 2007 Change

CT 4,577 6,528 43% 415 713 72% 2,612 1,723 -34%

DE 8,362 5,094 -39% 970 805 -17% 1,105 384 -65%

DC 4 6 56% 0 0 n/a 502 505 1%

ME 1,154 1,659 44% 184 134 -27% 269 1,369 409%

MD 2,531 16,027 533% 2,038 1,910 -6% 5,145 4,767 -7%

MA 2,590 3,246 25% 2,988 3,190 7% 7,161 6,133 -14%

NH 1,284 271 -79% 162 278 72% 332 891 169%

NJ 10,981 11,197 2% 4,739 5,105 8% 5,721 5,957 4%

NY 12,266 28,180 130% 4,880 6,998 43% 14,162 20,675 46%

PA 8,217 11,378 38% 4,131 3,738 -10% 29,292 20,675 -29%

RI 1 2,829 n/a 263 289 10% 186 144 -22%

VT 0 0 n/a 48 103 114% 7 736 10416%

VA 3,088 21,760 605% 3,885 5,520 42% 11,882 18,319 54%

55,055 108,174 96% 24,703 28,783 17% 78,376 82,279 5%
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Exhibit 6.7 – 2002 and 2007 MAR PM10-PRI Emissions by State (tons/year) 

Marine Vessels Airports Rail Locomotives

STATE 2002 2007 Change 2002 2007 Change 2002 2007 Change

CT 194 311 61% 45 66 46% 5 46 812%

DE 393 327 -17% 28 27 -5% 31 15 -50%

DC 0 0 n/a 0 0 n/a 12 12 -2%

ME 129 395 206% 97 83 -15% 8 28 246%

MD 637 657 3% 1,012 74 -93% 172 166 -3%

MA 217 316 45% 246 295 20% 183 159 -13%

NH 54 13 -76% 49 37 -24% 10 22 120%

NJ 796 622 -22% 280 170 -39% 143 160 12%

NY 506 1,671 230% 409 140 -66% 358 608 70%

PA 253 524 107% 2,421 396 -84% 792 704 -11%

RI 0 112 n/a 93 22 -76% 6 4 -40%

VT 0 0 n/a 12 46 282% 1 18 1712%

VA 359 946 164% 2,010 821 -59% 1,529 634 -59%

3,538 5,895 67% 6,702 2,176 -68% 3,250 2,574 -21%
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Exhibit 6.8 – 2002 and 2007 MAR PM25-PRI Emissions by State (tons/year) 

Marine Vessels Airports Rail Locomotives

STATE 2002 2007 Change 2002 2007 Change 2002 2007 Change

CT 178 296 66% 38 51 35% 5 39 686%

DE 354 305 -14% 20 19 -7% 28 15 -47%

DC 0 0 n/a 0 0 n/a 11 11 4%

ME 119 364 205% 69 61 -11% 8 25 218%

MD 637 606 -5% 698 16 -98% 155 161 4%

MA 200 290 45% 226 215 -5% 143 145 2%

NH 50 12 -76% 36 27 -24% 9 21 132%

NJ 732 575 -21% 195 143 -27% 128 147 15%

NY 466 1,541 231% 362 139 -62% 323 572 77%

PA 232 484 109% 1,718 294 -83% 713 650 -9%

RI 0 108 n/a 68 17 -75% 5 3 -34%

VT 0 0 n/a 9 32 259% 1 17 1567%

VA 330 908 175% 1,970 580 -71% 1,375 586 -57%

3,298 5,489 66% 5,409 1,595 -71% 2,904 2,395 -18%
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Exhibit 6.9 – 2002 and 2007 MAR SO2 Emissions by State (tons/year) 

Marine Vessels Airports Rail Locomotives

STATE 2002 2007 Change 2002 2007 Change 2002 2007 Change

CT 671 1,386 107% 39 96 145% 4 57 1323%

DE 3,377 2,079 -38% 30 55 84% 64 5 -92%

DC 1 1 30% 0 0 n/a 33 37 11%

ME 128 189 47% 3 14 376% 15 92 514%

MD 4,739 2,170 -54% 262 247 -6% 374 64 -83%

MA 489 698 43% 284 218 -23% 591 66 -89%

NH 188 506 169% 15 28 86% 16 10 -36%

NJ 11,444 6,712 -41% 374 507 35% 352 55 -84%

NY 4,753 9,321 96% 440 699 59% 765 616 -19%

PA 297 3,067 933% 399 416 4% 1,934 211 -89%

RI 0 632 n/a 29 30 3% 14 5 -61%

VT 0 0 n/a 5 12 134% 1 5 412%

VA 386 4,058 951% 272 424 56% 3,641 192 -95%

26,473 30,819 16% 2,152 2,746 28% 7,804 1,416 -82%
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Exhibit 6.10 – 2002 and 2007 MAR VOC Emissions by State (tons/year) 

Marine Vessels Airports Rail Locomotives

STATE 2002 2007 Change 2002 2007 Change 2002 2007 Change

CT 143 161 13% 115 509 343% 114 73 -36%

DE 132 158 20% 290 620 114% 60 28 -53%

DC 0 0 n/a 0 1 n/a 20 34 70%

ME 166 233 41% 222 161 -27% 19 51 166%

MD 74 371 401% 2,920 1,365 -53% 312 271 -13%

MA 433 528 22% 1,177 1,129 -4% 312 267 -15%

NH 40 23 -43% 88 134 53% 15 35 136%

NJ 413 658 59% 2,281 2,438 7% 221 258 17%

NY 424 1,905 349% 1,145 1,571 37% 600 1,112 85%

PA 703 538 -23% 1,155 2,813 144% 1,260 1,153 -8%

RI 0 64 n/a 74 112 51% 10 8 -22%

VT 0 0 n/a 27 204 655% 2 29 1331%

VA 531 522 -2% 2,825 2,764 -2% 492 1,025 108%

3,059 5,163 69% 12,319 13,822 12% 3,437 4,343 26%
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7.0 ANNUAL 2007 INVENTORY FOR ONROAD SOURCES 

7.1 OVERALL PROCESS TO DEVELOP THE ONROAD INVENTORY 

EPA’s recently released MOVES2010 (MOtor Vehicle Emission Simulator) is now the 

official model for estimating air pollution emissions from onroad mobile sources including 

buses, cars, trucks and motorcycles. MOVES2010 replaces MOBILE6.2, the previous 

mobile source model. MOVES input files are somewhat more detailed than the 

MOBILE6.2 input files. To assist in the transition to the new model, USEPA developed 

software tools to convert MOBILE6.2 inputs for MOVES. In addition, the MOVES model 

includes a preprocessing tool called the County Data Manager (CDM) to convert 

spreadsheet based information to MySQL database files required by MOVES. 

States were offered the option of having NESCAUM perform the MOVES modeling using 

input data provided by and/or reviewed by the state. Three states elected to perform the 

MOVES modeling for their state using in-house resources. Exhibit 7.1 shows the approach 

selected by each state: 

Exhibit 7.1 – MOVES Modeling Approach by State 

States Providing MOBILE6.2 

Input Files to NESCAUM

States Providing MOVES 

Input Files to NESCAUM

States Performing MOVES 

Modeling Themselves

DC, ME, NH, RI CT, DE, MD, MA, NJ, VT NY, PA, VA

7.2 MOVES MODEL RUN SPECIFICATIONS AND DOCUMENTATION 

Appendix F contains NESCAUM’s documentation of the MOVES modeling. 

7.3 SUMMARY OF ONROAD INVENTORY 

Exhibits 7.2 to 7.8 compare the 2002 and 2007 onroad emissions by state for each 

pollutant. The 2002 emissions were estimated using MOBILE6, while the 2007 emissions 

were estimated using MOVES. Differences between 2002 and 2007 results from the 

change in emission estimation methodologies (MOBILE6 vs. MOVES), VMT growth, and 

turnover of the vehicle fleet to newer, cleaner fuels and engines. 
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Exhibit 7.2 – 2002 and 2007 OnroadCO Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 562,124 365,925 -35%

Delaware 160,760 124,893 -22%

District of Columbia 66,018 36,379 -45%

Maine 410,958 215,689 -48%

Maryland 1,000,763 598,180 -40%

Massachusetts 1,039,100 583,234 -44%

New Hampshire 306,793 195,916 -36%

New Jersey 1,273,513 719,402 -44%

New York 3,711,150 2,024,775 -45%

Pennsylvania 2,784,197 1,962,326 -30%

Rhode Island 186,197 115,532 -38%

Vermont 248,248 115,532 -53%

Virginia 1,858,598 1,195,237 -36%

13,608,417 8,253,020 -39%

2002 emissions were estimated using MOBILE6; 2007 emissions were estimated using MOVES 
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Exhibit 7.3 – 2002 and 2007 Onroad NH3 Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 3,294 1,309 -60%

Delaware 903 406 -55%

District of Columbia 398 158 -60%

Maine 1,468 605 -59%

Maryland 5,594 2,335 -58%

Massachusetts 5,499 2,194 -60%

New Hampshire 1,447 511 -65%

New Jersey 7,382 3,216 -56%

New York 14,681 6,831 -53%

Pennsylvania 10,532 5,278 -50%

Rhode Island 853 356 -58%

Vermont 934 356 -62%

Virginia 7,918 4,041 -49%

60,902 27,597 -55%

2002 emissions were estimated using MOBILE6; 2007 emissions were estimated using MOVES
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Exhibit 7.4 – 2002 and 2007 Onroad NOx Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 68,816 53,814 -22%

Delaware 21,341 24,456 15%

District of Columbia 8,902 8,714 -2%

Maine 54,687 36,844 -33%

Maryland 122,210 114,792 -6%

Massachusetts 143,368 73,328 -49%

New Hampshire 33,283 33,858 2%

New Jersey 152,076 135,139 -11%

New York 319,733 305,617 -4%

Pennsylvania 346,472 353,083 2%

Rhode Island 16,677 18,055 8%

Vermont 20,670 18,055 -13%

Virginia 182,482 197,822 8%

1,490,716 1,373,575 -8%

2002 emissions were estimated using MOBILE6; 2007 emissions were estimated using MOVES
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Exhibit 7.5 – 2002 and 2007 Onroad PM10-PRI Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 1,580 2,057 30%

Delaware 581 828 42%

District of Columbia 222 387 74%

Maine 1,239 1,507 22%

Maryland 3,168 4,103 29%

Massachusetts 3,408 2,915 -14%

New Hampshire 814 1,479 82%

New Jersey 3,725 5,013 35%

New York 8,457 14,765 75%

Pennsylvania 7,351 12,947 76%

Rhode Island 345 754 118%

Vermont 670 754 13%

Virginia 4,358 6,799 56%

35,920 54,307 51%

2002 emissions were estimated using MOBILE6; 2007 emissions were estimated using MOVES
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Exhibit 7.6 – 2002 and 2007 Onroad PM25-PRI Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 1,042 1,949 87%

Delaware 415 795 91%

District of Columbia 153 373 144%

Maine 934 1,443 54%

Maryland 2,200 3,924 78%

Massachusetts 2,410 2,768 15%

New Hampshire 562 1,418 152%

New Jersey 2,469 4,789 94%

New York 5,898 14,115 139%

Pennsylvania 5,331 12,393 132%

Rhode Island 211 719 241%

Vermont 483 719 49%

Virginia 2,987 6,499 118%

25,095 51,903 107%

2002 emissions were estimated using MOBILE6; 2007 emissions were estimated using MOVES
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Exhibit 7.7 – 2002 and 2007 NMIM/NONROAD SO2 Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 1,667 402 -76%

Delaware 584 202 -65%

District of Columbia 271 89 -67%

Maine 1,804 377 -79%

Maryland 4,058 936 -77%

Massachusetts 4,399 769 -83%

New Hampshire 777 275 -65%

New Jersey 3,649 921 -75%

New York 10,640 2,187 -79%

Pennsylvania 10,924 2,518 -77%

Rhode Island 425 179 -58%

Vermont 894 179 -80%

Virginia 6,086 1,435 -76%

46,176 10,468 -77%

2002 emissions were estimated using MOBILE6; 2007 emissions were estimated using MOVES
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Exhibit 7.8 – 2002 and 2007 Onroad VOC Emissions by State (tons/year) 

STATE 2002 2007 Change

Connecticut 31,755 35,363 11%

Delaware 10,564 10,771 2%

District of Columbia 4,895 3,598 -27%

Maine 23,037 15,382 -33%

Maryland 61,847 57,789 -7%

Massachusetts 57,186 51,149 -11%

New Hampshire 16,762 13,650 -19%

New Jersey 89,753 73,624 -18%

New York 287,845 163,290 -43%

Pennsylvania 176,090 168,289 -4%

Rhode Island 12,538 9,780 -22%

Vermont 17,288 9,780 -43%

Virginia 114,994 108,001 -6%

904,554 720,465 -20%

2002 emissions were estimated using MOBILE6; 2007 emissions were estimated using MOVES 
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8.0 PREPARATION OF SMOKE MODEL FILES 

Air quality modelers in the Mid-Atlantic and Northeastern States use the SMOKE 

Modeling System to create gridded, speciated, hourly emissions for input into a variety of 

air quality models. This section describes how the SMOKE inventory files were 

developed. It also describes how the SMOKE the temporal allocation, speciation, and 

spatial allocation profiles, respectively, were developed. 

8.1 PREPARATION OF SMOKE EMISSION FILES 

8.1.1 Point Source SMOKE Emission Files 

Annual point source inventories were prepared in SMOKE PTINV ORL format. As 

previously discussed in Section 3.2.1, PTINV files were created for the following types of 

sources: 

Annual emissions for units that reported hourly data to USEPA CAMD for the 

entire 12 months of 2007; 

Ozone season emissions for units that reported hourly emissions to USEPA CAMD 

for either 6 or 9 months of 2007 (except for 6 month reporting units in Maryland); 

Non-ozone season emissions for units that reported hourly emissions to USEPA 

CAMD for either 6 or 9 months of 2007 (except for 6 month reporting units in 

Maryland); 

Units that reported hourly emissions to USEPA CAMD for either 6 or 9 months of 

2007 in Maryland; 

Units that are classified as distributed generation units by VDEQ; and 

All other units (these are not associated with the hourly PTHOUR files; temporal 

allocation for these units will be accomplished using the standard SMOKE V2.6 

temporal allocation profiles). 

The ORL were quality assured to conform to the SMOKE PTINV ORL format and to 

prevent double counting of emissions in the ORL files. 

EPA has developed a methodology to reduce fugitive dust emissions for use in air quality 

modeling analyses (USEPA 2007b). It is considered a logical step to account for the 

removal of particles near their emission source by vegetation and surface features. For the 

MANEVU+VA 2007 inventory the transport factors were NOT applied to the point source 

inventory because of the very small amount of fugitive particulate emissions in the point 

source inventory. 

Hourly point source inventories were prepared for units that report hourly emissions to 

USEPA’s Clean Air Markets Division in SMOKE PTHOUR EMS-95 format. Because of 
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the large size of the PTHOUR files, separate files were prepared by month. As previously 

discussed in Section 3.2.1, the following PTHOUR files were created: 

12 monthly PTHOUR files for units that reported hourly emissions to USEPA 

CAMD for the entire 12 months of 2007; 

5 monthly PTHOUR files (May-September) for units that reported hourly 

emissions to USEPA CAMD only for the ozone season 2007; 

12 monthly PTHOUR files for units in Maryland that reported hourly emissions to 

USEPA CAMD for the either 6 or 9 months of 2007; and 

12 monthly PTHOUR files for units in Virginia that are classified as distributed 

generations units 

Since some CAMD units only report hourly emissions data for the ozone season, there was 

a need for a set of actual 2007 hourly temporal profiles to be used in simulating hourly 

emissions for these units in non-ozone season months. Section 3.4 of this TSD discusses 

the development of the SMOKE temporal profiles for the non-ozone season months for 

these units. 

8.1.2 Area Source SMOKE Emission Files 

Annual area source inventories were prepared in SMOKE ARINV ORL format. In 

developing the SMOKE ARINV ORL files for area sources, the USEPA “transport factor” 

was applied to reduce fugitive dust emissions to account for the removal of particles near 

their emission source by vegetation and surface features. The transport factor was NOT 

applied to the NIF-formatted annual emissions, but only to the SMOKE ARINV ORLformatted file. 

The standard transport fractions and SCC assignments from the USEPA CHIEF website 

were used to reduce the PM10-PRI and PM25-PRI emissions in the MANEVU+VA 2007 

area source inventory. Two files were used. The first file contains a list of SCCs for 

which the transport factor was applied. The major source categories included paved and 

unpaved roads, construction activity, agricultural crop land tilling, and agricultural 

livestock operations. The second file contains the transport factor which varies by county. 

For example, in Connecticut the transport factors ranges from 0.21 in Tolland County to 

0.44 in New Haven County. 

Applying the transport factor to area source fugitive dust emissions significantly reduces 

that amount of particulate matter included in the air quality modeling. Exhibit 8.1 

compares the 2007 area source PM10-PRI and PM25-PRI emissions before and after the 

application of the transport fraction. Region wide, PM10-PRI emissions are reduced by 53 

percent and PM25-PRI emissions are reduced by 29 percent by applying the transport 
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fraction. The percent reduction varies by State due to the relative importance of the area 

source fugitive dust emissions compared to non-fugitive dust source emissions. The 

bottom part of Exhibit 8.1 shows the key area source fugitive dust categories and the 

reductions applied by using the transport fraction. 

Exhibit 8.1 – Comparison of 2007 Area Source Emissions With and Without the 

Application of the Fugitive Dust Transport Factor (tons/year) 

PM10-PRI PM25-PRI

State/SCC

Without

Transport 

Factor

With 

Transport 

Factor

Percent 

Reduction

Without 

Transport 

Factor

With 

Transport 

Factor

Percent 

Reduction

Emissions by State for All Area Source SCCs

CT 30,577 15,591 49 10,606 8,396 21

DE 10,499 7,208 31 3,031 2,407 21

DC 4,873 2,445 50 1,542 1,120 27

ME 54,445 20,227 63 12,526 8,744 30

MD 72,454 38,520 47 19,789 14,710 26

MA 148,756 58,380 61 30,438 18,621 39

NH 27,742 10,650 62 8,623 5,832 32

NJ 39,140 24,801 37 18,299 14,944 18

NY 272,674 140,760 48 63,906 47,023 26

PA 287,998 138,571 52 73,514 50,855 31

RI 11,361 5,553 51 3,896 2,957 24

VT 47,993 19,097 60 13,106 9,434 28

VA 183,341 78,204 57 44,102 29,533 33

All States and 

SCCs 1,191,853 560,007 53 303,378 214,576 29

MANE-VU+VA Emissions for Selected SCCs

2294000000

Paved Roads 230,004 78,795 66 54,207 18,727 65

2296000000

Unpaved 

Roads

417,951 129,150 69 41,525 12,837 69

2311xxxxxxx

Construction 205,811 74,598 64 20,934 7,585 64

2801000003

Ag. Tilling 94,443 33,949 64 17,789 6,511 64
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8.1.3 Nonroad NMIM SMOKE Emission Files 

As discussed in Section 5, the NMIM/NONROAD model was executed using 

specifications to generate monthly emission files. Monthly SMOKE ARINV ORL files 

were created. Average day emissions were calculated by dividing the NONROAD 

generated monthly emissions by the number of days in each month. Various summary 

reports were prepared to verify agreement between the average day, monthly, and annual 

emissions. 

8.1.4 Nonroad MAR SMOKE Emission Files 

Annual inventories for marine vessels, airport operations and railroad locomotives were 

prepared in SMOKE ARINV ORL format for each county in the region. Average day 

emissions were calculated by dividing the annual emissions by 365 days. The ORL files 

for Category 3 commercial marine vessels include only the emissions that occur in State 

waters (generally from the shoreline to 3–10 nautical miles from shore). 

8.1.5 Onroad SMOKE Emission Files 

Smoke emission files for the onroad sector are being developed by NESCAUM under a 

separate contract. Please contact NESCAUM for documentation and data files. 

8.1.1 Biogenic SMOKE Emission Files 

Smoke emission files for the biogenic sector are being developed by New Jersey and New 

York under separate efforts. Please contact MARAMA to obtain documentation and data 

files for biogenic sources. 

8.1.1 SMOKE Emission Files for Areas Outside of the MANE-VU+VA Region 

Smoke emission files for areas outside of the MANE-VU+VA are currently under 

development. Contact MARAMA for further information. 

8.2 REVIEW OF SMOKE AUXILIARY FILES 

The following activities were performed to quality assure and improve the SMOKE 

speciation, spatial and temporal profiles: 

QA checks were made to ensure that all SCCs in the annual emission inventory 

files are cross-referenced to SCCs in the SMOKE profiles. In cases where a proper 

cross-reference does not exist, the SMOKE files were updated using data for 

similar SCCs or as otherwise determined on a case-by-case basis. 
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SMOKE temporal profiles were reviewed and documented for key categories. 

Recommendations for improving SMOKE temporal profiles were made for 

categories where improved data is available and are reasonable feasible to use. 

SMOKE spatial profiles were reviewed and documented for selected categories. 

Recommendations for improving SMOKE spatial profiles were made for categories 

where improved data is available and are reasonable feasible to use. 

Each of these activities is documented in Appendix F of this TSD. 

8.2.1 SMOKE Speciation Files 

Based upon the review of Appendix F by SMOKE emission modelers in the Northeast / 

Mid-Atlantic region, MARAMA directed the Contractor to make the following changes to 

the SMOKE auxiliary files as recommended in Appendix F. 

GSREF Speciation Cross-Reference File 

Added records for SCC/pollutant code combinations in the 2007 inventory that 

needed to be added to the GSREF file 

GSPRO Speciation Profiles 

No changes were needed 

8.2.2 SMOKE Spatial Allocation Files 

Based upon the review of Appendix F by SMOKE emission modelers in the Northeast / 

Mid-Atlantic region, MARAMA directed the Contractor to make the following changes to 

the SMOKE auxiliary files as recommended in Appendix F. 

AMGREF Spatial Allocation Cross-Reference File

Added records for SCCs in the 2007 inventory that needed to be added to the 

AMGREF file 

SRGDESC Spatial Surrogate Code Descriptions 

No changes were needed 

To spatially allocate county-level emissions from airports, SMOKE modelers will use the 

SMOKE ARTOPNT file to allocate county-level to specific point source airport locations 

instead of being assigned spatial surrogates. We reviewed this SMOKE file and confirmed 

the county-level commercial aircraft emissions are being allocated to the location of the 
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large airport in the county. The only adjustment to the SMOKE ARTOPNT file was as 

follows: 

Changed the allocation factors for commercial aircraft (SCCs 2275000000, 

2275020000, and 2275070000) in Queens County NY to allocate county-level 

commercial aircraft emissions to JFK Airport and LaGuardia airport based on the 

2008 LTO data from USEPA’s 2008 emission inventory 

Emissions for Category 3 commercial marine vessels will be spatially allocated using the 

following procedures: 

For operations from shoreline to roughly 3-10 nautical miles from the shore, the 

county-level Category 3 emissions prepared by States will be allocated to grid cells 

using the SMOKE spatial allocation files (profile 800 {Marine Ports} for port 

emissions, profile 810 {Navigable Waterway Activity} for underway emissions); 

For operations outside of State waters (generally 10-200 nautical miles from shore) 

Northeast / Mid-Atlantic emission modelers will use a Category C3 ORL files 

(ptinv_eca_imo_fixFIPS_US_caps_2005_19OCT2010_orl.txt) generated by EPA 

for 2005. The SMOKE modelers will zero out the emissions that have been 

assigned to counties to avoid double counting of emissions with the State-provided 

emissions discussed in the previous bullet. 

See Appendix F for a further discussion of the Category 3 spatial allocation issue. 

8.2.3 SMOKE Temporal Allocation Files 

Based upon the review of Appendix F by SMOKE emission modelers in the Northeast / 

Mid-Atlantic region, MARAMA directed the Contractor to make the following changes to 

the SMOKE auxiliary files as recommended in Appendix F. 

AMPTREF Temporal Cross-Reference File 

Added records for SCCs in the 2007 inventory that needed to be added to the 

AMPTREF file 

Changed the monthly allocation code for commercial aircraft (SCC 2275000000) 

and auxiliary power units (SCC 2275070000) from 246 to 99246 (the new profile 

code that uses the Bureau of Transportation Statistics {BLS} monthly air travel 

data for 2007) 
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Changed the day-of-week allocation code for commercial aircraft (SCC 

2275000000) and auxiliary power units (SCC 2275070000) from 7 to 99007 (the 

new profile code that uses the BLS day-of-week air travel data for 2007) 

Changed the hour-of-day allocation code for commercial aircraft (SCC 

2275000000) and auxiliary power units (SCC 2275070000) from 26 to 99026 (the 

new profile code that uses the BLS hour-of-day air travel data for 2007) 

Changed the monthly allocation code for SCCs 22-80-003-100 (CMV/Residual/ 

Port) and 22-80-003-200 (CMV/Residual/Underway) from 262 to 19531, which is 

the code the EPA recently developed for their C3 inventory 

AMPTPRO Temporal Allocation Profiles 

Added the monthly allocation code of 99246 (the new profile code that uses the 

Bureau of Transportation Statistics {BLS} monthly air travel data for 2007) 

Added the day-of-week allocation code of 99007 (the new profile code that uses the 

BLS day-of-week air travel data for 2007) 

Added the hour-of-day allocation code of 99026 (the new profile code that uses the 

BLS hour-of-day air travel data for 2007) 
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9.0 FINAL DELIVERABLES 

Exhibits 9.1 and 9.2 identify all of the deliverable products for the 2007 MANE-VU+VA 

emission inventory developed by the Contractor under this contract. The exhibit also 

identifies deliverables associated with the 2007 MANE-VU+VA under development by 

other agencies. 

All files are stored on MARAMA ftp site: 

Address: ftp.marama.org 

Login ID: regionalei 

Password: marama2007 

Files are stored in the following directories: 

\MARAMA 07-17-20 Version 3\Final 2007 (Version 3_3)\NIF 

\MARAMA 07-17-20 Version 3\Final 2007 (Version 3_3)\SMOKE 

\MARAMA 07-17-20 Version 3\Final 2007 (Version 3_3)\TSD 

\MARAMA 07-17-20 Version 3\Final 2007 (Version 3_3)\XLS 

The deliverables are described in 9.1 and 9.2. 
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 132

Exhibit 9.1 – NIF Data and Emission Summary Files for the 2007 MANE-VU+VA Emission Inventory 

File Description File Name Format Notes

2007 Annual Point Source Emission 

Inventory in NOF format

MANEVU+VA_V3_3_Point_2007_NOF.mdb NOF 

ACCESS

EP table modified to include fields 

to (1) identify units as CAMDEGU, CAMD-nonEGU, and 

OTHER; (2) include the CAMD 

ORIS and UNITID for CAMD 

units; and (3) identify the percent 

operating time classification for 

CAMD units.

See file for Field Definitions

2007 Annual Area Source Emission 

Inventory in NOF format

MANEVU+VA_V3_3_Area_2007_NOF.mdb NOF 

ACCESS

See file for Field Definitions

2007 Annual NMIM/NONROAD 

Source Emission Inventory in NOF 

format

2007MARAMANRNMIMv3.mdb NOF 

ACCESS

See file for Field Definitions. 

2007 Annual Commercial Marine 

Vessel, Airport, and Rail (MAR)

Emission Inventory in NOF format

MANEVU+VA_V3_3_MAR_2007.mdb NOF 

ACCESS

See file for Field Definitions

2007 Annual Point Source Emission 

Inventory in a spreadsheet format to 

facilitate State and Stakeholder review

MANEVU+VA_V3_3_Point_2007_Process_Emissions.xls MS Excel See file for Column Definitions

2007 Annual Point Source Emission 

Inventory summaries by State and 

Source Classification Code (SCC)

MANEVU+VA_V3_3_Point_2007_State_SCC_Summary.xls MS Excel See file for Column Definitions

2007 Annual Area Source Emission 

Inventory summaries by State/SCC

MANEVU+VA_V3_3_Area_2007_State_SCC_Summary.xls MS Excel See file for Column Definitions

2007 Annual NMIM/NONROAD 

Emission Inventory summaries by 

State and SCC

MANEVU+VA_V3_3_NMIM_2007_State_SCC_Summary.xls MS Excel See file for Column Definitions. 

2007 Annual MAR Emission Inventory 

summaries by State and SCC

MANEVU+VA_V3_3_MAR_2007StateSCCSummaries.xls MS Excel See file for Column Definitions
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 133 

Exhibit 9.2 – SMOKE Files for the 2007 MANE-VU+VA Emission Inventory 

File Description File Name Format Notes

2007 Annual Point Source 

Emission Inventory in 

SMOKE ORL format

PTINV_2007_NonHourly_jan2012.orl

PTINV_2007_12MonthUnits_feb2011.orl

PTINV_2007_Ozone_5MonthUnits_feb2011.orl

PTINV_2007_NonOzone_5MonthUnits_feb2011.orl

PTINV_2007_VADGUnits_march2010.orl

PTINV_2007_MD6MonthUnits_march2010.orl

SMOKE 

PTINV

ORL

One file for all non-hourly units 

and five separate files for units 

with hourly emissions. See 

Section 3.2.1 for the TSD for 

discussion of the files and Exhibit 

3.1 for the file format.

SMOKE PTHOUR EMS-95 

zip files with hourly emissions 

for each month of 2007 for 

units that report hourly 

emissions to CAMD for the 

entire 12 months in 2007. The 

zip file contains 12 monthly

files.

pthour_2007_jan_12MonthUnits_nov2011.ems 

pthour_2007_feb_12MonthUnits_nov2011.ems 

pthour_2007_mar_12MonthUnits_nov2011.ems 

pthour_2007_apr_12MonthUnits_nov2011.ems 

pthour_2007_may_12MonthUnits_nov2011.ems 

pthour_2007_jun_12MonthUnits_nov2011.ems 

pthour_2007_jul_12MonthUnits_nov2011.ems 

pthour_2007_aug_12MonthUnits_nov2011.ems 

pthour_2007_sep_12MonthUnits_nov2011.ems 

pthour_2007_oct_12MonthUnits_nov2011.ems 

pthour_2007_nov_12MonthUnits_nov2011.ems

pthour_2007_dec_12MonthUnits_nov2011.ems

SMOKE 

PTHOUR

EMS-95

See Exhibit 3.2 for file format

SMOKE PTHOUR EMS-95 

files with hourly emissions for 

5 months of 2007 for units 

classified as “5-month 

reporters” in all States except 

MD. The zip file contains 5 

monthly files.

pthour_2007_may_5MonthUnits_Jan2012.ems 

pthour_2007_jun_5MonthUnits_Jan2012.ems 

pthour_2007_jul_5MonthUnits_Jan2012.ems 

pthour_2007_aug_5MonthUnits_Jan2012.ems 

pthour_2007_sep_5MonthUnits_Jan2012.ems

SMOKE 

PTHOUR

EMS-95

See Exhibit 3.2 for file format

SMOKE PTHOUR EMS-95 

files with hourly emissions for 

each month of 2007 for units 

classified as “6-month 

reporters” in MD. The zip file 

contains 12 monthly files.

pthour_2007_jan_MD6MonthUnits_march2010.ems 

pthour_2007_feb_MD6MonthUnits_march2010.ems 

pthour_2007_mar_MD6MonthUnits_march2010.ems 

pthour_2007_apr_MD6MonthUnits_march2010.ems 

pthour_2007_may_MD6MonthUnits_march2010.ems 

pthour_2007_jun_MD6MonthUnits_march2010.ems 

pthour_2007_jul_MD6MonthUnits_march2010.ems 

pthour_2007_aug_MD6MonthUnits_march2010.ems 

pthour_2007_sep_MD6MonthUnits_march2010.ems 

SMOKE 

PTHOUR

EMS-95

See Exhibit 3.2 for file format
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 134 

File Description File Name Format Notes

pthour_2007_oct_MD6MonthUnits_march2010.ems 

pthour_2007_nov_MD6MonthUnits_march2010.ems

pthour_2007_dec_MD6MonthUnits_march2010.ems

SMOKE PTHOUR EMS-95 

files with hourly emissions for 

each month of 2007 for units 

classified as “distributed 

generation units” by the 

Virginia DEQ. The zip file 

contains 12 monthly files.

pthours_2007_jan_VADGunits_march2010.ems 

pthours_2007_feb_VADGunits_march2010.ems 

pthours_2007_mar_VADGunits_march2010.ems 

pthours_2007_apr_VADGunits_march2010.ems 

pthours_2007_may_VADGunits_march2010.ems 

pthours_2007_jun_VADGunits_march2010.ems 

pthours_2007_jul_VADGunits_march2010.ems 

pthours_2007_aug_VADGunits_march2010.ems 

pthours_2007_sep_VADGunits_march2010.ems 

pthours_2007_oct_VADGunits_march2010.ems 

pthours_2007_nov_VADGunits_march2010.ems

pthours_2007_dec_VADGunits_march2010.ems

SMOKE 

PTHOUR

EMS-95

See Exhibit 3.2 for file format

2007 Annual Area Source 

Emission Inventory in 

SMOKE ORL format

arinv_marama_2007_jan2012_w_tf_orl.txt.gz SMOKE 

ARINV

ORL

This file has the PM transport 

factors by county applied to the 

NOF emissions. See section 

8.1.2 for discussion.

See http://www.smokemodel.org/version2.6/html/ for 

file format

2007 Annual MAR Emission 

Inventory in SMOKE ORL 

format

ARINV_2007_MAR_Jan2012.txt SMOKE 

ARINV

ORL

See http://www.smokemodel.org/version2.6/html/ for 

file format; includes commercial 

marine vessels, airports 

(including GSE), and railroad 

locomotives

2007 Monthly 

NMIM/NONROAD Emission 

Inventory in SMOKE ORL 

format

arinv_nonroad_2007_jan_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_feb_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_mar_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_apr_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_may_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_jun_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_jul_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_aug_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_sep_29sep2010_v1_orl.txt.gz

SMOKE 

ARINV

ORL

See http://www.smokemodel.org/version2.6/html/ for 

file format
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 135 

File Description File Name Format Notes

arinv_nonroad_2007_oct_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_nov_29sep2010_v1_orl.txt.gz

arinv_nonroad_2007_dec_29sep2010_v1_orl.txt.gz

SMOKE formatted temporal 

profiles for units that report to 

CAMD for only part of 2007.

ptpro_2007_marama_egu_13apr2010.txt SMOKE

PTPRO

See http://www.smokemodel.org/version2.6/html/ for 

file format and Section 3.4 of this 

TSD for discussion of these files SMOKE formatted temporal 

cross-reference tables for 

annual time periods

ptref_2007_marama_egu_annual_13apr2010.txt SMOKE

PTREF

SMOKE formatted temporal 

cross-reference tables for 

nonozone time periods

ptref_2007_marama_egu_nonozone_13apr2010.txt SMOKE

PTREF

SMOKE formatted temporal 

profiles 

MARAMA_amptref_v3_3_revised_10feb2011_v1.txt SMOKE

AMPTREF

Updated SMOKE temporal files 

based on EPA’s 2005v4 

modeling platform. See Section 

8.2.3 of this TSD for discussion 

SMOKE formatted temporal of the updates made.

cross-reference tables 

MARAMA_amptpro_2005_us_can_revised_10feb2011_v0.txt SMOKE 

AMPTPRO

SMOKE formatted spatial 

fridding cross-reference file

MARAMA_amgref_us_can_mex_revised_17feb20110_v8.txt SMOKE

AMGREF

Updated SMOKE spatial files 

based on EPA’s 2005v4 

modeling platform. See Section 

8.2.2 of this TSD for discussion 

of the updates made.

SMOKE formatted spatial 

surrogate designation file

MARAMA_srgdesc_36km_revised_10feb2011_v1.txt SMOKE

SRGDESC

SMOKE formatted area to 

point file for airports

MARAMA_artopnt_2002detroit_10feb2011_v0.txt SMOKE

ARTOPNT

SMOKE formatted speciation 

profile

MARAMA_gspro_cmaq_cb05_soa_2005ck_05b_10feb2011.txt SMOKE

GSPRO

Updated SMOKE speciation files 

based on EPA’s 2005v4 

modeling platform. See Section 

8.2.1 of this TSD for discussion 

of the updates made.

SMOKE formatted speciation 

cross-reference file

MARAMA_gsref_cmaq_cb05_soa_2005ck_05b_17feb2011.txt SMOKE

GSREF
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 136 

10.0 REFERENCES 

ERTAC 2010a. Eastern Regional Technical Advisory Committee. ERTAC Rail 

Emissions Inventory Part 1: Class I Line-Haul Locomotives. October 2010. 

ERTAC 2010b. Eastern Regional Technical Advisory Committee. ERTAC Rail 

Emissions Inventory Part 2: Class I Railyard Switcher Locomotives. September 2010. 

MARAMA 2006. Mid-Atlantic Regional Air Management Association. Technical 

Support Documentation for 2002 MANE-VU SIP Modeling Inventories, Version 3. 

November 20, 2006. http://www.marama.org/technical-center/emissions-inventory/2002-

inventory-and-projections/mane-vu-2002-emissions-inventory

MARAMA 2011. Prepared by MACTEC Engineering and Consulting, Inc. for the MidAtlantic Regional Air Management Association. Technical Support Document for the 

Development of the 2007 Emission Inventory for Regional Air Quality Modeling in the 

Northeast / Mid-Atlantic Region. February 27, 2011. 

SONOMA 2009. Sonoma Technology and US Forest Service. SMARTFIRE Algorithm 

Description. October 2009. 

http://www.getbluesky.org/smartfire/docs/SMARTFIRE_Algorithm_Description_Final.pdf

USEPA 2007a. U.S. Environmental Protection Agency. Guidance on the Use of Models 

and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, 

and Regional Haze. April 2007. 

http://www.epa.gov/ttn/scram/guidance/guide/final-03-pm-rh-guidance.pdf 

USEPA 2007b. U.S. Environmental Protections Agency. Emissions Modeling 

Clearinghouse - Fugitive Dust Fractions. February 2007. 

http://www.epa.gov/ttn/chief/emch/dustfractions )

USEPA 2009a. U.S. Environmental Protection Agency. Toxic Release Inventory 

Explorer Web Site; Chemical Download for Ammonia. File downloaded on July 9, 2009. 

http://www.epa.gov/triexplorer 

USEPA 2009b. U.S. Environmental Protection Agency. Clean Air Markets – Data and 

Maps Web Site; Unit Level Emissions Query for 2007. File downloaded on September 9, 

2009. http://camddataandmaps.epa.gov/gdm/index.cfm?fuseaction=emissions.wizard

USEPA 2009c. U.S. Environmental Protection Agency. Clean Air Markets – Emissions 

Data in SMOKE Format for 2007. File (hour_unit_2007.zip) downloaded on September 

15, 2009. http://camddataandmaps.epa.gov/gdm/index.cfm?fuseaction=emissions.prepacksmoke 
Technical Support Document for the 2007 Emission Inventory for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 137 

USEPA 2009d. U.S. Environmental Protection Agency. National Mobile Inventory 

Model. http://www.epa.gov/otaq/nmim.htm

USEPA 2009e. U.S. Environmental Protection Agency. Emission Factors for 

Locomotives; EPA-420F09025, 2009. 

http://www.epa.gov/otaq/regs/nonroad/locomotv/420f09025.pdf

USEPA 2010a. U.S. Environmental Protection Agency. 2008 National Emissions 

Inventory Data & Documentation; Workbooks and Documentation for NonPoint Sector.

http://www.epa.gov/ttn/chief/net/2008inventory.html#inventorydata 

USEPA 2010b. U.S. Environmental Protection Agency. 2008 National Emissions 

Inventory Data & Documentation; Residential Wood Combustion.

http://www.epa.gov/ttn/chief/net/2008inventory.html#inventorydata

USEPA 2010c. U.S. Environmental Protection Agency. 2008 National Emissions 

Inventory Data & Documentation; Animal Husbandry and Fertilizer Application.

http://www.epa.gov/ttn/chief/net/2008inventory.html#inventorydata 

USEPA 2010d. U.S. Environmental Protections Agency. Documentation for the 

Commercial Marine Vessel Component of the National Emissions Inventory Methodology, 

Eastern Research Group report # 0245.02.302.001, USEPA Contract number EP-D-07-

097. March 30, 2010. http://www.epa.gov/ttn/chief/net/cmv_report4.pdf 

USEPA 2010e. U.S. Environmental Protections Agency. Documentation for Aircraft 

Component of the National Emissions Inventory Methodology. Eastern Research Group 

report # 0245.02.302.001, USEPA Contract number EP-D-07-097. April 23, 2010. 

http://www.epa.gov/ttn/chief/net/aircraft_report_100423.pdf 

USEPA 2011. U.S. Environmental Protection Agency. Compilation of Air Pollutant 

Emission Factors, AP-42 Fifth Edition, Section 13.2.1, Paved Roads. Revised January 

2011. http://www.epa.gov/ttn/chief/ap42/ch13/final/c13s0201.pdf
APPENDIX C2

Technical Support Document for the Development of the 

2017/2020 Emission Inventories for Regional Air Quality 

Modeling in the Northeast/Mid-Atlantic Region Version 3.3 

(AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012) 

Bureau of Air Quality 

Department of Environmental Protection 
[This page intentionally left blank.] 
Technical Support Document 

for the 

Development of the 2017 / 2020

Emission Inventories 

for Regional Air Quality Modeling 

in the Northeast / Mid-Atlantic Region 

Version 3.3 

Prepared for: 

Mid-Atlantic Regional Air Management Association (MARAMA) 

8600 LaSalle Road, Suite 636 

Towson, MD 21286 

(443) 901-1882 

January 23, 2012 

MARAMA Contract Agreement FY2011-004 

Submitted by 

AMEC Environment & Infrastructure SRA International, Inc. 

4021 Stirrup Creek Drive 652 Peter Jefferson Parkway 

Suite 100 Suite 300 

Durham, NC 27703 Charlottesville, VA 22911 

919 381-9900 571 499-0833
Acknowledgements 

This work was supported by funds provided by MARAMA’s Memorandum of Agreement with 

the Ozone Transport Commission, which is funded by USEPA grant agreement XA973180 – 

Regional Haze Planning in the Northeast and Mid-Atlantic States. 

About MARAMA 

The Mid-Atlantic Regional Air Management Association, Inc. is a voluntary, non-profit 

association of ten state and local air pollution control agencies. MARAMA's mission is to 

strengthen the skills and capabilities of member agencies and to help them work together to 

prevent and reduce air pollution in the Mid-Atlantic Region. MARAMA provides cost-effective 

approaches to regional collaboration by pooling resources to develop and analyze data, share 

ideas, and train staff to implement common requirements. 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page i 

Table of Contents 

1.0 INTRODUCTION.................................................................................................................. 1

1.1 INVENTORY PURPOSE ................................................................................................ 1

1.2 POLLUTANTS ................................................................................................................ 2

1.3 SOURCE CATEGORIES ................................................................................................ 2

1.4 DATA FORMATS ........................................................................................................... 4

1.5 INVENTORY VERSIONS ............................................................................................... 4

1.5.1 Version 1 Modeling Inventory.................................................................................. 4

1.5.2 Version 2 Modeling Inventory.................................................................................. 5

1.5.3 Version 3 Modeling Inventories with Existing and Potential Controls....................... 5

1.6 REPORT ORGANIZATION ............................................................................................. 6

2.0 IDENTIFICATION OF EGU AND NONEGU POINT SOURCES ........................................... 7

3.0 GROWTH PROJECTION FACTORS FOR NONEGUS AND AREA SOURCES ................15

3.1 AEO FUEL USE PROJECTIONS ...................................................................................15

3.2 POPULATION PROJECTIONS .....................................................................................16

3.3 EMPLOYMENT PROJECTIONS ...................................................................................23

3.4 VEHICLE MILES TRAVELED PROJECTIONS ..............................................................23

3.5 NO GROWTH ASSIGNMENT FOR CERTAIN AREA SOURCE CATEGORIES .............23

3.6 EPA 2020 PROJECTIONS FOR RESIDENTIAL WOOD AND LIVESTOCK ...................27

3.7 SCC, SIC, NAICS AND GROWTH PARAMETER CROSSWALK ...................................28

3.8 FINAL GROWTH FACTORS FOR NONEGU / AREA SOURCES ..................................28

3.9 EMISSION REDUCTION CREDITS ...............................................................................30

4.0 AREA SOURCE CONTROL FACTORS .............................................................................33

4.1 FEDERAL RULES AFFECTING AREA SOURCES ........................................................33

4.2 FEDERAL MACT RULES ..............................................................................................34

4.3 RECENT CONTROL TECHNIQUE GUIDELINES ..........................................................35

4.4 OTC MODEL RULES FOR AREA SOURCES ................................................................37

4.4.1 OTC Model Rule for Adhesives/Sealants ...............................................................39

4.4.2 OTC Model Rules for Architectural and Industrial Maintenance Coatings ..............40

4.4.3 OTC Model Rule for Asphalt Paving ......................................................................43

4.4.4 OTC Model Rules for Consumer Products .............................................................44

4.4.5 OTC Model Rules for Mobile Equipment Repair and Refinishing ...........................46

4.4.6 OTC Model Rules for Portable Fuel Containers .....................................................49

4.4.7 OTC Model Rule for Solvent Cleaning ...................................................................50

4.4.8 OTC Model Rules for ICI Boilers ............................................................................51

4.4.9 OTC Model Rule for New, Small, Natural Gas-fired Boilers ...................................53

4.4.10 MANE-VU Low Sulfur Fuel Oil Strategy .............................................................55
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page ii

5.0 NONEGU POINT SOURCE CONTROL FACTORS ............................................................56

5.1 FEDERAL ACTIONS AFFECTING NONEGU POINT SOURCES ..................................56

5.2 RECENT CONTROL TECHNIQUE GUIDELINES ..........................................................59

5.3 OTC MODEL RULES FOR NONEGUS ..........................................................................59

5.3.1 OTC 2006 Model Rule for Adhesives and Sealants ...............................................62

5.3.2 OTC 2009/2010 Model Rule for Large Storage Tanks ...........................................63

5.3.3 OTC 2006 Model Rule for Asphalt Production Plants .............................................64

5.3.4 OTC 2006 Model Rule for Cement Manufacturing Plants .......................................64

5.3.5 OTC 2006 Model Rule for Glass and Fiberglass Furnaces ....................................66

5.3.6 OTC 2006 Model Rule for ICI Boilers .....................................................................66

5.4 FUEL OIL SULFUR LIMITS ...........................................................................................69

5.5 STATE-SPECIFIC NONEGU CONTROL FACTORS .....................................................70

6.0 NONROAD MODEL CATEGORIES ...................................................................................72

6.1 STATE REVIEW OF NMIM FUEL CHARACTERISTICS ................................................72

6.2 USE OF EXTERNAL FILES IN THE PROJECTION YEAR NMIM RUNS ........................73

6.3 NMIM RUN SPECIFICATIONS ......................................................................................73

6.4 REMOVAL OF AIRPORT GROUND SUPPORT EQUIPMENT ......................................74

6.5 STATE AND STAKEHOLDER REVIEW AND COMMENT .............................................74

6.6 CHANGES MADE FOR VERSION 3 MODEL RUNS ......................................................74

6.7 NMIM/NONROAD GROWTH AND CONTROL INFORMATION .....................................76

7.0 NONROAD MAR SOURCE CATEGORIES ........................................................................80

7.1 COMMERCIAL MARINE VESSELS ...............................................................................80

7.1.1 CMV Diesel Growth Factors...................................................................................80

7.1.2 CMV Diesel Control Factors...................................................................................81

7.1.3 CMV Residual Oil Growth Factors .........................................................................82

7.1.4 CMV Residual Oil Control Factors .........................................................................82

7.1.5 Military Vessels Growth and Control Factors .........................................................83

7.2 AIRCRAFT ....................................................................................................................83

7.2.1 Aircraft Growth Factors ..........................................................................................84

7.2.2 Aircraft Control Factors ..........................................................................................85

7.3 RAILROAD EQUIPMENT ..............................................................................................86

7.3.1 Railroad Growth Factors ........................................................................................87

7.3.2 Railroad Control Factors ........................................................................................87

8.0 SUMMARY OF PROJECTED EMISSIONS ........................................................................89

8.1 AREA SOURCE PROJECTED EMISSIONS ..................................................................89

8.2 NONEGU POINT SOURCE PROJECTED EMISSIONS ................................................98

8.3 NONROAD NMIM SOURCE PROJECT EMISSIONS ..................................................107

8.4 NONROAD COMMERCIAL MARINE VESSEL EMISSIONS ........................................115
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page iii 

8.5 NONROAD AIRPORT EMISSIONS .............................................................................123

8.6 NONROAD RAILROAD LOCOMOTIVE EMISSIONS ..................................................131

9.0 PREPARATION OF SMOKE MODEL FILES ...................................................................139

9.1 NONEGU POINT SOURCE SMOKE EMISSION FILES ...............................................139

9.2 AREA SOURCE SMOKE EMISSION FILES ................................................................139

9.3 NONROAD NMIM SMOKE EMISSION FILES..............................................................139

9.4 NONROAD MAR SMOKE EMISSION FILES ...............................................................140

10.0 FINAL DELIVERABLES ................................................................................................. 141

11.0 REFERENCES................................................................................................................146
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page iv

List of Appendices 

Appendix A Identification of EGUs and NonEGUs 

Appendix B1 AEO2010 New England.xls 

Appendix B2 AEO2010 Mid Atlantic.xls 

Appendix B3 AEO2010 South Atlantic.xls 

Appendix B4 AEO2011 New England.xls 

Appendix B5 AEO2011 Mid Atlantic.xls 

Appendix B6 AEO2011 South Atlantic.xls 

Appendix B7 AEO2010 vs AEO2011 Comparison.docx 

Appendix C Population Factors.xls 

Appendix D Employment Factors.xls 

Appendix E VMT Factors.xls 

Appendix F USEPA2020 Residential Wood Projection Factors 

Appendix G USEPA 2020 Livestock Projection Factors 

Appendix H Stage II Control Factors 

Appendix I Area Source ICI Boiler Control Factor Derivation.xlsx 

Appendix J Area Source New Small Gas-Fired Boiler Control Factor Derivation 

Appendix K Fuel Oil Sulfur Contents and MANE-VU Limits 

Appendix L – Supporting Data for Final MAR Source Growth and Control Factors for 2017 and 

2020
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page v 

List of Exhibits 

Exhibit 2.1 2007 EGU and NonEGU Point Source CO Emissions 

Exhibit 2.2 2007 EGU and NonEGU Point Source NH3 Emissions 

Exhibit 2.3 2007 EGU and NonEGU Point Source NOx Emissions 

Exhibit 2.4 2007 EGU and NonEGU Point Source PM10-PRI Emissions 

Exhibit 2.5 2007 EGU and NonEGU Point Source PM25-PRI Emissions 

Exhibit 2.6 2007 EGU and NonEGU Point Source SO2 Emissions 

Exhibit 2.7 2007 EGU and NonEGU Point Source VOC Emissions 

Exhibit 3.1 Growth Factors for Coal Fuel Use by AEO Region 2007 - 2025 

Exhibit 3.2 Growth Factors for Residual Oil Fuel Use by AEO Region 2007 - 2025

Exhibit 3.3 Growth Factors for Distillate Oil Fuel Use by AEO Region 2007 - 2025 

Exhibit 3.4 Growth Factors for Natural Gas Fuel Use by AEO Region 2007 - 2025

Exhibit 3.5 Growth Factors for Gasoline Fuel Use by AEO Region 2007 – 2025

Exhibit 3.6 Population Growth Factors by AEO Region 2007 – 2025

Exhibit 3.7. Employment Growth Factors by AEO Region 2007 - 2025

Exhibit 3.8 State VMT Growth Factors 2007 – 2020 

Exhibit 3.9 Area Source Categories with No Growth Assignment 

Exhibit 3.10 State Recommendations to Address Negative Growth for the NonEGU Point 

Source Sector 

Exhibit 3.11 State Recommendations to Address Negative Growth and Other Growth Factors 

for the Area Source Sector 

Exhibit 4.1 USEPA Estimated Percent Reductions for RICE MACT Standard 

Exhibit 4.2 Summary of Area Source OTC Control Measures 

Exhibit 4.3 State Recommendations for OTC Adhesives/Sealants Rule 

Exhibit 4.4 State Recommendations for OTC AIM Rule 

Exhibit 4.5 State Recommendations for OTC Cutback and Emulsified Asphalt Paving 

Exhibit 4.6 VOC Emission Factors for Consumer Products 

Exhibit 4.7 State Recommendations for OTC 2001 and 2006 Consumer Products Rules 

Exhibit 4.8 VOC Emission Reductions for Auto Refinishing 

Exhibit 4.9 State Recommendations for OTC Auto Refinishing Rule 

Exhibit 4.10 State Recommendations for OTC and Federal Portable Fuel Container Rules 

Exhibit 4.11 State Recommendations for OTC Solvent Cleaning Rule 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

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Exhibit 4.12 Area Source Emission Reductions from New Jersey ICI Boiler NOx Rules 

Exhibit 4.13 OTC Resolution 06-02 Guidelines for ICI Boiler NOx Rules 

Exhibit 4.14 NOx Emission Reductions Expected from the OTC Rule for New, Small, Natural 

Gas-fired Units 

Exhibit 4.15 MANE-VU Low Sulfur Fuel Oil Strategy 

Exhibit 5.1 USEPA Estimated Percent Reductions for RICE MACT Standard 

Exhibit 5.2 Summary of Point Source OTC Control Measures 

Exhibit 5.3 State Recommendations for OTC Adhesives/Sealants Rule 

Exhibit 5.4 NonEGU Point Source Emission Reductions from New Jersey ICI Boiler NOx Rules 

Exhibit 5.5 OTC Resolution 06-02 Guidelines for ICI Boiler NOx Rules 

Exhibit 6.1 Control Programs Included in the NMIM/NONROAD Model 

Exhibit 7.1 CMV Diesel Control Factors by Year, Pollutant, and SCC 

Exhibit 7.2 CMV Residual Oil Control Factors by Year, Pollutant, and SCC 

Exhibit 7.3 Crosswalk between SCC and FAA Operations Type 

Exhibit 7.4 Region-wide Growth Factors from 2007 by FAA Operations Type 

Exhibit 7.5 Rail Control Factors by Year, Pollutant, and SCC 

Exhibit 8.1 2007 and Projected Future Year Area Source CO Emissions 

Exhibit 8.2 2007 and Projected Future Year Area Source NH3 Emissions 

Exhibit 8.3 2007 and Projected Future Year Area Source NOx Emissions 

Exhibit 8.4 2007 and Projected Future Year Area Source PM10-PRI Emissions 

Exhibit 8.5 2007 and Projected Future Year Area Source PM25-PRI Emissions 

Exhibit 8.6 2007 and Projected Future Year Area Source SO2 Emissions 

Exhibit 8.7 2007 and Projected Future Year Area Source VOC Emissions 

Exhibit 8.8 2007 and Projected Future Year NonEGU Point Source CO Emissions 

Exhibit 8.9 2007 and Projected Future Year NonEGU Point Source NH3 Emissions 

Exhibit 8.10 2007 and Projected Future Year NonEGU Point Source NOx Emissions 

Exhibit 8.11 2007 and Projected Future Year NonEGU Point Source PM10-PRI Emissions 

Exhibit 8.12 2007 and Projected Future Year NonEGU Point Source PM25-PRI Emissions

Exhibit 8.13 2007 and Projected Future Year NonEGU Point Source SO2 Emissions 

Exhibit 8.14 2007 and Projected Future Year NonEGU Point Source VOC Emissions 

Exhibit 8.15 2007 and Projected Future Year NONROAD Source CO Emissions 
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Exhibit 8.16 2007 and Projected Future Year NONROAD Source NH3 Emissions 

Exhibit 8.17 2007 and Projected Future Year NONROAD Source NOx Emissions 

Exhibit 8.18 2007 and Projected Future Year NONROAD Source PM10-PRI Emissions 

Exhibit 8.19 2007 and Projected Future Year NONROAD Source PM25-PRI Emissions 

Exhibit 8.20 2007 and Projected Future Year NONROAD Source SO2 Emissions 

Exhibit 8.21 2007 and Projected Future Year NONROAD Source VOC Emissions 

Exhibit 8.22 2007 and Projected Future Year Marine Vessel CO Emissions 

Exhibit 8.23 2007 and Projected Future Year Marine Vessel NH3 Emissions 

Exhibit 8.24 2007 and Projected Future Year Marine Vessel NOx Emissions 

Exhibit 8.25 2007 and Projected Future Year Marine Vessel PM10-PRI Emissions 

Exhibit 8.26 2007 and Projected Future Year Marine Vessel PM25-PRI Emissions 

Exhibit 8.27 2007 and Projected Future Year Marine Vessel SO2 Emissions 

Exhibit 8.28 2007 and Projected Future Year Marine Vessel VOC Emissions 

Exhibit 8.29 2007 and Projected Future Year Airport CO Emissions 

Exhibit 8.30 2007 and Projected Future Year Airport NH3 Emissions 

Exhibit 8.31 2007 and Projected Future Year Airport NOx Emissions 

Exhibit 8.32 2007 and Projected Future Year Airport PM10-PRI Emissions 

Exhibit 8.33 2007 and Projected Future Year Airport PM25-PRI Emissions 

Exhibit 8.34 2007 and Projected Future Year Airport SO2 Emissions 

Exhibit 8.35 2007 and Projected Future Year Airport VOC Emissions 

Exhibit 8.36 2007 and Projected Future Year Railroad Locomotive CO Emissions 

Exhibit 8.37 2007 and Projected Future Year Railroad Locomotive NH3 Emissions 

Exhibit 8.38 2007 and Projected Future Year Railroad Locomotive NOx Emissions 

Exhibit 8.39 2007 and Projected Future Year Railroad Locomotive PM10-PRI Emissions 

Exhibit 8.40 2007 and Projected Future Year Railroad Locomotive PM25-PRI Emissions 

Exhibit 8.41 2007 and Projected Future Year Railroad Locomotive SO2 Emissions 

Exhibit 8.42 2007 and Projected Future Year Railroad Locomotive VOC Emissions 

Exhibit 10.1 – NIF Data Files 

Exhibit 10.2 – Emission Summary Files 

Exhibit 10.3 – SMOKE Files 
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Acronyms and Abbreviations 

Acronym Description

CAMD Clean Air Markets Division (USEPA)

CAP Criteria Air Pollutant

CEM Continuous Emission Monitoring 

CMV Commercial Marine Vessel

CO Carbon Monoxide 

CTG Control Technique Guideline

EGU Electric Generating Unit

ERTAC Eastern Regional Technical Advisory Committee

FIPS Federal Information Processing Standard

GACT Generally available control technology

GSE Ground Support Equipment

MACT Maximum Achievable Control Technology

MANE-VU Mid-Atlantic/Northeast Visibility Union

MANE-VU+VA MANE-VU States plus Virginia

MAR Marine, Airport, Rail 

MARAMA Mid-Atlantic Regional Air Management Association

MOBILE6 USEPA model

MOVES Motor Vehicle Emissions Simulator

NAICS North American Industry Classification System code

NCD National County Database 

NEI National Emission Inventory

NESCAUM Northeast States for Coordinated Air Use Management

NH3 Ammonia

NIF3.0 National Emission Inventory Input Format Version 3.0

NMIM National Mobile Input Model

NOF3.0 National Emission Inventory Output Format Version 3.0

NONROAD USEPA model

NOx Oxides of nitrogen

OAQPS Office of Air Quality Planning and Standards (USEPA)

ORL One-record-per-line (SMOKE Format)

OTAQ Office of Transportation and Air Quality (USEPA)

PFC Portable Fuel Container

PM-CON Primary PM, Condensable portion only ( < 1 micron)

PM-FIL Primary PM, Filterable portion only

PM-PRI Primary PM, includes filterables and condensables

PM-PRI= PM-FIL + PM-CON
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Acronym Description

PM10-FIL Primary PM10, Filterable portion only

PM10-PRI Primary PM10, includes filterables and condensables, 

PM10- PRI = PM0-FIL + PM-CON

PM25-FIL Primary PM2.5, Filterable portion only

PM25-PRI Primary PM2.5, includes filterables and condensables

PM25-PRI= PM25-FIL + PM-CON

RWC Residential Wood Combustion

SEMAP Southeast Modeling, Analysis and Planning

SIC Standard Industrial Classification code

SIP State Implementation Plan

SCC Source Classification Code

S/L State/local

SMOKE Sparse Matrix Operator Kernel Emissions

SO2 Sulfur Dioxide

USEPA U.S Environmental Protection Agency

VISTAS Visibility Improvement State and Tribal Association of the Southeast 

VMT Vehicle Miles Traveled

VOC Volatile Organic Compounds
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1.0 INTRODUCTION 

This technical support document (TSD) explains the data sources and methods used to 

prepare criteria air pollutant (CAP) and ammonia (NH3) emission projections for 2017 and 

2020 for the Northeast and Mid-Atlantic/Northeast region. The region includes the 

jurisdictions in the Mid-Atlantic / Northeast Visibility Union (MANE-VU) area plus 

Virginia. In this document, these jurisdictions will be referred to as the MANE-VU+VA 

region. The MANE-VU+VA region includes Connecticut, Delaware, the District of 

Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, 

Pennsylvania, Rhode Island, Vermont, and Virginia. 

1.1 INVENTORY PURPOSE 

The MANE-VU+VA regional inventories will be used to concurrently address national 

ambient air quality standard (NAAQS) requirements for the new ozone and fine particle 

ambient standards and to evaluate progress towards long-term regional haze goals. The 

emission inventories will support a single integrated, one-atmosphere air quality modeling 

platform, state air quality attainment demonstrations, and other state air quality technical 

analyses. 

The future year inventories account for emissions growth associated with changes in 

population, fuel use, and economic activity. The future year inventories also refect the 

emission changes between 2007 and the two future years that are projected under two 

emission control scenarios: 

Existing Controls – this scenario represents the best estimates for the future year, 

accounting for all in-place controls that are fully adopted into federal or individual 

state regulations or State Implementation Plans (SIPs). In the past, this inventory is 

also referred to as the “on-the-books (OTB)” inventory. Air quality modelers often 

refer to this scenario as the “future base case.”

Potential New OTC Controls – this scenario accounts for all of the emission 

reductions from the existing control scenario plus new state or regional measures 

that are under consideration by the Ozone Transport Commission (OTC) or 

individual states. This is a “what if” scenario that assumes that all states in the 

MANE-VU+VA region except Virginia will adopt all new OTC control measures 

under consideration by 2017. Air quality modelers sometimes call this the “future 

control case.” It does not include any potential new federal control measures that 

are under consideration. 
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The U.S. Environmental Protection Agency (USEPA) has provided guidance on 

developing emission projections to be used with models and other analyses for 

demonstrating attainment of air quality goals for ozone, fine particles, and regional haze 

(USEPA 1999, USEPA 2005a, USEPA 2007a). In addition, the USEPA has recently 

developed its own emission projections that provide data on growth and future controls 

that were useful in developing the MANE-VU+VA future year emission inventories 

(USEPA 2010a). The guidance and information available from USEPA was followed and 

used, as appropriate, in developing the future year emission projections. 

1.2 POLLUTANTS 

The inventory includes annual emissions for carbon monoxide (CO), ammonia (NH3), 

oxides of nitrogen (NOx), particulate matter (PM), sulfur dioxide (SO2), and volatile 

organic compounds (VOC). The PM species in the inventory are categorized as: filterable 

and condensable particles with an aerodynamic diameter less than or equal to a nominal 10 

and 2.5 micrometers (i.e., PM10-PRI and PM25-PRI); filterable particles with an 

aerodynamic diameter less than or equal to a nominal 10 and 2.5 micrometers (i.e., PM10-

FIL and PM25-FIL); and condensable particles (PM-CON). Note that PM10-PRI equals 

the sum of PM10-FIL and PM-CON, and PM25-PRI equals the sum of PM25-FIL and 

PM-CON. 

1.3 SOURCE CATEGORIES 

Emission inventory data from six general categories are needed to support air quality 

modeling: electric generating units (EGUs), stationary nonEGU point-sources, stationary 

area-sources, on-road mobile sources, nonroad mobile sources, and biogenic/geogenic 

emissions. This report documents the development of emission projections for three of 

these sectors, as follows: 

NonEGU Point Sources are individual facilities and are further subdivided by 

stack, emission unit (“point”), and emission process (“segment”). Point source data 

include source-specific information on source location (e.g., latitude/longitude 

coordinates); stack parameters (stack diameter and height, exit gas temperature and 

velocity); type of process (source classification code {SCC}); and annual 

emissions. 

Stationary Area Sources include sources that in and of themselves are quite small, 

but in aggregate may contribute significant emissions. Examples include small 

industrial/commercial facilities, residential heating furnaces, VOCs volatizing from 
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house painting or consumer products, gasoline service stations, and agricultural 

fertilizer/pesticide application. 

Non-road Mobile Sources include internal combustion engines used to propel 

marine vessels, airplanes, and locomotives, or to operate equipment such as 

forklifts, lawn and garden equipment, portable generators, etc. For activities other 

than marine vessels, airplanes, and railroad locomotives (MAR), the inventory was 

developed using the most current version of USEPA’s NONROAD model as 

embedded in the National Mobile Inventory Model (NMIM). Since the 

NONROAD model does not include emissions from MAR sources, these emissions 

were estimated based on data and methodologies used in recent USEPA regulatory 

impact analyses. 

For these three sectors, emissions projections were compiled on an annual basis to 

represent conditions in 2017 and 2020. 

Emission projections for the three other sectors are being developed by the OTC under 

separate efforts: 

EGU Point Sources are units that generate electric power and sell most of that

power to the electrical grid. Emission projections for EGUs are being developed as 

part of an inter-RPO coordination effort under the direction of the Eastern Regional 

Technical Advisory Committee (ERTAC). 

On-road Mobile Sources are sources of air pollution from internal combustion 

engines used to propel cars, trucks, buses, and other vehicles on public roadways. 

Emission projections for on-road mobile sources are being developed under a 

separate effort by the OTC that will use the USEPA Motor Vehicle Emission 

Simulator (MOVES) model. 

Biogenic emissions are emitted by natural sources, such as plants, trees, and soils. 

The sharp scent of pine needles, for instance, is caused by monoterpenes, which are 

VOCs. The USEPA developed estimates of biogenic emissions from vegetation for 

natural areas, crops, and urban vegetation. The USEPA estimates take into account 

the geographic variations in vegetation land cover and species composition, as well 

as seasonal variations in leaf cover. Emission projections for biogenic sources will 

be developed under a separate effort by the OTC modeling team. 

Documentation of the emission projections for these three sectors will be available from 

the OTC. 
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1.4 DATA FORMATS 

The annual mass emissions inventory files were prepared in the National Emissions 

Inventory (NEI) Output Format Version 3.0 (NOF 3.0). Spreadsheets summarizing 

emissions by county, sector, source classification code, and pollutant were also prepared. 

These annual emission inventories will be converted (through the emissions modeling 

process) from their original resolution (e.g., annual, county level) to input files for air 

quality models. These input files require emissions to be specified by model grid cell, 

hour, and model chemical species. The emission modelers in the MANE-VU+VA region 

are using the Sparse Matrix Operator Kernel Emissions (SMOKE) modeling system and 

data formats. Emission inventory files were prepared in SMOKE compatible format. 

1.5 INVENTORY VERSIONS 

1.5.1 Version 1 Modeling Inventory 

Work commenced in 2009 to assemble comprehensive 2007 and future year emission 

inventories to support air quality modeling. Using data available from state agencies and 

the USEPA, detailed point and area source emission inventories were compiled. The 

NONROAD model was used to estimate emissions for the nonroad equipment categories 

included in the model. State and USEPA data were used to assemble the inventory for 

nonroad sources not included in the NONROAD model (marine vessels, aircraft, and 

railroad locomotives, collectively referred to as the MAR sector). 

For the point, area, and MAR sectors, growth factors are applied to account for changes in 

population, fuel use and economic activity. Next, control factors are applied to account for 

future emission reductions from post-2007 control measures. The NONROAD model was 

used to project emissions for the nonroad equipment included in the model. The control 

scenario developed accounted for post-2007 emission reductions from promulgated 

federal, State, local, and site-specific control programs and proposed control programs that 

are reasonably anticipated to result in post-2007 emission reductions. A series of quality 

assurance steps are conducted to ensure the development of complete, accurate, and 

consistent emission inventories. The inventories are provided in two formats – SMOKE 

One-Record-Per-Line (ORL) format and a spreadsheet format suitable for SIP submittals. 

Finally, emission summary tables by state and pollutant were developed. 

Version 1 of the 2007 base year inventory and the emission projections for 

2013/2017/2020 were released for state and stakeholder review in late 2009 and early 

2010. 
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1.5.2 Version 2 Modeling Inventory 

Following the review of Version 1, significant efforts were made to improve the inventory 

by using more state-specific data and correcting errors or omissions that were uncovered. 

These improvements were completed in February of 2011 and are referred to as Version 2 

of the MANE-VU+VA 2007 and 2013/2017/2020 inventories. The inventories were 

documented in two TSDs (MARAMA 2011a, MARAMA 2011b). 

1.5.3 Version 3 Modeling Inventories with Existing and Potential Controls 

Beginning in the fall of 2011, MARAMA sponsored development of Version 3 of the 2007 

base year modeling inventory to incorporate new paved road emission estimates, revised 

modeling of nonroad and onroad sources, and other state-specific changes 

(MARAMA2012). 

This report documents the development of Version 3 of the future year inventories for the 

area source, nonEGU, and nonroad sectors. The future year modeling inventories for 

EGU) are currently being developed under a separate effort lead by ERTAC. The future 

year modeling inventories for onroad sources are currently being developed by 

NESCAUM, MARAMA or individual states. 

In Version 3, the state Air Directors issued guidance on the future year emission control 

scenarios to be developed, as follows: 

“A special meeting of the Air Directors was convened to discuss the controlled 

inventory. During that call many Air Directors indicated that they would not be 

able to clearly identify which of the control measures their states would adopt 

because of the uncertainty surrounding the ozone standard. Therefore, all states, 

except Virginia, requested that the contractor be instructed to calculate the effect of 

all measures being fully adopted by both 2017 and 2020. This will allow modelers 

to assess the potential effect of the measures if they were fully implemented on air 

quality. We can also then test the assumptions that we have been making about the 

cumulative percent reduction from the measures.” 

Thus, these TSD discusses two future control scenarios: an “existing controls” scenario 

scenario intended to include all 2017/2020 control measaures included in an individual 

state’s regulations or SIP, and a "what if" scenario that assumes that all states adopt 

certain new control measures by 2017. 
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1.6 REPORT ORGANIZATION 

Section 2 describes how point source emission units were classified into the EGU or 

nonEGU point source categories. Section 3 discusses the growth projection factors 

assembled for area and nonEGU point sources. Sections 4 and 5 describe the control 

factors used for area and nonEGU point sources, respectively. Section 6 describes the 

NONROAD model runs made for the future years. Section 7 documents how emissions 

for marine vessels, aircraft, and railroad equipment were projected. Section 8 provides 

state level emission pollutant summaries for area, nonEGU point, NONROAD, and MAR 

sectors. Section 9 documents the creation of SMOKE inventory modeling input files. 

Section 10 identifies the file names for final deliverable products. References for the TSD 

are provided in Section 11. 
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2.0 IDENTIFICATION OF EGU AND NONEGU POINT SOURCES 

Only the emissions from point sources classified as nonEGUs are being projected using the 

methods and data contained in this report. Emissions from EGU point sources are being 

developed by ERTAC. 

States were asked to classify units in the 2007 MANE-VU+VA emissions inventory as 

either EGU or nonEGU. Most, but not all, of the units that are required to report hourly 

emissions to USEPA’s Clean Air Markets Division (CAMD) are classified as EGUs. 

CAMD implements USEPA’s rule found in Volume 40 Part 75 of the Code of Federal 

Regulations (CFR), which requires an hourly accounting of emissions from each affected 

unit - i.e., sources participating in an emissions cap and trade program under the Acid 

Rain Control Program, the NOx Budget Trading Program, or the Clean Air Interstate Rule. 

For the ERTAC projection methodology, the following guidance was provided to states to 

classify a unit as an EGU if it meets the following criteria: 

An EGU sells most of the power generated to the electrical grid; 

An EGU burns mostly commercial fuel. Commercial fuel in this case means 

natural gas, oil, and coal. Wood is not considered a commercial fuel because some 

states identify wood as renewable. Therefore, to avoid double counting, units that 

burn wood and other renewable sources (depending on each state's own definition) 

should not be considered as an EGU (unless it is already in the CAMD database). 

The following are units were not considered as EGU for emission projections: (1) a unit 

that generates power for a facility but occasionally sells to the grid; (2) emergency 

generators; or (3) distributed generation units. 

States were provided with a list of units that report to CAMD (USEPA 2009a) and a list of 

units with an electric generating unit SCC (1-01-xxx-xx or 2-01-xxx-xx). States identified 

which units should be classified as EGUs and which should be classified as nonEGUs. 

Appendix A identifies the units that report emissions to CAMD and whether they are 

classified as EGUs or nonEGUs for emission projection purposes. A few states also 

identified units with SCCs beginning with 1-01 or 2-01 that do not report to CAMD but 

which should be classified as EGUs; however, for emission projection purposes these units 

will be processed using the nonEGU projection methodology described in this report. 

Exhibits 2.1 to 2.7 summarize EGU and nonEGU emissions for 2007. For these exhibits, 

EGUs are defined as units that report emissions to CAMD and have been classified as 

EGUs by the states for emission projection purposes. 
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Exhibit 2.1 2007 EGU and NonEGU Point Source CO Emissions (tons per year) 

State EGU NonEGU Total

CT 1,095 2,584 3,679 

DE 726 7,027 7,753 

DC 10 301 311 

ME 460 14,023 14,483 

MD 4,196 77,574 81,770 

MA 5,516 4,592 10,108 

NH 910 2,254 3,164 

NJ 3,640 6,932 10,572 

NY 13,480 52,877 66,357 

PA 20,900 80,540 101,440 

RI 602 1,051 1,653 

VT 1,444 702 2,146 

VA 7,273 63,080 70,353 

TOTAL 60,252 313,537 373,789 
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Exhibit 2.2 2007 EGU and NonEGU Point Source NH3 Emissions (tons per year) 

State EGU NonEGU Total

CT 0 0 0 

DE 32 62 94 

DC 0 0 0 

ME 59 606 665 

MD 0 137 137 

MA 283 365 648 

NH 98 30 128 

NJ 708 210 918 

NY 1,354 1,063 2,417 

PA 309 2,070 2,379 

RI 58 16 74 

VT 0 0 0 

VA 212 1,618 1,830 

TOTAL 3,113 6,177 9,290 
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Exhibit 2.3 2007 EGU and NonEGU Point Source NOx Emissions (tons per year) 

State EGU NonEGU Total

CT 3,760 6,301 10,061 

DE 10,507 5,121 15,628 

DC 55 734 789 

ME 696 17,050 17,746 

MD 51,418 23,472 74,890 

MA 10,755 12,873 23,628 

NH 4,754 2,687 7,441 

NJ 16,571 14,030 30,601 

NY 47,450 35,583 83,033 

PA 186,997 71,382 258,379 

RI 494 950 1,444 

VT 370 441 811 

VA 62,673 50,265 112,938 

TOTAL 396,500 240,889 637,389 
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Exhibit 2.4 2007 EGU and NonEGU Point Source PM10 Emissions (tons per year) 

State EGU NonEGU Total

CT 705 645 1,350 

DE 2,268 1,197 3,465 

DC 13 46 59 

ME 148 4,748 4,896 

MD 13,611 5,711 19,322 

MA 2,575 3,029 5,604 

NH 784 1,141 1,925 

NJ 4,496 3,188 7,684 

NY 5,044 4,463 9,507 

PA 27,470 22,275 49,745 

RI 16 173 189 

VT 0 146 146 

VA 6,175 13,028 19,203 

TOTAL 63,305 59,790 123,095 
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Exhibit 2.5 2007 EGU and NonEGU Point Source PM2.5 Emissions (tons per year) 

State EGU NonEGU Total

CT 669 573 1,242 

DE 2,024 1,083 3,107 

DC 10 43 53 

ME 125 3,727 3,852 

MD 11,805 3,877 15,682 

MA 2,292 2,572 4,864 

NH 602 1,061 1,663 

NJ 4,410 2,453 6,863 

NY 3,585 2,414 5,999 

PA 19,071 13,389 32,460 

RI 16 124 140 

VT 0 114 114 

VA 4,593 10,295 14,888 

TOTAL 49,202 41,725 90,927 
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Exhibit 2.6 2007 EGU and NonEGU Point Source SO2 Emissions (tons per year) 

State EGU NonEGU Total

CT 4,786 3,185 7,971 

DE 34,882 8,206 43,088 

DC 141 471 612 

ME 1,677 15,571 17,248 

MD 274,207 31,176 305,383 

MA 54,172 9,057 63,229 

NH 42,524 2,734 45,258 

NJ 37,302 3,490 40,792 

NY 108,444 44,307 152,751 

PA 970,726 57,330 1,028,056 

RI 16 1,500 1,516 

VT 6 316 322 

VA 188,562 54,486 243,048 

TOTAL 1,717,445 231,829 1,949,274 
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Exhibit 2.7 2007 EGU and NonEGU Point Source VOC Emissions (tons per year) 

State EGU NonEGU Total

CT 143 1,447 1,590 

DE 83 3,406 3,489 

DC 2 57 59 

ME 35 4,987 5,022 

MD 389 4,597 4,986 

MA 463 4,094 4,557 

NH 110 806 916 

NJ 420 10,620 11,040 

NY 1,119 9,772 10,891 

PA 770 28,195 28,965 

RI 49 921 970 

VT 22 373 395 

VA 600 35,018 35,618 

TOTAL 4,205 104,293 108,498 
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3.0 GROWTH PROJECTION FACTORS FOR NONEGUs AND AREA 

SOURCES 

The area and nonEGU point source growth factors were developed using six sets of data: 

The Annual Energy Outlook (AEO) fuel consumption forecasts; 

County-level population projections; 

State-level employment projections by NAICS code; 

County-level vehicle miles travelled (VMT) projections; 

USEPA projections for livestock and residential wood combustion; and 

Other state-specific emission projection data. 

The priority for applying these growth factors was to first use the state-supplied projection 

data (if available). If state-supplied data were not provided, then the AEO projection 

factors were used for fuel consumption sources, and the population/employment/VMT data 

were used for other source categories. 

3.1 AEO FUEL USE PROJECTIONS 

The AEO is published annually by the U.S. Energy Information Administration (EIA). It 

presents long-term projections of energy supply, demand, and prices through 2035, based 

on results from EIA’s National Energy Modeling System (NEMS). NEMS projects the 

production, imports, conversion, consumption, and prices of energy, subject to 

assumptions on macroeconomic and financial factors, world energy markets, resource 

availability and costs, behavioral and technological choice criteria, energy technology cost 

and performance characteristics, and demographics. 

AEO provides regional fuel-use forecasts for various fuel types (e.g., coal, residual oil, 

distillate oil, natural gas) by end use sector (e.g., residential, commercial, industrial, 

transportation, and electric power). Energy use projections are reported at the Census 

division level. The census divisions grouped states as follows: 

South Atlantic - DE, DC, MD, VA 

Middle Atlantic – NJ, NY, PA 

New England – CT, ME, MA, NH, RI, VT 

Appendices B1, B2, and B3 contain the AEO2010 fuel use projections for each of these 

three regions. Appendices B4, B5, and B6 contain the AEO2011 fuel use projections 

Version 2 of the MANE-VU+VA future year inventories was developed using AEO2010 

(EIA2010). After the release of Version 2, AEO2011 was published (EIA2011). 

MARAMA reviewed the updated fuel forecasts and compared the AEO2010 and 

AEO2011 projections. Appendix B7 documents MARAMA’s analysis. MARAMA 
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calculated the difference in projected fuel usage between AEO2010 and AEO2011 for the 

residential, commercial, industrial, transportation, and electric power sector for the 

distillate fuel oil, residual fuel oil, coal, natural gas, and renewable fuel types. MARAMA 

identified thresholds for what constitutes a major change as follows: 

An increase or decrease of 1% or less is considered to be no change and did not 

warrant a change in the growth factors between Versions 2 and 3 of the inventory; 

An increase or decrease of between 1% and 5% is considered to be a minor change, 

and states agreed that these differences between AEO2010 and AEO2011 did not 

warrant a change in the growth factors between Versions 2 and 3 of the inventory; 

An increase or decrease above 5% is considered a major change, and warrants a 

change in the growth factors used in Version 3. 

MARAMA recommended that the AEO2010 projections be retained for all residential, 

commercial, and industrial sector fuel use, except for industrial natural gas usage, where 

the AEO2011 projections will be used for Version 3 of the future year modeling inventory. 

New Jersey elected to use the more recent growth factors from AEO2011 instead of the 

AEO2010 growth factors for all area source fossil fuel use categories. 

Exhibits 3.1 to 3.5 summarize the projected fuel use rates by source sector (residential, 

commercial, industrial, transportation) , AEO region, and fuel type for the years 2007 to 

2025. The unusual growth in commercial residual oil use in the South Atlantic region 

could not be explained; Maryland elected to use manufacturing employment instead of the 

AEO2010 growth factor for commercial residual oil combustion, while Virginia and the 

District chose to assume flat growth in this sector. 

3.2 POPULATION PROJECTIONS 

States provided county-level 2007 populations and projections for future years. The 

historical and projection years varied from state-to-state, so values were interpolated, when 

necessary, to create population estimates for each year from 2007 to 2025. The population 

data were normalized to create growth factors from 2007 for each future year. For 

example, Delaware had a population of 861,087 in 2007 and the projected population in 

2017 is 953,204, then the growth factor for 2017 is 953,204 / 861,087 = 1.107. 

Population projections are provided in Appendix C. Exhibit 3.6 summarizes the 

population growth factors by state and AEO2010 region. Population is projected to grow 

in every state between 2007 and 2025. The population growth in the New England states 

varies significantly by state. Population growth in the South Atlantic states is projected to 

be much higher than in the New England and Mid-Atlantic states. 
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Exhibit 3.1 AEO2010 Growth Factors for Coal by AEO Region 2007 – 2025 
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Exhibit 3.2 Growth Factors for Residual Oil by AEO Region 2007 – 2025 
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Exhibit 3.3 AEO2010 Growth Factors for Distillate Oil by AEO Region 2007 – 2025
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Exhibit 3.4 Growth Factors for Natural Gas by AEO Region 2007 – 2025 

AEO2010 for Residential/Commercial, AEO2011 for Industrial 
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Exhibit 3.5 AEO2010 Growth Factors for Gasoline by AEO Region 2007 – 2025
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Exhibit 3.6 Population Growth Factors by AEO Region 2007 – 2025
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3.3 EMPLOYMENT PROJECTIONS 

Every two years, the federal Bureau of Labor Statistics produces long-term industry and 

occupation forecasts for ten future years and states are asked to do the same for their 

respective economies. The most recent projections from state Department’s of Labor of 

for the period 2006 to 2016, most of which were published in 2008. These 10-year 

forecasts are updated every other year. The next set of state-specific projections will be for 

the period 2008 to 2018. Only the District of Columbia and Delaware were able to provide 

employment projections for 2008 to 2018; the 2008 to 2018 projections were not available 

for other states in time for use on this project. The employment projections are state-wide 

by 3-digit NAICS code. Employment projections are provided in Appendix D. Exhibit 3.7 

summarizes the manufacturing employment (NAICS sector 31-33) growth factors by state 

and AEO2010 region. States in the Northeast / Mid-Atlantic region show a marked 

decrease in manufacturing employment from 2007 forward. 

3.4 VEHICLE MILES TRAVELED PROJECTIONS 

States developed projections of vehicle miles traveled (VMT) for 2007, 2017 and 2020 

which were used as the growth factor for projecting emissions from re-entrained road dust 

from travel on paved roads (SCC 22-94-000-000). The 2007 and future year VMT are 

identical to those used in the MOVES modeling. Exhibit 3.8 shows the state level VMT 

growth between 2007 and 2020. Growth factors for years where VMT were not directly 

provided by states were estimated by a linear interpolation of available data. Countyspecific VMT projections are provided in Appendix E. 

3.5 NO GROWTH ASSIGNMENT FOR CERTAIN AREA SOURCE 

CATEGORIES 

For several area source categories, it seems reasonable that emissions would not change 

from the 2007 values. No growth was applied to the 2007 emissions for the area source 

categories shown in Exhibit 3.9. 
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Exhibit 3.7. Manufacturing Employment Growth Factors by AEO Region 2007 - 2025
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Exhibit 3.8 State VMT Growth Factors 2007 – 2020
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Exhibit 3.9 Area Source Categories with No Growth Assignment 

SCC SCC Description

2296000000 Unpaved Roads /All Unpaved Roads /Total: Fugitives

2401008000 Surface Coating /Traffic Markings /Total: All Solvent Types

2461020000 Misc Non-industrial: Commercial /Asphalt Application: All Processes /Total: All

2461021000 Misc Non-industrial: Commercial /Cutback Asphalt /Total: All Solvent Types

2461022000 Misc Non-industrial: Commercial /Emulsified Asphalt /Total: All Solvent Types

2461023000 Misc Non-industrial: Commercial /Asphalt Roofing /Total: All Solvent Types

2601000000 On-site Incineration /All Categories /Total

2601010000 On-site Incineration /Industrial /Total

2601010000 On-site Incineration /Industrial /Total

2601020000 On-site Incineration /Commercial/Institutional /Total

2601020000 On-site Incineration /Commercial/Institutional /Total

2601030000 On-site Incineration /Residential /Total

2610000100 Open Burning /All Categories /Yard Waste - Leaf Species Unspecified

2610000400 Open Burning /All Categories /Yard Waste - Brush Species Unspecified

2610000500 Open Burning /All Categories /Land Clearing Debris (use 28-10-005-000 for Loggin

2610030000 Open Burning /Residential /Household Waste (use 26-10-000-xxx for Yard Wastes)

2610040400 Open Burning /Municipal (from residences, parks,other for central burn) 

2660000000 Leaking Underground Storage Tanks /Leaking Underground Storage Tanks /Total: All

2680001000 Composting /100% Biosolids (e.g., sewage sludge, manure, mixtures of these matls

2680002000 Composting /Mixed Waste (e.g., a 50:50 mixture of biosolids and green wastes)

2806010000 Domestic Animals Waste Emissions /Cats /Total

2806015000 Domestic Animals Waste Emissions /Dogs /Total

2807020001 Wild Animals Waste Emissions /Bears /Black Bears

2807020002 Wild Animals Waste Emissions /Bears /Grizzly Bears

2807025000 Wild Animals Waste Emissions /Elk /Total

2807030000 Wild Animals Waste Emissions /Deer /Total

2807040000 Wild Animals Waste Emissions /Birds /Total

2810001000 Forest Wildfires - Wildfires – Unspecified

2810005000 Managed Burning, Slash (Logging Debris) /Unspecified Burn Method

2810010000 Human Perspiration and Respiration /Total

2810014000 Prescribed Burning /Generic - Unspecified land cover, ownership, class/purpose

2810015000 Prescribed Forest Burning /Unspecified

2810020000 Prescribed Rangeland Burning /Unspecified

2810030000 Structure Fires /Unspecified

2810035000 Firefighting Training /Total

2810050000 Motor Vehicle Fires /Unspecified

2810060200 Cremation /Animals

2810090000 Open Fire /Not categorized

2820010000 Cooling Towers /Process Cooling Towers /Total

2830000000 Catastrophic/Accidental Releases /All Catastrophic/Accidental Releases /Total

2830010000 Catastrophic/Accidental Releases /Transportation Accidents /Total
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3.6 EPA 2020 PROJECTIONS FOR RESIDENTIAL WOOD AND 

LIVESTOCK 

EPA’s Office of Air Quality Planning and Standards (OAQPS) made available its 2020 

emissions projections associated with its 2005-based v4 modeling platform. MARAMA 

used the OAQPS emission projection parameters for two area source sectors –livestock 

and residential wood combustion. OAQPS’s methodology and data sources are 

summarized below (USEPA 2008a). 

OAQPS projected residential wood combustion emissions are based on the expected 

increase in the number of low-emitting wood stoves and the corresponding decrease in 

other types of wood stoves. As newer, cleaner woodstoves replace older, more polluting 

stoves, there will be an overall reduction of emissions from this category. The approach 

used by OAQPS was developed as part of a modeling exercise to estimate the expected 

benefits of the woodstove changeout program. This methodology uses a combination of 

growth and control factors and is based on activity not pollutant. The growth and control 

are accounted for in a single factor for each residential wood SCC (certain SCCs represent 

controlled equipment, while other SCCs represent uncontrolled equipment). Control 

factors are indirectly incorporated based on which stove is used. The specific assumptions 

OAQPS made were: 

Fireplaces, SCC=2104008001: increase 1%/year; 

Old woodstoves, SCC=2104008002, 2104008010, 2104008051: decrease 2%/year; 

New woodstoves, SCC=2104008003, 2104008004, 2104008030, 2104008050, 

2104008052 or 2104008053: increase 2%/year. 

For the general woodstoves and fireplaces category (SCC 2104008000) OAQPS computed 

a weighted average distribution based on 19.4% fireplaces, 71.6% old woodstoves, 9.1% 

new woodstoves using 2002 Platform emissions for PM2.5. These fractions are based on 

the fraction of emissions from these processes in states that did not have the “general 

woodstoves and fireplaces” SCC in the 2002 NEI. This approach results in an overall 

decrease of 1.056% per year for this source category. Appendix F contains the residential 

wood projection data from OAQPS. 

OAQPS based growth in emissions from livestock on projections of growth in animal 

population. Except for dairy cows and turkeys, the animal projection factors are derived 

from national-level animal population projections from the U.S. Department of Agriculture 

(USDA) and the Food and Agriculture Policy and Research Institute (FAPRI). 
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For dairy cows and turkeys OAQPS assumed that there would be no growth in emissions. 

This assumption was based on an analysis of historical trends in the number of such 

animals compared to production rates. While productions rates have increased, the number 

of animals has declined. In particular, the dairy cow population is projected to decrease in 

the future as it has for the past few decades; however, milk production is expected to 

increase over the same period. Thus, OAQPS does not believe that production forecasts 

provide representative estimates of the future number of cows and turkeys. Therefore, 

OAQPS did not use these forecasts for estimating future-year emissions from these 

animals. Note that the ammonia emissions from dairies are related to both animal 

population and nitrogen excretion. Appendix G contains the livestock projection data from 

OAQPS. 

3.7 SCC, SIC, NAICS AND GROWTH PARAMETER CROSSWALK 

Since the employment projections were based on 3-digit NAICS code, it was necessary to 

map NAICS codes to SCCs and SIC codes that were used by states. Employment 

projections at the more specific 4-digit or 6-digit NAICS codes were not available. 

The first step for developing a comprehensive crosswalk between the different source 

classification codes (SCC, SIC, and NAICS codes) and emission activity growth indicators 

was to compile a complete list of the NAICS codes in the 2007 point source inventory. 

Some states use the SIC code while other use the NAICS code. Still other states use both 

the SIC and NAICS codes. When the NAICS code was not available SIC codes were 

converted to NAICS codes. The 6-digit NAICS code was truncated to a 3-digit code, 

which represents major industry subsectors of the economy. A U.S. Census Bureau 

document was used to perform this conversion (CENSUS 2000). 

The next step was to review parameters that could be used as the emission activity growth 

indicator for each SCC or NAICS. We initially relied on two USEPA crosswalks (USEPA 

2004a, USEPA 2004b) to match area and nonEGU point source SCCs to AEO2010 

categories, employment NAICS codes, and population. The sector specific spreadsheets 

identify the growth parameter used to project emissions for each SCC.

3.8 FINAL GROWTH FACTORS FOR NONEGU / AREA SOURCES 

The previous section described the growth factors initially recommended to project future 

year emissions inventories for area and non-EGU sources. Draft growth and control 

factors, and a draft technical support document, were circulated for review by MARAMA 

and state agencies. During the review, it was noted that several emissions categories show 
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negative growth into the future, particularly categories related to fossil fuel combustion 

and manufacturing employment. 

Many of the growth factors used to project emissions for area and non-EGU sources were 

based on the AEO2010 fuel consumption forecasts and state-level employment projections. 

The AEO2010 forecasts show declining trends for many fuel consumption sectors, 

especially industrial, residential, and commercial distillate fuel oil use. Similarly, the 

employment projections show declines in the predicted number of employees for many 

sectors of the economy. This is particularly true for the manufacturing sector, which is of 

interest because this sector is often associated with higher emissions than those for other 

sectors. By contrast, the employment projections show increasing trends in retail and 

service-related sectors. However, these sectors are not typically associated with 

significant emissions. 

Predicted declines in fuel use and employment resulted in growth factors less than unity 

(i.e., represent negative growth) for many area and non-EGU point source categories. 

Consequently, for some categories, emissions are lower for the projected future years than 

for the base year, even before the application of control assumptions (i.e. the future 

"growth only" emissions are lower than the base year emissions). The MARAMA 

emissions inventory workgroup met on several occasions via conference calls and email 

exchanges to discuss whether the negative growth projections were realistic, and what 

additional assumptions should be made. A topic of particular concern is negative growth 

for non-EGU point sources versus the treatment of Emissions Reduction Credits (ERCs) in 

the future year inventories (see Section 3.9 for a discussion of how ERCs were handled). 

One conclusion the workgroup reached is that growth methods and assumptions for area 

sources and non-EGUs should be as consistent as possible with those that are being used 

by the Eastern Regional Technical Advisory Committee (ERTAC) for the projection of 

emissions from EGUs. ERTAC is using AEO2010 as a starting point for estimating 

projected future year emissions, and their preliminary analysis shows some indications of 

negative growth. But their analysis is still on-going, and it is too early in the process to 

draw firm conclusions or make solid recommendations at this time regarding their work 

and its relationship to the area and non-EGU projections. 

A few states cited the importance of the negative growth issue for non-EGUs and how it 

relates to their ERC programs which are critical to new businesses being able to locate in 

those states. Because businesses could apply for and sell ERCs at the level of the base 

year inventory, it would not be realistic to show negative growth for non-EGU point 

sources. During an economic downturn, a facility could shut down and sell its ERCs, 
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making the effective level of future year emissions equal to (i.e. no lower than) the base 

year. Therefore, a recommended conservative approach for addressing negative growth for 

non-EGU point sources is to set a minimum growth rate of 1 (no growth). 

During the July 23, 2010 conference call held to discuss the negative growth issue, state 

and agency representatives on the call were polled as to whether or not they felt that the 

current set of proposed growth factors - including the negative growth factors - were 

realistic for their state or district. In reply, some representatives mentioned that they have 

observed historic state-specific data that supports the trends displayed by the proposed 

growth factors. Other representatives mentioned that they feel comfortable with the 

growth factors and don't have a technical basis to change them or suggest others. 

As a result of these discussions, each state provided guidance on how to handle projections 

when negative growth is indicated. Exhibit 3.10 shows the state recommendations for 

nonEGU point source, and Exhibit 3.11 shows the state recommendations for area sources. 

The sector specific spreadsheets identify the growth parameter used to project emissions 

for each SCC. 

3.9 EMISSION REDUCTION CREDITS 

Mulitple states (Connecticut, Maryland, Massachesetts, New Hampshire and New Jersey) 

added county level records account for account emission reduction credits (ERCs) issued 

to stationary sources pursuant to state regulations. States provided ERCs on a county-bycounty basis. Fictitious facilities with an identifier of “OFFSET99999” were created for 

each county using SCC 23-99-000-000 (miscellaneous industrial processes: not elsewhere 

classified). Stack data were developed that assumed that emissions were released at the 

county centroid with an assumed release height of 10 feet. For the 2017 and 2020 

inventories, ERC emissions were set to the amount of banked emissions available in 2007. 

Delaware included the banked credits at the specific locations that they were generated. 

Virginia does not have a formal banking and trading program. Virginia used growth rates 

of 1 for those SCCs in the point source emissions inventory that showed a negative growth. 

In addition, for units that have or are projected to have shut down, Virginia preserved the 

2007 emissions in the inventory to account for potential use as offsets or credits. 

Other states did not provide any additional information on how to account for ERCs. 
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Exhibit 3.10 State Recommendations to Address Negative Growth 

for the NonEGU Point Source Sector 

State AEO Growth Factors Employment Growth Factors

CT Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use state DOL employment projections by 3-

digit NAICS 

DE Use AEO2010 growth rates For 2013, use state DOL employment 

projections by 3-digit NAICS; 

For 2017 and 2020, use no growth (growth 

factor=1) when employment growth is 

negative; otherwise use employment if 

positive growth

DC Use AEO2010 growth rates Use 2008-2018 employment projections; use 

no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth

ME Use AEO2010 growth rates Use state DOL employment projections by 3-

digit NAICS 

MD Do not use AEO growth factors 

Use MD DOL employment projections for 

industrial and commercial fuel use SCCs, 

unless employment growth rate is negative, in 

which case use no growth (growth factor=1)

Use updated state DOL employment 

projections by 3-digit NAICS; 

For DoD facilities, account for impacts of Base 

Realignment and Closure;

For source that have closed, account for 

emission reduction credits

MA Use AEO2010 growth rates Use state DOL employment projections by 3-

digit NAICS 

NH Use AEO2010 growth rates Use state DOL employment projections by 3-

digit NAICS 

NJ New Jersey submitted state specific growth 

factors. Used either state specific growth 

factors, no growth (growth factor=1) when 

state AEO growth is negative or AEO if 

positive growth

NJ submitted state specific growth factors. 

Used either state specific factors, no growth 

(growth factor=1) when state DOL 

employment growth is negative or

employment if positive growth

NY Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth

PA Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth

RI Use AEO2010 growth rates Use state DOL employment projections by 3-

digit NAICS 

VT Use AEO2010 growth rates Use state DOL employment projections by 3-

digit NAICS 

VA Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth
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Exhibit 3.11 State Recommendations to Address Negative Growth 

and Other Growth Factors for the Area Source Sector 

State AEO Growth Factors Employment 

Growth Factors

Population 

Growth Factors

CT Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS 

Use county-level 

population projections

DE Use AEO2010 growth rates; no 

growth for suspect AEO2010 

projection for commercial / 

institutional residual oil

For 2013, use state DOL 

employment projections by 3-digit 

NAICS; For 2017 and 2020, use 

no growth (growth factor=1) when 

employment growth is negative; 

otherwise use employment if 

positive growth

Use county-level 

population projections

DC Use AEO2010 growth rates; no 

growth for suspect AEO2010 

projection for commercial / 

institutional residual oil

Use DOL employment growth for 

NAICS 722 for food and kindred 

product SCC; otherwise use 

orginial estimates

For dry cleaning, use 

employment growth for 

NAICS 812 instead of 

population

ME Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

MD Not using AEO2010; used 

employment for commercial & 

institurional fuel; used housing 

units for residential fuel

Provided updated employment 

projections; changed xwalk 

between NAICS code and SCC 

for selected source categories

Provided updated 

population projections 

by county

MA Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

NH Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

NJ NJ submitted state specific 

growth factors. For fuel 

combustion categories only, 

used AEO2011 growth rates 

except for residual oil (use no 

growth)

NJ submitted state specific 

growth factors.

NJ submitted state 

specific growth factors 

and provided 

population projections 

by county

NY Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

PA Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

RI Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

VT Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

VA Use AEO2010 growth rates; no 

growth for suspect AEO2010 

projection for commercial / 

institutional residual oil

Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections
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4.0 AREA SOURCE CONTROL FACTORS 

Control factors were developed to estimate post-2007 emission reductions resulting from 

on-the-books regulations and proposed regulations/actions. Control factors were 

developed for the following national and regional measures: 

Federal Rules Affecting Area Sources 

Federal MACT Rules 

Control Technique Guidelines 

OTC Model Rules 

These control programs are discussed in the following subsections. The control factors 

used for area sources are provided in V3_3 Area_07_17_20.xlsx 

4.1 FEDERAL RULES AFFECTING AREA SOURCES 

USEPA made available its 2020 emissions projections associated with its 2005-based v4 

modeling platform (USEPA 2010b). USEPA accounted for control strategies for four area 

source categories. These categories, and their treatment in the emission projection 

inventories, are described below: 

Woodstoves - As noted in Section 3.6, USEPA developed projection factors to 

account for the replacement of retired woodstoves that emit at pre-new source 

performance standard (NSPS) levels with lower-emitting woodstoves. We used

USEPA’s latest methodology which uses a combination growth and control factor 

and is based on activity and not pollutant. The growth and control are accounted 

for in a single factor for specific SCCs that account for the turnover from pre-NSPS 

to post-NSPS woodstove. 

Landfills: USEPA estimated a 75% reduction in VOC emissions from municipal 

solid waste landfills. However, since the compliance date for this standard was 

January 2004, no post-2007 reductions were applied to the MANE-VU+VA 

projection inventory since the emission reductions from this MACT standard 

should be reflected in the 2007 inventory and not as an additional post-2007 credit. 

Vehicle Refueling (Stage II): VOC emissions from the gasoline Stage II (vehicle 

refueling) are affected by two emission control programs. Many areas in the region 

have Stage II vapor recovery rules that were in effect prior to 2007 that require the 

capture of gasoline vapors generated when a motor vehicle fuel tank is filled at a 

gasoline station. The vapors are transferred from the fuel tank in the vehicle to the 

storage tank at the station as the vehicle fuel tank is filled. Beginning with the 

1998 model year, USEPA established a phase-in schedule requiring vehicles to 
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incorporate on-board equipment to capture the gasoline vapor emissions from 

refueling. These controls, referred to as on-board refueling vapor recovery 

(ORVR), have been required on the vast majority of gasoline powered motor 

vehicles since the 2006 model year. VOC emissions for 2020 from vehicle 

refueling were estimated by NESCAUM using the MOVES model 

(NESCAUM2011). VOC emissions for 2017 were estimated by interpolating 

between the MOVES 2007 and 2020 results. Appendix H contains the VOC control 

efficiencies by county used in the MOVES modeling for displacement losses and 

for spillage losses. 

Portable fuel containers (PFCs): VOC emissions from PFCs will be reduced due to 

the federal regulation controlling air toxic emissions from mobile sources 

promulgated in 2007. Most northeastern and mid-Atlantic states had already 

adopted similar regulations prior to the federal rule. Refer to the OTC 2006 model 

rules subsection later in this document (Section 4.4.6) for a discussion of the 

approach for accounting for VOC emission reductions from PFCs. 

4.2 FEDERAL MACT RULES 

USEPA developed guidance for estimating VOC and NOx emission changes from MACT 

Rules (USEPA 2007b). We reviewed the guidance to identify possible area source 

controls associated with the federal maximum achievable control technology (MACT) 

standards for controlling hazardous air pollutants (HAPs). Although designed to reduce 

HAPs, many of the MACT standards also provide a reduction in criteria air pollutants. 

The USEPA document provides an estimate of the percent reduction in VOC and NOx 

from each standard, and the compliance date for the standard. This information was used 

to determine whether the MACT standard provided post-2007 emission reductions. For 

example, if a compliance period of a MACT standard was 2007 or earlier, then we 

assumed that the emission reductions from the MACT standard should be reflected in the 

baseline year and not as an additional post- 2007 credit. 

Only one area source category was listed in the USEPA guidance document - municipal 

solid waste landfills. Since the compliance date for this standard was January 2004, no 

post-2007 reductions were applied since the emission reductions from the MACT standard 

should be reflected in the 2007 inventory and not as an additional post-2007 credit. 

USEPA has or will soon develop MACT standards for about 70 area source categories. 

We reviewed USEPA’s 2020 emissions projections described in the previous section and 

found that USEPA did not include emission reductions from recent area source MACT 

standards. We conducted a review of USEPA’s air toxic website and found that USEPA 
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determined that many area source MACT standards would result in nationwide reductions 

in criteria air pollutants in addition to the reductions in HAP emissions. However, many 

states in the MANE-VU+VA region already have emission standards for many categories 

that are as stringent as the Federal area source MACT standards. For example, many states 

in the MANE-VU+VA region already have requirements as stringent as the Gasoline 

Distribution MACT and GACT (generally achievable control technology) standards, and 

little additional VOC reductions would be realized in the region. Given the resources 

allocated to this project, it was beyond the scope to conduct an analysis of the area source 

MACT requirements and state-by-state emission regulations to determine whether there 

would be emission reductions resulting from the area source MACT standards. 

The only exception to the above discussion of area source MACT standards pertains to the 

recently promulgated rules for reciprocating internal combustion engines (RICE). USEPA 

made available an estimate of the percent reduction in emissions attributable to the RICE 

MACT rule in 2012 and 2014 (USEPA 2010c). The USEPA 2014 estimates shown in 

Exhibit 4.1 were used for the MANE-VU+VA 2017 and 2020 inventories. 

4.3 RECENT CONTROL TECHNIQUE GUIDELINES 

Control Techniques Guidelines (CTGs) are documents issued by USEPA to provide states 

with recommendation on VOC controls from a specific product or source category in an 

ozone nonattainment area. USEPA issued new or updated CTGs for 13 VOC categories in 

3 groups during 2006, 2007 and 2008 (USEPA 2008b). The categories are: 

2006 CTGs 

 Flat Wood Paneling Coatings 

 Industrial Cleaning Solvents 

 Flexible Package, Lithographic and Letterpress Printing 

2007 CTGs 

 Large Appliance Surface Coating 

 Metal Furniture Coatings 

 Paper Film and Foil Coatings 

2008 CTGs 

 Miscellaneous Metal Parts Coatings 

 Plastic Parts Coatings 

 Auto and Light-duty Truck Assembly Coatings 

 Fiberglass Boat Manufacturing 

 Miscellaneous Industrial Adhesives 

States indicated that they expected very littleadditional reductions from these new or 

amended CTGs. Therefore, no emission reductions were included in the inventory.
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Exhibit 4.1 USEPA Estimated Percent Reductions for RICE MACT Standard by 2014 

SCC CO NOx PM10 PM2.5 VOC SCC Description

2101004000 12.42 7.57 7.57 30.85 Electric Utility;Distillate Oil;Total: Boilers and IC Engines

2101004002 16.9 11.81 11.81 33.78 Electric Utility;Distillate Oil;All IC Engine Types

2101006000 11.07 7.97 16.71 Electric Utility;Natural Gas;Total: Boilers and IC Engines

2101006002 15.47 9.87 21.24 Electric Utility;Natural Gas;All IC Engine Types

2102004000 12.42 7.57 7.57 30.85 Industrial;Distillate Oil;Total: Boilers and IC Engines

2102006000 11.07 7.97 16.71 Industrial;Natural Gas;Total: Boilers and IC Engines

2102006002 15.47 9.87 21.24 Industrial;Natural Gas;All IC Engine Types

2103004000 12.42 7.57 7.57 30.85 Commercial/Institutional;Distillate Oil;Total: Boilers and IC Engines

2103006000 11.07 7.97 16.71 Commercial/Institutional;Natural Gas;Total: Boilers and IC Engines

2199004000 12.42 7.57 7.57 30.85 Area Source Fuel Combustion;Distillate Oil;Total: Boilers and IC Engines

2199004002 16.9 11.81 11.81 33.78 Area Source Fuel Combustion;Distillate Oil;All IC Engine Types

2199006000 11.07 7.97 16.71 Area Source Fuel Combustion;Natural Gas;Total: Boilers and IC Engines

2310000000 19.86 12.53 23.87 Oil and Gas Production: All Processes;Total: All Processes

2310000220 19.86 12.53 23.87 Oil and Gas Exploration/Production; Drill Rigs

2310000440 19.86 12.53 23.87 Oil and Gas Exploration/Production; Saltwater Disposal Engines

2310001000 19.86 12.53 23.87 Oil and Gas Production: SIC 13; On-shore;Total: All Processes

2310002000 19.86 12.53 23.87 Oil and Gas Production: SIC 13; Off-shore;Total: All Processes

2310020000 19.86 12.53 23.87 Oil and Gas Production: SIC 13;Natural Gas;Total: All Processes

2310020600 19.86 12.53 23.87 Oil and Gas Exploration and Production;Natural Gas;Compressor 

Engines

2310023000 19.86 12.53 23.87 Oil and Gas Exploration and Production;Natural Gas;Cbm Gas Well -

Dewatering Pump Engines
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 37

4.4 OTC MODEL RULES FOR AREA SOURCES 

The Ozone Transport Commission (OTC) developed model rules for member states in 

2001 for several area source categories: consumer products, architectural and industrial 

maintenance (AIM) coatings, portable fuel containers (PFCs), mobile equipment repair and 

refinishing, solvent cleaning, and industrial boilers. In 2006 the OTC introduced model 

rules for two additional area source categories (adhesives/sealants and asphalt paving), 

more stringent requirements for consumer products, portable fuel containers, and industrial 

boilers. In 2009/2010, the OTC recommended additional controls for autobody refinishing 

operations, consumer products, AIM coatings, and small new natural gas-fired boilers. In 

addition, MANE-VU states committed to the use of low sulfur home heating, distillate and 

residual fuel oil. Exhibit 4-2 briefly describes the OTC and MANE-VU control measures 

affecting area sources that have been recommended for adoption by the states in the OTR. 

Individual states are in various stages of adopting the OTC recommendations into their 

rules and SIPs. OTC’s status reports were reviewed to identify each state’s adoption status 

(OTC 2009, OTC 2011a, OTC2011b). To obtain further clarification, states were polled to 

determine whether they have adopted a rule that would achieve reductions equivalent to 

the OTC model rule or recommendation and whether credit for each rule was already 

accounted for in the 2007 inventory. 

To evaluate the impact of the rules currently in place as well as the potential adoption of all 

control measures by all states except Virginia, the state Air Directors specified that two 

emission control scenarios should be developed as follows: 

Existing Controls - this scenario represents the best estimates for the future year, 

accounting for all in-place controls that are fully adopted into federal or individual 

state regulations or SIPs. 

Potential New OTC Controls – this scenario accounts for all of the emission 

reductions from the existing control scenario plus new state or regional measures 

that are under consideration by the OTC or individual states. This is a “what if” 

scenario that assumes that all states in the MANE-VU+VA region except Virginia 

will adopt all new OTC control measures under consideration by 2017. It does 

not include any potential new federal control measures that are under consideration. 

The following paragraphs describe the control factors applied for each control measure by 

state and future year. 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 38

Exhibit 4.2 Summary of Area Source OTC Control Measures 

Source Category Pollutants Description

Consumer Products VOC OTC 2001. Specified VOC content limits for certain 

categories that are more stringent than Federal limits

OTC 2006. Included additional products and more 

restrictive VOC limits for certain products

OTC 2009/2010. Specified more restrictive VOC limits 

for 14 existing consumer product categories and three 

new categories

Architectural and Industrial 

Maintenance Coatings

VOC OTC 2001. Specified VOC content limits for certain 

categories that are more stringent than Federal limits

OTC 2009/2010. Eliminated 15 categories (replaced 

by new categories or deemed unnecessary), added 

10 new categories, and specified stricter VOC limits 

for 19 categories

Portable Fuel Containers VOC OTC 2001. Provided container design specifications 

to reduce emissions from spillage and evaporation

OTC 2006. Revised and clarified design specifications

and added kerosene containers and utility jugs.

Mobile Equipment Repair 

and Refinishing

VOC OTC 2001. Required use of high efficiency coating 

application equipment, spray gun cleaning equipment 

that minimizes solvent loss, and enclosed spray gun 

cleaning.

OTC 2009/2010. Limited the VOC content of coatings

more stringent than the Federal limits and the VOC 

content of cleaning solvents

Solvent Cleaning VOC OTC 2001. Established hardware and operating 

requirements for specified vapor cleaning machines, 

and solvent volatility limits and operating practices for 

cold cleaners 

Adhesives and Sealants VOC OTC 2006. Provided VOC content limits and other 

restrictions on adhesives used primarily by 

commercial and industrial users. 

Asphalt Paving VOC OTC 2006. Suggested VOC content limits for 

emulsified and cutback asphalts use for road paving

NOx ICI Boiler Controls NOx OTC 2001. Recommended NOx emission rate limits 

for industrial boilers greater than 5 mmBtu/hour

OTC 2006. Recommended lower NOx emission rate 

limits for industrial, commercial, and institutional 

boilers

OTC 2010. Recommended national NOx controls for 

ICI boilers

Small Natural Gas-Fired 

Boilers

NOx OTC 2009/2010. Recommended NOx emission rate 

limits for new boilers less than 5 mmBtu/hr

Low Sulfur Fuel Oil SO2 MANE-VU 2006. Recommends sulfur content limits 

for home heating oil, distillate oil, and residual oil
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 39

4.4.1 OTC Model Rule for Adhesives/Sealants 

VOC emissions in this category are primarily from commercial applications such as floor 

covering installation (carpet and wood flooring), roof installations and repair and 

upholstery shops. The category also includes industrial applications such as wood product 

manufacturers. Adhesives in small containers are not included in this category but are 

regulated under the consumer products regulations. 

The OTC 2006 model rule for industrial adhesives and sealants is based on the reasonably 

available control technology (RACT) and best available retrofit control technology 

(BARCT) determination by the California Air Resources Board (CARB) developed in 

1998. The OTC model rule regulates the application of adhesives, sealants, adhesive 

primers and sealant primers by providing options for appliers to either use a product with a 

VOC content equal to or less than a specified limit or to use add-on controls to achieve an 

equivalent reduction. The emission reduction benefit estimation methodology for area 

sources is based on information developed and used by CARB as discussed in their 1998 

RACT report. A 64.4 percent reduction in VOC emissions was estimated for SCC 24-40-

020-000. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in VOC emissions should be applied in 2017 and 2020. State-by-state 

recommendations are shown in Exhibit 4.3. 

It should be noted that not all states account for emissions from this category in a separate 

area source inventory. Some states, based on information received from USEPA, excluded 

this category because the emissions to some extent may be accounted for in the area source 

commercial and consumer products category or in the nonEGU point source inventory. 

Exhibit 4.3 State Recommendations for OTC Industrial Adhesives/Sealants Rule 

State

Is Rule 

Accounted 

for in 2007 

Inventory*

Incremental VOC Reduction to Apply:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

CT No 64.4 0 64.4 0

DE No 64.4 0 64.4 0

DC No n/a n/a n/a n/a

ME No 64.4 0 64.4 0

MD No 64.4 0 64.4 0
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 40

State

Is Rule 

Accounted 

for in 2007 

Inventory*

Incremental VOC Reduction to Apply:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

MA No 64.4 0 64.4 0

NH No n/a n/a n/a n/a

NJ No 64.4 0 64.4 0

NY No 64.4 0 64.4 0

PA No 64.4 0 64.4 0

RI No n/a n/a n/a n/a

VT n/a n/a n/a n/a n/a

VA No n/a n/a n/a n/a

* n/a means SCC 24-40-020-000 not included in 2007 inventory; see text for further discussion 

4.4.2 OTC Model Rules for Architectural and Industrial Maintenance Coatings 

On August 14, 1998, USEPA issued the final version of their National Volatile Organic 

Compound Emission Standards for Architectural Coatings under Section 183(e) of the 

Clean Air Act. This final rule applied only to manufacturers and importers of architectural 

coatings, and set VOC content limits for 61 coating categories. This rule specifically 

allowed states or local governments to adopt more stringent coating limits. 

The OTC adopted an AIM model rule more stringent than the national rule, and based 

primarily on the 2000 CARB suggested control measure (SCM) for AIM coatings. The 

2001 OTC model rule was estimated to provide a 31 percent incremental reduction in VOC 

emissions compared to the Federal Part 59 rule and was applied to the following SCCs: 

24-01-001-000 All Architectural Coatings 

24-01-002-000 Architectural Coatings Solvent Based 

24-01-003-000 Architectural Coatings Water Based 

24-01-008-000 Traffic Markings 

24-01-100-000 Industrial Maintenance Coatings 

24-01-200-000 Other Special Purpose Coatings 

The OTC 2009/2010 model rule is an update of the 2001 model rule. It is based the 2007 

CARB suggested control measure. The OTC 2009/2010 rule includes new categories 

which were defined in the 2007 CARB measure and revised limits for several coating 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 41

categories In addition to the revised limits in the 2007 CARB SCM, the OTC model rule 

also includes a more stringent VOC limit for the Industrial Maintenance (IM) coating 

category that was included in the 2000 CARB SCM. The 2000 CARB SCM proposed a 

limit of 250 g/L with an optional limit of 340 g/L for colder climates. The 2002 OTC 

model rule included the 340 g/l due to concerns about the ability to comply in the colder 

northeast. Because of the success of implementing the revised limit throughout California 

and the advent of t-butyl acetate as a delisted solvent, OTC believes a 250 g/L VOC limit 

is now feasible and has included this new lowered limit in the 2010 model rule. 

The CARB SCM data was used to estimate a 34.4 percent reduction for architectural 

coatings and a 9.7 percent reduction for traffic markings. For industrial maintenance 

coatings, a 26.5 percent reduction was estimated based on lowering the VOC content limit 

from 340 g/L to 250 g/L. Other specialty coatings are another form of industrial high 

performance maintenance coatings (IM), so the IM control factor was also used for the 

other specialty coatings SCC. 

States were polled to determine whether they had adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in VOC emissions should be applied in 2017 and 2020. Many states adopted the 

rule prior to 2007 and have already accounted for the reductions attributable to the rule in 

their 2007 inventories. Other states had compliance dates after 2007 and the effect of the 

rule was not accounted for in their 2007 inventory. State-by-state recommendations to 

account for the AIM rule are shown in Exhibit 4.4. 

Exhibit 4.4 State Recommendations for OTC AIM Rule 

State

Is OTC 

2001 Rule 

Accounted 

for in 2007 

Inventory*

Incremental VOC Percent Reduction to Apply:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

CT No 31 AIM

34.4 ARCH

9.7 TM

26.5 IM

31 AIM

34.4 ARCH

9.7 TM

26.5 IM

DE Yes 0 AIM

34.4 ARCH

9.7 TM

26.5 IM

0 AIM

34.4 ARCH

9.7 TM

26.5 IM

DC Yes 0 AIM

34.4 ARCH

9.7 TM

26.5 IM 0 AIM

34.4 ARCH

9.7 TM

26.5 IM

ME No 31 AIM 34.4 ARCH

9.7 TM 31 AIM 34.4 ARCH9.7 TM
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 42

State

Is OTC 

2001 Rule 

Accounted 

for in 2007 

Inventory*

Incremental VOC Percent Reduction to Apply:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

26.5 IM 26.5 IM

MD Yes 0 AIM

34.4 ARCH

9.7 TM

26.5 IM

0 AIM

34.4 ARCH

9.7 TM

26.5 IM

MA No 31 AIM

34.4 ARCH

9.7 TM

26.5 IM

31 AIM

34.4 ARCH

9.7 TM

26.5 IM

NH No 0 AIM

55.5 ARCH

37.7 TM

49.4 IM

0 AIM

55.5 ARCH

37.7 TM

49.4 IM

NJ Yes 0 AIM

34.4 ARCH

9.7 TM

26.5 IM

0 AIM

34.4 ARCH

9.7 TM

26.5 IM

NY Yes 0 AIM

34.4 ARCH

9.7 TM

26.5 IM

0 AIM

34.4 ARCH

9.7 TM

26.5 IM

PA Yes 0 AIM

34.4 ARCH

9.7 TM

26.5 IM

0 AIM

34.4 ARCH

9.7 TM

26.5 IM

RI No 31 AIM

34.4 ARCH

9.7 TM

26.5 IM

31 AIM

34.4 ARCH

9.7 TM

26.5 IM

VT No 0 AIM

55.5 ARCH

37.7 TM

49.4 IM

0 AIM

55.5 ARCH

37.7 TM

49.4 IM

VA-NVA Yes 0 AIM 0 AIM 0 AIM 0 AIM

VA-FRD No 31 AIM 0 AIM 31 AIM 0 AIM

VA-Other No 0 AIM 0 AIM 0 AIM 0 AIM

AIM – includes all AIM coatings listed below: 

ARCH – architectural 

TM - traffic markings 

IM - industrial maintenance 

VA-NVA includes the cities/counties in the Northern Virginia emission control area 

VA-FRD includes the cities/counties in the Fredericksburg emission control area 

VA-Other includes cities/counties in Virginia not listed above 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 43

4.4.3 OTC Model Rule for Asphalt Paving 

OTC Resolution 06-02 recommends that states establish rules to achieve a 20 percent 

reduction in VOC emissions from the application and use of emulsified and cutback 

asphalt. The reductions apply to the following SCCs: 

24-61-021-000 Cutback Asphalt 

24-61-022-000 Emulsified Asphalt 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in VOC emissions should be applied in 2017 and 2020. Some states adopted the 

rule prior to 2007 and have already accounted for the reductions attributable to the rule in 

their 2007 inventories. Other states had compliance dates after 2007 and the effect of the 

rule was not accounted for in their 2007 inventory. State recommendations to account for 

the asphalt paving recommendation are shown in Exhibit 4.5. 

Exhibit 4.5 State Recommendations for OTC Cutback and Emulsified 

Asphalt Paving Recommendation 

State

Is Rule 

Accounted 

for in 2007 

Inventory*

Incremental VOC Percent Reduction to Apply:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

CT No 20 0 20 0

DE Yes 0 0 0 0

DC No 0 20 0 20

ME No emissions 

in inventory 0 0 0 0

MD No 0 20 0 20

MA No 20 0 20 0

NH No 0 20 0 20

NJ No 56% Cutback

25% Emulsified 0

56% Cutback

25% Emulsified 0

NY No 20 0 20 0

PA No 0 20 0 20

RI No 20 0 20 0

VT No emissions 

in inventory 0 0 0 0

VA-NVA No 0 0 0 0

VA-Other No 0 0 0 0
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 44

4.4.4 OTC Model Rules for Consumer Products 

Several states began regulating the VOC content of consumer products in the early 1990s. 

The USEPA promulgated a national rule in 1998 (40CFR, Part 59, Subpart C). Both the 

California Air Resources Board (CARB) and the OTC states have periodically updated 

their state rules to obtain VOC reductions beyond those required by the federal rule. 

Following the lead of CARB, the OTC 2001 model rule for consumer products adopted 

more stringent VOC content limits for certain categories. The OTC 2006 model rule 

modified the OTC 2001 model rule based on amendments adopted by CARB in July 2005 

to include additional products and more stringent VOC limits for certain products. CARB 

amended their rules again in 2006 and the OTC 2010 model rule is based on those 

amendments. 

The OTC 2010 model amendments have more restrictive VOC limits for 14 existing 

consumer product categories (15 including subcategories) and three new categories (five 

including subcategories) will be regulated for the first time with VOC limits. The OTC 

2010 model rule amendments also clarify or modify previously defined or regulated 

categories. The model rules also contained optional prohibitions on the use of chlorinated 

toxic compounds in certain consumer product categories. CARB adopted these provisions 

simultaneous with their VOC limits to address the use of non-VOC chlorinated solvent use 

increasing as they are used as replacement compounds. 

The VOC percentage reduction from the various rules and amendments are summarized in 

Exhibit 4.6. The emissions reductions from the latest OTC consumer products rule update 

used information developed by CARB for its 2006 amendments. The OTC estimated a 4.8 

percent reduction of the total consumer products inventory for states that included CARB’s 

ban of chlorinated toxic compounds in brake cleaners, and an estimated 3.3 percent 

reduction of the total consumer products inventory for states that did not include this ban. 

States reported VOC emissions from consumer products inventory in two different 

manners – using an aggregated SCC or subcategory SCCs, as follows: 

Aggregated SCC: 24-60-000-000 Consumer Products, All Products 

24-65-000-000 Consumer Products, All Products 

Disaggregated SCCs: 24-60-100-000 Consumer Products, Personal Care Products 

24-60-200-000 Consumer Products, Household Products 

24-60-400-000 Consumer Products, Auto Aftermarket Products 

24-60-500-000 Consumer Products, Coatings 

24-60-600-000 Consumer Products, Adhesives and Sealants 

24-60-800-000 Consumer Products, FIFRA Products 

24-60-900-000 Consumer Products, Misc. Products 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 45

Exhibit 4.6 VOC Emission Factors for Consumer Products

Uncontrolled Emission Factor: = 7.84 lbs/capita

Emission Factor after 1998 Federal Rule: = 7.06 lbs/capita

Percent Reduction from 1998 Federal Rule 

compared to uncontrolled

=

=

100%* (7.84 - 7.06) / 7.84

9.95%

Emission Factor after 2001 OTC Rule = 6.06 lbs/capita

Percent Reduction from 2001 OTC Rule compared 

to Federal Rule

=

=

100%* (7.06 - 6.06) / 7.06

14.2%

Emission Factor after 2006 OTC Rule = 5.94 lbs/capita

Percent Reduction from 2006 OTC Rule compared 

to OTC 2001 Rule

=

=

100%* (6.06 -5.94) / 6.06

2.0%

Emission Factor after 2010 OTC Rule

(without brake cleaner chlorinated toxic ban)

= 5.745 lbs/capita

Percent Reduction from 2010 OTC Rule compared 

to OTC 2006 Rule

=

=

100%* (5.94 – 5.745) / 5.94

3.3%

Emission Factor after 2010 OTC Rule

(with brake cleaner chlorinated toxic ban)

= 5.655 lbs/capita

Percent Reduction from 2010 OTC Rule compared 

to OTC 2006 Rule

=

=

100%* (5.94 – 5.655) / 5.94

4.8%

The reductions shown above were applied to the above SCCs based on each state’s 

adoption of the various rules and amendments as well as the decision with respect to the 

ban on chlorinated toxic compounds used in brake cleaners. States were polled to 

determine whether they have adopted a rule that would achieve reductions equivalent to 

the OTC 2006 recommendations and whether the estimated reduction in VOC emissions 

should be applied in 2017 and 2020. For the 2001 OTC rule, some states adopted the rule 

prior to 2007 and have already accounted for the reductions attributable to the OTC 2001 

rule in their 2007 inventories. Other states had compliance dates after 2007 and the effect 

of the OTC 2001 rule was not accounted for in their 2007 inventory. None of the states 

have accounted for the OTC 2006 rule in their 2007 inventories. State-by-state 

recommendations to account for both the OTC 2001 and 2006 consumer products rules are 

shown in Exhibit 4.7. 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 46

Exhibit 4.7 State Recommendations for OTC 2001 and 2006 

Consumer Products Rules 

State

Is 2001 Rule 

Accounted 

for in 2007 

Inventory

Is 2006 Rule 

Accounted 

for in 2007 

Inventory

VOC Percent Reduction to use in:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

CT No No 15.9 4.8 15.9 4.8

DE Yes No 2.0 4.8 2.0 4.8

DC No No 2.0 4.8 2.0 4.8

ME No No 15.9 4.8 15.9 4.8

MD Yes No 2.0 4.8 2.0 4.8

MA No No 15.9 4.8 15.9 4.8

NH No No 14.2 5.2 14.2 5.2

NJ Yes No 2.0 4.8 2.0 4.8

NY Yes No 2.0 4.8 2.0 4.8

PA Yes No 2.0 4.8 2.0 4.8

RI No No 15.9 4.8 15.9 4.8

VT No No 0 18.6 0 18.6

VA-NVA Yes No 2.0 0 2.0 0

VA-FRD No No 15.9 0 15.9 0

VA-RCH No No 15.9 0 15.9 0

VA-Other No No 0 0 0 0

NH indicated that their amendments to include the OTC 2006 recommendations 

won’t be completed in time to include in the OTB/OTW inventory 

4.4.5 OTC Model Rules for Mobile Equipment Repair and Refinishing 

The USEPA promulgated a national rule in 1998 (40CFR, Part 59, Subpart B) to limit the 

VOC content of coatings usedin the refinishing of automobiles. The federal standards 

were estimated to reduce nationwide emissions of VOC by about 37 percent compared to 

uncontrolled 1998 emissions. The 2002 OTC model rule established requirements for 

using higher efficiency coating application equipment, such as high volume-low pressure 

paint guns, using spray gun cleaning equipment that minimizes solvent loss, and enclosed 

spray gun cleaning. The Federal VOC limits on the paints was maintained in the model 

rule. An incremental control effectiveness of 38 percent was estimated for the OTC 2001 

model rule (post-1998 federal standard emissions). 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 47

The 2009 OTC model rule for Motor Vehicle and Mobile Equipment Non-assembly Line 

Coating Operations (2009 OTC MVME model rule) seeks to limit the VOC content in 

coatings and cleaning solvents used in motor vehicle and mobile equipment non-assembly 

line coating operations. The 2009 OTC MVME model rule is an update of the 2002 OTC 

MERR model rule. The OTC developed the 2009 OTC MVME Model Rule using the 

CARB 2005 Suggested Control Measure (SCM) for Automotive Coatings as a guideline. 

The CARB 2005 SCM estimated a 65 percent reduction in VOC emissions from 2002 

CARB baseline emissions, which are post-1998 federal standard emissions. Similar 

reductions of 65 percent are expected from implementation of the 2009 OTC MVME 

Model Rule. 

A few OTC states adopted the 2002 OTC model rule and accounted for the 38 percent 

reduction in the 2007 MANEVU+VA inventory. Other states adopted the 2002 OTC 

model rules after 2007, so the reduction was not included in 2007 but was included in the 

2017/2020 “on-the-books” inventory. Still other states have not yet adopted the 2002 OTC 

model rule. Exhibit 4.8 summarizes the percent reductions that will be applied based on 

the adoption status of each state: 

Exhibit 4.8 VOC Emission Reductions for Auto Refinishing

State Rule Adoption Status

VOC Reduction:

2017/2020 

Existing

2017/2020 

Potential

Accounted for 2002 OTC rule in 2007 inventory

Will adopt 2009 OTC rule by 2017 0 % 65 %

Did not account for 2002 OTC rule in 2007 inventory

Did account for 2002 OTC rule in 2017/2020 OTB inventory

Will adopt 2009 OTC rule by 2017

38 % 65 %

Did not account for 2002 OTC rule in 2007 inventory

Did not account for it in 2017/2020 OTB inventory

Will adopt 2009 OTC rule by 2017

0 % 78.3 %

The reductions have traditionally been applied to the following area source SCCs: 

24-01-005-000 Auto Refinishing / All Solvent Types 

24-01-005-500 Auto Refinishing / Surface Preparation Solvents 

24-01-005-600 Auto Refinishing / Primers 

24-01-005-700 Auto Refinishing / Top Coats 

24-01-005-800 Auto Refinishing / Clean-up Solvents 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 48

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in VOC emissions should be applied in 2017 and 2020. Many states adopted the 

rule prior to 2007 and have already accounted for the reductions attributable to the rule in 

their 2007 inventories. Other states had compliance dates after 2007 and the effect of the 

rule was not accounted for in their 2007 inventory. State-by-state recommendations to 

account for the auto refinishing rule are shown in Exhibit 4.9. 

Exhibit 4.9 State Recommendations for OTC Auto Refinishing Rule 

State

Is OTC 

2001 Rule 

Accounted 

for in 2007 

Inventory*

Incremental VOC Reduction to Apply:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

CT Yes 0 65 0 65

DE Yes 0 65 0 65

DC No 38 65 38 65

ME No 38 65 38 65

MD Yes Yes 0 65 0

MA No 0 78.3 0 78.3

NH No 0 78.3 0 78.3

NJ Yes 0 65 0 65

NY Yes 0 65 0 65

PA Yes 0 65 0 65

RI Yes 0 65 0 65

VT No emissions 

in inventory 0 0 0 0

VA-NVA Yes 0 0 0 0

VA-FRD No 38 0 38 0

VA-Other No 0 0 0 0
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 49

4.4.6 OTC Model Rules for Portable Fuel Containers 

In 2001, the OTC developed a model rule to control VOC emissions from portable fuel 

containers. The 2001 model rule was based on the technical work conducted by California 

Air Resources Board (CARB) for developing California’s 2000 fuel container rule. 

Several, but not all, of the MANEVU+VA states adopted regulations which became 

effective prior to 2007. 

After OTC developed its model rule in 2001, CARB realized that its original study and 

rule had some defects and decided to conduct further studies and research on fuel 

containers. Based on its new studies, CARB revised its rule twice. In 2006, the OTC 

developed a second model rule for PFCs to reflect the CARB revisions. Thereafter, 

USEPA developed a federal rule in 2007 which included, among other things, 

requirements for portable fuel containers equivalent to OTC’s 2006 requirements. 

The federal requirements became effective on January 1, 2009. States have analyzed the 

federal rule and determined that the federal rule has requirements that are essentially 

equivalent to the OTC 2006 model rule. These new federal requirements will reduce 

hydrocarbon emissions from uncontrolled fuel containers by approximately 75 percent. 

Assuming a 10-year turnover to compliant cans, only 10 percent of the existing inventory 

of PFCs will comply with the new requirements in 2010. Therefore, only 10 percent of the 

full emission benefit estimated by USEPA will occur by 2010 – the incremental reduction 

will be about 7.5 percent in 2010. In 2013, there will be a 40 percent turnover to compliant 

cans, resulting in an incremental reduction of about 60 percent. By 2017, the will be 80 

percent penetration to compliant PFCs, resulting in an incremental reduction of 58 percent 

in 2018. By 2020, there will be 100 percent penetration to compliant PFCs, resulting in an 

incremental reduction of 75 percent in 2020. 

The reductions apply to the following SCCs: 

25-01-011-xxx Residential PFCs 

24-01-012-xxx Commercial PFCs 

States were polled to determine the status of PFC regulations in each state. Some states 

have adopted a rule that would achieve reductions equivalent to the 2001 or 2006 OTC 

rules. Other states will rely exclusively on the Federal rule. State-by-state 

recommendations to account for the OTC and federal PFC rules are shown in Exhibit 4.10. 
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Exhibit 4.10 State Recommendations for OTC and Federal 

Portable Fuel Container Rules 

State

Compliance 

Date for 

OTC 2001 

Rule

Compliance 

Date for 

OTC 2006 

Rule

Rely on 

Federal 

Rule?

VOC Percent Reduction to use in:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

CT May 2004 Jun 2008 No 81 0 81 0

DE Jan 2003 Apr 2010 Yes 75 0 78 0

DC Dec 2004 Feb 2012 Yes 79 0 81 0

ME Jan 2004 n/a Yes 77 0 80 0

MD May 2003 Jan 2009 No 76 0 79 0

MA n/a n/a Yes 77 0 85 0

NH n/a Jan 2008 No 85 0 85 0

NJ Jan 2005 Jan 2009 No 83 0 83 0

NY Jan 2005 Jan 2010 Yes 79 0 82 0

PA Jan 2005 n/a Yes 75 0 78 0

RI n/a n/a Yes 77 0 85 0

VT n/a n/a Yes 77 0 85 0

VA-NVA Jan 2005 Aug 2010 Yes 79 0 82 0

VA-FRD Jan 2008 Aug 2010 Yes 83 0 85 0

VA-RCH n/a n/a Yes 77 0 85 0

VA-Oth n/a n/a Yes 77 0 85 0

4.4.7 OTC Model Rule for Solvent Cleaning 

The OTC model rule establishes hardware and operating requirements for specified vapor 

cleaning machines, and solvent volatility limits and operating practices for cold cleaners. 

An incremental control effectiveness of 66 percent was estimated for the OTC model rule 

relative to the base case. The reductions apply SCCs in the 24-15-xxx-xxx series 

(Degreasing All Industries and Processes). States were polled to determine whether they 

have adopted a rule that would achieve reductions equivalent to the 2001 OTC 

recommendations and whether the estimated reduction in VOC emissions should be 

applied in 2017 and 2020. Many states adopted the rule prior to 2007 and have already 

accounted for the reductions attributable to the rule in their 2007 inventories. Other states 

had compliance dates after 2007 and the effect of the rule was not accounted for in their 

2007 inventory. State-by-state recommendations to account for the solvent cleaning rule 

are shown in Exhibit 4.11. 
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Exhibit 4.11 State Recommendations for 2001 OTC Solvent Cleaning Rule 

State

Is Rule 

Accounted 

for in 2007 

Inventory*

Incremental VOC Reduction to Apply:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

CT No 66 0 66 0

DE Yes 0 0 0 0

DC No 66 0 66 0

ME No 66 0 66 0

MD Partially 30 0 30 0

MA No 66 0 66 0

NH No 0 66 0 66

NJ Yes 0 0 0 0

NY Yes 0 0 0 0

PA Yes 0 0 0 0

RI No 66 0 66 0

VT n/a 0 66 0 66

VA-NVA Yes 0 0 0 0

VA-Other No 0 0 0 0

4.4.8 OTC Model Rules for ICI Boilers 

In Resolution 06-02, the OTC Commissioners recommended that OTC member states 

pursue as necessary and appropriate state-specific rulemakings or other implementation 

methods to establish emission reduction percentages, emission rates or technologies for ICI 

boilers based on guidelines that varied by boiler size and fuel type. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in NOx emissions should be applied in 2017 and 2020. All but one state 

indicated that they have not adopted rules for area sources equivalent to the 2006 OTC 

recommendations. New Jersey specified that they have post-2007 ICI boiler rules that 

reduce NOx emissions and provided the estimates of the reductions in NOx emissions by 

SCC resulting from boiler tuneup requirements, as shown in Exhibit 4.12: 
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Exhibit 4.12 Area Source Emission Reductions from 

New Jersey ICI Boiler NOx Rules 

SCC Source Category

Percent

Reduction 

from 

Tuneups 

2007-2017

Rule 

Effectiveness

Rule 

Penetration

Overall

Percent 

Reduction 

2007-2017

2102004000 Industrial Distillate 25% 80% 30% 6%

2102005000 Industrial Residual 25% 80% 30% 6%

2102006000 Industrial Natural Gas 25% 80% 30% 6%

2102007000 Industrial LPG 25% 80% 30% 6%

2103004000 Commercial Distillate 25% 80% 30% 6%

2103005000 Commercial Residual 25% 80% 30% 6%

2103006000 Commercial Natural Gas 25% 80% 30% 6%

2103007000 Commercial LPG 25% 80% 30% 6%

Other states indicated that they will likely depend on USEPA national rule for possible 

inclusion in the BOTW inventory. OTC Resolution 10-01 (June, 2010) called on USEPA 

for national regulations for ICI boilers. The guidelines from OTC Resolution 06-02 shown 

in Exhibit 4.13 were used to estimate potential area source NOx reductions for the “what 

if” control scenario for all states in the MANE-VU+VA inventory except New Jersey and 

Virginia. 

Exhibit 4.13 OTC Resolution 06-02 Guidelines for ICI Boiler NOx Rules 

Boiler Size

(mmBtu/hr)

NOx Percent Reduction from Base Emissions by Fuel Type

Natural Gas #2 Fuel Oil #4/#6 Fuel Oil Coal

<25 10 10 10 10

25 to 50 50 50 50 50*

50 to 100 10 10 10 10*

100 to 250 76 40 40 40*

>250 **   ** 

* Resolution 06-02 did not specify a percent reduction for coal; for modeling purposes, the same 

percent reduction specified for #4/#6 fuel oil was used for coal. 

** Resolution 06-02 specified the reduction for > 250mmBtu/hour boilers to be the “same as EGUs 

of similar size.” The OTC Commissioners have not yet recommended an emission rate or percent 

reduction for EGUs. As a result, no reductions for ICI boilers > 250 mmBtu/hour were included in 

the potential controls inventory. 
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Since the above guidelines vary by boiler size and fuel type, the specific percent reduction 

applied to an area source category depends on the SCC and design capacity of the source. 

The SCC identifies the fuel type (for example, SCC 21-02-004-xxx describes distillate 

oilfired industrial boilers, SCC 21-02-006-xxx describes natural gas-fired industrial 

boilers). The area source inventory does not contain any information on the sizes of the 

units included in the inventories. To apportion area source emissions to the boiler size 

ranges listed above, we used data from an Oak Ridge National Laboratory study (EEA 

2005). We used the national estimates of boiler capacity by size range to calculate the 

percentage of total boiler capacity in each size range. Since the Oak Ridge report 

distinguished between industrial boilers and commercial/institutional boilers, we 

developed separate profiles for industrial boilers and for commercial/institutional boilers. 

We used these boiler size profiles to calculate weighted average percent reductions 

industrial boilers by fuel type and commercial/institutional boilers by fuel type, as follows: 

34.5 percent reduction in NOx emissions from industrial boilers, all fuel types 

28.1 percent reduction in NOx emissions from commercial/institutional boilers, all 

fuel types 

Appendix I contains the data used to develop the NOx control factors for area source ICI 

boilers. 

4.4.9 OTC Model Rule for New, Small, Natural Gas-fired Boilers 

The provisions of this model rule limit NOx emissions from new natural gas-fired ICI and 

residential boilers, steam generators, process heaters, and water heaters greater than 75,000 

BTUs and less than 5.0 million BTUs. This model rule may be implemented as a 

manufacturing restriction, a sales restriction, a use restriction, or a combination of these 

restrictions. Each implementing state agency will choose the entities to regulate after 

consideration of the agency’s compliance assurance and enforcement practices and 

policies. 

The emission limits of this model rule were developed from requirements now in effect in 

certain jurisdictions, including: (1) San Joaquin Valley Air Pollution Control District Rule 

4308 for boilers, steam generators, process heaters and water heaters with maximum rated 

heat input capacity equal to or greater than 75,000 Btu/hr and up to but less than 2.0 

million Btu/hr; (2) San Joaquin Valley Air Pollution Control District Rule 4307 for gasfired and liquid fuel-fired boilers, steam generators, and process heaters with maximum 

rated capacity of 2.0 million Btu/hr up to and including 5.0 million Btu/hr; and (3) similar 

rules adopted by other California Air Pollution Control Districts and the State of Texas. 
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Since the OTC model rule is based on SJVAPCD Rules 4307 and 4308, one method for 

estimating potential NOx reductions for the OTC states from both Rule 4307 and Rule 

4308 is to compare the natural gas usage in the San Joaquin Valley to the natural gas usage 

in the OTC states and calculate the proportional NOx reductions. 

The SJV 4308 Rule, Final Staff Report estimated NOx reductions of 2.0 annual average 

tons per day (730 tons per year), and the 2008 SJV 4307 Rule Proposal estimated NOx 

reductions of 1.15 annual average tons per day (420 tons per year). The total reduction 

from both rules was estimated to be 3.15 tons per day (1,150 tons per year) after a 15-year 

period for complete turnover to compliant equipment. These SJV data were used to 

calculate a ton per year emission reduction, assuming implementation begins in 2014, as 

summarized in Exhibit 4.14 and further documented in Appendix J. 

Exhibit 4.14 NOx Control Factors for the OTC Rule for 

New, Small, Natural Gas-fired Units 

State

Percent Reduction in NOx 

Emissions from Residential and 

Commercial Natural Gas Use

2017 2020

CT 5.0% 8.4%

DE 6.1% 10.1%

DC 2.3% 3.9%

ME 0.0% 0.0%

MD 3.2% 5.4%

MA 5.3% 8.8%

NH 7.1% 11.8%

NJ 3.5% 5.9%

NY 5.1% 8.5%

PA 4.7% 7.8%

RI 7.0% 11.7%

VT 3.1% 5.1%

VA 0% 0%
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4.4.10 MANE-VU Low Sulfur Fuel Oil Strategy 

MANE-VU developed a low sulfur fuel oil strategy to help states develop Regional Haze 

SIPs (MANE_VU 2007). The sulfur in fuel oil recommendations are shown in Exhibit 

4.15 and vary by state, type of fuel oil, and year of implementation. 

Exhibit 4.15 MANE-VU Low Sulfur Fuel Oil Strategy 

Inner Zone States (DE, NJ, NY, PA)

Fuel Oil Type Sulfur Content

2012

Sulfur Content

2016

Distillate 500 ppm 15 ppm

#4 Residual 0.25 % 0.25 %

#6 Residual 0.3 to 0.5 % 0.3 to 0.5 %

Outer Zone States (CT, DC, MA, MD, ME, NH, RI, VT)

Fuel Oil Type Sulfur Content

2014

Sulfur Content

2018

Distillate 500 ppm 15 ppm

#4 Residual n/a 0.25 to 0.5 %

#6 Residual n/a 0.5 %

Each state was polled and asked to provide guidance as to when, if at all, the MANE-VU 

strategy would be incorporated into their state rules. States were also asked to provide the 

2007 sulfur contents for each fuel type by county in order to calculate the percent reduction 

in emissions for the future years. Three states (MD, NJ, and NY) have adopted or are 

committed to adopting the strategy into their rules. The reductions for these three states 

were accounted for in the “existing controls” inventory. All other jurisdictions indicated 

that not enough regulatory development progress has been made to include the reductions 

in future years with absolute certainty. The potential reductions for these states were 

accounted for in the “potential new controls” inventory. One state (VA) has no plans to 

adopt the low sulfur fuel oil strategy. The percent reductions by fuel type and county are 

contained in Appendix K. 
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5.0 NONEGU POINT SOURCE CONTROL FACTORS 

Control factors were developed to estimate post-2007 emission reductions resulting from 

on-the-books regulations and proposed regulations/actions. Control factors were 

considered for the following national and regional measures: 

Federal Rules Affecting NonEGU Point Sources 

Control Technique Guidelines 

OTC Model Rules 

These control programs are discussed in the following subsections. The control factors 

used for nonEGU point sources are provided in V3_3 NonEGU_07_17_20.xlsx. 

5.1 FEDERAL ACTIONS AFFECTING NONEGU POINT SOURCES 

USEPA made available its 2020 emissions projections associated with its 2005-based v4 

modeling platform (USEPA 2010a). These categories, and how they were accounted for in 

the MANE-VU+VA emission projection inventories, are described below: 

MACT Standards - USEPA developed guidance for estimating VOC and NOx

emission changes from MACT Rules (USEPA 2007b). We reviewed the guidance 

to identify nonEGU source controls associated with MACT standards for 

controlling HAPs. The information concerning MACT compliance periods was 

used to determine whether the MACT standard resulted in post-2007 emission 

reductions. Because major source categories had a compliance period of 2007 or 

earlier, we assumed that the emission reductions from the MACT standard should 

be reflected in the baseline year and not as an additional post- 2007 credit. The 

only exception to the above discussion of area source MACT standards pertains to 

the recently promulgated rules for reciprocating internal combustion engines. 

USEPA made available an estimate of the percent reduction in emissions 

attributable to the RICE MACT rule in 2012 and 2014 (USEPA 2010b). These 

reductions by SCC are shown in Exhibit 5.1. The USEPA 2014 estimates were 

used for the MANE-VU+VA 2017, 2020 and 2025 inventories. 

Industrial, Commercial, and Institutional Boilers and Process Heaters MACT 

Standard - USEPA’ s 2020 control factor file identified a number of solid fuelburning SCCs for which they estimated an 87% reduction in both PM10 and 

PM2.5. These were used for 2025 also for the affected SCCs. 
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Exhibit 5.1 USEPA Estimated Percent Reductions for RICE MACT Standard 

SCC CO NOx PM10 PM2.5 VOC SCC Description

20100102 20.36 15.14 15.14 36.72 Electric Generation;Distillate Oil (Diesel);Reciprocating

20100105 20.36 15.14 15.14 36.72 Electric Generation;Distillate Oil (Diesel);Reciprocating: Crankcase Blowby

20100107 20.36 15.14 15.14 36.72 Electric Generation;Distillate Oil (Diesel);Reciprocating: Exhaust

20100202 19.86 12.53 23.87 Electric Generation;Natural Gas;Reciprocating

20100207 19.86 12.53 23.87 Electric Generation;Natural Gas;Reciprocating: Exhaust

20200102 20.36 15.14 15.14 36.72 Industrial;Distillate Oil (Diesel);Reciprocating

20200104 20.36 15.14 15.14 36.72 Industrial;Distillate Oil (Diesel);Reciprocating: Cogeneration

20200107 20.36 15.14 15.14 36.72 Industrial;Distillate Oil (Diesel);Reciprocating: Exhaust

20200202 19.86 12.53 23.87 Industrial;Natural Gas;Reciprocating

20200204 19.86 12.53 23.87 Industrial;Natural Gas;Reciprocating: Cogeneration

20200207 19.86 12.53 23.87 Industrial;Natural Gas;Reciprocating: Exhaust

20200253 19.18 37.96 29.74 Industrial;Natural Gas;4-cycle Rich Burn

20200254 37.85 28.59 Industrial;Natural Gas;4-cycle Lean Burn

20200256 37.85 28.59 Industrial;Natural Gas;4-cycle Clean Burn

20200301 19.18 37.96 29.74 Industrial;Gasoline;Reciprocating

20200307 19.18 37.96 29.74 Industrial;Gasoline;Reciprocating: Exhaust

20201001 19.86 12.53 23.87 Industrial;Liquified Petroleum Gas (LPG);Propane

20201002 19.86 12.53 23.87 Industrial;Liquified Petroleum Gas (LPG);Butane

20201702 19.18 37.96 29.74 Industrial;Gasoline;Reciprocating Engine

20201707 19.18 37.96 29.74 Industrial;Gasoline;Reciprocating: Exhaust

20300101 20.36 15.14 15.14 36.72 Commercial/Institutional;Distillate Oil (Diesel);Reciprocating

20300105 20.36 15.14 15.14 36.72 Commercial/Institutional;Distillate Oil (Diesel);Reciprocating: Crankcase Blowby

20300106 20.36 15.14 15.14 36.72 Commercial/Institutional;Distillate Oil (Diesel);Reciprocating: Evaporative Losses 

20300107 20.36 15.14 15.14 36.72 Commercial/Institutional;Distillate Oil (Diesel);Reciprocating: Exhaust

20300201 19.86 12.53 23.87 Commercial/Institutional;Natural Gas;Reciprocating
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SCC CO NOx PM10 PM2.5 VOC SCC Description

20300204 19.86 12.53 23.87 Commercial/Institutional;Natural Gas;Cogeneration

20300207 19.86 12.53 23.87 Commercial/Institutional;Natural Gas;Reciprocating: Exhaust

20300301 19.18 37.96 29.74 Commercial/Institutional;Gasoline;Reciprocating

20300307 19.18 37.96 29.74 Commercial/Institutional;Gasoline;Reciprocating: Exhaust

20301001 19.86 12.53 23.87 Commercial/Institutional;Liquified Petroleum Gas (LPG);Propane

20301002 19.86 12.53 23.87 Commercial/Institutional;Liquified Petroleum Gas (LPG);Butane

20400401 19.18 37.96 29.74 Engine Testing;Reciprocating Engine;Gasoline

20400402 20.36 15.14 15.14 36.72 Engine Testing;Reciprocating Engine;Diesel/Kerosene

20400403 20.36 15.14 15.14 36.72 Engine Testing;Reciprocating Engine;Distillate Oil: CI: CI: VOC 2005cr = 0

31000203 19.86 12.53 23.87 Oil and Gas Production;Natural Gas Production;Compressors

50100421 19.86 12.53 23.87 Solid Waste Disposal;Landfill Dump;Waste Gas Recovery: Internal Combustion 

Device
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Petroleum refinery enforcement settlements - For the facilities identified by 

USEPA located in New Jersey and Pennsylvania we applied post-2007 estimated 

reductions for NOx, PM10, PM2.5, and SO2 to affected units. 

5.2 RECENT CONTROL TECHNIQUE GUIDELINES 

Control Techniques Guidelines (CTGs) are documents issued by USEPA to provide states 

with the USEPA’s recommendation on how to control the emissions of VOC from a 

specific type of product or source category in an ozone nonattainment area. USEPA issued 

new or updated CTGs for 13 VOC categories in 3 groups during 2006, 2007 and 2008 

(USEPA 2008b). The categories are: 

2006 CTGs 

 Flat Wood Paneling Coatings 

 Industrial Cleaning Solvents 

 Flexible Package Printing 

 Lithographic Printing 

 Letterpress Printing 

2007 CTGs 

 Large Appliance Surface Coating 

 Metal Furniture Coatings 

 Paper Film and Foil Coatings 

2008 CTGs 

 Miscellaneous Metal Parts Coatings 

 Plastic Parts Coatings 

 Auto and Light-duty Truck Assembly Coatings 

 Fiberglass Boat Manufacturing 

 Miscellaneous Industrial Adhesives 

States indicated that they expected very little additional reductions from these new or 

amended CTGs. Therefore, no emission reductions were included in the inventory. 

5.3 OTC MODEL RULES FOR NONEGUs 

The OTC developed NOx control measures for industrial, commercial, and institutional 

(ICI) boilers and distributed generation units in 2001 (OTC 2001). We reviewed the 

OTC’s status reports to identify states status in adopting the OTC 2001 model rules (OTC 

2009). Most states have adopted the OTC model rules with compliance dates in 2007 or 

earlier. As a result, we assumed that the emission reductions from the 2001 OTC model 

rules for nonEGUs are already reflected in the 2007 inventory and no post- 2007 

reductions were applied. 
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In 2006, the OTC introduced model rules (OTC 2007) for one nonEGU VOC source 

category (adhesives/sealants) and new/more stringent requirements for several NOx source 

categories (asphalt production plants, cement kilns, glass/fiberglass furnaces, and 

industrial, commercial, and institutional {ICI} boilers). 

These model rules and recommendations provided a consistent framework for air pollution 

regulation throughout the region. In addition, MANE-VU provided recommendations to 

require low sulfur home heating, distillate and residul fuel oil. Exhibit 5-2 briefly 

describes the OTC and MANE-VU control measures affecting point sources that have been 

recommended for adoption by the states in the OTR. Recommendations for EGUs are not 

addressed in this section since the projection of EGU emissions is being accomplished by 

ERTAC under a separate agreement. 

Individual states are in various stages of adopting the OTC recommendations into the rules 

and SIPs. We reviewed the OTC’s status reports to identify each state’s adoption status 

(OTC 2009, OTC 2011a, OTC2011b). To obtain further clarification, states were polled to 

determine whether they have adopted a rule that would achieve reductions equivalent to 

the OTC model rule or recommendation and whether credit for each rule was already 

accounted for in the 2007 inventory. 

Not all states have adopted all rules. In order to evaluate the impact of both the rules 

currently in place as well as the potential adoption of all control measures by all states, the 

state Air Directors specified that two emission control scenarios should be developed. 

Existing Controls - this scenario represents the best estimates for the future year, 

accounting for all in-place controls that are fully adopted into federal or individual 

state regulations or SIPs. 

Potential New OTC Controls – this scenario accounts for all of the emission 

reductions from the existing control scenario plus new state or regional measures 

that are under consideration by the OTC or individual states. This is a “what if” 

scenario that assumes that all states in the MANE-VU+VA region except Virginia 

will adopt all new OTC control measures under consideration by 2017. It does not 

include any potential new federal control measures that are under consideration. 

The following paragraphs describe the control factors applied for each control measure by 

state and future year. 
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Exhibit 5.2 Summary of Point Source OTC Control Measures 

Source Category Pollutants Description

EGUs NOx OTC 2001. Provided emission standards for 

stationary combustion turbines, emergency 

generators, and load shaving units.

OTC 2009/2010. Recommended NOx emission rate 

limits for oil and gas boilers serving EGUs and 

emission rate limits for high energy demand day 

combustion turbines.

Asphalt Production Plants NOx OTC 2006. Provided emission rate limits and 

recommended a 35% reduction in NOx emissions.

Cement Kilns NOx OTC 2006. Provided emission rate limits and 

recommended a 60% reduction in NOx emissions.

Glass Furnaces NOx OTC 2006. Provided emission rate limits and 

recommended a 85% reduction in NOx emissions.

ICI Boiler Controls NOx OTC 2001. Recommended NOx emission rate limits 

for industrial boilers greater than 5 mmBtu/hour

OTC 2006. Recommended lower NOx emission rate 

limits for industrial, commercial, and institutional 

boilers

OTC 2010. Recommended national NOx controls for 

ICI boilers

Low Sulfur Fuel Oil SO2 MANE-VU 2006. Recommends sulfur content limits 

for home heating oil, distillate oil, and residual oil

Adhesives and Sealants VOC OTC 2006. Provided VOC content limits and other 

restrictions on adhesives used in industrial and 

commercial settings. 

Large Petroleum Storage 

Tanks

VOC OTC 2009/2010. Addresses high vapor pressure 

VOCs, such as gasoline and crude oil, stored in large 

aboveground stationary storage tanks, which are 

typically located at refineries, terminals and pipeline 

breakout stations. 
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5.3.1 OTC 2006 Model Rule for Adhesives and Sealants 

The 2006 OTC model rule is intended to achieve VOC emission reductions from adhesive 

application sources. The OTC 2006 model rule for adhesives and sealants is based on the 

reasonably available control technology (RACT) and best available retrofit control 

technology (BARCT) determination by the California Air Resources Board (CARB) 

developed in 1998. The emission reduction benefit estimation methodology is based on 

information developed and used by CARB for their RACT/BARCT determination in 1998. 

The vast majority of the emissions regulated by this rule are in the area source inventory. 

For point sources, we first identified those sources applying adhesives and sealants (using 

the SCC of 4-02-007-xx, adhesives application). Next, we reviewed the 2007 inventory to 

determine whether these sources had existing capture and control systems. Most of the 

sources did not have control information in the NIF database. However, several sources 

reported capture and destruction efficiencies in the 70 to 99 percent range, with a few 

sources reporting capture and destruction efficiencies of 99+ percent. Sources with 

existing control systems that exceeded an 85 percent overall capture and destruction 

efficiency would comply with the OTC 2006 model rule provision for add-on air pollution 

control equipment; therefore, no additional reductions were calculated for these sources. 

For point sources without add-on control equipment, we used a 64.4 percent reduction 

based on the CARB determination. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC model rule and whether the estimated reduction in 

VOC emissions should be applied in 2017 and 2020. New Hampshire indicated that they 

have no existing rule in place and no reductions should be applied. Virginia indicated that 

reductions from existing rules only apply in three regions: 

Northern Virginia (Arlington, Alexandria, Manassas, Manassas Park, Prince 

William, Loudon, Fairfax, Fairfax City, Falls Church, and Stafford), 

Fredericksburg (Fredericksburg and Spotsylvania), and 

Richmond (Charles City, Colonial Heights, Chesterfield, Hopewell, Hanover, 

Petersburg, Henrico, City of Richmond, and Prince George). 

All other states have existing rules in place that will require VOC reductions before 2017. 

Exhibit 5.3 shows the reduction that were applied by state under both the existing controls 

inventory and the “what if” inventory. 
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Exhibit 5.3 State Recommendations for OTC Adhesives/Sealants Rule 

State

Is Rule 

Accounted 

for in 2007 

Inventory*

Incremental VOC Reduction to Apply:

2017

Existing

Controls

2017

Potential

Controls

2020

Existing

Controls

2020

Potential

Controls

CT No 64.4 0 64.4 0

DE No 64.4 0 64.4 0

DC n/a n/a n/a n/a n/a

ME No 64.4 0 64.4 0

MD No 64.4 0 64.4 0

MA No 64.4 0 64.4 0

NH No 0 64.40 0 64.4

NJ No 64.4 0 64.4 0

NY No 64.4 0 64.4 0

PA No 64.4 0 64.4 0

RI No 64.4 0 64.4 0

VT n/a n/a n/a n/a n/a

VA-NVA No 64.4 0 64.4 0

VA-FRD No 64.4 0 64.4 0

VA-RCH No 64.4 0 64.4 0

VA-Other No 0 0 0 0

* Some sources in the 2007 inventory had VOC controls greater than 85% and already complied 

with the requirements; no incremental reduction was taken for these sources (see text) 

n/a - no affected point sources identified in the inventory 

5.3.2 OTC 2009/2010 Model Rule for Large Storage Tanks 

The OTC model rule addresses high vapor pressure VOCs, such as gasoline and crude oil, 

stored in large aboveground stationary storage tanks, which are typically located at 

refineries, terminals and pipeline breakout stations. The OTC model rule is based on 

recent revisions to New Jersey’s VOC storage tank rules located at N.J.A.C. 7:27-16.2. 

The OTC model rules requires: 1) retrofiting floating roof tanks to reduce emissions from 

deck fittings; 2) retrofitting external floating roof tanks with domes; 3) controlling roof 

landing losses; and 4) adding controls for degassing and interior tank cleaning. New Jersey 

estimated reductions for tanks located in New Jersey would total approximately 2,000 tons 

per year by 2020. In making these estimates, New Jersey developed the following VOC 

percent reduction estimates for the following categories of storage tanks: 
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Tank Location Point Source SCC

VOC Percent Reduction

2017 2020

Refinery

4-03-011-xx

(floating roof tank SCCs,

gasoline or crude oil only)

82 85

Bulk Terminal 4-04-001-xx

(floating roof tank SCCs) 40 50

Bulk Plant and Pipeline 

Breakout Station

4-04-002-xx

(floating roof tank SCCs

gasoline or crude oil only)

52 65

Only New Jersey has existing rules in place, and the above percent reductions were applied 

to the existing controls inventory. 

For all other states with affected sources, the potential reductions from the OTC rule were 

applied in the “what if” inventory. 

5.3.3 OTC 2006 Model Rule for Asphalt Production Plants 

The OTC recommended that member states pursue state-specific rulemakings or other 

implementation methods that would achieve a 35 percent reduction in NOx emissions. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC model rule and whether the estimated reduction in 

NOx emissions should be applied in 2017 and 2020. Only Maine, New Jersey and New 

York indicated that the reductions should be applied. A 35 percent reduction in NOx 

emissions for fuel burning SCCs in the 3-05-002-xx series was applied to the existing 

controls inventory for Maine, New Jersey, and New York. 

All other states indicated that the NOx reductions should not be applied in the existing 

controls inventory. The 35 percent reduction for other states was applied in the “what if” 

inventory. 

5.3.4 OTC 2006 Model Rule for Cement Manufacturing Plants 

Cement kilns are located in Maine, Maryland, New York, Pennsylvania, and Virginia. The 

OTC recommended state-specific rulemakings or other implementation methods that 

would result in about a 60 percent reduction in uncontrolled levels NOx emissions or meet 

the following emission limits based on kiln type: 

Wet: 3.88 lb/ton clinker 

Long Dry: 3.44 lb/ton clinker 

Preheater: 2.36 lb/ton clinker 

Precalciner: 1.52 lb/ton clinker 
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Cement kilns are already subject to NOx controls as part of Phase I of the NOx SIP call or 

state-specific RACT requriements. The emission reductions resulting from the NOx SIP 

call or RACT requirements are already accounted for in the 2007 inventory. 

The following methods were used to calculate the additional reductions from the OTC 

2006 Control Measure in each state: 

Maine has a single kiln that was converted from an existing wet process cement 

kiln to a dry process (preheater/precalciner type) kiln and underwent a BACT 

review around 2005. The permitted emission rate is 1,533 tons per year with an 

annual capacity of 766,500 tons of clinker (e.g., about 4 lbs/ton of clinker). Maine 

does not plan on any additional controls, so no incremental reductions were applied 

for the either the existing controls or “what if” inventory. 

Maryland indicated controls will become effective in 2011 for the two facilities in 

the state. Maryland specified a 25 percent reduction for the Holcim facility and a 

40 percent reduction for the Lehigh facility for the existing controls inventory. No 

reductions were specified for the two kilns at the Essroc facility for the existing 

controls inventory. No additional reductions were specified for any cement kiln for 

the “what if” inventory. 

New York three cement plants: Each has a different RACT requirement effective 

7/1/2012. The three limits are; 6.59 lb/ton, 2.88 lb/ton and 1.5 lb/tom (30 day 

rolling average). For this inventory, we have assumed that these post-2007 RACT 

requirements have an incremental control efficiency of 40 percent and we have 

applied this reduction in the existing controls inventory. No additional reductions 

were specified for any cement kiln for the “what if” inventory. 

Pennsylvania provided kiln-specific projected future year NOx emissions for 2017 

and 2020 based on existing post-2007 state requirements. A kiln-specific control 

factor was calculated based on the ratio of the future year emissions to the 2007 

emissions and was applied for the existing controls inventory. No additional 

reductions were specified for any cement kiln for the “what if” inventory. 

Virginia has a single preheater/precalciner kiln that is not located in the OTR. 

Virginia does not plan on any additional controls since the facility is not in the 

OTR, so no incremental reductions were applied for the either the existing controls 

or “what if “ inventories. 
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5.3.5 OTC 2006 Model Rule for Glass and Fiberglass Furnaces 

The OTC recommended state-specific rulemakings or other implementation methods to 

achieve an approximately 85 percent reduction in NOx emissions from uncontrolled levels. 

Emission reductions for glass and fiberglass furnaces were calculated using the 

methodology previously developed and documented in the OTC report (OTC 2007). Glass 

and fiberglass furnaces are located in Maryland, Massachusetts, New Jersey, New York, 

Pennsylvania, and Virginia. The following methods were used to calculate the additional 

reductions from the OTC 2006 Control Measure in each state: 

Maryland indicated that a 48 percent reduction should be applied to the single glass 

manufacturing facility in Maryland. 

Massachusetts indicated that they have a single facility with two furnaces furnaces; 

one furnace installing oxy-firing at 1.3 lb NOx per ton of glass, and the other at 5.3 

lb/ton. The facility will be complying with EPA NSR enforcement Consent Decree 

by 2017. Massachusetts indicated that plant-wide emissions are expected to 

decrease by 35 percent in 2017 and 2020. 

New Jersey indicated that a 50 percent reduction in NOx emissions should be 

applied to glass and fiberglass furnaces in 2013, 2017, 2020 and 2025. 

New York did not provide guidance regarding glass and fiberglass furnaces. We 

used the percent reductions developed and documented in the previous round of 

emission projections developed for MARAMA (MARAMA 2007). An 

incremental control efficiency of 70 percent was used for New York glass and 

fiberglass furnaces in that inventory. 

Virginia indicated that they have no plans to implement the OTC measure, and no 

NOx reductions were applied to glass/fiberglass furnaces in Virginia. 

All of the above reductions for glass and fiberglass furnaces were accounted for in the 

existing controls inventory. No additional reductions were specified for any glass or 

fiberglass furnace for the “what if” inventory. 

5.3.6 OTC 2006 Model Rule for ICI Boilers 

In Resolution 06-02, the OTC recommended that OTC member states pursue as necessary 

and appropriate state-specific rulemakings or other implementation methods to establish 

emission reduction percentages, emission rates or technologies for ICI boilers based on 

guidelines that varied by boiler size and fuel type.. 
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States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in NOx emissions should be applied in 2017 and 2020. Most states have not 

adopted rules equivalent to the 2006 OTC recommendations. These states indicated that 

they will likely to depend on USEPA national rule for possible inclusion in the BOTW 

inventory. Specifically, the OTC Resolution 10-01 (June, 2010) called on USEPA for 

national regulations for ICI boilers. 

Three states specified that that have adopted post-2007 ICI boiler rules to reduce NOx 

emissions. The percent reductions for ICI boilers were for these states were calculated as 

describe in the following paragraphs. 

New Jersey provided NOx percent reductions that varied by heat input rate and fuel/boiler 

type and included an 80 percent rule effectiveness adjustment, as shown in Exhibit 5.4. 

The NIF file submitted by New Jersey for this project did not include the boiler design 

capacity. This data gap was filled using the boiler design capacities previously developed 

for the OTC study in 2006, if available; otherwise the SCC description was used to assign 

a default boiler design capacity. No additional reductions were specified for the “what if” 

inventory for New Jersey. 

Exhibit 5.4 NonEGU Point Source Emission Reductions from 

New Jersey ICI Boiler NOx Rules 

Heat Input Rate

(mmBtu/hr) Fuel/Boiler Type

Overall % 

Reduction 

2007-2017

at least 5 but < 10 All 20%

at least 10 but < 20 All 20%

at least 25 but < 50 Natural gas only 40%

No. 2 Fuel oil only 40%

Refinery fuel gas and 

other gaseous fuels 40%

Other liquid fuels 40%

Duel Fuel using fuel oil 

and/or natural gas 40%

at least 50 but < 100 Natural gas only 40%

No. 2 Fuel oil only 27%

Other liquid fuels 27%

Duel Fuel using fuel oil 

and/or natural gas 40%

at least 100 or greater No. 2 Fuel oil only 40%
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New York specified that a 50 percent reduction should be applied in the existing controls 

inventory for all boilers with greater than 25 mmBtu/hour design capacity. The NIF file 

submitted by New York for this project did not include the boiler design capacity. This 

data gap was filled using the boiler design capacities previously developed for the OTC 

study in 2006, if available; otherwise the SCC description was used to assign a default 

boiler design capacity. No additional reductions were specified for the “what if” inventory 

for New York. 

New Hampshire specified that reductions should be applied to boilers in the 50-100 and 

100-250 mmBtu/hour size ranges. We used the methodology previously developed and 

documented in the OTC report (OTC 2007). Reductions vary by size range and fuel type. 

State-by-state emission reduction percentages were developed by comparing the state 

emission limit in lbs/mmBTU to the OTC 2006 recommended limit. There are no coalfired ICI boilers in New Hampshire. For other fossil fuels used in New Hampshire, the 

NOx percent reduction was as follows: 

Natural gas, 50-100 mmBtu/hr: 50% reduction 

Natural gas, 100-250 mmBtu/hr: 0% reduction 

Residual/distillate oil, 50-100 mmBtu/hr: 33.3% reduction 

Residual/distillate oil, 100-250 mmBtu/hr: 33.3% reduction 

No additional reductions were specified for the “what if” inventory for New Hampshire. 

All other states do not have existing rules that would result in post-2007 emission 

reductions. These states indicated that they will likely to depend on USEPA national rule 

for possible inclusion in the BOTW inventory. Specifically, the OTC Resolution 10-01 

(June, 2010) called on USEPA for national regulations for ICI boilers. However, in order 

to estimate the potential NOx emission reductions for the “what if” control scenario, the 

guidelines from OTC Resolution 06-02 shown in Exhibit 5.5 were used to estimate 

potential NOx reductions in the “what if” inventory for those states without existing rules, 

except Virginia. 

Exhibit 5.5 OTC Resolution 06-02 Guidelines for ICI Boiler NOx Rules 

Boiler Size

(mmBtu/hr)

NOx Percent Reduction from Base Emissions by Fuel Type

Natural Gas #2 Fuel Oil #4/#6 Fuel Oil Coal

<25 10 10 10 10

25 to 50 50 50 50 50*

50 to 100 10 10 10 10*

100 to 250 76 40 40 40*
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>250 **   ** 

* Resolution 06-02 did not specify a percent reduction for coal; for modeling purposes, the same 

percent reduction specified for #4/#6 fuel oil was used for coal. 

** Resolution 06-02 specified the reduction for > 250mmBtu/hour boilers to be the “same as EGUs 

of similar size.” The OTC Commissioners have not yet recommended an emission rate or percent 

reduction for EGUs. As a result, no reductions for ICI boilers > 250 mmBtu/hour were included in 

the potential controls inventory. 

Since the above guidelines vary by boiler size and fuel type, the specific percent reduction 

applied to an individual source depends on the SCC and design capacity of the source. The 

SCC identifies the fuel type, while the design capacity identifies the boiler size. In many 

cases, the design capacities in the MANE-VU NIF database were missing. The following 

hierarchy was used in filling in gaps where design capacities were missing: 

Use the design capacity field from the NIF EU table, if available; 

Use the design capacities provided by agencies to fill in the data gaps in the 

MANE-VU 2002 inventory; 

Use design capacity as reported either the Unit Description field in the NIF EU 

table or the Process Description field from the NIF EP table, if available; 

Use design capacity from the source’s Title V permit, if the Title V permit was 

online; 

Use the SCC description to determine the design capacity (for example, SCC 1-02-

006-01 describes a >100 mmBtu/hr natural gas-fired boiler, SCC 1-02-006-02 

describes a 10-100 mmBtu/hr natural gas-fired boiler). 

After performing this gap-filling exercise, each boiler was assigned to one of the size 

ranges and fuel types shown in the above table. The emission reduction percentages by 

boiler size range and fuel type were then applied. 

5.4 FUEL OIL SULFUR LIMITS 

MANE-VU developed a low sulfur fuel oil strategy to help states develop Regional Haze 

SIPs (MANE-VU 2007). As previously discussed in Section 4.5, Each state was polled 

and asked to indicate when, if at all, the MANE-VU strategy would be incorporated into 

their state rules. States were also asked to provide the 2007 sulfur contents for each fuel 

type by county in order to calculate the percent reduction in emissions for the future years. 

Three states (MD, NJ, and NY) have adopted or are committed to adopting the strategy 

into their rules. The reductions for these three states were accounted for in the “existing 
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controls” inventory. All other jurisdictions indicated that not enough regulatory 

development progress has been made to include the reductions in future years with 

absolute certainty. The potential reductions for these states were accounted for in the 

“potential new controls” inventory. One state (VA) has no plans to adopt the low sulfur 

fuel oil strategy. The percent reductions by fuel type and county are contained in 

Appendix K. 

5.5 STATE-SPECIFIC NONEGU CONTROL FACTORS 

The following state-specific nonEGU control factors were provided: 

Bellefield Boiler Plant, Allegheny County. Allegheny County indicated that this 

facility changed their fuel source from coal to natural gas in July 2009 and future 

year emissions were changed to reflect the fuel switch. 

USS Clairton Works, Allegheny County. The facility will remove Batteries 7-9 

and have Battery C operational by 2013, resulting in a change in PM emissions in 

2013. Also, USS Clairton Works will remove Batteries 1-3 and have Battery D 

operational in 2015, resulting in a change in PM emissions in 2017 and 2020. 

Chrysler, Delaware. The Chrysler facility (ID 1000300128) shut down in 2009. 

Delaware specified that only a 25 percent reduction should be taken for all 

pollutants since some emissions will be banked for future use by other sources. 

O S G Ship Management (ID 1000500093), Delaware. Delaware provided 

source-specific growth factors and percent reductions in VOC emissions for 2017 

and 2020 from the lightering operations at O S G Ship Management (ID 

1000500093).

Control Technology Guidance (CTG) Documents, Delaware. Delaware 

determined that VOC emission reductions from new CTG recommendations would 

be very small. Although the new CTGs set up new recommendations for higher 

control efficiencies, the actual VOC reductions would be minimum, if not none, 

because most DE’s existing facilities are not affected by the new requirements and 

emissions from those facilities are relatively small (based on 2002 inventory). 

Unit Shutdowns, Delaware. Delaware identified several emission units that have 

shut down at the following facilities: Dow Reichhold Specialty Latex (ID 

1000100016), SPI Poly-Ols (ID 1000300426), and Invistas (ID 1000500002). 

Emissions for all pollutants were set to zero for these units. 
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Dover Air Force Base, Delaware. Delaware identified four boilers at Dover Air 

Force Base (ID 1000100001) that ceased using fuel oil in March 2010. SO2 

emissions for these boilers were set to zero. 

Premcor Refinery NOx Plantwide Cap, Delaware. The refinery was sold to the 

Delaware City Refining Company and an agreement was reached with DNREC's 

Secretary that allows plant-wide applicability limit (cap) for NOx. To project 

emissions, as well as for modeling purposes, Delaware decided to spread out the 

NOx-cap to each stack. Delaware estimated a plantwide reduction of 10.05 percent 

in 2013 and 41.22 percent in both 2017 and 2020. 

Wausau Paper Specialty Products, Maine. The Wausau Paper Specialty 

Products facility (ID 2300700007) closed in 2009. All emissions were set to zero 

for this facility in the 2017 and 2020 projection inventories. 

2009 NJ Rule for NOx for Municipal Solid Waste Incinerators, New Jersey. 

This rule will achieve a 27 percent reduction from one facility - Camden County 

Energy Recovery Associates, L.P. (ID 3400751614). 

NJ rule for VOC Storage Tanks, New Jersey. New Jersey provided expected 

VOC emission reductions resulting from post-2007 rules for VOC storage tanks. 

For refinery floating roof storage tanks (SCC 4-03-011-xx), the reductions are 75 

percent for 2013, 82 percent for 2017, and 85 percent for 2020. For bulk terminal 

tanks (SCC 4-04-001-xx), the reductions are 20 percent for 2013, 40 percent for 

2017, and 50 percent for 2020. For pipeline breakout stations (SCCs 4-04-002-xx 

and 4-06-005-xx), the reductions are 26 percent for 2013, 52 percent for 2017, and 

65 percent for 2020. 

International Paper – Franklin Mill, Virginia. The International Paper – 

Franklin Mill (ID 5109300006) closed effective 2010. All emissions were set to 

zero for this facility in the 2017 and 2020 projection inventories. 
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6.0 NONROAD MODEL CATEGORIES 

The USEPA’s NONROAD model estimates emissions from equipment such as 

recreational marine vessels, recreational land-based vehicles, farm and construction 

machinery, lawn and garden equipment, aircraft ground support equipment (GSE) and rail 

maintenance equipment. This equipment is powered by diesel, gasoline, compressed 

natural gas (CNG) or liquefied petroleum gas (LPG) engines. 

The National Mobile Inventory Model (NMIM) was developed by USEPA to develop 

county-level emission estimates for certain types of nonroad equipment. NMIM uses the 

current version the NONROAD model to develop emission estimates and was used to 

develop the projection inventories discussed here. The NMIM national county database 

contains monthly input data to reflect county specific fuel parameters and temperatures. 

Most of the work associated with executing NMIM involved updating the NMIM county 

database with State-specific information. For this analysis, we used the NMIM2008 

software (version NMIM20090504), the National County Database (version 

NCD20090531), and NONROAD2008a (July 2009 version) as a starting point. Changes 

were made to the NCD20090531 based on review of data by the States. The purpose of 

this review was to create a new NCD specific to the 2007 base year model runs and the 

three projection year model runs. Changes were made to a copy of the NCD20090531 to 

create a new NCD used for the emission inventory runs. That NCD is called 

NCD20090910MARAMA. 

6.1 STATE REVIEW OF NMIM FUEL CHARACTERISTICS 

For the 2017 and 2020 projection year inventories, AMEC provided data on fuel 

characteristics from the NCD20090531 to the States to determine if they had additional 

changes required for the fuel characteristics for future year inventories. None of the States 

had changes to the fuel characteristics, except for CT which provided revisions to the six 

fuels that they had provided for the 2007 base year inventory to account for a number of 

changes including changes to RVP and fuel sulfur. 

Connecticut provided updated values for the volume and market share components for 

ethanol which is used by NMIM to determine the oxygen percentage for NONROAD runs. 

Complete data replacement records were obtained for CT for the following tables: gasoline 

inputs, diesel inputs, countymonthyear inputs, and datasource inputs. CT added six new 

fuels which were given NRGasolineIds of 5000-5005 inclusive. Data was provided for 

both the base year (2007) and projection years (2013, 2017, and 2020). 
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The diesel fuel sulfur values for the projection years were maintained at their default 

values for all other States since they matched the USEPA recommended values. 

6.2 USE OF EXTERNAL FILES IN THE PROJECTION YEAR NMIM 

RUNS

For the 2007 base year inventory (MARAMA 2012), revisions were made to the allocation 

files for several categories. These files are used to allocate emissions calculated at the state 

level down to the county level and to add entries to the countynrfile NCD table. States 

were asked if they would like to revise this table for future years. No revisions were 

recommended. Thus external files used for the 2007 base year runs were used in the runs 

for the projection years. 

6.3 NMIM RUN SPECIFICATIONS 

The specifications for each NMIM run were developed for groups of States within the 

MANE-VU+VA region. All States except for CT, NY, NJ and PA were run together for 

each year. CT was run alone for 2007, 2017, and 2020 because changes were requested for 

the base year. NY, NJ and PA were run together for each individual projection year. The 

settings for each specification panel within the NMIM model for the projection year runs 

are detailed below. 

Description: A short descriptive term for the run was entered for each specific run. 

Geography: The “county” option was selected for each run. All counties within the 

State were selected. 

Time: Every month in the Months check box area was selected. On the time panel, 

the year (2017 or 2020) was selected in the drop down box and added to the year 

selections area. With the exception of the CT, all runs were performed for only one 

year. The Use Yearly Weather Data check box was selected; however, year 

specific data was not available within NMIM for the projection years. The only 

years included within the NMIM model for NCD20090531 are 1999-2008 

inclusive. If the specific year requested is not available, then NMIM uses 20 year 

average data for the estimates. Thus while the Use Yearly Weather Data box was 

checked, since the specific year was not there (except for the CT 2007 base year rerun), the 20 year average data in the countymonthhour table are used. However, 

because the meteorology data for future years will be assumed to be the same as 

was used for 2007, AMEC revised the AverageTemp and AverageRelHumidity 

values in the countymonthhour table of the NCD20090910MARAMA to reflect 

actual 2007 values. Thus the values in that table are 2007 values not 20 year 

average values and thus causes the NMIM model to run with the same data used for 

the 2007 base year runs. 

Vehicles/Equipment: Only the nonroad vehicle/equipment area was selected. All 

fuels and all vehicle types were selected for each State run. Aircraft ground support 
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equipment was included in the run specifications but those records were removed 

during post-processing steps. 

Fleet: No selections or information was entered in this panel. 

Pollutants: Exhaust PM10, PM2.5, and Criteria pollutants (with HC reported as 

VOC) were selected except for CO2.

Advanced features: Only the server and database were selected in this panel. 

Output: Under the Geographic Representation panel the County selection was 

made. In the General Output area, a new database was selected on the server for 

the output. 

All added external files for use in each State run were placed in the externalfiles directory 

of the NCD. Entries for all external files included were included in the countynrfiles table 

of the NCD. 

6.4 REMOVAL OF AIRPORT GROUND SUPPORT EQUIPMENT 

The NMIM/NONROAD model calculates emissions from airport ground support 

equipment. As discussed in Section 7 of this TSD, emissions from airport ground support 

equipment is also included in USEPA’s aircraft inventory prepared using the Federal 

Aviation Administration’s Emissions and Dispersion Modeling System (EDMS). 

Correspondence with USEPA indicated that USEPA considers the emissions calculated by 

EDMS to be better than those calculated by NONROAD. For this reason, all emissions 

calculated by NMIM/NONROAD for airport ground support equipment were removed 

from the inventory to avoid double counting. 

6.5 STATE AND STAKEHOLDER REVIEW AND COMMENT 

New York state provided the results of their own NONROAD model runs for 2017 and 

2020. These model results were provided by month and were used instead of the NMIM 

model runs made by MACTEC. 

6.6 CHANGES MADE FOR VERSION 3 MODEL RUNS 

Two sectors of the inventory were updated in version 3. First, Virginia and New York 

requested that their emissions be recalculated using the information developed through 

Version 2 of the inventory for the MARAMA States. The Virginia reruns were performed 

for all categories except for ground support equipment and for recreational marine vessels. 

Recreational marine vessel emissions for Virginia were calculated along with those for 

other states (see below). Those values replaced the SEMAP supplied values used in 

versions prior to Version 3. In addition, estimates for all sectors of the inventory for New 

York other than ground support equipment and recreational marine vessels were calculated 
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using NMIM default data for the MARAMA area. New York had originally provided data 

from NONROAD model runs that they performed separately. For Version 3 of the 

inventory, New York emissions were calculated using NMIM runs set up using the same 

criteria as those for other states in earlier versions of the inventory. Both New York and 

Virginia were provided with the opportunity to review fuel characteristics prior to their 

runs. Only Virginia made changes to the fuels, however the only changes that were made 

were to assign alternative default fuels to counties. The fuel characteristics were not 

modified from the NMIM defaults, only the fuel IDs associated with a particular 

county/month combination were changed to another default fuel. Those changes were 

instituted in the NCD developed specifically for MARAMA. New York did not request 

any changes to the default values. In addition, the revisions made to the housing 

population allocation files were instituted for both states. 

The second change in version 3 was to modify the recreational marine vessel populations 

for all states except Vermont and Maine. A revised population file was prepared for 

Virginia but not utilized in the version 3 runs. Estimates for Virginia, Vermont and Maine 

were prepared using the growth algorithm built into the NMIM/NONROAD model. For 

all other states, revised population data was estimated for the years 2017 and 2020. EPA 

had recommended that rather than use the default growth algorithm of the model for those 

states that had their 2007 base year data updated for this category, separate population 

estimates for each projection year should be prepared and included in the population files. 

The 2007 population data was provided by the National Marine Manufacturers Association 

(NMMA). Total state populations for each of the three major categories contained in the 

NONROAD model (outboard, inboard/sterndrive and personal watercraft) were provided 

for each state. Because the population files used by the NONROAD model (and thus 

NMIM) were configured with population values for various horsepower categories, AMEC 

(formerly AMEC) determined the fraction of the total for each marine vessel type in each 

horsepower category from the NONROAD default population files. These fractions were 

then used to allocate the total state population obtained from NMMA to the various 

horsepower categories. 

The only exception to this was that some states added in data for sailboats. The sailboat 

populations were split among two of the default categories. In addition, New Hampshire 

provided their own revised population file. Their population data for New Hampshire was 

provided by the New Hampshire DMV and is not from NMMA. 

AMEC then used the national growth factors supplied in the default NMIM/NONROAD 

model to estimate populations for each year. Each horsepower/population category in the 

2007 population file was grown to either 2017 or 2020 using the ratio between the 2005 
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and 2015 growth factors (to represent growth between 2007 and 2017) and between the 

2005 and 2025 growth factors (to represent growth between 2007 and 2020). Those ratios 

were used to grow the 2007 population to 2017 and 2020 respectively. The only exception 

to this was Pennsylvania. Pennsylvania presented data indicating that there was little 

growth expected during the time periods that were considered and thus maintained the 

2007 population estimates for both 2017 and 2020. 

Pennsylvania presented information showing from historical data that indicated a 

downward trend in the overall motorized pleasure craft population in 6 of the last 9 years. 

The data also indicated that the population was essentially unchanged in the last three years 

due to an adverse economic environment. Populations of all motorized pleasure craft in 

Pennsylvania as tracked by the Pennsylvania Fish and Boat Commission showed nearly a 6 

percent decline from 2001 to 2007 or an average annual decline of 1.0 percent over that 

period. Pleasure craft populations remained nearly unchanged from 2008 to 2010. 

As a consequence, they forecaste zero percent growth for pleasure craft is from 2007 to 

2017 and 2007 to 2020. The types of pleasure craft affected by this growth rate are: 

2282005010, 2-stroke outboard, 

2282005015, 2-stroke personal water craft, 

2282010005, 4-stroke inboard/sterndrive, 

2282020005, diesel inboard/sterndrive, and 

2282020010, diesel outboards 

6.7 NMIM/NONROAD GROWTH AND CONTROL INFORMATION 

In estimating future year emissions, the NMIM/NONROAD model includes growth and 

scrappage rates for equipment in addition to a variety of control programs. It is not 

possible separate out the future year emissions due to “growth only” or “control only” in a 

single run. That is, the model run provides a single future year estimate that is a “growth 

and control” scenario. 

The growth data used in the NMIM/NONROAD model is documented in a USEPA report 

(USEPA 2004c). The GROWTH packet of the NONROAD model cross-references each 

SCC to a growth indicator code. The indicator code is an arbitrary code that identifies an 

actual predicted value such as human population or employment that is used to estimate 

the future year equipment population. The GROWTH packet also defines the scrappage 

curves used to estimate the future year model year distribution. 
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The NMIM/NONROAD model also accounts for all USEPA emission standards for 

nonroad equipment. There are mulitiple standards that vary by equipment type, rated 

power, model year, and pollutatant. Exhibit 6.1 is a summary of the emission control 

programs accounted for in the NMIM/NONROAD model. A complete summary of the 

nonroad equipment emission standards can be found on the USEPA nonroad emission 

standards reference guide website (USEPA 2011). 

Exhibit 6.1 Control Programs Included in the NMIM/NONROAD Model 

Regulation Description

Control of Air Pollution; 

Determination of Significance for 

Nonroad Sources and Emission 

Standards for New Nonroad 

Compression Ignition Engines At or 

Above 37 Kilowatts

59 FR 31036

June 17, 1994

This rule establishes Tier 1 exhaust emission standards for 

HC, NOx, CO, and PM for nonroad compression-ignition 

(CI) engines ≥37kW (≥50hp). Marine engines are not 

included in this rule. The start dates and pollutants 

affected vary by hp category as follows:

50-100 hp: Tier 1,1998; NOx only

100-175 hp: Tier 1, 1997; NOx only

175-750 hp: Tier 1, 1996; HC, CO, NOx, PM

>750 hp: Tier 1, 2000; HC, CO, NOx, PM

Emissions for New Nonroad SparkIgnition Engines At or Below 19 

Kilowatts; Final Rule

60 FR 34581

July 3, 1995

This rule establishes Phase 1 exhaust emission standards 

for HC, NOx, and CO for nonroad spark-ignition engines 

≤19kW (≤25hp). This rule includes both handheld (HH) 

and nonhandheld (NHH) engines. The Phase 1 standards 

become effective in 1997 for :

 Class I NHH engines (<225cc), 

 Class II NHH engines (≥225cc), 

 Class III HH engines (<20cc), and 

 Class IV HH engines (≥20cc and <50cc). 

The Phase 1 standards become effective in 1998 for:

 Class V HH engines (≥50cc) 

Final Rule for New Gasoline SparkIgnition Marine Engines; Exemptions 

for New Nonroad CompressionIgnition Engines at or Above 37 

Kilowatts and New Nonroad SparkIgnition Engines at or Below 19 

Kilowatts

61 FR 52088

October 4, 1996

This rule establishes exhaust emission standards for 

HC+NOx for personal watercraft and outboard (PWC/OB) 

marine SI engines. The standards are phased in from 

1998-2006.

Control of Emissions of Air Pollution 

From Nonroad Diesel Engines

63 FR 56967

October 23, 1998

This final rule sets Tier 1 standards for engines under 50 

hp, phasing in from 1999 to 2000. It also phases in more 

stringent Tier 2 standards for all engine sizes from 2001 to 

2006, and yet more stringent Tier 3 standards for engines 

rated over 50 hp from 2006 to 2008. The Tier 2 standards 

apply to NMHC+NOx, CO, and PM, whereas the Tier 3 

standards apply to NMHC+NOx and CO. The start dates 

by hp category and tier are as follows:
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Regulation Description

 hp<25: Tier 1,2000; Tier 2, 2005; no Tier 3

 25-50 hp: Tier 1, 1999; Tier 2, 2004; no Tier 3

 50-100 hp: Tier 2, 2004; Tier 3, 2008

 100-175 hp: Tier 2, 2003; Tier 3, 2007

 175-300 hp: Tier 2, 2003; Tier 3, 2006

 300-600 hp: Tier 2, 2001, Tier 3, 2006

 600-750 hp: Tier 2, 2002; Tier 3, 2006

 >750 hp: Tier 2, 2006, no Tier 3

This rule does not apply to marine diesel engines above 50 

hp.

Phase 2: Emission Standards for 

New Nonroad Nonhandheld Spark 

Ignition Engines At or Below 19 

Kilowatts

64 FR 15207

March 30, 1999

This rule establishes Phase 2 exhaust emission standards 

for HC+NOx for nonroad nonhandheld (NHH) spark-ignition 

engines ≤19kW (≤25hp). The Phase 2 standards for Class 

I NHH engines (<225cc) become effective on August 1, 

2007 (or August 1, 2003 for any engine initially produced 

on or after that date). The Phase 2 standards for Class II 

NHH engines (≥225cc) are phased in from 2001-2005.

Phase 2: Emission Standards for 

New Nonroad Spark-Ignition 

Handheld Engines At or Below 19 

Kilowatts and Minor Amendments to 

Emission Requirements Applicable 

to Small Spark-Ignition Engines and 

Marine Spark-Ignition Engines; Final 

Rule

65 FR 24268

April 25, 2000

This rule establishes Phase 2 exhaust emission standards 

for HC+NOx for nonroad handheld (HH) spark-ignition 

engines ≤19kW (≤25hp). The Phase 2 standards are 

phased in from 2002-2005 for Class III and Class IV 

engines and are phased in from 2004-2007 for Class V 

engines.

Control of Emissions From Nonroad 

Large Spark-Ignition Engines and 

Recreational Engines (Marine and 

Land-Based); Final Rule

67 FR 68241

November 8, 2002

This rule establishes exhaust and evaporative standards 

for several nonroad categories: 

1) Two tiers of emission standards are established for large 

spark-ignition engines over 19 kW. Tier 1 includes exhaust 

standards for HC+NOx and CO and is phased in from 

2004-2006. Tier 2 becomes effective in 2007 and includes 

exhaust standards for HC+NOx and CO as well as 

evaporative controls affecting fuel line permeation, diurnal 

emissions and running loss emissions.

2) Exhaust and evaporative emission standards are 

established for recreational vehicles, which include 

snowmobiles, off-highway motorcycles, and all-terrain 

vehicles (ATVs). For snowmobiles, HC and CO exhaust 

standards are phased-in from 2006-2012. For off-highway 

motorcycles, HC+NOx and CO exhaust emission 

standards are phased in from 2006-2007. For ATVs, 

HC+NOx and CO exhaust emission standards are phased 

in from 2006-2007. Evaporative emission standards for 

fuel tank and hose permeation apply to all recreational 

vehicles beginning in 2008.

3) Exhaust emission standards for HC+NOx, CO, and PM 

for recreational marine diesel engines over 50 hp begin in 

2006-2009, depending on the engine displacement. These 

are “Tier 2” equivalent standards.
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Regulation Description

Control of Emissions of Air Pollution 

From Nonroad Diesel Engines and 

Fuel; Final Rule (Clean Air Nonroad 

Diesel Rule – Tier 4)

69 FR 38958

June 29, 2004

This final rule sets Tier 4 exhaust standards for CI engines 

covering all hp categories (except marine and 

locomotives), and also regulates nonroad diesel fuel sulfur 

content.

1) The Tier 4 start dates and pollutants affected vary by hp 

and tier as follows:

 hp<25: 2008, PM only

 25-50 hp: Tier 4 transitional, 2008, PM only; 

 Tier 4 final, 2013, NMHC+NOx and PM

 50-75 hp: Tier 4 transitional, 2008; PM only; 

 Tier 4 final, 2013, NMHC+NOx and PM

 75-175 hp: Tier 4 transitional, 2012, HC, NOx, and PM; 

 Tier 4 final, 2014, HC,NOx,PM

 175-750 hp:Tier 4 transitional, 2011, HC, NOx, and PM;

 Tier 4 final, 2014, HC,NOx,PM

 >750 hp: Tier 4 transitional, 2011, HC, NOx, and PM; 

 Tier 4 final, 2015, HC,NOx,PM

2) This rule will reduce nonroad diesel fuel sulfur levels in 

two steps. First, starting in 2007, fuel sulfur levels in 

nonroad diesel fuel will be limited to a maximum of 500 

ppm, the same as for current highway diesel fuel. Second, 

starting in 2010, fuel sulfur levels in most nonroad diesel 

fuel will be reduced to 15 ppm.

Control of Emissions From Nonroad 

Spark-Ignition Engines and 

Equipment; Final Rule (Bond Rule)

73 FR 59034

October 8, 2008

This rule establishes exhaust and evaporative standards 

for small SI engines and marine SI engines:

1) Phase 3 HC+NOx exhaust emission standards are 

established for Class I NHH engines starting in 2012 and 

for Class II NHH engines starting in 2011. There are no 

new exhaust emission standards for handheld engines. 

New evaporative standards are adopted for both handheld 

and nonhandheld equipment. The new evaporative 

standards control fuel tank permeation, fuel hose 

permeation, and diffusion losses. The evaporative 

standards begin in 2012 for Class I NHH engines and 2011 

for Class II NHH engines. For handheld engines, the 

evaporative standards are phased-in from 2012-2016.

2) More stringent HC+NOx and CO standards are 

established for marine SI PWC/OB engines beginning in 

2010. In addition, new exhaust HC+NOx and CO 

standards are established for sterndrive and inboard (SD/I) 

marine SI engines also beginning in 2010. High 

performance SD/I engines are subject to separate 

HC+NOx and CO exhaust standards that are phased-in 

from 2010-2011. New evaporative standards were also 

adopted for all marine SI engines that control fuel hose 

permeation, diurnal emissions, and fuel tank permeation 

emissions. The hose permeation, diurnal, and tank 

permeation standards take effect in 2009, 2010, and 2011.

Source: USEPA 2010e 
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7.0 NONROAD MAR SOURCE CATEGORIES 

The USEPA’s NONROAD model does not estimate emissions for three nonroad source 

categories: commercial marine vessel, aircraft, and railroad locomotives. The emission 

projection methodology and data sources for these three categories (collectively referred to 

as marine, airport, railroad {or MAR}) are discussed in this section. The data used to 

calculate the growth and control factors for MAR sources are included in Appendix L. 

7.1 COMMERCIAL MARINE VESSELS 

For the purpose of emission calculations, marine vessel engines are divided into three 

categories based on displacement (swept volume) per cylinder. Category 1 and Category 2 

marine diesel engines typically range in size from about 500 to 8,000 kW (700 to 11,000 

hp). These engines are used to provide propulsion power on many kinds of vessels 

including tugboats, pushboats, supply vessels, fishing vessels, and other commercial 

vessels in and around ports. They are also used as stand-alone generators for auxiliary 

electrical power on vessels. Category 3 marine diesel engines typically range in size from 

2,500 to 70,000 kW (3,000 to 100,000 hp). These are very large marine diesel engines used 

for propulsion power on ocean-going vessels such as container ships, oil tankers, bulk 

carriers, and cruise ships. 

The majority of marine vessels are powered by diesel engines that are either fueled with 

distillate or residual fuel oil blends. For the purpose of emission inventories, USEPA has 

assumed that Category 3 vessels primarily use residual blends while Category 1 and 2 

vessels typically use distillate fuels. 

EPA developed national emission inventories for Category 1 and 2 vessels and Category 3 

vessels for calendar years 2002 through 2040 as part of its effort to develop emission 

standards for these vessels. The methodologies used to develop the emission projections 

(for both a baseline and controlled scenario) are documented in a regulatory impact 

assessment (USEPA 2008c). We used the USEPA data and methodologies from these 

RIAs to develop separate growth and control factors for Category 1 and 2 vessels (diesel) 

and Category 3 vessels (residual). 

7.1.1 CMV Diesel Growth Factors 

For Category 1 and 2 diesel vessels, USEPA used projection data for domestic shipping 

from the AEO2006 (EIA 2006). The annual growth rate reported in the RIA is 0.9%. 

More recent growth data for domestic shipping is available in the AEO2010 (EIA 2010). 

Since Category 1 and 2 vessels primarily accounts for activity data for ships that carry 

domestic cargo, we decided to use the recent growth data for domestic shipping available 
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in the AEO2010. We used Table A-7 of the AEO2010 for international shipping to 

calculate the growth factor for 2007-2013 to be 0.975, for 2007-2017 to be 1.003, and for 

2007-2020 to be 1/033. These growth factors were used for for CMV diesel port emissions 

(SCC 22-80-002-100) and CMV diesel underway emissions (SCC 22-80-002-200). 

7.1.2 CMV Diesel Control Factors 

In developing their emission projections, USEPA developed two scenarios that accounted 

for both the 2004 nonroad diesel rule and the 2008 diesel marine vessel rule: 

The USEPA’s baseline (pre-control) inventory accounted for: 

1. the 0.9 percent annual growth in fuel use, 

2. the impact of existing engine regulations that took effect in 2008, 

3. the 2004 Clean Air Nonroad Diesel Rule that will decrease the allowable 

levels of sulfur in fuel beginning in 2012, and 

4. fleet turnover. 

The USEPA’s controlled inventory accounted for: 

1. the 0.9 percent annual growth in fuel use; 

2. the reductions included in the baseline inventory, and the reductions from 

USEPA’s 2008 rule Final Locomotive-Marine rule for Tier 3 and 4 engines; 

and 

3. The 2008 final rule that includes the first-ever national emission standards 

for existing marine diesel engines, applying to engines larger than 600kW 

when they are remanufactured. The rule also sets Tier 3 emissions 

standards for newly-built engines that are phasing in from 2009. Finally, 

the rule establishes Tier 4 standards for newly-built commercial marine 

diesel engines above 600kW, phasing in beginning in 2014. 

To calculate a control factor that accounts for reductions included in the USEPA controlled 

inventory, it was necessary to first calculate a “growth only” scenario applying USEPA’s 

0.9 percent annual growth rate to the 2006 base emissions. Once the growth rate was 

applied, then a control factor for each pollutant was calculated by dividing the future year 

controlled emissions by the future year “growth only” emissions. Exhibit 7.1 shows the 

control factors for 2017 and 2020 for diesel commercial marine vessels. 
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Exhibit 7.1 CMV Diesel Control Factors by Year and Pollutant

Year CO NOx PM10 PM2.5 SO2 VOC

2013 0.885 0.787 0.747 0.747 0.464 0.871

2017 0.830 0.642 0.550 0.550 0.076 0.708

2020 0.801 0.537 0.460 0.460 0.032 0.586

7.1.3 CMV Residual Oil Growth Factors 

For Category 3 residual oil vessels, data from an USEPA-sponsored study was used to 

develop an annualized growth factor of 4.5 percent for the region. A few states considered 

the growth rate to be extremely high and not reflective of recent economic conditions. 

Since USEPA’s Category 3 vessel inventory is primarily based on activity data for ships 

that carry foreign cargo, we decided to use the recent growth data for international 

shipping available in the AEO2010. We used data from Table A-7 of the AEO2010 for 

international shipping to calculate the growth factor for 2007-2013 to be 0.940, for 2007-

2017 to be 0.946, and for 2007-2020 to be 0.950. These growth factors were used for 

CMV residual oil port emissions (SCC 22-80-003-100) and CMV residual oil underway 

emissions (SCC 22-80-003-200). 

7.1.4 CMV Residual Oil Control Factors 

On December 22nd, 2009, USEPA announced final emission standards under the Clean 

Air Act for new marine diesel engines with per-cylinder displacement at or above 30 liters 

(called Category 3 marine diesel engines) installed on U.S.-flagged vessels. The final 

engine standards are equivalent to those adopted in the amendments to Annex VI to the 

International Convention for the Prevention of Pollution from Ships (a treaty called 

"MARPOL"). The emission standards apply in two stages: near-term standards for newlybuilt engines will apply beginning in 2011, and long-term standards requiring an 80 

percent reduction in NOx will begin in 2016. USEPA also adopted changes to the diesel 

fuel program to allow for the production and sale of diesel fuel with no more than 1,000 

ppm sulfur for use in Category 3 marine vessels. The regulations generally forbid 

production and sale of fuels with more than 1,000 ppm sulfur for use in most U.S. waters, 

unless operators achieve equivalent emission reductions in other ways. 

On March 26, 2010, the International Maritime Organization (IMO) officially designated 

waters off North American coasts as an emissions control area (ECA) in which stringent 

international emission standards will apply to ships. In practice, implementation of the 

ECA means that ships entering the designated area would need to use compliant fuel for 

the duration of their voyage that is within that area, including time in port and voyages 

whose routes pass through the area without calling on a port. The North American ECA 
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includes waters adjacent the Atlantic extending up to 200 nautical miles from east coast of 

the United States. The quality of fuel that complies with the ECA standard will change 

over time. From the effective date in 2012 until 2015, fuel used by vessels operating in 

designated areas cannot exceed 1.0 percent sulfur (10,000 ppm). Beginning in 2015, fuel 

used by vessels operating in these areas cannot exceed 0.1 percent sulfur (1000 ppm). 

Beginning in 2016, NOx aftertreatment requirements become applicable. 

To calculate a control factor that accounted for reductions included in the USEPA 

controlled inventory, it was necessary to first calculate a “growth only” scenario applying 

USEPA’s 4.5 percent annual growth rate to the 2006 base emissions. Once the growth rate 

was applied, then a control factor for each pollutant was calculated by dividing the future 

year controlled emissions by the future year “growth only” emissions. 

Exhibit 7.2 shows the control factors for 2017 and 2020 for residual oil commercial marine 

vessels. 

Exhibit 7.2 CMV Residual Oil Control Factors by Year and Pollutant

Year CO NOx PM10 PM2.5 SO2 VOC

2013 1.000 0.736 0.353 0.353 0.270 1.000

2017 1.000 0.654 0.216 0.216 0.120 1.000

2020 1.000 0.597 0.137 0.137 0.036 1.000

7.1.5 Military Vessels Growth and Control Factors 

Virginia reported emissions for military vessels, but did not distinguish between diesel or 

residual fuels. We assumed that there would be “no growth” for military vessel activity 

and emissions in Virginia would remain at 2007 levels in 2017 and 2020. Virginia was the 

only state to report emission from military vessels. 

7.2 AIRCRAFT 

Aircraft emissions in the 2007 MANE-VU+VA inventory are available on either a countyby-county or airport-by-airport basis for six types of aircraft operations: 

Air carrier operations represent landings and take-offs (LTOs) of commercial 

aircraft with seating capacity of more than 60 seats; 

Commuter/air taxi operations are one category. Commuter operations include 

LTOs by aircraft with 60 or fewer seats that transport regional passengers on 
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scheduled commercial flights. Air taxi operations include LTOs by aircraft with 60 

or fewer seats conducted on non-scheduled or for-hire flights; 

General aviation represents all civil aviation LTOs not classified as commercial; 

Military operations represent LTOs by military aircraft; 

Ground Support Equipment (GSE) typically includes aircraft refueling and baggage 

handling vehicles and equipment, aircraft towing vehicles, and passenger buses; 

and 

Auxiliary power units (APUs) provide power to start the main engines and run the 

heating, cooling, and ventilation systems prior to starting the main engines. 

7.2.1 Aircraft Growth Factors 

Aircraft operations were projected to future years by applying activity growth using data 

on itinerant (ITN) operations at airports as reported in the Federal Aviation 

Administration’s (FAA) Terminal Area Forecast (TAF) System for 2009-2030 (FAA 

2010). The ITN operations are defined as aircraft take-offs or landings. This information is 

available for approximately 3300 individual airports. Actual LTOs are reported for 2007 

and projected LTOs are provided for all years up to 2030. 

We aggregated and applied this information at the county level for the four operation 

types: commercial, general, air taxi, military. We computed growth factors for each 

operation type by dividing future-year ITN by 2007-year ITN. We assigned factors to 

inventory SCCs based on the operation type, as shown in Exhibit 7.3. 

Exhibit 7.3 Crosswalk between SCC and FAA Operations Type 

SCC SCC Description FAA Operation Type Used for 

Growth Factor

2265008005 Airport Ground Support Equipment, 4-Stroke Gas Total Itinerant Operations

2267008005 Airport Ground Support Equipment, LPG Total Itinerant Operations

2268008005 Airport Ground Support Equipment, CNG Total Itinerant Operations

2270008000 Airport Ground Support Equipment, Diesel Total Itinerant Operations

2270008005 Airport Ground Support Equipment, Diesel Total Itinerant Operations

2275001000 Aircraft /Military Aircraft /Total Itinerant Military Operations

2275020000 Aircraft /Commercial Aircraft /Total: All Types Itinerant Air Carrier Operations

2275050000 Aircraft /General Aviation /Total Itinerant General Aviation Operations

2275050011 Aircraft /General Aviation /Piston Itinerant General Aviation Operations

2275050012 Aircraft /General Aviation /Turbine Itinerant General Aviation Operations
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SCC SCC Description FAA Operation Type Used for 

Growth Factor

2275060000 Aircraft /Air Taxi /Total Itinerant Air Taxi Operations

2275060011 Aircraft /Air Taxi /Piston Itinerant Air Taxi Operations

2275060012 Aircraft /Air Taxi /Turbine Itinerant Air Taxi Operations

2275070000 Aircraft /Aircraft Auxiliary Power Units /Total Total Itinerant Operations

Exhibit 7.4 summarizes the region-wide growth factors by FAA operation type. The 

growth factor for individual airports/counties may deviate substantially from these regionwide growth factors. 

Exhibit 7.4 Region-wide Growth Factors from 2007 by FAA Operations Type 

7.2.2 Aircraft Control Factors 

The NOx aircraft engine emissions standards adopted by USEPA in November 2005 

(USEPA 2005b) were reviewed. The standards are equivalent to the NOx emission 

standards (adopted in 1999 for implementation beginning in 2004) of the United Nations 

International Civil Aviation Organization (ICAO), and will bring the United States aircraft 

standards into alignment with the international standards. The standards apply to new 

aircraft engines used on commercial aircraft including small regional jets, single-aisle and 
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twin-aisle aircraft, and 747s and larger aircraft. The standards also apply to general 

aviation and military aircraft, which sometimes use commercial engines. For example, 

small regional jet engines are used in executive general aviation aircraft, and larger 

commercial aircraft engines may be used in military transport aircraft. 

Nearly all previously certified or in-production engine models currently meet or perform 

better than the standards USEPA adopted in the November 2005 rule. In addition, 

manufacturers have already been developing improved technology in response to the 

ICAO standards. According to USEPA’s recent analysis for the proposed transport rule 

(USEPA 2010a), this rule is expected to reduce NOx emissions by approximately 2 percent 

in 2015 and 3 percent in 2020. Because of the relatively small amount of NOx reductions, 

our aircraft emission projections do not account for this control program. 

EPA has also issued an Advance Notice of Proposed Rulemaking (ANPR) on lead 

emissions from piston-engine aircraft using leaded aviation gasoline (USEPA 2010d). 

However, this rule has not yet been adopted and co-benefits for criteria air pollutants are 

likely to be small. Therefore, the effects of this rule were not included in the future-year 

emissions projections. 

7.3 RAILROAD EQUIPMENT 

Railroad locomotive engine emissions in the 2007 MARAMA inventory are classified into 

the following categories: 

Class I line haul locomotives are operated by large freight railroad companies and 

are used to power freight train operations over long distances (SCC 22-85-002-

006);

Class II/III line haul locomotives are operated by smaller freight railroad 

companies and are used to power freight train operations over long distances (SCC 

22-85-002-007); 

Inter-city passenger train locomotives are operated primarily by Amtrak to provide 

inter-city passenger transport (SCC 22-85-002-008); 

Independent commuter rail systems operate locomotives provide passenger 

transport within a metropolitan area (SCC 22-85-002-009); and 

Yard/switch locomotives are used in freight yards to assemble and disassemble 

trains, or for short hauls of trains that are made up of only a few cars (SCC 22-85-

002-010).
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7.3.1 Railroad Growth Factors 

In March 2008, USEPA finalized a three part program that will dramatically reduce 

emissions from diesel locomotives of all types -- line-haul, switch, and passenger rail. As 

part of this work USEPA developed a national emission inventory for calendar years 2002 

through 2040. Emission projections methodologies for a baseline and controlled scenario 

were developed and documented (USEPA 2008c). USEPA used projection data from the 

AEO2006 (EIA 2006). Table A-7 of AEO2006 showed that freight rail energy use will 

grow 1.6 percent annually. 

More recent growth data is available in the AEO2010 which was published in May 2010. 

There are separate projections for passenger rail and freight rail energy use. For the 

MANE VU+VA inventory we relied on the more recent AEO2010 growth projections. 

Passenger rail data from AEO2010 Table A-7 was used to calculate the growth factor for 

2007-2013 to be 1.046, for 2007-2017 to be 1.121, and for 2007-2020 to be 1.171. These 

growth factors were applied to inter-city passenger train locomotives (SCC 22-85-002-

008) and independent commuter rail systems (SCC 22-85-002-009). 

For freight rail, the data from AEO2010 Table A-7 was used to calculate the growth factor 

for 2007-2013 to be 0.969, for 2007-2017 to be 1.018, and for 2007-2020 to be 1.053. We 

used the freight rail annual growth factors for Class I line haul (SCC 22-85-002-006), 

Class II/III line haul (SCC 22-85-002-007), and yard switch (SCC 22-85-002-010) 

locomotives. 

7.3.2 Railroad Control Factors 

USEPA developed two scenarios that accounted for both the 2004 nonroad diesel rule and 

the 2008 diesel locomotive rule: 

The USEPA baseline (pre-control) inventory accounted for 

1. AEO2006 annual growth in fuel use, 

2. The impact of existing regulations for Tier 0, 1, and 2 locomotive engines 

that take effect in 2008, 

3. The 2004 Clean Air Nonroad Diesel Rule that will decrease allowable 

levels of sulfur in locomotives fuel beginning in 2012, and 

4. Fleet turnover. 

The USEPA controlled inventory accounted for 

1. AEO2006 annual growth in fuel use, 

2. Reductions included in the baseline inventory, and 
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3. Reductions from USEPA’s 2008 rule Final Locomotive-Marine rule for 

Tier 3 and 4 engines. This rule lowered diesel sulfur content and tightened 

emission standards for existing and new locomotives. 

4. Voluntary retrofits under the National Clean Diesel Campaign are not 

included in our projections. 

To calculate a factor that accounted for reductions included in the USEPA controlled 

inventory, it was necessary to first calculate a “growth only” scenario applying USEPA’s 

1.6% annual growth rate to the 2006 base emissions. Once the growth rate was applied, 

then a control factor for each pollutant was calculated by dividing the future year 

controlled emissions by the future year “growth only” emissions. 

Exhibit 7.5 shows the control factors for 2017 and 2020 for the five locomotive 

classifications and pollutants. 

Exhibit 7.5 Rail Control Factors by Year, Pollutant, and SCC 

Year NOx PM10 PM2.5 HC CO VOC SO2

SCC 22-85-002-006 Line Haul Class I Operations

2017 0.633 0.449 0.449 0.480 1.000 0.480 0.003

2020 0.547 0.364 0.364 0.382 1.000 0.382 0.003

SCC 22-85-002-007 Line Haul Class II / III Operations

2017 0.960 0.791 0.791 1.000 1.000 1.000 0.003

2020 0.920 0.752 0.752 1.000 1.000 1.000 0.003

SCC 22-85-002-008 Inter-City Passenger

2017 0.421 0.402 0.402 0.437 0.917 0.437 0.003

2020 0.340 0.294 0.294 0.290 0.895 0.290 0.003

SCC 22-85-002-009 Commuter Rail

2017 0.421 0.402 0.402 0.437 0.917 0.437 0.003

2020 0.340 0.294 0.294 0.290 0.895 0.290 0.003

SCC 22-85-002-010 Yard / Switch

2017 0.843 0.712 0.712 0.809 1.000 0.809 0.003

2020 0.771 0.650 0.650 0.726 1.000 0.726 0.003
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8.0 SUMMARY OF PROJECTED EMISSIONS 

8.1 AREA SOURCE PROJECTED EMISSIONS 

Exhibits 8.1 to 8.7 summarize the 2007 and projected future year area source emissions by 

state for each criteria air pollutant. Seven values are listed for each pollutant: 

2007 emissions 

2017 projected emissions with growth only (GO) 

2017 projected emissions with growth and existing controls (GC) 

2017 projected emissions with growth, existing and potential new OTC controls (GX) 

2020 projected emissions with growth only (GO) 

2020 projected emissions with growth and existing controls (GC) 

2020 projected emissions with growth, existing and potential new OTC controls (GX) 

Detailed summaries by County and SCC are provided on MARAMA’s ftp site. 

CO emissions in most states decline between 2007 and 2020, primarily due to decreases in 

residential wood combustion emissions resulting from the turnover to NSPS-compliant 

wood stoves. The two exceptions are DC and NY, where there is a slight increase in CO 

emissions from 2007 to 2020. There are no additional reductions expected from potential 

new OTC control measures. 

NH3 emissions are projected to increase in most states between 2007 and 2020. This is 

due primarily to the growth predicted for fertilizer application on cropland and certain 

livestock waste products. There are no additional reductions expected from any existing 

control program or any potential new OTC control measures. 

Under the “growth only” scenario, NOx emissions are projected to decline by about 5 

percent between 2007 and 2017 due to AEO fuel use projections that generally show 

decreases in residential, commercial, and industrial fuel consumption. Under the “existing 

controls” scenario, NOx emissions in 2017 are projected to decrease by about 6.7 percent 

regionwide from 2007 levels due primarily to RICE MACT controls. Under the “potential 

new OTC controls” scenario, NOx emissions are projected to decrease by about 17 percent 

between 2007 and 2017 due to potential new controls on ICI boilers and new, small, 

natural gas-fired units. 

PM10-PRI emissions are projected to increase slightly in all states between 2007 and 2017. 

Reentrained road dust on paved roads is a large source of PM10-PRI emissions and is 

directly proportional to the projected increases in VMT on paved roads. These increases 

from paved road dust are somewhat offset by decreases resulting from the turnover to 

NSPS-compliant wood stoves and the AEO fuel use projections that generally show 
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Page 90

decreases in residential, commercial, and industrial fuel consumption, especially for coal 

and oil. There are no additional reductions expected from potential new OTC control 

measures. 

PM25-PRI emissions are projected to increase slightly from 2007 to 2020. Increases from 

paved road dust are somewhat offset by decreases resulting from the turnover to NSPScompliant wood stoves and the AEO fuel use projections that generally show decreases in 

residential, commercial, and industrial fuel consumption, especially for coal and oil. There 

are no additional reductions expected from potential new OTC control measures. 

Under the “growth only” scenario, SO2 emissions are projected to decline by about 16

percent between 2007 and 2017 due to AEO fuel use projections that generally show 

decreases in residential, commercial, and industrial fuel consumption, especially for coal 

and oil. Under the “existing controls” scenario, SO2 emissions in 2017 are projected to 

decrease by about 42 percent regionwide from 2007 levels due primarily to low sulfur fuel 

oil limits in MD, NJ, and NY. Under the “potential new OTC controls” scenario, SO2 

emissions are projected to decrease by about 68 percent between 2007 and 2017 due to the 

potential implementation of low sulfur fuel oil limits in other MANE-VU states. 

Under the “growth only” scenario, VOC emissions are projected to decrease slightly due to 

the turnover to NSPS-compliant wood stoves and the turnover over of vehicles equipped 

with on-board vapor recovery canisters. Under the “existing controls” scenario, VOC 

emissions in 2017 are projected to decrease by about 10 percent regionwide from 2007 

levels due implementation of various OTC control measures in multiple states. Under the 

“potential new OTC controls” scenario, VOC emissions are projected to decrease by about 

15 percent between 2007 and 2017 due to the continued implementation of both OTC 

control measures. 
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Exhibit 8.1 2007 and Projected Future Year Area Source CO Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 41,496 38,245 38,161 38,161 37,352 37,266 37,266

DE 8,266 7,961 7,881 7,881 7,857 7,776 7,776

DC 5,488 5,319 5,247 5,247 5,274 5,200 5,200

ME 50,496 47,290 47,266 47,266 46,359 46,337 46,337

MD 74,188 72,896 72,631 72,631 72,501 72,231 72,231

MA 79,226 75,912 75,482 75,482 75,073 74,626 74,626

NH 39,677 37,470 37,405 37,405 36,883 36,816 36,816

NJ 77,687 74,444 73,562 73,562 73,298 72,406 72,406

NY 205,055 218,875 218,374 218,374 223,510 223,021 223,021

PA 217,079 205,020 203,489 203,489 202,084 200,507 200,507

RI 15,419 14,391 14,308 14,308 14,097 14,011 14,011

VT 51,109 46,595 46,551 46,551 45,288 45,243 45,243

VA 132,098 129,923 129,479 129,479 129,390 128,937 128,937

997,285 974,342 969,836 969,836 968,966 964,377 964,377 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 92

Exhibit 8.2 2007 and Projected Future Year Area Source NH3 Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 4,421 4,451 4,451 4,451 4,476 4,476 4,476

DE 12,382 15,233 15,233 15,233 15,924 15,924 15,924

DC 183 188 188 188 191 191 191

ME 5,736 6,203 6,203 6,203 6,337 6,337 6,337

MD 26,006 26,081 26,081 26,081 26,102 26,102 26,102

MA 13,791 13,913 13,913 13,913 13,996 13,996 13,996

NH 1,500 1,528 1,528 1,528 1,534 1,534 1,534

NJ 15,736 16,375 16,375 16,375 16,593 16,593 16,593

NY 45,693 46,221 46,221 46,221 46,368 46,368 46,368

PA 72,569 77,383 77,383 77,383 78,550 78,550 78,550

RI 625 629 629 629 636 636 636

VT 8,013 8,013 8,013 8,013 8,013 8,013 8,013

VA 43,394 45,862 45,862 45,862 46,434 46,434 46,434

250,049 262,079 262,079 262,079 265,152 265,152 265,152 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

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Exhibit 8.3 2007 and Projected Future Year Area Source NOx Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 12,421 11,278 11,101 9,747 11,232 11,049 9,560

DE 2,237 2,292 2,210 1,796 2,300 2,218 1,768

DC 1,547 1,620 1,560 1,318 1,654 1,592 1,325

ME 6,656 5,960 5,960 5,734 5,851 5,851 5,633

MD 10,312 11,148 10,948 9,887 11,389 11,185 9,978

MA 20,252 19,316 18,984 16,730 19,498 19,151 16,638

NH 4,737 4,196 4,152 3,761 4,156 4,111 3,699

NJ 24,175 24,662 23,331 22,727 24,685 23,339 22,310

NY 72,053 63,961 63,711 55,057 63,337 63,082 53,872

PA 47,545 47,179 45,925 37,636 47,613 46,318 37,392

RI 3,469 3,370 3,301 2,830 3,400 3,329 2,788

VT 3,996 3,667 3,641 3,305 3,672 3,645 3,302

VA 19,056 18,704 18,411 18,411 18,821 18,520 18,520

228,457 217,352 213,235 188,939 217,608 213,387 186,784 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

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Exhibit 8.4 2007 and Projected Future Year Area Source PM10-PRI Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 30,577 31,061 31,052 31,052 31,224 31,214 31,214

DE 10,499 11,169 11,168 11,168 11,675 11,675 11,675

DC 4,873 5,078 5,077 5,077 5,141 5,141 5,141

ME 54,445 54,438 54,431 54,431 54,995 54,988 54,988

MD 72,454 78,559 78,555 78,555 80,345 80,340 80,340

MA 148,756 148,471 148,459 148,459 148,577 148,564 148,564

NH 27,742 28,916 28,912 28,912 29,420 29,416 29,416

NJ 39,140 41,202 41,189 41,189 42,104 42,090 42,090

NY 272,674 291,578 291,476 291,476 297,738 297,639 297,639

PA 287,998 295,026 295,006 295,006 298,020 298,001 298,001

RI 11,361 12,151 12,150 12,150 12,395 12,394 12,394

VT 47,993 47,675 47,671 47,671 47,823 47,819 47,819

VA 183,341 188,240 188,211 188,211 190,126 190,097 190,097

1,191,853 1,233,566 1,233,356 1,233,356 1,249,581 1,249,377 1,249,377 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

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Exhibit 8.5 2007 and Projected Future Year Area Source PM25-PRI Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 10,606 10,298 10,290 10,290 10,225 10,217 10,217

DE 3,031 3,131 3,131 3,131 3,212 3,212 3,212

DC 1,542 1,560 1,560 1,560 1,567 1,566 1,566

ME 12,526 12,068 12,062 12,062 12,005 11,999 11,999

MD 19,789 20,888 20,884 20,884 21,206 21,201 21,201

MA 30,438 29,955 29,945 29,945 29,893 29,883 29,883

NH 8,623 8,602 8,598 8,598 8,637 8,633 8,633

NJ 18,299 18,453 18,441 18,441 18,579 18,568 18,568

NY 63,906 68,492 68,408 68,408 70,080 70,000 70,000

PA 73,514 73,070 73,054 73,054 73,243 73,227 73,227

RI 3,896 3,923 3,922 3,922 3,937 3,936 3,936

VT 13,106 12,596 12,593 12,593 12,520 12,517 12,517

VA 44,102 44,872 44,851 44,851 45,237 45,216 45,216

303,378 307,908 307,739 307,739 310,340 310,175 310,175 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

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Exhibit 8.6 2007 and Projected Future Year Area Source SO2 Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 16,083 12,943 12,943 3,325 12,401 12,401 838

DE 1,144 946 946 107 911 911 106

DC 1,241 995 995 181 953 953 23

ME 9,812 7,870 7,870 1,450 7,609 7,609 200

MD 5,960 6,566 1,674 1,674 6,745 1,704 1,704

MA 19,859 15,996 15,996 4,093 15,357 15,357 1,391

NH 5,283 4,176 4,176 804 3,991 3,991 147

NJ 8,811 7,423 706 706 7,090 704 704

NY 70,044 58,753 11,651 11,651 57,030 11,670 11,670

PA 66,584 55,878 55,878 32,309 55,018 55,018 32,278

RI 3,897 3,222 3,222 1,270 3,108 3,108 491

VT 3,752 3,158 3,158 1,654 3,085 3,085 634

VA 17,098 14,880 14,880 14,880 14,616 14,616 14,616

229,569 192,807 134,097 74,104 187,914 131,127 64,803 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 97

Exhibit 8.7 2007 and Projected Future Year Area Source VOC Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 57,253 55,386 46,364 43,764 54,857 45,849 43,229

DE 9,482 9,525 8,631 7,910 9,596 8,673 7,930

DC 5,568 5,540 5,324 4,932 5,591 5,369 4,965

ME 31,966 29,957 26,113 25,412 29,422 25,631 24,931

MD 64,429 66,399 57,045 52,018 66,825 57,042 51,901

MA 85,870 82,334 66,211 59,886 81,373 65,306 58,945

NH 22,343 22,117 20,894 17,258 22,041 20,807 17,164

NJ 98,121 97,769 89,972 83,323 97,551 89,699 82,956

NY 195,976 199,975 184,269 173,703 199,522 183,721 173,081

PA 176,781 170,123 164,863 153,166 167,744 162,374 150,596

RI 24,214 22,319 20,292 19,603 21,796 19,750 19,053

VT 14,108 12,516 12,311 10,972 12,127 11,904 10,561

VA 142,218 139,719 135,379 135,379 139,631 135,002 135,002

928,330 913,678 837,668 787,325 908,077 831,128 780,314 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 98

8.2 NONEGU POINT SOURCE PROJECTED EMISSIONS 

Exhibits 8.8 to 8.14 summarize the 2007 and projected future year area source emissions 

by state for each criteria air pollutant. Seven values are listed for each pollutant: 

2007 emissions 

2017 projected emissions with growth only (GO) 

2017 projected emissions with growth and existing controls (GC) 

2017 projected emissions with growth, existing and potential new OTC controls (GX) 

2020 projected emissions with growth only (GO) 

2020 projected emissions with growth and existing controls (GC) 

2020 projected emissions with growth, existing and potential new OTC controls (GX) 

Detailed summaries by County and SCC are provided on MARAMA’s ftp site. 

Regionwide, CO emissions increase slightly between 2007 and 2020. Maryland shows a 

significant decline due to a source closure. Maine, New Hampshire, and Vermont show 

significant increases due to projected increases in nonEGU wood combustion. There are no 

additional reductions expected from potential new OTC control measures. 

NH3 emissions are projected to increase slightly between 2007 and 2020. There are no 

additional reductions expected from any existing control program or any potential new 

OTC control measures. 

Under the “growth only” scenario, regional NOx emissions are projected to increase by 

about 12 percent from 2007 to 2017. This is due partially to the projected increases in fuel 

consumption and the addition of ERCs to the inventory. Under the “existing controls” 

scenario, NOx emissions are projected to be about 2 percent lower in 2017 than in 2007 

because of petroleum refinery enforcement settlements; source shutdowns; ICI boiler 

controls in New Hampshire, New Jersey, and New York; and additional controls on glass 

furnace and cement kilns. Under the “potential new OTC controls” scenario, NOx 

emissions are projected to be about 5 percent lower in 2017 than in 2007 because of ICI 

boiler controls in additional states. 

Under the “growth only” scenario, regional PM10-PRI and PM2.5-PRI emissions are 

projected to increase slightly. Under the “existing controls” scenario, PM10-PRI and 

PM2.5-PRI are project to be about 5 percent lower in 2017 than in 2007 due primarily to 

reductions the ICI boiler MACT standard and source closures. There are no additional 

reductions expected from potential new OTC control measures. 

Under the “growth only” scenario, regional SO2 emissions are projected to remain 

relatively constant from 2007 to 2017. Under the “existing controls” scenario, SO2 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 99

emissions are projected to be about 5 percent lower in 2017 than in 2007 because of 

petroleum refinery enforcement settlements; source shutdowns; and low sulfur fuel oil 

requirements in Maryland, New Jersey, and New York. Under the “potential new OTC 

controls” scenario, SO2 emissions are projected to be about 8 percent lower in 2017 than 

in 2007 because of low sulfur fuel oil limits in additional states. SO2 emission are 

projected to be about 12 percent lower in 2020 than in 2007 because of additional low 

sulfur fuel oil limits in outer zone states that are projected to take effect in 2018.. 

VOC emissions are projected to increase slightly between 2007 and 2020 under the 

“growth only” scenario due primarily to the inclusion of ERCs in the future year 

inventories. Under the “existing controls” scenario, VOC emissions are projected to be 

less than 1 percent lower in 2017 than in 2007, with reductions resulting from the RICE 

MACT standard and OTC adhesives application rule. Under the “potential new OTC 

controls” scenario, VOC emissions are projected to be about 1.5 percent lower in 2017 

than in 2007 due to the projected implementation of the OTC rule on large storage tanks. 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 100 

Exhibit 8.8 2007 and Projected Future Year NonEGU CO Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 2,583 3,067 3,041 3,041 3,197 3,171 3,171

DE 7,027 7,300 7,271 7,271 7,320 7,292 7,292

DC 301 335 327 327 338 330 330

ME 14,023 20,975 20,941 20,941 21,238 21,204 21,204

MD 77,574 68,273 68,221 68,221 68,323 68,268 68,268

MA 4,592 5,999 5,919 5,919 6,165 6,082 6,082

NH 2,255 4,977 4,975 4,975 5,084 5,081 5,081

NJ 6,907 7,227 7,151 7,151 7,323 7,246 7,246

NY 52,877 54,959 54,646 54,646 55,439 55,115 55,115

PA 80,540 84,178 83,211 83,211 84,799 83,800 83,800

RI 1,051 873 870 870 940 937 937

VT 702 1,242 1,242 1,242 1,294 1,294 1,294

VA 63,079 67,090 65,740 65,740 67,833 66,212 66,212

313,512 326,496 323,556 323,556 329,293 326,031 326,031 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 101 

Exhibit 8.9 2007 and Projected Future Year NonEGU NH3 Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 0 0 0 0 0 0 0

DE 62 63 58 58 63 58 58

DC 0 0 0 0 0 0 0

ME 605 588 585 585 569 566 566

MD 137 137 137 137 137 137 137

MA 365 353 353 353 357 357 357

NH 30 36 36 36 36 36 36

NJ 208 216 216 216 219 219 219

NY 1,064 1,083 1,083 1,083 1,086 1,086 1,086

PA 2,070 2,111 2,111 2,111 2,119 2,119 2,119

RI 16 13 13 13 13 13 13

VT 0 0 0 0 0 0 0

VA 1,618 1,698 1,698 1,698 1,709 1,709 1,709

6,175 6,298 6,290 6,290 6,307 6,300 6,300 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 102 

Exhibit 8.10 2007 and Projected Future Year NonEGU NOx Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 6,302 8,949 8,913 8,531 9,336 9,297 8,900

DE 5,122 4,774 3,328 2,861 4,652 3,271 2,796

DC 734 844 779 598 860 792 609

ME 17,050 20,527 20,398 19,272 20,573 20,447 19,332

MD 23,472 28,520 26,322 25,197 28,694 26,496 25,353

MA 12,872 15,011 14,797 13,238 15,525 15,298 13,695

NH 2,687 5,529 3,388 3,277 5,642 3,467 3,356

NJ 13,517 14,880 11,879 11,879 15,155 12,092 12,092

NY 35,583 38,125 27,632 27,632 38,686 28,080 28,080

PA 71,382 76,378 63,904 61,046 77,220 62,606 59,691

RI 950 857 854 720 868 862 727

VT 441 791 791 743 808 808 761

VA 50,265 53,919 53,236 53,236 54,476 53,591 53,591

240,378 269,103 236,221 228,228 272,496 237,107 228,984 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 103 

Exhibit 8.11 2007 and Projected Future Year NonEGU PM10-PRI Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 645 702 594 594 717 609 609

DE 1,197 1,140 973 973 1,115 947 947

DC 46 52 29 29 53 30 30

ME 4,748 4,667 4,475 4,475 4,636 4,449 4,449

MD 5,711 6,177 5,498 5,498 6,181 5,502 5,502

MA 3,029 2,927 2,904 2,904 2,977 2,953 2,953

NH 1,141 1,259 1,258 1,258 1,270 1,269 1,269

NJ 3,147 3,381 3,331 3,331 3,444 3,392 3,392

NY 4,463 4,572 4,260 4,260 4,595 4,283 4,283

PA 22,275 22,832 20,891 20,891 22,937 20,996 20,996

RI 173 174 174 174 179 179 179

VT 146 128 128 128 128 128 128

VA 13,028 13,419 12,517 12,517 13,507 12,602 12,602

59,749 61,430 57,032 57,032 61,741 57,339 57,339 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 104 

Exhibit 8.12 2007 and Projected Future Year NonEGU PM25-PRI Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 573 627 526 526 641 540 540

DE 1,083 1,021 876 876 993 848 848

DC 43 48 28 28 48 29 29

ME 3,727 3,811 3,658 3,658 3,802 3,653 3,653

MD 3,876 4,328 3,764 3,764 4,336 3,772 3,772

MA 2,572 2,495 2,485 2,485 2,542 2,532 2,532

NH 1,061 1,169 1,169 1,169 1,179 1,179 1,179

NJ 2,452 2,583 2,533 2,533 2,625 2,574 2,574

NY 2,415 2,517 2,329 2,329 2,538 2,350 2,350

PA 13,389 13,851 12,729 12,729 13,934 12,845 12,845

RI 124 124 124 124 128 128 128

VT 114 98 98 98 97 97 97

VA 10,296 10,611 9,885 9,885 10,674 9,947 9,947

41,726 43,281 40,204 40,204 43,538 40,492 40,492 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 105 

Exhibit 8.13 2007 and Projected Future Year NonEGU SO2 Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 3,185 3,236 3,236 3,117 3,253 3,253 2,773

DE 8,206 7,883 6,541 5,598 7,703 6,357 5,378

DC 471 510 380 358 518 382 337

ME 15,571 13,194 12,678 12,462 13,049 12,545 6,510

MD 31,176 36,658 34,278 34,278 36,636 34,289 34,289

MA 9,057 8,259 8,041 7,592 8,254 8,041 5,192

NH 2,734 2,655 2,655 2,582 2,658 2,658 1,030

NJ 3,401 3,736 2,591 2,591 3,818 2,645 2,645

NY 44,307 44,712 42,072 42,072 44,792 42,150 42,150

PA 57,330 58,464 53,489 49,814 58,627 53,652 49,975

RI 1,501 1,415 1,415 1,321 1,437 1,437 1,002

VT 316 248 248 243 243 243 92

VA 54,486 55,328 52,044 52,044 55,623 52,338 52,338

231,742 236,297 219,668 214,071 236,610 219,988 203,710 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 106 

Exhibit 8.14 2007 and Projected Future Year NonEGU VOC Emissions (tons) 

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 1,447 1,547 1,530 1,468 1,574 1,556 1,476

DE 3,406 3,068 2,588 2,547 2,972 2,572 2,530

DC 58 60 59 59 60 59 59

ME 4,987 4,931 4,885 4,745 4,760 4,718 4,559

MD 4,598 5,745 5,715 5,466 5,707 5,677 5,367

MA 4,094 4,156 4,102 4,057 4,077 4,022 3,965

NH 807 1,490 1,489 1,448 1,479 1,478 1,440

NJ 10,106 11,044 10,086 10,086 11,180 10,041 10,041

NY 9,772 9,948 9,815 9,640 9,985 9,849 9,635

PA 28,195 29,153 28,712 28,236 29,376 28,925 28,396

RI 922 950 945 919 967 963 930

VT 373 316 316 316 302 302 302

VA 35,018 35,538 35,461 35,461 35,670 35,593 35,593

103,783 107,947 105,705 104,450 108,110 105,755 104,292 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 107 

8.3 NONROAD NMIM SOURCE PROJECT EMISSIONS

Exhibits 8.15 to 8.21 summarize the 2007 and projected emissions for NONROAD model 

sources by state for each criteria air pollutant. Seven values are listed for each pollutant: 

2007 emissions 

2017 projected emissions with growth only (GO) 

2017 projected emissions with growth and existing controls (GC) 

2017 projected emissions with growth, existing and potential new OTC controls (GX) 

2020 projected emissions with growth only (GO) 

2020 projected emissions with growth and existing controls (GC) 

2020 projected emissions with growth, existing and potential new OTC controls (GX) 

Detailed summaries by County and SCC are provided on MARAMA’s ftp site. 

It is not possible to isolate the emission changes due to growth versus the emission changes 

due to future controls in a single NMIM run. Therefore, the emissions under the growth 

only (GO) and growth and existing controls (GC) scenarios are the same. There are 

currently no potential new OTC control measures for sources whose emissions are 

estimated by the NONROAD model. Therefore, the emissions under the growth and 

existing controls (GC) and with growth, existing and potential new OTC controls (GX) 

scenarios are the same. 

Exhibit 8.15 presents a state-level comparison of 2007, 2017 and 2020 annual CO 

emissions for NMIM/NONROAD sources. Emissions decrease by about 21% between 

2007 and 2013, but remain relatively flat from 2017 to 2020. 

Exhibit 8.16 shows that annual NH3 emissions are very small relative to other source 

sectors (e.g., agricultural ammonia) and generally increase slightly from 2007 to 2020. 

Exhibit 8.17 shows that annual NOx emissions decrease by about 42% between 2007 and 

2020 and by about 49% between 2007 and 2020 due to the turnover to newer engines 

subject to more stringent national emission standards. 

Exhibits 8.18 and 8.19 shows that PM10-PRI and PM25-PRI emissions decrease about 

33% between 2007 and 2020 and by about 41% between 2007 and 2020. 

Exhibit 8.20 shows that annual SO2 emissions are virtually eliminated by 2017 due to 

lower national limits on the sulfur content of nonroad diesel fuel. 

Exhibit 8.21 shows that annual VOC emissions decrease by about 41% between 2007 and 

2020 and by about 46% between 2007 and 2020 due to the turnover to newer engines 

subject to more stringent national emission standards. 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 108 

Exhibit 8.15 2007/2013/2017/2020 NMIM/NONROAD CO Emissions by State (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 181,817 143,586 143,586 143,586 147,193 147,193 147,193

DE 55,173 40,188 40,188 40,188 40,703 40,703 40,703

DC 14,319 10,246 10,246 10,246 10,322 10,322 10,322

ME 131,319 92,029 92,029 92,029 90,629 90,629 90,629

MD 297,832 247,766 247,766 247,766 254,083 254,083 254,083

MA 324,793 240,812 240,812 240,812 246,540 246,540 246,540

NH 90,461 73,012 73,012 73,012 73,294 73,294 73,294

NJ 445,302 362,054 362,054 362,054 372,857 372,857 372,857

NY 911,813 716,153 716,153 716,153 730,897 730,897 730,897

PA 719,517 533,798 533,798 533,798 542,133 542,133 542,133

RI 54,028 35,863 35,863 35,863 36,713 36,713 36,713

VT 52,497 35,978 35,978 35,978 35,608 35,608 35,608

VA 415,093 335,531 335,531 335,531 341,458 341,458 341,458

3,693,965 2,867,016 2,867,016 2,867,016 2,922,431 2,922,431 2,922,431 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 109 

Exhibit 8.16 2007/2013/2017/2020 NMIM/NONROAD NH3 Emissions by State (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 16 20 20 20 21 21 21

DE 6 6 6 6 7 7 7

DC 3 3 3 3 3 3 3

ME 13 15 15 15 15 15 15

MD 29 35 35 35 37 37 37

MA 28 34 34 34 36 36 36

NH 10 12 12 12 13 13 13

NJ 40 47 47 47 50 50 50

NY 83 99 99 99 105 105 105

PA 60 71 71 71 74 74 74

RI 5 5 5 5 5 5 5

VT 5 6 6 6 6 6 6

VA 45 53 53 53 55 55 55

342 405 405 405 427 427 427 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 110 

Exhibit 8.17 2007/2013/2017/2020 NMIM/NONROAD NOx Emissions by State (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 16,056 8,748 8,748 8,748 7,786 7,786 7,786

DE 4,998 3,096 3,096 3,096 2,723 2,723 2,723

DC 2,788 1,534 1,534 1,534 1,250 1,250 1,250

ME 7,439 5,216 5,216 5,216 4,783 4,783 4,783

MD 25,726 15,357 15,357 15,357 13,481 13,481 13,481

MA 26,471 14,820 14,820 14,820 13,163 13,163 13,163

NH 8,562 5,530 5,530 5,530 5,277 5,277 5,277

NJ 36,345 20,713 20,713 20,713 18,361 18,361 18,361

NY 72,271 43,490 43,490 43,490 38,871 38,871 38,871

PA 55,362 30,467 30,467 30,467 26,182 26,182 26,182

RI 4,388 2,348 2,348 2,348 2,114 2,114 2,114

VT 3,743 2,364 2,364 2,364 2,109 2,109 2,109

VA 41,325 23,658 23,658 23,658 20,189 20,189 20,189

305,475 177,343 177,343 177,343 156,288 156,288 156,288 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 111 

Exhibit 8.18 2007/2013/2017/2020 NMIM/NONROAD PM10-PRI Emissions by State 

(tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 1,412 976 976 976 868 868 868

DE 476 300 300 300 258 258 258

DC 242 138 138 138 106 106 106

ME 1,151 810 810 810 706 706 706

MD 2,600 1,781 1,781 1,781 1,570 1,570 1,570

MA 2,384 1,630 1,630 1,630 1,438 1,438 1,438

NH 846 595 595 595 527 527 527

NJ 3,377 2,347 2,347 2,347 2,086 2,086 2,086

NY 7,059 4,684 4,684 4,684 4,075 4,075 4,075

PA 5,623 3,717 3,717 3,717 3,217 3,217 3,217

RI 367 229 229 229 202 202 202

VT 482 327 327 327 281 281 281

VA 4,128 2,695 2,695 2,695 2,319 2,319 2,319

30,146 20,229 20,229 20,229 17,652 17,652 17,652 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 112 

Exhibit 8.19 2007/2013/2017/2020 NMIM/NONROAD PM25-PRI Emissions by State 

(tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 1,343 922 922 922 818 818 818

DE 453 284 284 284 243 243 243

DC 234 132 132 132 102 102 102

ME 1,080 756 756 756 657 657 657

MD 2,473 1,681 1,681 1,681 1,477 1,477 1,477

MA 2,268 1,540 1,540 1,540 1,355 1,355 1,355

NH 799 559 559 559 494 494 494

NJ 3,213 2,217 2,217 2,217 1,964 1,964 1,964

NY 6,715 4,430 4,430 4,430 3,843 3,843 3,843

PA 5,346 3,511 3,511 3,511 3,029 3,029 3,029

RI 349 216 216 216 191 191 191

VT 455 307 307 307 263 263 263

VA 3,933 2,549 2,549 2,549 2,185 2,185 2,185

28,660 19,105 19,105 19,105 16,621 16,621 16,621 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 113 

Exhibit 8.20 2007/2013/2017/2020 NMIM/NONROAD SO2 Emissions by State (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 802 30 30 30 32 32 32

DE 266 7 7 7 7 7 7

DC 196 3 3 3 3 3 3

ME 416 16 16 16 17 17 17

MD 1,436 36 36 36 38 38 38

MA 1,377 41 41 41 44 44 44

NH 441 16 16 16 18 18 18

NJ 1,905 55 55 55 58 58 58

NY 3,957 118 118 118 126 126 126

PA 2,972 84 84 84 86 86 86

RI 211 7 7 7 7 7 7

VT 202 7 7 7 7 7 7

VA 2,284 90 90 90 94 94 94

16,464 511 511 511 537 537 537 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 114 

Exhibit 8.21 2007/2013/2017/2020 NMIM/NONROAD VOC Emissions by State 

(tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 20,721 11,803 11,803 11,803 10,985 10,985 10,985

DE 7,157 3,888 3,888 3,888 3,498 3,498 3,498

DC 1,324 749 749 749 710 710 710

ME 29,880 19,303 19,303 19,303 16,729 16,729 16,729

MD 35,160 21,226 21,226 21,226 19,890 19,890 19,890

MA 35,676 20,510 20,510 20,510 18,990 18,990 18,990

NH 17,108 11,030 11,030 11,030 9,785 9,785 9,785

NJ 47,521 27,430 27,430 27,430 25,802 25,802 25,802

NY 114,935 67,238 67,238 67,238 60,945 60,945 60,945

PA 86,397 51,382 51,382 51,382 46,399 46,399 46,399

RI 6,721 2,885 2,885 2,885 2,657 2,657 2,657

VT 10,339 6,714 6,714 6,714 5,864 5,864 5,864

VA 55,135 32,141 32,141 32,141 29,303 29,303 29,303

468,074 276,299 276,299 276,299 251,556 251,556 251,556 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 115 

8.4 NONROAD COMMERCIAL MARINE VESSEL EMISSIONS 

Exhibits 8.22 to 8.28 summarize the 2007 and projected future year commercial marine 

vessel emissions by state for each criteria air pollutant. Seven values are listed for each 

pollutant: 

2007 emissions 

2017 projected emissions with growth only (GO) 

2017 projected emissions with growth and existing controls (GC) 

2017 projected emissions with growth, existing and potential new OTC controls (GX) 

2020 projected emissions with growth only (GO) 

2020 projected emissions with growth and existing controls (GC) 

2020 projected emissions with growth, existing and potential new OTC controls (GX) 

Detailed summaries by County and SCC are provided on MARAMA’s ftp site. 

Emissions of all pollutants except NH3 are projected to decrease as a result of Federal 

rules affecting Category 1 / 2 and Category 3 marine engines, including more stringent 

engine emission standards and sulfur in fuel limitations. There are currently no potential 

new OTC control measures for commercial marine vessels. 

Exhibit 8.22 presents a state-level comparison of 2007, 2017 and 2020 annual CO 

emissions for commercial marine vessels. Emissions decrease by about 13 percent from 

2007 to 2017, and 12 percent from 2007 to 2020. 

Exhibit 8.23 shows that there are very little NH3 emissions from this sector. 

Exhibit 8.24 shows that annual NOx emissions from commercial marine vessels decrease 

by 32 percent from 2007 to 2017 and 40 percent from 2007 to 2020. 

Exhibits 9.25 and 9.26 show that annual PM10-PRI and PM2.5-PRI emissions from 

commercial marine vessels decrease substantially after 2007. For both pollutants, 

emissions are reduced by about 57 percent from 2007 to 2017 and 66 percent from 2007 to 

2020. 

Exhibit 8.27 shows that that annual SO2 emissions from commercial marine vessels 

decrease dramatically after 2007. SO2 emissions are reduced by about 89 percent from 

2007 to 2017 and 93 percent from 2007 to 2020. 

Exhibit 8.28 shows that annual VOC emissions from commercial marine vessels decrease 

by 15 percent from 2007 to 2017, and 20 percent from 2007 to 2020. 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 116 

Exhibit 8.22 2007 and Projected CO Emissions for CMV (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 1,078 1,073 912 912 1,102 908 908

DE 554 543 485 485 554 484 484

DC 1 1 1 1 1 1 1

ME 522 521 438 438 536 435 435

MD 2,795 2,792 2,350 2,350 2,871 2,337 2,337

MA 1,473 1,475 1,232 1,232 1,518 1,225 1,225

NH 89 84 83 83 85 84 84

NJ 1,619 2,202 2,067 2,067 2,427 2,254 2,254

NY 3,476 3,452 2,961 2,961 3,541 2,949 2,949

PA 1,294 1,283 1,106 1,106 1,315 1,102 1,102

RI 522 523 437 437 538 434 434

VT 0 0 0 0 0 0 0

VA 3,735 3,731 3,166 3,166 3,831 3,150 3,150

17,156 17,681 15,238 15,238 18,319 15,363 15,363 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 117 

Exhibit 8.23 2007 and Projected NH3 Emissions for CMV (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 3 3 3 3 3 3 3

DE 0 0 0 0 0 0

DC 0 0 0 0 0 0 0

ME 0 0 0 0 0 0

MD 8 8 8 8 8 8 8

MA 0 0 0 0 0 0

NH 0 0 0 0 0 0

NJ 8 11 11 11 12 12 12

NY 2 2 2 2 2 2 2

PA 13 12 12 12 13 13 13

RI 1 1 1 1 1 1 1

VT 0 0 0 0 0 0 0

VA 9 9 9 9 9 9 9

44 46 46 46 47 47 47 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 118 

Exhibit 8.24 2007 and Projected NOx Emissions for CMV (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 6,528 6,454 4,162 4,162 6,608 3,642 3,642

DE 5,095 4,966 3,217 3,217 5,054 2,857 2,857

DC 6 6 4 4 6 3 3

ME 1,659 1,638 1,057 1,057 1,676 926 926

MD 16,027 15,929 10,256 10,256 16,343 8,922 8,922

MA 3,246 3,247 2,086 2,086 3,340 1,803 1,803

NH 271 258 169 169 260 154 154

NJ 11,197 15,318 11,140 11,140 16,906 10,251 10,251

NY 28,180 27,913 17,990 17,990 28,598 15,709 15,709

PA 11,378 11,237 7,249 7,249 11,498 6,350 6,350

RI 2,829 2,825 1,816 1,816 2,904 1,572 1,572

VT 0 0 0 0 0 0 0

VA 21,760 21,643 14,445 14,445 22,172 12,750 12,750

108,175 111,435 73,591 73,591 115,365 64,937 64,937 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 119 

Exhibit 8.25 2007 and Projected PM10-PRI Emissions for CMV (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 312 305 124 124 310 101 101

DE 327 315 99 99 319 75 75

DC 0 0 0 0 0 0 0

ME 395 384 144 144 391 114 114

MD 657 649 301 301 664 251 251

MA 316 315 162 162 323 138 138

NH 13 12 3 3 13 2 2

NJ 622 887 244 244 989 241 241

NY 1,671 1,649 753 753 1,686 626 626

PA 524 511 197 197 519 158 158

RI 112 112 55 55 115 47 47

VT 0 0 0 0 0 0 0

VA 947 934 461 461 953 394 394

5,897 6,072 2,543 2,543 6,283 2,146 2,146 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 120 

Exhibit 8.26 2007 and Projected PM25-PRI Emissions for CMV (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 296 290 119 119 295 97 97

DE 305 294 93 93 297 70 70

DC 0 0 0 0 0 0 0

ME 364 354 132 132 359 105 105

MD 606 600 285 285 614 239 239

MA 290 289 149 149 297 127 127

NH 12 11 3 3 12 2 2

NJ 575 820 225 225 915 223 223

NY 1,541 1,520 695 695 1,555 578 578

PA 484 472 183 183 480 146 146

RI 108 107 53 53 110 45 45

VT 0 0 0 0 0 0 0

VA 908 896 446 446 915 383 383

5,491 5,654 2,384 2,384 5,851 2,016 2,016 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 121 

Exhibit 8.27 2007 and Projected SO2 Emissions for CMV (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 1,386 1,327 147 147 1,341 60 60

DE 2,079 1,984 225 225 2,000 84 84

DC 1 1 0 0 1 0 0

ME 189 185 17 17 189 12 12

MD 2,170 2,099 217 217 2,128 109 109

MA 698 684 64 64 698 42 42

NH 506 482 55 55 486 20 20

NJ 6,712 10,085 403 403 11,405 452 452

NY 9,321 9,181 821 821 9,383 601 601

PA 3,067 2,909 343 343 2,925 111 111

RI 632 607 66 66 613 28 28

VT 0 0 0 0 0 0 0

VA 4,058 3,928 940 940 3,969 747 747

30,820 33,473 3,296 3,296 35,139 2,268 2,268 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 122 

Exhibit 8.28 2007 and Projected VOC Emissions for CMV (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 161 158 127 127 162 117 117

DE 158 153 133 133 156 127 127

DC 0 0 0 0 0 0 0

ME 234 234 168 168 240 145 145

MD 371 367 282 282 376 252 252

MA 528 529 381 381 544 328 328

NH 23 21 21 21 22 21 21

NJ 658 857 753 753 933 754 754

NY 1,906 1,895 1,681 1,681 1,918 1,606 1,606

PA 538 534 406 406 547 360 360

RI 64 64 47 47 66 42 42

VT 0 0 0 0 0 0 0

VA 523 518 409 409 530 370 370

5,164 5,331 4,410 4,410 5,493 4,121 4,121 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 123 

8.5 NONROAD AIRPORT EMISSIONS 

Exhibits 9.29 to 9.35 summarize the 2007 and projected future year airport emissions by 

state for each criteria air pollutant. Seven values are listed for each pollutant: 

2007 emissions 

2017 projected emissions with growth only (GO) 

2017 projected emissions with growth and existing controls (GC) 

2017 projected emissions with growth, existing and potential new OTC controls (GX) 

2020 projected emissions with growth only (GO) 

2020 projected emissions with growth and existing controls (GC) 

2020 projected emissions with growth, existing and potential new OTC controls (GX) 

Detailed summaries by County and SCC are provided on MARAMA’s ftp site. 

There were no NH3 emissions reported for airport operations. Emissions of other 

pollutants are projected to change as a result of changes in airline activity levels. No state 

or Federal rules were identified that would reduce emissions from aircraft operations in the 

future. There are currently no potential new OTC control measures for airports. 

CO, PM10, PM2.5 and VOC emissions are projected to remain relatively constant between 

2007 levels by 2017. By 2020, the will be a slight increase in emissions from 2007 due to 

increased operations by 2020. 

NOx and SO2 emissions are projected to increase by 7 percent from 2007 levels by 2017 

and by 13 percent by 2020 due to increased air traffic. 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 124 

Exhibit 8.29 2007 and Projected CO Emissions for Airports (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 4,659 4,224 4,224 4,224 4,386 4,386 4,386

DE 1,625 1,550 1,550 1,550 1,593 1,593 1,593

DC 14 14 14 14 14 14 14

ME 32,879 32,774 32,774 32,774 32,802 32,802 32,802

MD 10,265 10,042 10,042 10,042 10,335 10,335 10,335

MA 15,495 14,592 14,592 14,592 14,940 14,940 14,940

NH 2,089 1,861 1,861 1,861 1,883 1,883 1,883

NJ 21,878 21,837 21,837 21,837 22,411 22,411 22,411

NY 17,403 18,579 18,579 18,579 19,706 19,706 19,706

PA 26,540 26,165 26,165 26,165 27,345 27,345 27,345

RI 1,739 2,255 2,255 2,255 2,280 2,280 2,280

VT 2,420 2,100 2,100 2,100 2,127 2,127 2,127

VA 22,009 22,689 22,689 22,689 23,190 23,190 23,190

159,016 158,684 158,684 158,684 163,012 163,012 163,012 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 125 

Exhibit 8.30 2007 and Projected NH3 Emissions for Airports (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 0 0 0 0 0 0 0

DE 0 0 0 0 0 0 0

DC 0 0 0 0 0 0 0

ME 0 0 0 0 0 0 0

MD 0 0 0 0 0 0 0

MA 0 0 0 0 0 0 0

NH 0 0 0 0 0 0 0

NJ 0 0 0 0 0 0 0

NY 0 0 0 0 0 0 0

PA 0 0 0 0 0 0 0

RI 0 0 0 0 0 0 0

VT 0 0 0 0 0 0 0

VA 0 0 0 0 0 0 0

0 0 0 0 0 0 0
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 126 

Exhibit 8.31 2007 and Projected NOx Emissions for Airports (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 713 657 657 657 688 688 688

DE 805 801 801 801 802 802 802

DC 0 0 0 0 0 0 0

ME 134 144 144 144 144 144 144

MD 1,910 2,021 2,021 2,021 2,119 2,119 2,119

MA 3,190 3,267 3,267 3,267 3,365 3,365 3,365

NH 278 256 256 256 260 260 260

NJ 5,105 5,408 5,408 5,408 5,612 5,612 5,612

NY 6,998 8,081 8,081 8,081 8,789 8,789 8,789

PA 3,738 4,094 4,094 4,094 4,406 4,406 4,406

RI 289 281 281 281 294 294 294

VT 103 113 113 113 117 117 117

VA 5,520 5,762 5,762 5,762 5,889 5,889 5,889

28,783 30,885 30,885 30,885 32,485 32,485 32,485 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 127 

Exhibit 8.32 2007 and Projected PM10-PRI Emissions for Airports (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 66 59 59 59 61 61 61

DE 27 25 25 25 25 25 25

DC 0 0 0 0 0 0 0

ME 83 82 82 82 82 82 82

MD 74 70 70 70 73 73 73

MA 295 284 284 284 289 289 289

NH 37 34 34 34 34 34 34

NJ 170 173 173 173 177 177 177

NY 140 158 158 158 170 170 170

PA 396 385 385 385 400 400 400

RI 22 33 33 33 33 33 33

VT 46 40 40 40 40 40 40

VA 821 840 840 840 847 847 847

2,176 2,183 2,183 2,183 2,234 2,234 2,234 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 128 

Exhibit 8.33 2007 and Projected PM25-PRI Emissions for Airports (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 51 46 46 46 48 48 48

DE 19 17 17 17 18 18 18

DC 0 0 0 0 0 0 0

ME 61 61 61 61 61 61 61

MD 16 17 17 17 17 17 17

MA 215 208 208 208 212 212 212

NH 27 25 25 25 25 25 25

NJ 143 146 146 146 150 150 150

NY 139 157 157 157 170 170 170

PA 294 288 288 288 300 300 300

RI 17 25 25 25 25 25 25

VT 32 28 28 28 29 29 29

VA 580 595 595 595 601 601 601

1,595 1,613 1,613 1,613 1,656 1,656 1,656 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 129 

Exhibit 8.34 2007 and Projected SO2 Emissions for Airports (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 96 87 87 87 91 91 91

DE 55 55 55 55 55 55 55

DC 0 0 0 0 0 0 0

ME 14 16 16 16 16 16 16

MD 247 255 255 255 266 266 266

MA 218 226 226 226 236 236 236

NH 28 26 26 26 26 26 26

NJ 507 534 534 534 557 557 557

NY 699 808 808 808 877 877 877

PA 416 455 455 455 488 488 488

RI 30 29 29 29 31 31 31

VT 12 13 13 13 13 13 13

VA 424 455 455 455 466 466 466

2,746 2,959 2,959 2,959 3,122 3,122 3,122 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 130 

Exhibit 8.35 2007 and Projected VOC Emissions for Airports (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 509 452 452 452 469 469 469

DE 620 598 598 598 600 600 600

DC 1 1 1 1 1 1 1

ME 161 161 161 161 162 162 162

MD 1,365 1,228 1,228 1,228 1,265 1,265 1,265

MA 1,129 1,080 1,080 1,080 1,105 1,105 1,105

NH 134 116 116 116 118 118 118

NJ 2,438 2,426 2,426 2,426 2,498 2,498 2,498

NY 1,571 1,761 1,761 1,761 1,896 1,896 1,896

PA 2,813 2,879 2,879 2,879 3,004 3,004 3,004

RI 112 166 166 166 168 168 168

VT 204 179 179 179 181 181 181

VA 2,764 2,764 2,764 2,764 2,802 2,802 2,802

13,822 13,813 13,813 13,813 14,269 14,269 14,269 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 131 

8.6 NONROAD RAILROAD LOCOMOTIVE EMISSIONS 

Exhibits 9.36 to 9.42 summarize the 2007 and projected future year railroad locomotive 

emissions by state for each criteria air pollutant. Seven values are listed for each pollutant: 

2007 emissions 

2017 projected emissions with growth only (GO) 

2017 projected emissions with growth and existing controls (GC) 

2017 projected emissions with growth, existing and potential new OTC controls (GX) 

2020 projected emissions with growth only (GO) 

2020 projected emissions with growth and existing controls (GC) 

2020 projected emissions with growth, existing and potential new OTC controls (GX) 

Detailed summaries by County and SCC are provided on MARAMA’s ftp site. 

Emissions of all pollutants except CO and NH3 are projected to decrease as a result of 

Federal rules affecting railroad locomotive engines, including more stringent engine 

emission standards and sulfur in fuel limitations. There are currently no potential new 

OTC control measures for railroad locomotives. 

Exhibit 8.36 presents a state-level comparison of 2007, 2017 and 2020 annual CO 

emissions for railroad locomotives. CO emissions show small changes (< 7 percent) 

between 2007 and 2017/2020. 

Exhibit 8.37 shows that there are very little NH3 emissions from this sector. 

Exhibit 8.38 shows that annual NOx emissions from railroad locomotives decrease by 33 

percent from 2007 to 2017, and 39 percent from 2007 to 2020. 

Exhibits 9.39 and 9.40 show that annual PM10-PRI and PM2.5-PRI emissions from 

railroad locomotives decrease substantially after 2007. For both pollutants, emissions are 

reduced by about 49 percent from 2007 to 2017, and 57 percent from 2007 to 2020. 

Exhibit 8.41 shows that SO2 emissions from railroad locomotives are virtually eliminatd 

by 2017. 

Exhibit 8.42 shows that annual VOC emissions from railroad locomotives decrease by 42

percent from 2007 to 2017 and 50 percent from 2007 to 2020.
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 132 

Exhibit 8.36 2007 and Projected CO Emissions for Railroads (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 184 198 188 188 206 193 193

DE 75 76 76 76 79 79 79

DC 73 75 75 75 78 77 77

ME 188 191 191 191 198 198 198

MD 700 720 713 713 746 736 736

MA 646 695 662 662 723 679 679

NH 88 90 90 90 93 93 93

NJ 665 780 744 744 818 771 771

NY 3,061 3,181 3,122 3,122 3,298 3,220 3,220

PA 2,987 3,044 3,041 3,041 3,149 3,145 3,145

RI 15 15 15 15 16 16 16

VT 72 74 74 74 76 76 76

VA 2,701 2,758 2,750 2,750 2,854 2,843 2,843

11,456 11,899 11,741 11,741 12,333 12,126 12,126 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 133 

Exhibit 8.37 2007 and Projected NH3 Emissions for Railroads (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 1 1 1 1 1 1 1

DE 0 0 0 0 0 0 0

DC 0 0 0 0 0 0 0

ME 0 0 0 0 0 0 0

MD 0 0 0 0 0 0 0

MA 2 2 2 2 2 2 2

NH 0 0 0 0 0 0 0

NJ 2 2 2 2 3 3 3

NY 0 1 1 1 1 1 1

PA 9 9 9 9 10 10 10

RI 0 0 0 0 0 0 0

VT 0 0 0 0 0 0 0

VA 8 8 8 8 9 9 9

23 24 24 24 25 25 25 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 134 

Exhibit 8.38 2007 and Projected NOx Emissions for Railroads (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 1,723 1,866 1,088 1,088 1,942 991 991

DE 384 391 279 279 404 256 256

DC 505 521 353 353 540 322 322

ME 1,369 1,394 1,289 1,289 1,442 1,262 1,262

MD 4,767 4,904 3,127 3,127 5,078 2,815 2,815

MA 6,133 6,623 3,743 3,743 6,893 3,368 3,368

NH 891 907 871 871 939 864 864

NJ 5,957 6,982 3,839 3,839 7,323 3,469 3,469

NY 20,675 21,473 13,144 13,144 22,259 11,782 11,782

PA 20,675 21,080 14,413 14,413 21,808 13,174 13,174

RI 144 147 99 99 152 90 90

VT 736 749 719 719 775 713 713

VA 18,319 18,728 12,061 12,061 19,381 10,856 10,856

82,279 85,765 55,025 55,025 88,936 49,960 49,960 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 135 

Exhibit 8.39 2007 and Projected PM10-PRI Emissions for Railroads (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 46 49 27 27 51 23 23

DE 15 16 8 8 16 7 7

DC 12 12 6 6 13 6 6

ME 28 28 22 22 29 21 21

MD 166 171 80 80 177 68 68

MA 159 171 84 84 178 71 71

NH 22 22 18 18 23 17 17

NJ 160 187 89 89 196 75 75

NY 608 631 295 295 654 249 249

PA 704 717 356 356 742 309 309

RI 4 4 2 2 4 2 2

VT 18 18 15 15 19 14 14

VA 634 648 303 303 670 257 257

2,574 2,675 1,303 1,303 2,772 1,119 1,119 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 136 

Exhibit 8.40 2007 and Projected PM25-PRI Emissions for Railroads (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 39 42 22 22 44 19 19

DE 15 15 8 8 16 7 7

DC 11 12 6 6 12 6 6

ME 25 26 20 20 27 19 19

MD 161 166 78 78 172 66 66

MA 145 157 77 77 163 65 65

NH 21 21 17 17 22 17 17

NJ 147 173 82 82 181 69 69

NY 572 595 278 278 616 235 235

PA 650 663 330 330 686 286 286

RI 3 3 2 2 3 1 1

VT 17 17 13 13 18 13 13

VA 586 599 280 280 620 238 238

2,395 2,488 1,213 1,213 2,579 1,041 1,041 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 137 

Exhibit 8.41 2007 and Projected SO2 Emissions for Railroads (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 57 61 5 5 64 5 5

DE 5 5 0 0 6 0 0

DC 37 38 0 0 39 0 0

ME 92 94 0 0 97 0 0

MD 64 66 0 0 68 0 0

MA 66 70 0 0 73 0 0

NH 10 10 0 0 11 0 0

NJ 52 61 0 0 64 0 0

NY 616 641 2 2 665 2 2

PA 211 216 1 1 223 1 1

RI 5 6 0 0 6 0 0

VT 5 5 0 0 5 0 0

VA 192 196 1 1 203 1 1

1,413 1,469 9 9 1,522 10 10 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 138 

Exhibit 8.42 2007 and Projected VOC Emissions for Railroads (tons)

2007

2017

Growth

Only

2017

Growth &

Existing

Controls

2017

Growth &

Existing & 

New OTC

Controls

2020

Growth

Only

2020

Growth &

Existing

Controls

2020

Growth &

Existing & 

New OTC

Controls

State 2007 2017 GO 2017 GC 2017 GX 2020 GO 2020 GC 2020 GX

CT 73 79 49 49 82 42 42

DE 28 29 17 17 30 15 15

DC 34 35 23 23 36 20 20

ME 51 51 47 47 53 47 47

MD 271 279 146 146 289 122 122

MA 267 286 162 162 298 135 135

NH 35 36 36 36 37 37 37

NJ 258 302 216 216 317 200 200

NY 1,112 1,155 596 596 1,197 493 493

PA 1,153 1,176 655 655 1,216 569 569

RI 8 8 4 4 8 4 4

VT 29 29 29 29 30 30 30

VA 1,025 1,047 537 537 1,083 451 451

4,343 4,511 2,519 2,519 4,676 2,167 2,167 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 139 

9.0 PREPARATION OF SMOKE MODEL FILES 

Air quality modelers in the Mid-Atlantic and Northeastern states use the SMOKE 

Modeling System to create gridded, speciated, hourly emissions for input into a variety of 

air quality models. This section describes how the SMOKE inventory files were 

developed. It also describes how the SMOKE the temporal allocation, speciation, and 

spatial allocation profiles, respectively, were developed. . SMOKE inventory files were 

created for the following types of sources (which are described in Section 1.3): 

9.1 NONEGU POINT SOURCE SMOKE EMISSION FILES 

Annual nonEGU point source inventories were prepared in SMOKE PTINV ORL format. 

9.2 AREA SOURCE SMOKE EMISSION FILES 

Annual area source inventories for 2017 and 2020 were prepared in SMOKE ARINV ORL 

format. In developing the SMOKE ARINV ORL files for area sources, the USEPA 

“transport factor” was applied to reduce fugitive dust emissions to account for the removal 

of particles near their emission source by vegetation and surface features. The transport 

factor was NOT applied to the NIF-formatted annual emissions, but only to the SMOKE 

ARINV ORL-formatted file. 

The standard transport fractions and SCC assignments from the USEPA CHIEF website 

(USEPA 2007c) were used to reduce the PM10-PRI and PM25-PRI emissions in the area 

source inventories. Two files were used. The first file contains a list of SCCs for which 

the transport factor was applied. The major source categories included paved and unpaved 

roads, construction activity, agricultural crop land tilling, and agricultural livestock 

operations. The second file contains the transport factor which varies by county. For 

example, in Connecticut the transport fraction ranges from 0.21 in Tolland County to 0.44 

in New Haven County. 

Applying the transport factor to area source fugitive dust emissions significantly reduces 

that amount of particulate matter included in the air quality modeling. Region wide, 

PM10-PRI emissions are reduced by about 54 percent and PM25-PRI emissions are 

reduced by about 25 percent by applying the transport fraction. The percent reduction 

varies by state due to the relative importance of the area source fugitive dust emissions 

compared to non-fugitive dust source emissions. 

9.3 NONROAD NMIM SMOKE EMISSION FILES 

As discussed in Section 7, the NMIM/NONROAD model was executed using 

specifications to generate monthly emission files. Monthly SMOKE ARINV ORL files 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 140 

were created. Average day emissions were calculated by dividing the NONROAD 

generated monthly emissions by the number of days in each month. Summary reports 

were prepared to verify agreement between the average day, monthly, and annual 

emissions. 

9.4 NONROAD MAR SMOKE EMISSION FILES 

Annual inventories for marine vessels, airport operations and railroad locomotives were 

prepared in SMOKE ARINV ORL format for each county in the region. Average day 

emissions were calculated by dividing the annual emissions by 365 days. The ORL files 

for Category 3 commercial marine vessels include only the emissions that occur in state 

waters (generally from the shoreline to 3–10 nautical miles from shore). 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 141 

10.0 FINAL DELIVERABLES 

Exhibits 10.1 to10.3 identify the deliverable products for the 2017 and 2020 MANEVU+VA emission inventories developed by MACTEC under this contract. The exhibit 

also identifies deliverables associated with the 2017 and 2020 MANE-VU+VA inventories 

under development by other agencies. 

Files are stored on MARAMA ftp site: 

Address: ftp.marama.org 

Login ID: regionalei 

Password: marama2007 

Files are stored in the following directories: 

\MARAMA 07-17-20 Version 3\Final 2017 2020 (Version 3_3)/NIF 

\MARAMA 07-17-20 Version 3\Final 2017 2020 (Version 3_3)/SMOKE 

\MARAMA 07-17-20 Version 3\Final 2017 2020 (Version 3_3)/TSD 

\MARAMA 07-17-20 Version 3\Final 2017 2020 (Version 3_3)/XLS 

The contents of each folder are provided in Exhibits 10.1, 10.2, and 10.3. 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 142 

Exhibit 10.1 – NIF Data Files for the 2017/2020 MANE-VU+VA Emission Inventories 

File Description File Name Format Notes

2017 Annual Point Source Emission 

Inventory in NOF format

MANEVU+VA_V3_3 Point_2017_NOF.mdb NOF ACCESS File includes only those point 

sources classified as “nonEGU” 

according to the ERTAC definition.

See file for Field Definitions

2020 Annual Point Source Emission 

Inventory in NOF format

MANEVU+VA_V3_3 Point_2020_NOF.mdb NOF ACCESS

2017 Annual Area Source Emission 

Inventory in NOF format

MANEVU+VA_V3_3 Area_2017_NOF.mdb NOF ACCESS See file for Field Definitions

2020 Annual Area Source Emission 

Inventory in NOF format

MANEVU+VA_V3_3 Area_2020_NOF.mdb NOF ACCESS See file for Field Definitions

2017 Annual NMIM/NONROAD 

Emission Inventory in NOF format

2017MARAMANMIMv3.mdb NOF ACCESS See file for Field Definitions

2020 Annual NMIM/NONROAD 

Emission Inventory in NOF format

2020MARAMANMIMv3.mdb NOF ACCESS See file for Field Definitions

2017 Annual MAR Emission 

Inventory in NOF format

MANEVU+VA_V3_3_MAR_2017_NOF.mdb NOF ACCESS See file for Field Definitions

2020 Annual MAR Emission 

Inventory in NOF format

MANEVU+VA_V3_3_MAR_2020_NOF.mdb NOF ACCESS See file for Field Definitions
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 143 

Exhibit 10.2 – Summary Spreadsheet Files for the 2017/2020 MANE-VU+VA Emission Inventories 

File Description File Name Format Notes

County/SCC level emissions 

for all 2017/2020 scenarios

V3_3 Area_07_17_20.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2017

MANEVU+VA_V3_3_Area_2017_ExistingControls_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2017

MANEVU+VA_V3_3_Area_2017_What IfControls_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2020

MANEVU+VA_V3_3_Area_2020_ExistingControls_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2020

MANEVU+VA_V3_3_Area_2020_What IfControls_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Tables and graphs used in the 

TSD

TSD V3_3 2017_2020 Area Graphs.xlsx MS EXCEL See file for Field 

Definitions

County/SCC level emissions 

for all 2017/2020 scenarios

V3_3 MAR_07_17_20.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2017

MANEVU+VA_V3_3_MAR_2017_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2020

MANEVU+VA_V3_3_MAR_2020_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Tables and graphs used in the 

TSD

TSD V3_3 2017_2020 MAR Graphs.xlsx MS EXCEL See file for Field 

Definitions

Process level emissions for all 

2017/2020 scenarios

V3_3 NonEGU_07_17_20.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2017

MANEVU+VA_V3_3_NonEGU_2017_ExistingControls_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2017

MANEVU+VA_V3_3_NonEGU_2017_What IfControls_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2020

MANEVU+VA_V3_3_NonEGU_2020_ExistingControls_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 144 

Excel summary of emissions 

by State and SCC for 2020

MANEVU+VA_V3_3_NonEGU_2020_What IfControls_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Tables and graphs used in the 

TSD

TSD V3_3 2017_2020 NonEGU Graphs.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2017

MANEVU+VA_V3_3_NMIM_2017_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Excel summary of emissions 

by State and SCC for 2020

MANEVU+VA_V3_3_NMIM_2020_StateSCCSummaries.xlsx MS EXCEL See file for Field 

Definitions

Tables and graphs used in the 

TSD

TSD V3_3 2017_2020 NMIM Graphs.xlsx MS EXCEL See file for Field 

Definitions
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 145 

Exhibit 10.2 – SMOKE Files for the 2013/2017/2020 MANE-VU+VA Emission Inventories 

File Description File Name Format Notes

2017 Annual Point Source Emission 

Inventory in SMOKE ORL format

PTINV_2017_NonHourly_ExistingControls_Jan2012.orl SMOKE 

PTINV

ORL

Files includes only those point 

sources classified as “nonEGU” 

according to the ERTAC definition.

See file for Field Definitions 2017 Annual Point Source Emission 

Inventory in SMOKE ORL format

PTINV_2017_NonHourly_WhatIfControls_Jan2012.orl SMOKE 

PTINV

ORL

2020 Annual Point Source Emission 

Inventory in SMOKE ORL format

PTINV_2020_NonHourly_ExistingControls_Jan2012.orl SMOKE 

PTINV

ORL

2020 Annual Point Source Emission 

Inventory in SMOKE ORL format

PTINV_2020_NonHourly_WhatIfControls_Jan2012.orl SMOKE 

PTINV

ORL

2017 Annual Area Source Emission 

Inventory in SMOKE ORL format

ARINV_2017_Area_ExistingControls_Jan2012.orl SMOKE 

ARINV

ORL Nonpoint

These files have the PM transport 

factors by county applied to the NOF 

emissions. See section 10.2 for 

discussion.

See http://www.smokemodel.org/version2.6/html/ for file 

format

2017 Annual Area Source Emission 

Inventory in SMOKE ORL format

ARINV_2017_Area_WhatIfControls_Jan2012.orl SMOKE 

ARINV

ORL Nonpoint

2020 Annual Area Source Emission 

Inventory in SMOKE ORL format

ARINV_2020_Area_ExistingControls_Jan2012.orl SMOKE 

ARINV

ORL nonpoint

2020 Annual Area Source Emission 

Inventory in SMOKE ORL format

ARINV_2020_Area_WhatIfControls_Jan2012.orl SMOKE 

ARINV

ORL nonpoint

2013 Annual MAR Source 

Emission Inventory in SMOKE 

ORL format

ARINV_2017_MAR_Jan2012.txt SMOKE 

ARINV

ORL Nonpoint

See http://www.smokemodel.org/version2.6/html/ for file 

format

2017 Annual MAR Source 

Emission Inventory in SMOKE 

ORL format

ARINV_2020_MAR_Jan2012.txt SMOKE 

ARINV

ORL Nonpoint

See http://www.smokemodel.org/version2.6/html/ for file 

format
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 146 

11.0 REFERENCES 

CENSUS 2000. U.S. Census Bureau. 1997 Economic Census: Bridge Between NAICS 

and SIC. June 2000. http://www.census.gov/epcd/ec97brdg 

EEA2005. Energy and Environmental Analysis, Inc. (Prepared for Oak Ridge National 

Laboratory). Characterization of the U.S. Industrial/Commercial Boiler Population, May 

2005. http://www.cibo.org/pubs/industrialboilerpopulationanalysis.pdf 

EIA 2006. U.S. Department of Energy, Energy Information Administration. Annual 

Energy Outlook with Projections to 2030 (AEO2006). DOE/EIA-0383(2006). February 

2006. http://www.eia.doe.gov/oiaf/archive/aeo06/pdf/0383(2006).pdf 

EIA 2010. U.S. Department of Energy, Energy Information Administration. Annual 

Energy Outlook with Projections to 2035 (AEO2010); DOE/EIA-0383(2010). April 2010. 

http://www.eia.doe.gov/oiaf/aeo/assumption/pdf/0554(2010).pdf 

EIA 2011. U.S. Department of Energy, Energy Information Administration. Annual 

Energy Outlook with Projections to 2035 (AEO2011); DOE/EIA-0383(2011). April 2011. 

http://www.eia.gov/forecasts/aeo/pdf/0383(2011).pdf 

FAA 2010. Federal Aviation Administration. Terminal Area Forecast 2009-2030. 

Database file (APO100_TAF_Final_2010.zip) downloaded July 2010. 

http://aspm.faa.gov/main/taf.asp 

MANE-VU 2007. Mid-Atlantic / Northeast Visibility. Statement of the MidAtlantic/Northeast Visibility Union Concerning a Course of Action within MANE-VU 

Toward Assuring Reasonable Progress. June 20, 2007. 

http://www.otcair.org/manevu/document.asp?fview=Formal%20Actions 

MARAMA 2007. Prepared by MACTEC Federal Programs, Inc. for the Mid-Atlantic 

Regional Air Management Association. Development of Emissions Projections for 2009, 

2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region. 

February 2007. http://www.marama.org/technical-center/emissions-inventory/2002-

inventory-and-projections/mane-vu-future-year-emissions-inventory 

MARAMA 2011a. Prepared by MACTEC Engineering and Consulting, Inc. for the MidAtlantic Regional Air Management Association. Technical Support Document for the 

Development of the 2007 Emission Inventory for Regional Air Quality Modeling in the 

Northeast / Mid-Atlantic Region. February 27, 2011. 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 147 

MARAMA 2011b. Prepared by MACTEC Engineering and Consulting, Inc. for the MidAtlantic Regional Air Management Association. Technical Support Document for the 

Development of the 2013 / 2017/ 2020 Emission Inventories for Regional Air Quality 

Modeling in the Northeast / Mid-Atlantic Region. February 27, 2011. 

MARAMA 2012. Prepared by AMEC Environment and Infrastructure and SRA 

International for the Mid-Atlantic Regional Air Management Association. Technical 

Support Document for the Development of the 2007 Emission Inventory for Regional Air 

Quality Modeling in the Northeast / Mid-Atlantic Region Version 3_3. January 23, 2012. 

OTC 2001. Prepared by E.H. Pechan & Associates, Inc. for the Ozone Transport 

Commission. Control Measure Development Support Analysis of Ozone Transport 

Commission Model Rules. March 31, 2001. 

http://www.otcair.org/Document.asp?fview=Report#

OTC 2007. Prepared by MACTEC Federal Programs, Inc. for the Ozone Transport 

Commission. Identification and Evaluation of Candidate Control Measures – Final 

Technical Support Document. February 28, 2007. 

http://www.otcair.org/Document.asp?fview=Report#

OTC 2009. Ozone Transport Commission. Status Report on OTC States’ Efforts to 

Promulgate Regulations Based on OTC 2001 Model Rules. October 19, 2009. 

http://www.otcair.org/interest.asp?Fview=stationary 

OTC 2011a. Ozone Transport Commission. Status Report on OTC States’ Efforts to 

Promulgate Regulations Based on OTC 2006 Model Rules. May 9, 2011. 

http://www.otcair.org/interest.asp?Fview=stationary 

OTC 2011b. Ozone Transport Commission. Status Report on OTC States’ Efforts to 

Promulgate Regulations Based on OTC 2009/2010 Model Rules. May 9, 2011. 

http://www.otcair.org/interest.asp?Fview=stationary 

OTC 2011c. Ozone Transport Commission. Technical Support Document, NOx Section, 

Draft for Public Comment. March 16, 2011. 

OTC 2011d. Ozone Transport Commission. Technical Support Document, VOC Section, 

Draft for Public Comment. March 16, 2011. (with editss provided by Judy Rand, NJDEP). 

USEPA 1999. U.S. Environmental Protection Agency. Emission Inventory Improvement 

Program, Volume 10, Emission Projections. . December 1999. 

http://www.epa.gov/ttn/chief/eiip/techreport/volume10/x01.pdf 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 148 

USEPA 2004a. E.H. Pechan & Associates, Inc. for the U.S. Environmental Protection 

Agency Crosswalk Between Source Classification Code (SCC)and Emission Activity 

Growth Factors – Final Technical Memorandum. September 9, 2004. 

http://www.epa.gov/ttn/ecas/SCCcrosswalk.pdf 

USEPA 2004b. E.H. Pechan & Associates, Inc. for the U.S. Environmental Protection 

Agency Crosswalk Between Standard Industrial Classification (SIC) Codes and Emission 

Activity Growth Factors – Final Technical Memorandum. September 9, 2004. 

http://www.epa.gov/ttn/ecas/SICcrosswalk.pdf 

USEPA 2004c. U.S. Environmental Protection Agency. NonroadEngine Grwoth 

Estimates. EPA-420/P-04-08. April 2004. 

http://www.epa.gov/otaq/models/nonrdmdl/nonrdmdl2004/420p04008.pdf

USEPA 2005a. U.S. Environmental Protection Agency. Emissions Inventory Guidance 

for Implementation of Ozone and Particulate Matter National Ambient Air Quality 

Standards (NAAQS) and Regional Haze Regulations. EPA-454/R-05-001. August 2005. 

http://www.epa.gov/ttn/chief/eidocs/eiguid/eiguidfinal_nov2005.pdf 

USEPA 2005b. U.S. Environmental Protection Agency. Control of Air Pollution From 

Aircraft and Aircraft Engines; Emission Standards and Test Procedures: Final Rule. 

November 17, 2005. http://www.epa.gov/fedrgstr/EPA-AIR/2005/November/Day17/a22704.pdf 

USEPA 2007a. U.S. Environmental Protection Agency. Guidance on the Use of Models 

and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, 

and Regional Haze. April 2007. 

http://www.epa.gov/ttn/scram/guidance/guide/final-03-pm-rh-guidance.pdf 

USEPA 2007b. U.S. Environmental Protection Agency. Guidance for Estimating VOC 

and NOx Emission Changes from MACT Rules. EPA-457/B-07-001. May 2007. 

http://www.epa.gov/ttn/naaqs/ozone/o3imp8hr/documents/guidance/200705_epa457_b-07-

001_emission_changes_mact_rules.pdf 

USEPA 2007c. U.S. Environmental Protections Agency. Emissions Modeling 

Clearinghouse - Fugitive Dust Fractions. February 2007. 

http://www.epa.gov/ttn/chief/emch/dustfractions )

USEPA 2008a. U.S. Environmental Protection Agency. Technical Support Document: 

Preparation of Emissions Inventories For the 2002-based Platform, Version 3, Criteria Air 
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 149 

Pollutants. January 2008. 

http://www.epa.gov/scram001/reports/Emissions%20TSD%20Vol1_02-28-08.pdf 

USEPA 2008b. U.S. Environmental Protection Agency. Control Techniques Guidelines. 

http://www.epa.gov/ttncaaa1/t1ctg.html

USEPA 2008c. U.S. Environmental Protection Agency. Regulatory Impact Analysis: 

Control or Emissions of Air Pollution from Locomotive Engines and Marine Compression 

Engines Less than 30 Liters Per Cylinder. EPA420-R-08-001a. May 2008.

http://www.epa.gov/otaq/regs/nonroad/420r08001a.pdf 

USEPA 2009a. U.S. Environmental Protection Agency. Clean Air Markets – Data and 

Maps Web Site; Unit Level Emissions Query for 2007. File downloaded on September 9, 

2009. http://camddataandmaps.epa.gov/gdm/index.cfm?fuseaction=emissions.wizard

USEPA 2009b. U.S. Environmental Protection Agency. Suggested Nationwide Average 

Fuel Properties. EPA-420-B-09-018. April 2009 

http://www.epa.gov/oms/models/nonrdmdl/nonrdmdl2008/420b09018.pdf

USEPA 2009c. U.S. Environmental Protection Agency. Regulatory Impact Analysis: 

Control of Emissions of Air Pollution from Category 3 Marine Diesel Engines. EPA420-R09-019. December 2009. http://www.epa.gov/otaq/regs/nonroad/marine/ci/420r09019.pdf 

USEPA 2009d. U.S. Environmental Protection Agency. Proposal to Designate an 

Emissions Control Area for Nitrogen Oxides, Sulfur Oxides, and Particulate Matter. EPA420-R-09-007. April 2009. http://www.epa.gov/otaq/regs/nonroad/marine/ci/420r09007-

chap2.pdf 

USEPA 2010a. U.S. Environmental Protection Agency. Technical Support Document 

(TSD) for the Transport Rule: Emission Inventories. Docket ID No. EPA-HQ-OAR-2009-

0491. June 2010. 

http://www.epa.gov/ttn/chief/emch/transport/tr_proposal_emissions_tsd.pdf

USEPA 2010b. U.S. Environmental Protection Agency. 2020 Emissions Data from 

EPA’s 2005-based V4 Modeling Platform; Projection and Control Factors. Provided by 

Rich Mason on April 15, 2010. 

ftp://ftp.epa.gov/EmisInventory/2005v4/projection_control_packets 

USEPA 2010c. U.S. Environmental Protection Agency. Transport Rule Emission 

Inventories Notice of Data Availability (NODA). Docket ID No. EPA-HQ-OAR-2009-

0491. October 27, 2010. TR_EI_NODA_relevant_CoSTpackets_and_inventories.xls 

ftp://ftp.epa.gov/EmisInventory/2005v4/tr_ei_noda
Documentation for the 2017/2020 Emission Inventories for the Northeast / Mid-Atlantic Region January 23, 2012 

Page 150 

USEPA 2010d. U.S. Environmental Protection Agency. Advance Notice of Proposed 

Rulemaking on Lead Emissions from Piston-Engine Aircraft Using Leaded Aviation 

Gasoline. April 2010. http://www.epa.gov/oms/regs/nonroad/aviation/420f10013.pdf 

USEPA 2010e. U.S. Environmental Protection Agency. Nonroad Regulations 9-9-10. 

September 9, 2010. Provided by Penny Carey, USEPA Office of Transporation and Air 

Quality. 

USEPA 2011. U.S. Environmental Protection Agency. Emission Standards Reference 

Guide. http://www.epa.gov/oms/regs/nonroad/aviation/420f10013.pdf
APPENDIX C3

Technical Support Document for the Development of the 

2025 Emission Inventory for PM Nonattainment Counties in 

the MANE-VU Region Version 3.3 Rev.1 

(AMEC Environment & Infrastructure and SRA 

International, Inc. for MARAMA, January 2012) 

Bureau of Air Quality 

Department of Environmental Protection 
[This page intentionally left blank.] 
Technical Support Document 

for the 

Development of the 2025

Emission Inventory 

for PM Nonattainment Counties 

in the MANE-VU Region 

Version 3.3 

Revision 2.1

Initial report and Revision 1 - January 23, 2012 

MARAMA Contract Agreement FY2011-004 

Prepared for: 

Mid-Atlantic Regional Air Management Association (MARAMA) 

8600 LaSalle Road, Suite 636 

Towson, MD 21286 

(443) 901-1882 

Submitted by 

AMEC Environment & Infrastructure SRA International, Inc. 

4021 Stirrup Creek Drive 652 Peter Jefferson Parkway 

Suite 100 Suite 300 

Durham, NC 27703 Charlottesville, VA 22911 

919 381-9900 571 499-0833

Revision 2 – June 13, 2012 

Completed in house by MARAMA staff 

Note: Revision 1 includes a revision by New Jersey to Exhibit 7.7. 

Revision 2 includes revised CT & VA NMIM runs. 
Acknowledgements 

Funds for this CONTRACT are provided by MARAMA’s Memorandum of Agreement with the 

Ozone Transport Commission (OTC), which is funded by USEPA grant agreement XA973181 – 

Regional Haze Planning in the Northeast and Mid-Atlantic States (CFDA 66.034). The purpose 

of that Memorandum of Agreement is to support the Mid-Atlantic / Northeast Visibility Union 

(MANE-VU) in developing programs to control regional haze or visibility impairment in the 

Northeast and Mid-Atlantic states. 

About MARAMA 

The Mid-Atlantic Regional Air Management Association, Inc. is a voluntary, non-profit 

association of ten state and local air pollution control agencies. MARAMA's mission is to 

strengthen the skills and capabilities of member agencies and to help them work together to 

prevent and reduce air pollution in the Mid-Atlantic Region. MARAMA provides cost-effective 

approaches to regional collaboration by pooling resources to develop and analyze data, share 

ideas, and train staff to implement common requirements. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

Page i 

Table of Contents 

1.0 INTRODUCTION ................................................................................................................................................. 1

1.1 INVENTORY PURPOSE ............................................................................................................................... 1

1.2 SOURCE CATEGORIES................................................................................................................................ 1

1.3 GEOGRAPHIC AND TEMPORAL RESOLUTION ...................................................................................... 2

1.4 POLLUTANTS ............................................................................................................................................... 3

1.5 DATA FORMATS .......................................................................................................................................... 3

1.6 INVENTORY VERSIONS ............................................................................................................................. 3

1.6.1 Version 2 Modeling Inventories with Existing Controls ........................................................................ 3

1.6.2 Version 3 Modeling Inventories with Existing Controls ........................................................................ 3

1.6.3 Version 3 2025 Inventory for PM Nonattainment Counties Rev 1` ....................................................... 4

1.6.4 Version 3 2025 Inventory for PM Nonattainment Counties - Rev 2 ..................................................... 4

1.7 REPORT ORGANIZATION .......................................................................................................................... 5

2.0 AREA SOURCES .................................................................................................................................................. 8

2.1 AREA SOURCE CATEGORIES .................................................................................................................... 8

2.2 2007 INVENTORY DEVELOPMENT ........................................................................................................... 8

2.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections ........................................................ 8

2.3 2025 INVENTORY DEVELOPMENT .........................................................................................................13

2.3.1 Area Source Growth Factors ...............................................................................................................13

2.3.1.1 AEO Fuel Use Projection ................................................................................................................................ 13

2.3.1.2 Population Projections..................................................................................................................................... 14

2.3.1.3 Employment Projections ................................................................................................................................. 15

2.3.1.4 VMT Projections ............................................................................................................................................. 15

2.3.1.5 No Growth Assignment for Certain Area Source Categories .......................................................................... 25

2.3.1.6 USEPA 2020 Projections for Residential Wood ............................................................................................. 26

2.3.1.7 SCC, SIC, NAICS and Growth Parameter Crosswalk ..................................................................................... 27

2.3.1.8 Final Version 2 Growth Factors for Area Sources .......................................................................................... 27

2.3.1.9 Version 3 Update to New Jersey Growth Factors for Area Sources ................................................................ 28

2.3.1.10 Version 3 Update to Growth Factors for the District of Columbia ............................................................ 28

2.3.2 Area Source Control Factors ...............................................................................................................30

2.3.2.1 Federal Rules Affecting Area Sources ............................................................................................................ 30

2.3.2.2 Federal MACT Rules ...................................................................................................................................... 30

2.3.2.3 OTC Model Rules for VOC Sources ............................................................................................................... 31

2.3.2.4 OTC Model Rule for ICI Boilers..................................................................................................................... 32

2.3.2.5 MANE-VU Fuel Oil Sulfur Strategy ............................................................................................................... 33

3.0 POINT SOURCES ...............................................................................................................................................45

3.1 POINT SOURCE CATEGORIES .................................................................................................................45

3.2 2007 INVENTORY DEVELOPMENT .........................................................................................................45

3.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections ......................................................46

3.3 2025 NONEGU INVENTORY DEVELOPMENT .......................................................................................47

3.3.1 NonEGU Growth Factors ....................................................................................................................47

3.3.2 Emission Reduction Credits .................................................................................................................49

3.3.3 NonEGU Control Factors ....................................................................................................................50
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3.3.3.1 Federal Actions Affecting NonEGU Point Sources ........................................................................................ 50

3.3.3.2 OTC 2001 Model Rules for NonEGUs ........................................................................................................... 52

3.3.3.3 OTC 2006 Model Rules for NonEGUs ........................................................................................................... 52

3.3.3.4 MANE-VU Fuel Oil Sulfur Strategy ............................................................................................................... 55

3.3.3.5 State-specific NonEGU Control Factors ......................................................................................................... 55

3.4 2025 EGU INVENTORY DEVELOPMENT ................................................................................................57

3.4.1 EGU Growth Factors...........................................................................................................................58

3.4.2 EGU Control Factors ..........................................................................................................................62

3.4.3 Consideration of CSAPR Emission Allowances ...................................................................................63

4.0 NONROAD MOBILE SOURCES INCLUDED IN NMIM .............................................................................64

4.1 NONROAD MODEL CATEGORIES ..........................................................................................................64

4.2 2007 INVENTORY DEVELOPMENT .........................................................................................................64

4.3 2025 INVENTORY DEVELOPMENT .........................................................................................................66

4.4 REMOVAL OF AIRPORT GROUND SUPPORT EQUIPMENT ................................................................66

4.5 NMIM/NONROAD GROWTH AND CONTROL INFORMATION ...........................................................66

5.0 MARINE VESSELS, AIRPORTS, AND RAILROADS ..................................................................................70

5.1 MAR INVENTORY CATEGORIES ............................................................................................................70

5.2 2007 INVENTORY DEVELOPMENT .........................................................................................................70

5.3 2025 INVENTORY DEVELOPMENT .........................................................................................................70

5.3.1 Commercial Marine Vessels ................................................................................................................70

5.3.1.1 CMV Diesel Growth Factors ........................................................................................................................... 71

5.3.1.2 CMV Diesel Control Factors ........................................................................................................................... 71

5.3.1.3 CMV Residual Oil Growth Factors ................................................................................................................. 72

5.3.1.4 CMV Residual Oil Control Factors ................................................................................................................. 73

5.3.1.5 Military Vessels Growth and Control Factors ................................................................................................. 74

5.3.1.6 State-specific CMV Updates for 2025............................................................................................................. 74

5.3.2 Airports ................................................................................................................................................74

5.3.2.1 Airport Growth Factors ................................................................................................................................... 75

5.3.2.2 Aircraft Control Factors .................................................................................................................................. 76

5.3.2.3 State-specific Airport Updates for 2025 .......................................................................................................... 77

5.3.3 Railroad Locomotives ..........................................................................................................................77

5.3.3.1 Railroad Growth Factors ................................................................................................................................. 77

5.3.3.2 Railroad Control Factors ................................................................................................................................. 78

5.3.3.3 State-specific Railroad Updates for 2025 ........................................................................................................ 79

6.0 ONROAD MOBILE SOURCES INCLUDED IN MOVES .............................................................................80

6.1 MOVES MODEL CATEGORIES ................................................................................................................80

6.2 2007 MOVES MODEL INVENTORY .........................................................................................................80

6.3 2025 MOVES MODEL INVENTORY .........................................................................................................80

7.0 EMISSION SUMMARIES ................................................................................................................................. 81

8.0 DELIVERABLES ................................................................................................................................................94

9.0 REFERENCES ....................................................................................................................................................96
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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List of Appendices 

Appendix A1 AEO2010 New England.xls 

Appendix A2 AEO2010 Mid Atlantic.xls 

Appendix A3 AEO2010 South Atlantic.xls 

Appendix A4 AEO2011 New England.xls 

Appendix A5 AEO2011 Mid Atlantic.xls 

Appendix A6 AEO2011 South Atlantic.xls 

Appendix A7 AEO2010 vs AEO2011 Comparison.docx 

Appendix B Population_Factors.xls 

Appendix C Employment_Factors.xls 

Appendix D VMT GF Nonattainment Counties.xls

Appendix E EPA2020 Res Wood.xls 

Appendix F AEO2011-Electricity Generation by EMM.xlsx 

Appendix G UAF NEEDS Control FileMASTER92211.xls 

Appendix H MAR Growth and Control.xls 
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List of Exhibits 

Exhibit 1-1 Comparison of Data Used for the 2025 PM Nonattainment Inventory and 

Version 3 of the Modeling Inventory 

Exhibit 1-2 List of PM Nonattainment Areas and Counties 

Exhibit 2-1 Area Source SCCs Affected by PM Transport Fraction 

Exhibit 2-2 PM Transport Fractions for PM Nonattainment Counties 

Exhibit 2-3 Comparison of 2007 Paved Road Dust PM10 Emission Estimates 

Exhibit 2-4 Comparison of 2007 Paved Road Dust PM2.5 Emission Estimates 

Exhibit 2-5 Growth Factors for Coal Fuel Use by AEO Region 2007 - 2025

Exhibit 2-6 Growth Factors for Residual Oil Fuel Use by AEO Region 2007 - 2025

Exhibit 2-7 Growth Factors for Distillate Oil Fuel Use by AEO Region 2007 - 2025

Exhibit 2-8 Growth Factors for Natural Gas Fuel Use by AEO Region 2007 - 2025

Exhibit 2-9 Growth Factors for Gasoline Fuel Use by AEO Region 2007 – 2025

Exhibit 2-10 Population Growth Factors by AEO Region 2007 – 2025

Exhibit 2-11 Employment Growth Factors by AEO Region 2007 – 2025

Exhibit 2-12 2007 and 2025 VMT and the 2007-2025 Growth Factor 

Exhibit 2-13 Area Source Categories with No Growth Assignment 

Exhibit 2-14 State Recommendations to Address Negative Growth 

and Other Growth Factors for the Area Source Sector 

Exhibit 2-15 USEPA Estimated Percent Reductions for RICE MACT Standard

Exhibit 2-16 Area Source Emission Reductions from New Jersey ICI Boiler NOx Rules 

Exhibit 2-17 MANE-VU Low Sulfur Fuel Oil Strategy 

Exhibit 2-18 Sulfur Content and Control Factors for Residential Fuel Oil Combustion 

Exhibit 2-19 Sulfur Content and Control Factors for Distillate Fuel Oil Combustion 

Exhibit 2-20 Sulfur Content and Control Factors for Residual Fuel Oil Combustion 

Exhibit 3-1 NonEGU Point Source SCCs Affected by PM Transport Fraction 

Exhibit 3-2 State Recommendations to Address Negative Growth for the NonEGU 

Point Source Sector 

Exhibit 3-3 USEPA Estimated Percent Reductions for RICE MACT Standard 

Exhibit 3-4 NonEGU Point Source Emission Reductions from New Jersey 

ICI Boiler NOx Rules 

Exhibit 3.5 Electricity Market Module Regions 

Exhibit 3.6 Electricity Generation Growth Factors for Coal 

Exhibit 3.7 Electricity Generation Growth Factors for Petroleum 

Exhibit 3.8 Electricity Generation Growth Factors for Natural Gas 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 3.9 Electricity Generation Growth Factors for Renewables 

Exhibit 4-1 State by state data source for NMIM 

Exhibit 4-2 Control Programs Included in the NMIM/NONROAD Model 

Exhibit 5-1 CMV Diesel Control Factors by Year and Pollutant 

Exhibit 5-2 CMV Residual Oil Control Factors by Year and Pollutant 

Exhibit 5-3 Crosswalk between SCC and FAA Operations Type 

Exhibit 5-4 Region-wide Growth Factors from 2007 by FAA Operations Type 

Exhibit 5-5 Rail Control Factors by Year, Pollutant, and SCC 

Exhibit 7.1 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Allentown, PA 

Exhibit 7.2 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Baltimore, MD 

Exhibit 7.3 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Hagerstown-Martinsburg, MD-WV

Exhibit 7.4 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Harrisburg-Lebanon-Carlisle-York, PA 

Exhibit 7.5 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Johnstown, PA 

Exhibit 7.6 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Lancaster, PA 

Exhibit 7.7 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Metro New York/Northern New Jersey/Long Island 

NY/NJ/CT 

Exhibit 7.8 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Philadelphia-Wilmington, PA/DE/NJ 

Exhibit 7.9 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Pittsburgh-Beaver Valley, PA 

Exhibit 7.10 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Reading, PA 

Exhibit 7.11 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Washington DC/MD/VA 

Exhibit 7.12 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: York, PA 

Exhibit 8.1 Final Deliverables 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Acronyms and Abbreviations 

Acronym Description

CAA Clean Air Act

CAMD Clean Air Markets Division (USEPA)

CEM Continuous emission monitoring 

CMV Commercial marine vessel

CO Carbon monoxide 

EGU Electric generating unit

ERTAC Eastern Regional Technical Advisory Committee

FIPS Federal Information Processing Standard

GSE Ground support equipment

MACT Maximum achievable control technology

MANE-VU Mid-Atlantic/Northeast Visibility Union

MANE-VU+VA MANE-VU states plus Virginia

MAR Marine, airport, rail 

MARAMA Mid-Atlantic Regional Air Management Association

MOBILE6 USEPA model

MOVES Motor Vehicle Emissions Simulator model

NAAQS National Ambient Air Quality Standards

NAICS North American Industry Classification System code

NCD National county database 

NEI National Emission Inventory

NESCAUM Northeast States for Coordinated Air Use Management

NIF3.0 NEI Input Format Version 3.0

NMIM National Mobile Input Model

NOF3.0 NEI Output Format Version 3.0

NONROAD USEPA model

NOx Oxides of nitrogen

ORL One-record-per-line (SMOKE format)

OTAQ Office of Transportation and Air Quality (USEPA)

PFC Portable fuel container

PM-CON Primary PM, condensable portion only ( < 1 micron)

PM-FIL Primary PM, Filterable portion only

PM-PRI Primary PM, includes filterable and condensable

PM-PRI= PM-FIL + PM-CON

PM10-FIL Primary PM10, filterable portion only

PM10-PRI Primary PM10, includes filterable and condensable, 

PM10- PRI = PM0-FIL + PM-CON

PM25-FIL Primary PM2.5, filterable portion only
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Acronym Description

PM25-PRI Primary PM2.5, includes filterable and condensable

PM25-PRI= PM25-FIL + PM-CON

RWC Residential wood combustion

SEMAP Southeast Modeling, Analysis and Planning

SIC Standard Industrial Classification code

SIP State Implementation Plan

SCC Source classification code

S/L State/local

SMOKE Sparse Matrix Operator Kernel Emissions

SO2 Sulfur dioxide

TSD Technical Support Document

USEPA U.S. Environmental Protection Agency

VISTAS Visibility Improvement State and Tribal Association of the Southeast 

VMT Vehicle miles traveled

VOC Volatile organic compounds
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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1.0 INTRODUCTION 

This technical support document (TSD) explains the data sources, methods, and results for 

preparing emission projections for 2025 for particulate matter (PM) nonattainment areas in 

the Mid-Atlantic / Northeast Visibility Union (MANE-VU) region. The MANE-VU 

region includes Connecticut, Delaware, the District of Columbia, Maine, Maryland, 

Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and 

Vermont. Virginia is not included in the MANE-VU region; however, several cities and 

counties in northern Virginia were included in this inventory as they are part of a 

nonattainment area that includes MANE-VU jurisdictions. 

1.1 INVENTORY PURPOSE 

The Clean Air Act (CAA), as amended, requires each state with areas failing to meet the 

National Ambient Air Quality Standards (NAAQS) to develop State Implementation Plans 

(SIPs) to expeditiously attain and maintain the standards. The CAA allows states to 

request nonattainment areas to be re-designated to attainment provided certain criteria are 

met. For particulate matter, the U.S. Environmental Protections Agency’s (USEPA’s) redesignation guidance requires the submittal of a comprehensive inventory of direct PM2.5 

emissions and emissions of PM precursors representative of the year when the area 

achieves attainment of the PM2.5 air quality standards. Another emission inventory 

related requirement includes a projection of the emission inventory to a year at least 10 

years following re-designation. 

To support state’s efforts in developing PM2.5 maintenance plans and re-designation 

requests, MARAMA issued a contract to AMEC to assemble a comprehensive emission 

inventory for 2025. A workgroup was formed to guide the 2025 inventory development 

process. Participants included a member from each state with a PM2.5 nonattainment area, 

as follows: Paul Bodner (CT), Dave Fees and Jack Sipple (DE), Roger Thunell (MD), 

Judy Rand and Danny Wong (NJ), Ron Stannard (NY), Arleen Shulman (PA), and Doris 

McLeod (VA). The committee has met via teleconference on multiple occasions to discuss 

plans for the 2025 inventory. The 2025 inventory was developed using a combination of 

MARAMA’s in-house resources, support from state agencies and contractor support from 

AMEC and SRA International, Inc. 

1.2 SOURCE CATEGORIES 

This report documents the development of annual emission projections for 2025 for each 

of these sectors, as follows: 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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 EGU Point Sources are units that generate electric power and sell most of the 

power generated to the electrical grid. 

 NonEGU Point Sources are individual industrial, commercial, and institutional 

facilities and are further subdivided by stack, emission unit, and emission process. 

 Stationary Area Sources include sources that in and of themselves are quite small, 

but in aggregate may contribute significant emissions. Examples include small 

industrial/commercial facilities, residential heating furnaces, VOCs volatizing from 

house painting or consumer products, gasoline service stations, and agricultural 

fertilizer/pesticide application. 

 Non-road Mobile Sources include internal combustion engines used to propel 

marine vessels, airplanes, and locomotives, or to operate equipment such as 

forklifts, lawn and garden equipment, portable generators, etc. For activities other 

than marine vessels, airplanes, and railroad locomotives (MAR), the inventory was 

developed using the most current version of USEPA’s NONROAD model as 

embedded in the National Mobile Inventory Model (NMIM). Because the 

NONROAD model does not include emissions from MAR sources, these emissions 

were estimated based on data and methodologies used in recent USEPA regulatory 

impact analyses. 

 On-road Mobile Sources are sources of air pollution from internal combustion 

engines used to propel cars, trucks, buses, and other vehicles on public roadways. 

Emission projections for on-road mobile sources were developed by MARAMA or 

state staff using USEPA’s Motor Vehicle Emission Simulator (MOVES) model. 

Biogenic/geogenic emissions are not included in this inventory. 

1.3 GEOGRAPHIC AND TEMPORAL RESOLUTION 

The geographic area for the 2025 inventory includes only those counties that are classified 

as nonattainment for the annual (1997) or daily (2006) particulate matter NAAQS. The 

inventory was developed at the county-level for non-point sources and at the process level 

for point sources. 

Annual inventories are required for re-designation of areas designated as nonattainment for 

the 1997 and 2006 NAAQS. Other inventory elements required by USEPA (such as 

interim inventory years) are being addressed by individual states in their SIP submittals. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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1.4 POLLUTANTS 

The inventory includes emissions for directly emitted PM and PM-precursors (oxides of 

nitrogen {NOx}, and sulfur dioxide {SO2}). The PM species in the inventory are 

categorized as particles with an aerodynamic diameter less than or equal to a nominal 2.5 

micrometers (PM25-PRI), which includes both condensable particles (PM-CON) and 

filterable particles (PM25-FIL). 

1.5 DATA FORMATS 

For each sector, we prepared easy-to-review spreadsheets that provide 2007 emissions and 

2025 growth factors, control factors, and emissions. We also prepared county level and 

nonattainment area summaries for all PM nonattainment counties and areas. The 

summaries show the 2007 and 2025 emissions, along with the percent change in emissions 

from 2007 to 2025 for each source sector. 

1.6 INVENTORY VERSIONS 

The development of base and future year inventories is an iterative process that continually 

attempts to use the best data available to meet air quality planning needs, given time and 

resource constraints. The following subsections summarize the work completed to date. 

1.6.1 Version 2 Modeling Inventories with Existing Controls 

MARAMA developed comprehensive emission inventories to support air quality modeling 

in the region. MARAMA developed a calendar year 2007 (MARAMA 2011a) inventory 

for all sectors except the onroad sector. These inventories, completed in February of 2011, 

are referred to as Version 2 of the MANE-VU+VA 2007 base year inventory. The 

inventories were provided in formats required for air quality modeling. Under a separate 

effort, the Northeast States for Coordinated Air Use Management (NESCAUM) developed 

a 2007 onroad inventory using the MOVES model to support air quality modeling. 

MARAMA also prepared emission projections for 2013/2017/2020 (MARAMA 2011b) 

for all sectors except the electric generation and onroad sectors. These projections reflect a 

scenario representing the best estimates for the future year, accounting for all in-place 

controls that are fully adopted into federal or individual state regulations or SIPs. In the 

past, this inventory is also referred to as the "on-the-books" inventory. Modelers often 

refer to this scenario as the "future base case". 

1.6.2 Version 3 Modeling Inventories with Existing Controls 

Beginning in the fall of 2011, MARAMA sponsored development of Version 3_3 of the 

2007 base year modeling inventory to incorporate new paved road emission estimates, 
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revised modeling of nonroad and onroad sources, and other state-specific changes 

(MARAMA2012a). MARAMA developed Version 3_3 of the future year inventory to 

account for changes to the 2007 base year inventory and selected changes in growth and 

control factors identified by states (MARAMA2012b). The future year modeling 

inventories for electric generating units (EGUs) are currently being developed under a 

separate effort lead by the Eastern Regional Technical Advisory Committee (ERTAC). 

The future year modeling inventories for onroad sources are currently being developed by 

NESCAUM, MARAMA or individual states. 

1.6.3 Version 3 2025 Inventory for PM Nonattainment Counties Rev 1` 

The 2025 inventory for PM nonattainment counties was developed using Version 3_3 of 

the modeling inventory, with the following exceptions: 

 Growth and control factors for 2025 were developed for the area, nonEGU point, 

and nonroad MAR sectors, using the same methodologies and data sources that 

were used to develop the 2017/2020 inventories with existing controls. 

 For nonroad sources included in NMIM, Version 2 results were available for 2007, 

2017, and 2020. MARAMA and New York made additional NMIM runs for 2025 

based on Version 2 inputs. MARAMA made revisions to some of the inputs to 

NMIM for Version 3_3 of the modeling inventory; however, these revised NMIM 

runs were not used in the 2025 PM nonattainment county inventory due to time 

constraints. 

 For onroad sources included in the MOVES model, MARAMA and states executed 

the model in the inventory mode for 2007 and 2025. Version 3_3 of the modeling 

inventory used results of the MOVES model executed in a manner to support air 

quality modeling. 

 For EGU point sources, the results of the ERTAC EGU projection methodology are 

not currently available. An alternative methodology for projecting EGU emissions 

based on growth and control factors was used, as described in Section 4. 

 Only counties classified as nonattainment for the PM2.5 annual or 24-hour 

NAAQS were included. 

1.6.4 Version 3 2025 Inventory for PM Nonattainment Counties - Rev 2 

Only very minor changes are included in Revision 2 of the 2025 inventory. These 

included 
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 Updating the CT NMIM emissions to reflect the NMMA Pleasure Craft Population. 

 Updating the VA NMIM emissions to reflect a rerun with improved fuel 

characteristics. No change was made to the NMMA Pleasure Craft Population. 

 Adding New York 2007 NMIM emissions. These emissions were provided by 

New York staff. MARAMA does not have information about what pleasure craft 

population was used in these runs. 

Exhibit 1-1 shows the data sources used for the 2025 PM nonattainment area inventory. 

Exhibit 1-2 lists the counties included in the 2025 PM nonattainment area inventory. 

Exhibit 1.1 – Comparison of Data Used for Version 3 of the Modeling Inventory 

and the 2025 PM Nonattainment Inventory 

Sector

Modeling Inventory 2025 PM Nonattainment Inventory

2007 2017/2020 2007 2025

Area Version 3_3 Version 3_3 Version 3_3 Version 3_3

Nonroad-NMIM Version 3_3 Version 3_3 Version 2 2025 NMIM run 

based on 

Version 2 inputs

(1)

Nonroad-MAR Version 3_3 Version 3_3 Version 3_3 Version 3_3

Onroad MOVES runs by 

NESCAUM to 

support AQ 

modeling

MOVES runs by 

NESCAUM to 

support AQ 

modeling

MOVES runs by 

MARAMA or 

states in 

inventory mode

MOVES runs by 

MARAMA or 

states in 

inventory mode

Point-EGU Version 3_3 To be developed 

by ERTAC

Version 3_3 See section 4 for 

projection 

methodology

Point-nonEGU Version 3_3 Version 3_3 Version 3_3 Version 3_3

(1) Except CT and VA where Version 3 inputs were used. 

CT reflects NMMA Pleasure Craft Population 

VA reflects NMMA Default Pleasure Craft population. 

1.7 REPORT ORGANIZATION 

Sections 2 to 6 describe the emission projection process for the following source sectors: 

area sources; point sources; nonroad mobile sources included in the NMIM model; other 

nonroad mobile sources (marine vessels, aircraft, and railroad locomotives); and onroad 

mobile sources included in the MOVES model. Section 7 provides nonattainment area 

emission pollutant summaries. Section 8 provides a description of the final deliverables, 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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including the file names for all final deliverable products. References for the TSD are 

provided in Section 9. 

Exhibit 1.2 – List of PM Nonattainment Areas and Counties 

Nonattainment Area State

FIPS

Code County

PM Nonattainment?

2006 

Daily

NAAQS

1997 

Annual

NAAQS

Allentown, PA PA 42077 Lehigh Yes Yes

PA 42095 Northampton Yes Yes

Baltimore, MD MD 24003 Anne Arundel No Yes

MD 24005 Baltimore No Yes

MD 24013 Carroll No Yes

MD 24025 Harford No Yes

MD 24027 Howard No Yes

MD 24510 Baltimore City No Yes

Hagerstown-Martinsburg, MD-WV MD 24043 Washington No Yes

Harrisburg-Lebanon-Carlisle-York, PA PA 42041 Cumberland Yes Yes

PA 42043 Dauphin Yes Yes

PA 42075 Lebanon Yes Yes

PA 42133 York* Yes No

Johnstown, PA PA 42021 Cambria Yes Yes

PA 42063 Indiana(P) Yes Yes

Lancaster, PA PA 42071 Lancaster Yes Yes

New York-N. New Jersey-Long Island, CT 09001 Fairfield Yes Yes

NY-NJ-CT CT 09009 New Haven Yes Yes

NJ 34003 Bergen Yes Yes

NJ 34013 Essex Yes Yes

NJ 34017 Hudson Yes Yes

NJ 34021 Mercer Yes Yes

NJ 34023 Middlesex Yes Yes

NJ 34025 Monmouth Yes Yes

NJ 34027 Morris Yes Yes

NJ 34031 Passaic Yes Yes

NJ 34035 Somerset Yes Yes

NJ 34039 Union Yes Yes

NY 36005 Bronx Yes Yes

NY 36047 Kings Yes Yes

NY 36059 Nassau Yes Yes

NY 36061 New York Yes Yes

NY 36071 Orange Yes Yes

NY 36081 Queens Yes Yes

NY 36085 Richmond Yes Yes

NY 36087 Rockland Yes Yes

NY 36103 Suffolk Yes Yes

NY 36119 Westchester Yes Yes

Philadelphia-Wilmington, PA-NJ-DE DE 10003 New Castle Yes Yes

NJ 34005 Burlington Yes Yes
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Nonattainment Area State

FIPS

Code County

PM Nonattainment?

2006 

Daily

NAAQS

1997 

Annual

NAAQS

NJ 34007 Camden Yes Yes

NJ 34015 Gloucester Yes Yes

PA 42017 Bucks Yes Yes

PA 42029 Chester Yes Yes

PA 42045 Delaware Yes Yes

PA 42091 Montgomery Yes Yes

PA 42101 Philadelphia Yes Yes

Pittsburgh-Beaver Valley, PA PA 42003 Allegheny(P) Yes Yes

PA 42005 Armstrong(P) Yes Yes

PA 42007 Beaver Yes Yes

PA 42019 Butler Yes Yes

PA 42059 Greene(P) Yes Yes

PA 42073 Lawrence(P)* Yes Yes

PA 42125 Washington Yes Yes

PA 42129 Westmoreland Yes Yes

Reading, PA PA 42011 Berks No Yes

Washington, DC-MD-VA DC 11001 Washington No Yes

MD 24017 Charles No Yes

MD 24021 Frederick No Yes

MD 24031 Montgomery No Yes

MD 24033 Prince George No Yes

VA 51013 Arlington No Yes

VA 51059 Fairfax No Yes

VA 51107 Loudoun No Yes

VA 51153 Prince William No Yes

VA 51510 Alexandria No Yes

VA 51600 Fairfax City No Yes

VA 51610 Falls Church No Yes

VA 51683 Manassas City No Yes

VA 51685 Manassas 

Park No Yes

York, PA PA 42133 York* No Yes

* York County, PA, is in one nonattainment area for the 2006 24-hour standard (HarrisburgLebanon-Carlisle-York, PA) and another for the 1997 annual standard (York, PA). 

(P) indicates that only part of the county is in the nonattainment area; for this inventory, emissions 

for the entire county are included. 
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2.0 AREA SOURCES 

2.1 AREA SOURCE CATEGORIES 

The area source sector contains emissions estimates for sources which individually are too 

small in magnitude or too numerous to inventory as individual point sources, and which 

can often be estimated more accurately as a single aggregate source for a county. 

Examples are emissions from home heating systems, house painting, consumer products 

usage, and small industrial/commercial operations that are not permitted as point sources. 

There are 356 individual area source categories in the MANE-VU+VA inventory, 

categorized by a 10-digit SCC. 

2.2 2007 INVENTORY DEVELOPMENT 

The emission projections for the 2025 area source inventory were based on Version 3_3 of 

the 2007 MANE-VU+VA inventory and are fully documented in the TSD for that effort 

(MARAMA 2012a). The only adjustment to the 2007 Version 3_3 area source inventory 

was to apply “transport factors” to fugitive dust sources, as described in the following 

subsection. 

2.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections 

Grid air quality models consistently overestimate fugitive dust impacts as compared to 

ambient samples. USEPA developed a methodology to reduce fugitive dust emissions for 

use in grid modeling analyses. It is considered a logical step to improve the ability to 

account for the removal of particles near their emission source by vegetation and surface 

features and can be useful in grid-based modeling analyses. 

In February 2011, MARAMA developed 2007 emission modeling files for area sources 

which applied the USEPA “transport factor” to reduce fugitive dust emissions to account 

for the removal of particles near their emission source by vegetation and surface features. 

The standard transport fractions and SCC assignments from USEPA’s CHIEF website 

(USEPA 2007a) were used to reduce the PM25-PRI emissions in this inventory. Two files 

were used. Exhibit 2.1 shows the list of nonEGU SCCs for which the transport factor was 

applied. The major source categories included paved and unpaved roads, construction 

activity, agricultural crop land tilling, and agricultural livestock operations. Exhibit 2.2 

lists the transport fractions for PM nonattainment counties which vary by county. For 

example, the transport factors ranges from 0.1375 in Camden, New Jersey to 0.80 in 

Suffolk County, New York. For Virginia, no transport fraction was provided for the City 

of Fairfax; Fairfax County’s transport fraction was used for this jurisdiction. 
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Exhibit 2.1 Area Source SCCs Affected by PM Transport Fraction 

SCC SCC Description

2294000000 Paved Roads: All Paved Roads: Total: Fugitives

2296000000 Unpaved Roads: All Unpaved Roads: Total: Fugitives

2311000000 Construction: All Processes: Total

2311010000 Construction: General Building Construction: Total

2311020000 Construction: Heavy Construction: Total

2311030000 Construction: Road Construction: Total

2801000000 Miscellaneous Area Sources;Agriculture Production - Crops;Agriculture - Crops;Total

2801000001 Ag crops: Agriculture - Crops: Land Breaking

2801000002 Ag crops: Agriculture - Crops: Planting

2801000003 Ag crops: Agriculture - Crops: Tilling

2801000004 Ag crops: Agriculture - Crops: Defoliation

2801000005 Ag crops: Agriculture - Crops: Harvesting

2801000006 Ag crops: Agriculture - Crops: Drying

2801000007 Ag crops: Agriculture - Crops: Loading

2801000008 Ag crops: Agriculture - Crops: Transport

2805000000 Ag livestock: Agriculture - Livestock: Total

2805001000 Ag livestock: Beef Cattle Feedlots: Total (also see 2805020000)

2805001001 Ag livestock: Beef Cattle Feedlots: Feed Preparation

2805005000 Ag livestock: Poultry Operations: Total

2805010000 Ag livestock: Dairy Operations: Total 

2805015000 Ag livestock: Hog Operations: Total 

2805020000 Ag livestock: Cattle and Calves Composite: Total

2805025000 Ag livestock: Hogs and Pigs Composite: Total

2805030000 Ag livestock: Poultry and Chickens Composite: Total

2805035000 Ag livestock: Horses and Ponies Composite: Total

2805040000 Ag livestock: Sheep and Lambs Composite: Total

2805045001 Ag livestock: Goats: Total
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Exhibit 2.2 PM Transport Fractions for PM Nonattainment Counties 

State FIPS County

PM Transport 

Fraction

CT 09001 FAIRFIELD 0.4347

CT 09009 NEW HAVEN 0.4442

DE 10003 NEW CASTLE 0.5087

DC 11001 WASHINGTON 0.3953

MD 24003 ANNE ARUNDEL 0.4874

MD 24005 BALTIMORE 0.4047

MD 24013 CARROLL 0.5641

MD 24017 CHARLES 0.4879

MD 24021 FREDERICK 0.4904

MD 24025 HARFORD 0.5147

MD 24027 HOWARD 0.2798

MD 24031 MONTGOMERY 0.3089

MD 24033 PRINCE GEORGES 0.2950

MD 24043 WASHINGTON 0.4003

MD 24510 BALTIMORE (CITY) 0.4874

NJ 34003 BERGEN 0.2657

NJ 34005 BURLINGTON 0.3008

NJ 34007 CAMDEN 0.1375

NJ 34013 ESSEX 0.3461

NJ 34015 GLOUCESTER 0.4361

NJ 34017 HUDSON 0.5286

NJ 34021 MERCER 0.3472

NJ 34023 MIDDLESEX 0.3273

NJ 34025 MONMOUTH 0.5468

NJ 34027 MORRIS 0.2297

NJ 34031 PASSAIC 0.1971

NJ 34035 SOMERSET 0.3635

NJ 34039 UNION 0.3117

NY 36005 BRONX 0.6145

NY 36059 NASSAU 0.6595

NY 36061 NEW YORK 0.6483

NY 36071 ORANGE 0.3803

NY 36081 QUEENS 0.6505

NY 36085 RICHMOND 0.7159

NY 36087 ROCKLAND 0.3556

NY 36103 SUFFOLK 0.7997

NY 36119 WESTCHESTER 0.3531

PA 42003 ALLEGHENY 0.2308

PA 42005 ARMSTRONG 0.3289

PA 42007 BEAVER 0.3141
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State FIPS County

PM Transport 

Fraction

PA 42011 BERKS 0.4682

PA 42017 BUCKS 0.3980

PA 42019 BUTLER 0.3621

PA 42021 CAMBRIA 0.2253

PA 42029 CHESTER 0.4757

PA 42041 CUMBERLAND 0.4649

PA 42043 DAUPHIN 0.3438

PA 42045 DELAWARE 0.3515

PA 42059 GREENE 0.3224

PA 42063 INDIANA 0.2884

PA 42071 LANCASTER 0.6183

PA 42073 LAWRENCE 0.4422

PA 42075 LEBANON 0.4521

PA 42077 LEHIGH 0.4487

PA 42091 MONTGOMERY 0.3729

PA 42095 NORTHAMPTON 0.4306

PA 42101 PHILADELPHIA 0.3471

PA 42125 WASHINGTON 0.3436

PA 42129 WESTMORELAND 0.2875

PA 42133 YORK 0.5134

VA 51013 ARLINGTON 0.3534

VA 51059 FAIRFAX 0.2457

VA 51107 LOUDOUN 0.3345

VA 51153 PRINCE WILLIAM 0.1814

VA 51510 ALEXANDRIA 0.3745

VA 51610 FALLS CHURCH 0.3400

VA 51683 MANASSAS 0.3474

VA 51685 MANASSAS PARK 0.3551
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Exhibit 2.3 – Comparison of 2007 Paved Road Dust PM10 Emission Estimates 

Nonattainment Area

Without 

Transport Factor

With 

Transport Factor

Version2

Version 3 

New 

Method

Version2

Version 3 

New 

Method

Allentown 4,228 1,733 1,859 764

Baltimore 15,175 5,412 6,658 2,400

Hagerstown 1,490 263 596 105

Harrisburg-Lebanon-Carlisle-York 9,133 4,124 4,149 1,855

Johnstown 2,663 1,133 673 289

Lancaster 4,339 1,808 2,683 1,118

New York-Northern NJ-Long Island-CT 58,512 28,747 29,128 14,260

Philadelphia-Wilmington 29,379 12,644 11,070 4,801

Pittsburgh-Beaver Valley 14,470 6,173 4,491 1,920

Reading 3,346 1,423 1,567 666

Washington, DC-MD-VA 21,067 9,909 6,846 3,194

York 3,684 1,458 1,891 749

Exhibit 2.4 – Comparison of 2007 Paved Road Dust PM2.5 Emission Estimates 

Nonattainment Area

Without 

Transport Factor

With 

Transport Factor

Version2

Version 3 

New

Method

Version2

Version 3 

New 

Method

Allentown 264 433 116 191

Baltimore 1,770 1,328 782 589

Hagerstown 196 64 78 26

Harrisburg-Lebanon-Carlisle-York 605 1,031 277 464

Johnstown 198 283 50 72

Lancaster 295 452 182 280

New York-Northern NJ-Long Island-CT 2,400 7,173 1,252 3,547

Philadelphia-Wilmington 1,396 3,165 547 1,202

Pittsburgh-Beaver Valley 942 1,543 299 480

Reading 209 356 98 167

Washington, DC-MD-VA 1,713 2,432 594 784

York 257 365 132 187
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2.3 2025 INVENTORY DEVELOPMENT 

The general procedures and data used for projecting emissions for the area source sector 

are summarized in this section. Growth factors were applied to the MANE-VU+VA 2007 

inventory to account for changes in fuel use, population, economic activity. Next, control 

factors were applied to account for future emission reductions from control regulations. 

The 2025 inventory accounts for post-2007 emission reductions from promulgated federal, 

State, local, and site-specific control programs and proposed control programs that are 

reasonably anticipated to result in post-2007 emission reductions. 

2.3.1 Area Source Growth Factors 

The area and nonEGU point source growth factors were developed using six sets of data: 

 The Annual Energy Outlook (AEO) fuel consumption forecasts; 

 County-level population projections; 

 State-level employment projections by NAICS code; 

 County-level vehicle miles travelled (VMT) projections; 

 USEPA projections for livestock and residential wood combustion; and 

 Other state-specific emission projection data. 

The priority for applying these growth factors was to first use the state-supplied projection 

data (if available). If state-supplied data were not provided, then the AEO projection 

factors were used for fuel consumption sources, and the population/employment/VMT data 

were used for other source categories. 

2.3.1.1 AEO Fuel Use Projection 

The AEO is published annually by the U.S. Energy Information Administration (EIA). It 

presents long-term projections of energy supply, demand, and prices through 2035, based 

on results from EIA’s National Energy Modeling System (NEMS). NEMS projects the 

production, imports, conversion, consumption, and prices of energy, subject to 

assumptions on macroeconomic and financial factors, world energy markets, resource 

availability and costs, behavioral and technological choice criteria, energy technology cost 

and performance characteristics, and demographics. 

AEO provides regional fuel-use forecasts for various fuel types (e.g., coal, residual oil, 

distillate oil, natural gas) by end use sector (e.g., residential, commercial, industrial, 

transportation, and electric power). Energy use projections are reported at the Census 

division level. The census divisions grouped states as follows: 

 South Atlantic - DE, DC, MD, VA 

 Middle Atlantic – NJ, NY, PA 

 New England – CT, ME, MA, NH, RI, VT 
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Appendices A1, A2, and A3 contain the AEO2010 fuel use projections for each of these 

three regions. Appendices A4, A5, and A6 contain the AEO2011 fuel use projections 

Version 2 of the MANE-VU+VA future year inventories was developed using AEO2010 

(EIA2010). After the release of Version 2, AEO2011 was published (EIA2011a). 

MARAMA reviewed the updated fuel forecasts and compared the AEO2010 and 

AEO2011 projections. Appendix A7 documents MARAMA’s analysis. MARAMA 

calculated the difference in projected fuel usage between AEO2010 and AEO2011 for the 

residential, commercial, industrial, transportation, and electric power sector for the 

distillate fuel oil, residual fuel oil, coal, natural gas, and renewable fuel types. MARAMA 

identified thresholds for what constitutes a major change as follows: 

 An increase or decrease of 1% or less is considered to be no change and did not 

warrant a change in the growth factors between Versions 2 and 3 of the inventory; 

 An increase or decrease of between 1% and 5% is considered to be a minor change, 

and states agreed that these differences between AEO2010 and AEO2011 did not 

warrant a change in the growth factors between Versions 2 and 3 of the inventory; 

 An increase or decrease above 5% is considered a major change, and warrants a 

change in the growth factors used in Version 3. 

MARAMA recommended that the AEO2010 projections be retained for all residential, 

commercial, and industrial sector fuel use, except for industrial natural gas usage, where 

the AEO2011 projections will be used for Version 3 of the future year modeling inventory. 

New Jersey elected to use the more recent growth factors from AEO2011 instead of the 

AEO2010 growth factors for all area source fossil fuel use categories. 

Exhibits 2.5 to 2.9 summarize the projected fuel use rates by source sector (residential, 

commercial, industrial, transportation) and AEO geographic area for the years 2007 to 

2025. The unusual growth in commercial residual oil use in the South Atlantic region 

could not be explained; Maryland elected to use employment instead of the AEO2010 

growth factor for commercial residual oil combustion, while Virginia and the District 

chose to assume flat growth in this sector. 

2.3.1.2 Population Projections 

States provided county-level historic population data and projections for future years. The 

historical and projection years varied from state to state, so values were interpolated, when 

necessary, to create population estimates for each year from 2007 to 2025. The population 

data were then normalized to create growth factors from 2007 for each year future year. 
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For example, Delaware had a population of 861,087 in 2007, and the projected population 

in 2017 is 953,204. Thus, the growth factor for 2017 is 953,204 / 861,087 = 1.107. 

Exhibit 2.10 summarizes the population growth factors by state and AEO2010 region. 

Population is projected to grow in every state between 2007 and 2025. The population 

growth in the New England states varies significantly by state. Population growth in the 

South Atlantic states is projected to be much higher than in the New England and MidAtlantic states. Appendix B contains the data use to develop the population projections. 

2.3.1.3 Employment Projections 

Every two years, the federal Bureau of Labor Statistics produces long-term industry and 

occupation forecasts for ten future years, and states are asked to do the same for their 

respective economies. The most recent projections are from state Departments of Labor 

for the period 2006 to 2016, most of which were published in 2008. These 10-year 

forecasts are updated every other year. The next set of state-specific projections will be for 

the period 2008 to 2018. Only the District of Columbia and Delaware were able to provide 

employment projections for 2008 to 2017; the 2008 to 2018 projections were not available 

for other states in time for use on this project. The employment projections are state-wide 

by 3-digit NAICS code. Exhibit 2.11 summarizes the manufacturing employment (NAICS 

sector 310) growth factors by state and AEO2010 region. States in the Northeast / MidAtlantic region show a marked decrease in manufacturing employment from 2007 forward. 

Appendix C contains the data that were used to develop the employment projections. 

2.3.1.4 VMT Projections 

States developed projections of vehicle miles traveled (VMT) for 2007 and 2025 which 

were used as the growth factor for projecting emissions from re-entrained road dust from 

travel on paved roads (SCC 22-94-000-000). The 2007 and 2025 VMT are identical to 

those used in the MOVES modeling discussed in Section 8. Exhibit 2.12 shows the county 

level VMT for 2007 and 2025, and the growth factor for projecting 2007 emissions to 

2025. Growth factors for 2013, 2017, and 2020 were based on a linear interpolation of the 

2007 and 2025 VMT. Appendix D contains additional information on the data used to 

develop the VMT growth factors. 
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Exhibit 2.5 AEO2010 Growth Factors for Coal by AEO Region 2007 – 2025 
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Exhibit 2.6 Growth Factors for Residual Oil by AEO Region 2007 – 2025 
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Exhibit 2.7 AEO2010 Growth Factors for Distillate Oil by AEO Region 2007 – 2025
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Exhibit 2.8 Growth Factors for Natural Gas by AEO Region 2007 – 2025 

AEO2010 for Residential/Commercial, AEO2011 for Industrial 
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Exhibit 2.9 AEO2010 Growth Factors for Gasoline by AEO Region 2007 – 2025
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Exhibit 2.10 Population Growth Factors by AEO Region 2007 – 2025 
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Exhibit 2.11 Manufacturing Employment Growth Factors by Region 2007 - 2025
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Exhibit 2.12 2007 and 2025 VMT and the 2007-2025 Growth Factor 

Million VMT Growth

Nonattainment Area County FIPS 2007 2025 2007-2005

Allentown Lehigh 42077 2,947 3,700 1.256

Allentown Northampton 42095 2,020 2,629 1.301

Baltimore Anne Arundel 24003 5,786 7,907 1.367

Baltimore Baltimore 24005 8,261 10,330 1.251

Baltimore Carroll 24013 1,296 1,766 1.363

Baltimore Harford 24025 2,362 3,060 1.296

Baltimore Howard 24027 3,815 6,059 1.588

Baltimore Baltimore City 24510 3,626 4,150 1.145

Hagerstown Washington 24043 2,090 2,940 1.407

Harrisburg-Lebanon-Carlisle-York Cumberland 42041 2,861 3,704 1.295

Harrisburg-Lebanon-Carlisle-York Dauphin 42043 3,072 3,689 1.201

Harrisburg-Lebanon-Carlisle-York Lebanon 42075 1,209 1,507 1.247

Harrisburg-Lebanon-Carlisle-York York 42133 3,304 4,209 1.274

Johnstown Cambria 42021 1,157 1,110 0.959

Johnstown Indiana 42063 844 928 1.100

Lancaster Lancaster 42071 4,255 5,395 1.268

New York Metro NY/NJ/CT Fairfield 9001 7,560 8,568 1.133

New York Metro NY/NJ/CT New Haven 9009 6,856 8,085 1.179

New York Metro NY/NJ/CT Bergen 34003 7,879 10,464 1.328

New York Metro NY/NJ/CT Essex 34013 4,895 6,131 1.253

New York Metro NY/NJ/CT Hudson 34017 2,313 2,801 1.211

New York Metro NY/NJ/CT Mercer 34021 3,566 3,996 1.121

New York Metro NY/NJ/CT Middlesex 34023 7,810 9,748 1.248

New York Metro NY/NJ/CT Monmouth 34025 6,319 8,595 1.360

New York Metro NY/NJ/CT Morris 34027 5,530 6,523 1.180

New York Metro NY/NJ/CT Passaic 34031 2,918 3,490 1.196

New York Metro NY/NJ/CT Somerset 34035 3,230 3,667 1.135

New York Metro NY/NJ/CT Union 34039 4,623 5,730 1.239

New York Metro NY/NJ/CT Bronx 36005 3,677 4,830 1.314

New York Metro NY/NJ/CT Kings 36047 5,461 6,272 1.148

New York Metro NY/NJ/CT Nassau 36059 11,780 14,705 1.248

New York Metro NY/NJ/CT New York 36061 3,938 5,203 1.321

New York Metro NY/NJ/CT Orange 36071 4,431 5,906 1.333

New York Metro NY/NJ/CT Queens 36081 8,859 10,949 1.236

New York Metro NY/NJ/CT Richmond 36085 2,152 3,354 1.558

New York Metro NY/NJ/CT Rockland 36087 2,675 4,060 1.517

New York Metro NY/NJ/CT Suffolk 36103 13,767 20,514 1.485

New York Metro NY/NJ/CT Westchester 36119 8,201 11,811 1.490

Philadelphia PA/DE/NJ New Castle 10003 5,544 6,959 1.255

Philadelphia PA/DE/NJ Burlington 34005 4,704 5,062 1.076
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Million VMT Growth

Nonattainment Area County FIPS 2007 2025 2007-2005

Philadelphia PA/DE/NJ Camden 34007 4,090 4,267 1.043

Philadelphia PA/DE/NJ Gloucester 34015 2,723 3,284 1.206

Philadelphia PA/DE/NJ Bucks 42017 5,047 6,516 1.291

Philadelphia PA/DE/NJ Chester 42029 4,423 6,201 1.402

Philadelphia PA/DE/NJ Delaware 42045 3,766 4,371 1.161

Philadelphia PA/DE/NJ Montgomery 42091 7,075 8,220 1.162

Philadelphia PA/DE/NJ Philadelphia 42101 5,973 6,337 1.061

Pittsburgh-Beaver Valley Allegheny 42003 9,345 10,134 1.084

Pittsburgh-Beaver Valley Armstrong 42005 628 672 1.071

Pittsburgh-Beaver Valley Beaver 42007 1,487 1,585 1.066

Pittsburgh-Beaver Valley Butler 42019 1,762 2,173 1.233

Pittsburgh-Beaver Valley Greene 42059 464 504 1.086

Pittsburgh-Beaver Valley Lawrence 42073 812 880 1.084

Pittsburgh-Beaver Valley Washington 42125 2,245 2,531 1.127

Pittsburgh-Beaver Valley Westmoreland 42129 3,512 3,898 1.110

Reading Berks 42011 3,341 4,079 1.221

Washington DC/MD/VA DC 11001 3,666 3,861 1.053

Washington DC/MD/VA Charles 24017 1,284 1,825 1.421

Washington DC/MD/VA Frederick 24021 3,009 4,442 1.476

Washington DC/MD/VA Montgomery 24031 7,471 9,711 1.300

Washington DC/MD/VA Prince George's 24033 8,754 11,616 1.327

Washington DC/MD/VA Arlington 51013 1,663 1,917 1.153

Washington DC/MD/VA Fairfax 51059 10,123 13,880 1.371

Washington DC/MD/VA Loudoun 51107 2,403 3,741 1.557

Washington DC/MD/VA Prince William 51153 3,202 4,643 1.450

Washington DC/MD/VA Alexandria 51510 736 866 1.177

Washington DC/MD/VA Fairfax 51600 193 220 1.143

Washington DC/MD/VA Falls Church 51610 64 76 1.186

Washington DC/MD/VA Manassas 51683 273 360 1.317

Washington DC/MD/VA Manassas Park 51685 26 30 1.166
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2.3.1.5 No Growth Assignment for Certain Area Source Categories 

For several area source categories, it seems reasonable that emissions would not change 

from the 2007 values. No growth was applied to the 2007 emissions for the area source 

categories shown in Exhibit 2.13. 

Exhibit 2.13 Area Source Categories with No Growth Assignment 

SCC SCC Description

2296000000 Unpaved Roads /All Unpaved Roads /Total: Fugitives

2401008000 Surface Coating /Traffic Markings /Total: All Solvent Types

2461020000 Misc Non-industrial: Commercial /Asphalt Application: All Processes /Total: All

2461021000 Misc Non-industrial: Commercial /Cutback Asphalt /Total: All Solvent Types

2461022000 Misc Non-industrial: Commercial /Emulsified Asphalt /Total: All Solvent Types

2461023000 Misc Non-industrial: Commercial /Asphalt Roofing /Total: All Solvent Types

2601000000 On-site Incineration /All Categories /Total

2601010000 On-site Incineration /Industrial /Total

2601010000 On-site Incineration /Industrial /Total

2601020000 On-site Incineration /Commercial/Institutional /Total

2601020000 On-site Incineration /Commercial/Institutional /Total

2601030000 On-site Incineration /Residential /Total

2610000100 Open Burning /All Categories /Yard Waste - Leaf Species Unspecified

2610000400 Open Burning /All Categories /Yard Waste - Brush Species Unspecified

2610000500 Open Burning /All Categories /Land Clearing Debris (use 28-10-005-000 for Logging

2610030000 Open Burning /Residential /Household Waste (use 26-10-000-xxx for Yard Wastes)

2610040400 Open Burning /Municipal (from residences, parks, other for central burn) 

2660000000 Leaking Underground Storage Tanks /Leaking Underground Storage Tanks /Total: All

2680001000 Composting /100% Biosolids (e.g., sewage sludge, manure, mixtures of these matls

2680002000 Composting /Mixed Waste (e.g., a 50:50 mixture of biosolids and green wastes)

2806010000 Domestic Animals Waste Emissions /Cats /Total

2806015000 Domestic Animals Waste Emissions /Dogs /Total

2807020001 Wild Animals Waste Emissions /Bears /Black Bears

2807020002 Wild Animals Waste Emissions /Bears /Grizzly Bears

2807025000 Wild Animals Waste Emissions /Elk /Total

2807030000 Wild Animals Waste Emissions /Deer /Total

2807040000 Wild Animals Waste Emissions /Birds /Total

2810001000 Forest Wildfires - Wildfires – Unspecified

2810003000 Cigarette Smoke /Total

2810005000 Managed Burning, Slash (Logging Debris) /Unspecified Burn Method

2810010000 Human Perspiration and Respiration /Total

2810014000 Prescribed Burning /Generic - Unspecified land cover, ownership, class/purpose
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SCC SCC Description

2810015000 Prescribed Forest Burning /Unspecified

2810020000 Prescribed Rangeland Burning /Unspecified

2810030000 Structure Fires /Unspecified

2810035000 Firefighting Training /Total

2810050000 Motor Vehicle Fires /Unspecified

2810060200 Cremation /Animals

2810090000 Open Fire /Not categorized

2820010000 Cooling Towers /Process Cooling Towers /Total

2830000000 Catastrophic/Accidental Releases /All Catastrophic/Accidental Releases /Total

2830010000 Catastrophic/Accidental Releases /Transportation Accidents /Total

2.3.1.6 USEPA 2020 Projections for Residential Wood 

USEPA made available its 2020 emissions projections associated with its 2005-based v4 

modeling platform. MARAMA decided to use USEPA emission projection parameters for 

residential wood combustion. USEPA’s methodology and data sources are summarized 

below (USEPA 2010a). 

USEPA projected residential wood combustion emissions are based on the expected 

increase in the number of low-emitting wood stoves and the corresponding decrease in 

other types of wood stoves. As newer, cleaner woodstoves replace older, more polluting 

stoves, there will be an overall reduction of emissions from this category. The approach 

used by USEPA was developed as part of a modeling exercise to estimate the expected 

benefits of the woodstove change-out program. This methodology uses a combination 

growth and control factors and is based on activity not pollutant. The growth and control 

are accounted for in a single factor for each residential wood SCC (certain SCCs represent 

controlled equipment, while other SCCs represent uncontrolled equipment). Control 

factors are indirectly incorporated based on which stove is used. The specific assumptions 

USEPA made were: 

 Fireplaces, SCC=2104008001: increase 1%/year; 

 Old woodstoves, SCC=2104008002, 2104008010, 2104008051: decrease 2%/year; 

 New woodstoves, SCC=2104008003, 2104008004, 2104008030, 2104008050, 

2104008052 or 2104008053: increase 2%/year. 

For the general woodstoves and fireplaces category (SCC 2104008000) USEPA computed 

a weighted average distribution based on 19.4% fireplaces, 71.6% old woodstoves, 9.1% 

new woodstoves using 2002 Platform emissions for PM2.5. These fractions are based on 

the fraction of emissions from these processes in the states that did not have the “general 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

Page 27

woodstoves and fireplaces” SCC in the 2002 NEI. This approach results in an overall 

decrease of 1.056% per year for this source category. Appendix E contains the residential 

wood projection data from USEPA. 

2.3.1.7 SCC, SIC, NAICS and Growth Parameter Crosswalk 

Since the employment projections were based on 3-digit NAICS code, it was necessary to 

map NAICS codes to SCCs and SIC codes that were used by states. Employment 

projections at the more specific 4-digit or 6-digit NAICS codes were not available. 

The first step for developing a comprehensive crosswalk between the different source 

classification codes (SCC, SIC, and NAICS codes) and emission activity growth indicators 

was to compile a complete list of the NAICS codes in the 2007 point source inventory. 

Some states use the SIC code while other use the NAICS code. Still other states use both 

the SIC and NAICS codes. When the NAICS code was not available SIC codes were 

converted to NAICS codes. The 6-digit NAICS code was truncated to a 3-digit code, 

which represents major industry subsectors of the economy. A U.S. Census Bureau 

document was used to perform this conversion (CENSUS 2000). 

The next step was to review parameters that could be used as the emission activity growth 

indicator for each SCC or NAICS. We initially relied on two USEPA crosswalks (USEPA 

2004a, USEPA 2004b) to match area and nonEGU point source SCCs to AEO2010 

categories, employment NAICS codes, and population. 

2.3.1.8 Final Version 2 Growth Factors for Area Sources 

The previous sections described the initial growth factors recommended to develop 

projected future year emissions inventories for area and non-EGU sources. Draft growth 

and control factors, and a draft technical support document, were circulated for review by 

MARAMA and state agencies. During the review, it was noted that several emissions 

categories show negative growth into the future, particularly categories related to fossil 

fuel combustion and manufacturing employment. 

Many of the growth factors used to project emissions for area and non-EGU sources were 

based on the AEO2010 fuel consumption forecasts and state-level employment projections. 

The AEO2010 forecasts show declining trends for many fuel consumption sectors, 

especially industrial, residential, and commercial distillate fuel oil use. Similarly, the 

employment projections show declines in the predicted number of employees for many 

sectors of the economy. This is particularly true for the manufacturing sector, which is of 

interest because this sector is often associated with higher emissions than those for other 

sectors. By contrast, the employment projections show increasing trends in retail and 
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service-related sectors. However, these sectors are not typically associated with significant 

emissions. 

Predicted declines in fuel use and employment resulted in growth factors less than unity 

(i.e., represent negative growth) for many area and non-EGU point source categories. 

Consequently, for some categories, emissions were initially projected to be lower for the 

projected future years than for the base year, even before the application of control 

assumptions (i.e., the future "growth only" emissions are lower than the base year 

emissions). A conference call was held to discuss the negative growth issue, and states 

were polled as to whether or not they felt that the current set of proposed growth factors - 

including the negative growth factors - were realistic for their state. In reply, some 

representatives mentioned that they have observed historic state-specific data that supports 

the trends displayed by the proposed growth factors. Other representatives mentioned that 

they feel comfortable with the growth factors and don't have a technical basis to change 

them or suggest others. Some states will supply their own factors or make their own 

assumptions. 

As a result of these discussions, each state provided guidance on how to handle projections 

when negative growth is indicated. Exhibit 2.14 shows the state recommendations for area 

sources. 

2.3.1.9 Version 3 Update to New Jersey Growth Factors for Area Sources 

New Jersey provided updated growth factors for area source for use in developing the 2025 

inventory for PM nonattainment counties. One of the key revisions was to use the more 

recent data from AEO2011 for energy consumption instead of the AEO2010 projections. 

New Jersey also provided updated employment, paved road, pesticide and agricultural 

livestock growth factors. 

2.3.1.10 Version 3 Update to Growth Factors for the District of Columbia 

The District of Columbia provided updated employment growth factors based on DC 

Department of Labor forecasts for the period 2008 to 2018. 
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Exhibit 2-14 State Recommendations to Address Negative Growth 

and Other Growth Factors for the Area Source Sector 

State AEO2010 

Growth Factors

Employment 

Growth Factors

Population 

Growth Factors

CT Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS 

Use county-level 

population projections

DE Use AEO2010 growth rates; no 

growth for suspect AEO2010 

projection for commercial / 

institutional residual oil

For 2013, use state DOL 

employment projections by 3-digit 

NAICS; For 2017 and 2020, use 

no growth (growth factor=1) when 

employment growth is negative; 

otherwise use employment if 

positive growth

Use county-level 

population projections

DC Use AEO2010 growth rates; no 

growth for suspect AEO2010 

projection for commercial / 

institutional residual oil

Use DOL employment growth for 

NAICS 722 for food and kindred 

product SCC; otherwise use 

2008-2018 data

For dry cleaning, use 

employment growth for 

NAICS 812 instead of 

population

MD Not using AEO2010; used 

employment for commercial & 

institutional fuel; used housing 

units for residential fuel

Provided updated employment 

projections; changed cross-walk 

between NAICS code and SCC 

for selected source categories

Provided updated 

population projections 

by county

NJ NJ submitted state specific 

growth factors. For fuel 

combustion categories only, 

used AEO2011 growth rates 

except for residual oil (use no 

growth)

NJ submitted state specific 

growth factors.

NJ submitted state 

specific growth factors 

and provided 

population projections 

by county

NY Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

PA Use AEO2010 growth rates Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections

VA Use AEO2010 growth rates; no 

growth for suspect AEO2010 

projection for commercial / 

institutional residual oil

Use state DOL employment 

projections by 3-digit NAICS

Use county-level 

population projections
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2.3.2 Area Source Control Factors 

Control factors were developed to estimate post-2007 emission reductions resulting from 

on-the-books regulations and other emission reduction measures. Control factors were 

developed for the following national, regional and state measures: 

 Federal Rules Affecting Area Sources 

 Federal MACT Rules 

 OTC 2001 Model Rules 

 OTC 2006 Model Rules 

 MANE-VU Sulfur in Fuel Oil Limitations 

These control programs, including their impact on PM2.5 and PM precursor emissions, are 

discussed in the following subsections. 

2.3.2.1 Federal Rules Affecting Area Sources 

USEPA made available its 2020 emissions projections associated with its 2005-based v4 

modeling platform (USEPA 2010a). USEPA accounted for control strategies for four area 

source categories, only one of which reduced emissions of PM2.5 or PM2.5 precursors. 

USEPA developed projection factors to account for the replacement of retired woodstoves 

that were installed before promulgation of the new source performance standard (NSPS). 

We used USEPA’s latest methodology which uses a combination growth and control factor 

and is based on activity and not pollutant. The growth and control are accounted for in a 

single factor for specific SCCs that account for the turnover from pre-NSPS to post-NSPS 

woodstove. 

2.3.2.2 Federal MACT Rules 

USEPA developed guidance for estimating VOC and NOx emission changes from MACT 

Rules (USEPA 2007b). We reviewed the guidance to identify area source controls 

associated with the federal maximum achievable control technology (MACT) standards for 

controlling hazardous air pollutants (HAPs). Although designed to reduce HAPs, many of 

the MACT standards also provide a reduction in criteria air pollutants. USEPA’s guidance 

document provides an estimate of the percent reduction in VOC and NOx from each 

standard, and the compliance date for the standard. The information concerning MACT 

compliance periods provided was used to determine whether the MACT standard provided 

post-2007 emission reductions. For example, if a compliance period of a MACT standard 

was 2007 or earlier, then we assumed that the emission reductions from the MACT 

standard should be reflected in the baseline year and not as an additional post-2007 credit. 
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Only one area source category was listed in USEPA’s guidance document - municipal 

solid waste landfills. As the compliance date for this standard was January 2004, no post2007 reductions were applied because the emission reductions from the MACT standard 

should be reflected in the 2007 inventory and not as an additional post-2007 credit. 

USEPA has or will soon develop MACT standards for about 70 area source categories. 

We reviewed USEPA’s 2020 emissions projections described in the previous section and 

found that USEPA did not include emission reductions from recent area source MACT 

standards. We conducted a review of USEPA’s air toxic website and found that USEPA 

determined that many area source MACT standards would result in nationwide reductions 

in criteria air pollutants in addition to the reductions in HAP emissions. However, many 

States in the MANE-VU+VA region already have emission standards for many categories 

that are as stringent as the Federal area source MACT standards. For example, many states 

in the MANE-VU+VA region already have requirements as stringent as the Gasoline 

Distribution MACT and GACT (generally achievable control technology) standards, and 

little additional VOC reductions would be realized in the region. Given the resources 

allocated to this project, it was beyond the scope to conduct an analysis of the area source 

MACT requirements and state-by-state emission regulations to determine whether there 

would be emission reductions resulting from the area source MACT standards. 

The only exception to the above discussion of area source MACT standards pertains to the 

recently promulgated rules for reciprocating internal combustion engines (RICE). USEPA 

made available an estimate of the percent reduction in emissions attributable to the RICE 

MACT rule in 2012 and 2014 (USEPA 2010b). These reductions by SCC are shown in 

Exhibit 2-15. The USEPA 2014 estimates were used for the MANE-VU+VA 2017, 2020 

and 2025 inventories. 

2.3.2.3 OTC Model Rules for VOC Sources 

The Ozone Transport Commission (OTC) developed model rules for its member states in 

2002 for several area source VOC categories: consumer products, architectural and 

industrial maintenance (AIM) coatings, portable fuel containers (PFCs), mobile equipment 

repair and refinishing, and solvent cleaning (OTC 2001). In 2006 the OTC introduced 

model rules for two additional area source categories (adhesives/sealants and asphalt 

paving) and more stringent requirements for consumer products and portable fuel 

containers (OTC 2007). These rules resulted in reductions of VOC emissions. Because 

VOC emissions are generally not considered to be significant PM precursors, and these 

rules did not result in reductions in PM2.5 or precursor emissions, no further discussion of 

the OTC model rules for VOC sources is warranted. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 2-15 USEPA Estimated Percent Reductions for RICE MACT Standard 

SCC NOx PM2.5 SCC Description

2101004000 7.57 Electric Utility;Distillate Oil;Total: Boilers and IC Engines

2101004002 11.81 Electric Utility;Distillate Oil;All IC Engine Types

2101006000 7.97 Electric Utility;Natural Gas;Total: Boilers and IC Engines

2101006002 9.87 Electric Utility;Natural Gas;All IC Engine Types

2102004000 7.57 Industrial;Distillate Oil;Total: Boilers and IC Engines

2102006000 7.97 Industrial;Natural Gas;Total: Boilers and IC Engines

2102006002 9.87 Industrial;Natural Gas;All IC Engine Types

2103004000 7.57 Commercial/Institutional;Distillate Oil;Total: Boilers and IC 

Engines

2103006000 7.97 Commercial/Institutional;Natural Gas;Total: Boilers and IC 

Engines

2199004000 7.57 Area Source Fuel Combustion;Distillate Oil;Total: Boilers and IC 

Engines

2199004002 11.81 Area Source Fuel Combustion;Distillate Oil;All IC Engine Types

2199006000 7.97 Area Source Fuel Combustion;Natural Gas;Total: Boilers and IC 

Engines

2310000000 12.53 Oil and Gas Production: All Processes;Total: All Processes

2310000220 12.53 Oil and Gas Exploration/Production; Drill Rigs

2310000440 12.53 Oil and Gas Exploration/Production; Saltwater Disposal Engines

2310001000 12.53 Oil and Gas Production: SIC 13; On-shore;Total: All Processes

2310002000 12.53 Oil and Gas Production: SIC 13; Off-shore;Total: All Processes

2310020000 12.53 Oil and Gas Production: SIC 13;Natural Gas;Total: All Processes

2310020600 12.53 Oil and Gas Exploration and Production;Natural Gas;Compressor 

Engines

2310023000 12.53 Oil and Gas Exploration and Production;Natural Gas;Cbm Gas 

Well - Dewatering Pump Engines

2.3.2.4 OTC Model Rule for ICI Boilers 

The OTC recommended that member states pursue state-specific rulemakings or other 

implementation methods to achieve NOx emission reduction for industrial, commercial, 

and institutional (ICI) boilers based on guidelines that varied by boiler size and fuel type. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in NOx emissions should be applied in 2013, 2017, and 2020. 

All but one state, New Jersey, indicated that they have not adopted rules for area sources 

equivalent to the 2006 OTC recommendations. New Jersey specified that the state has 

post-2007 ICI boiler rules that reduce NOx emissions and provided the estimates of the 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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reductions in NOx emissions by SCC resulting from boiler tune-up requirements, as shown 

in Exhibit 2.16: 

Exhibit 2.16 Area Source Emission Reductions from 

New Jersey ICI Boiler NOx Rules 

SCC SOURCE 

CATEGORY

Percent

Reduction 

from Tuneups 2007-

2013

Rule 

Effectivenes

s

Rule 

Penetratio

n

Overall 

Percent 

Reduction 

2007-2013

2102004000 Industrial: Distillate 25% 80% 30% 6%

2102005000 Industrial: Residual 25% 80% 30% 6%

2102006000 Industrial: Nat Gas 25% 80% 30% 6%

2102007000 Industrial: LPG 25% 80% 30% 6%

2103004000 Comm/Inst: Distillate 25% 80% 30% 6%

2103005000 Comm/Inst: Residual 25% 80% 30% 6%

2103006000 Comm/Inst: Nat Gas 25% 80% 30% 6%

2103007000 Comm/Inst - LPG 25% 80% 30% 6%

2.3.2.5 MANE-VU Fuel Oil Sulfur Strategy 

MANE-VU developed a low sulfur fuel oil strategy to help states develop Regional Haze 

SIPs (MANE_VU 2007). The sulfur in fuel oil recommendations are shown in Exhibit 

2.17 and vary by state, type of fuel oil, and year of implementation. 

Exhibit 2.17 MANE-VU Low Sulfur Fuel Oil Strategy 

Inner Zone States (DE, NJ, NY, PA)

Fuel Oil Type Sulfur Content

2012

Sulfur Content

2016

Distillate 500 ppm 15 ppm

#4 Residual 0.25 % 0.25 %

#6 Residual 0.3 to 0.5 % 0.3 to 0.5 %

Outer Zone States (CT, DC, MD)

Fuel Oil Type Sulfur Content

2014

Sulfur Content

2018

Distillate 500 ppm 15 ppm

#4 Residual n/a 0.25 to 0.5 %

#6 Residual n/a 0.5 %
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Each state was polled and asked to provide guidance as to when, if at all, the MANE-VU 

strategy would be incorporated into their state rules. States were also asked to provide the 

2007 sulfur contents for each fuel type by county in order to calculate the percent reduction 

in emissions for the future years. Three states (MD, NJ, NY) have adopted or are 

committed to adopting the strategy into their rules. Four jurisdictions (CT, DC, DE, PA) 

indicated that not enough regulatory development progress has been made to include the 

reductions in future years with absolute certainty. One state (VA) has no plans to adopt the 

low sulfur fuel oil strategy. The response from each jurisdiction is summarized below: 

 Connecticut will not include the reductions from MANE-VU low sulfur fuel oil 

strategy at this time for official SIP inventories used for the PM2.5 redesignation 

effort. Section 16a-21a of the Connecticut General Statutes (as amended by PA 10-

74) conditions implementation of number two heating oil sulfur limitation (50 ppm 

beginning 7/1/2011 and 15 ppm beginning 7/1/2014) on similar implementation in 

NY, MA and RI. NY has taken action, but the other states have not done so yet. 

CTDEP expects that 15ppm residential heating oil will be in place in CT by the 

"MANE-VU Ask" 2018 target date. However, until the other states act, SIP 

emission inventories will not be approvable with the 15 ppm value. Therefore, at 

this time CT elects to retain the 2007 sulfur value through 2025. For residual oil, 

Section 22a-174-19a of the Regulations of CT State Agencies (RCSA) limits 

sources >=15MW and boilers >=250 mmBtu/hr to 0.5% and further limits any of 

those sources that are also Title IV acid rain sources to 0.3%. For affected sources, 

these limits are consistent with the "MANE-VU Ask", and should be reflected in 

the actual emissions incorporated into the 2007 point source inventory. Other 

sources (including most area sources) not otherwise restricted by permit/order are 

limited to 1.0% by RCSA 22a-174-19. As both of these regulations have not 

changed after 2007, there are no new controls (i.e., post 2007 control factors are 

1.0) for residual oil. 

 The District of Columbia does not have a low sulfur rule in place yet. They do 

have a draft, and anticipate adopting a rule by 2014, but are inclined not to take 

credit for reductions at this point in time. 

 Delaware’s low-sulfur fuel regulation development is running behind schedule and 

will not be promulgated done in time to include in the re-designation 

requests/maintenance plans. Emission reductions from MANE-VU low sulfur fuel 

oil strategy are not included in the 2025 inventory at this time. 

 Maryland expects to revise COMAR 26.11.09.07 (Sulfur Content Limitations for 

Fuel) by 2014 to adopt the limits in the MANE-VU low sulfur fuel oil strategy. 
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 New Jersey has revised N.J.A.C. 7:27-9.2 (Sulfur content standards) to adopt the 

2016 sulfur content limits and schedule shown in Exhibit 2.19. All of the PM 

nonattainment counties in New Jersey already meet the MANE-VU limits for 

residual oil. 

 New York adopted a law that limits the sulfur content of No. 2 heating oil to no 

more than 15 parts per million starting in July 2012, down from the current range 

of 2,000 to 15,000 parts per million. New York expects to revise 6 NYCRR 

Subpart 225-1 (Fuel Composition and Use - Sulfur Limitations) to lower the sulfur 

content of distillate fuel oil for all stationary sources (including home heating) and 

stationary internal combustion engines. Nearly all of the PM nonattainment 

counties in New York already meet the MANE-VU limits for residual oil. For the 

two counties (Orange and Suffolk), compliance with the MANE-VU limits is 

expected by 2017. 

 Pennsylvania low-sulfur fuel regulation development is running behind schedule 

and will not be promulgated done in time to include in the re-designation 

requests/maintenance plans. Emission reductions from MANE-VU low sulfur fuel 

oil strategy are not included in the 2025 inventory at this time. 

 Virginia will not include the emission reductions from low sulfur fuel oil, as it is 

not part of MANE-VU and has no plans to adopt the low sulfur fuel oil strategy. 

The state responses regarding the currently adopted sulfur contents for home heating oil, 

distillate oil, and residual oil are summarized in Exhibits 2.18, 2.19 and 2.20, respectively. 

For the purposes of developing the 2025 inventory that will be used for re-designations and 

maintenance plans, the sulfur contents and control factors shown in the Exhibits were used 

on a county-by-county basis to account for the emission reductions from the MANE-VU 

low sulfur fuel oil strategy. There are separate columns in the detailed area source 

inventory spreadsheet that specify SO2 control factors and emissions for each projection 

year for a “currently adopted” scenario that includes reductions for states (MD, NJ, NY) 

that have or are committed to having rules in place. No emission reductions are applied for 

the other states (CT, DC, DE, PA, VA) in the “currently adopted” scenario. 

For other air quality planning purposes, we accounted separately for emission reductions 

that would occur assuming all states fully adopt the MANE-VU low sulfur fuel limits by 

2025. There are separate columns for SO2 control factors and emissions for a “fully 

adopted” scenario where all states (except Virginia) have the MANE-VU low sulfur fuel 

oil limits in place. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 2.18 Currently Adopted Sulfur Content and Control Factors for Residential Fuel Oil Combustion 

Sulfur Content (ppm) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

CT 09001 Fairfield 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

CT 09009 New Haven 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DE 10003 New Castle 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DC 11001 Washington 1000 1000 1000 1000 1000 1.000 1.000 1.000 1.000

MD 24003 Anne Arundel 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24005 Baltimore 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24013 Carroll 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24017 Charles 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24021 Frederick 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24025 Harford 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24027 Howard 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24031 Montgomery 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24033 Prince Georges 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24043 Washington 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24510 Baltimore City 3000 3000 15 15 15 1.000 0.005 0.005 0.005

NJ 34003 Bergen 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34005 Burlington 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34007 Camden 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34013 Essex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34015 Gloucester 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34017 Hudson 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34021 Mercer 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34023 Middlesex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34025 Monmouth 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34027 Morris 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34031 Passaic 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075
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Sulfur Content (ppm) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

NJ 34035 Somerset 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34039 Union 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NY 36005 Bronx 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36047 Kings 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36059 Nassau 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36061 New York 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36071 Orange 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36081 Queens 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36085 Richmond 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36087 Rockland 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36103 Suffolk 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36119 Westchester 3700 15 15 15 15 0.004 0.004 0.004 0.004

PA 42003 Allegheny 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42005 Armstrong 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42007 Beaver 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42011 Berks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42017 Bucks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42019 Butler 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42021 Cambria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42029 Chester 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42041 Cumberland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42043 Dauphin 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42045 Delaware 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42059 Greene 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42063 Indiana 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42071 Lancaster 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42073 Lawrence 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42075 Lebanon 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000
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Sulfur Content (ppm) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

PA 42077 Lehigh 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42091 Montgomery 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42095 Northampton 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42101 Philadelphia 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42125 Washington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42129 Westmoreland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42133 York 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51013 Arlington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51059 Fairfax 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51107 Loudoun 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51153 Prince William 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51510 Alexandria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51600 Fairfax City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51610 Falls Church 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51683 Manassas City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51685 Manassas Park City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 2.19 Currently Adopted Sulfur Content and Control Factors for Distillate Fuel Oil Combustion 

Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

CT 09001 Fairfield 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

CT 09009 New Haven 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DE 10003 New Castle 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DC 11001 Washington 1000 1000 1000 1000 1000 1.000 1.000 1.000 1.000

MD 24003 Anne Arundel 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24005 Baltimore 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24013 Carroll 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24017 Charles 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24021 Frederick 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24025 Harford 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24027 Howard 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24031 Montgomery 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24033 Prince Georges 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24043 Washington 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24510 Baltimore City 3000 3000 15 15 15 1.000 0.005 0.005 0.005

NJ 34003 Bergen 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34005 Burlington 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34007 Camden 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34013 Essex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34015 Gloucester 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34017 Hudson 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34021 Mercer 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34023 Middlesex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34025 Monmouth 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34027 Morris 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34031 Passaic 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075
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Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

NJ 34035 Somerset 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34039 Union 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NY 36005 Bronx 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36047 Kings 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36059 Nassau 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36061 New York 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36071 Orange 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36081 Queens 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36085 Richmond 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36087 Rockland 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36103 Suffolk 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36119 Westchester 3700 3700 15 15 15 1.000 0.004 0.004 0.004

PA 42003 Allegheny 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42005 Armstrong 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42007 Beaver 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42011 Berks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42017 Bucks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42019 Butler 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42021 Cambria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42029 Chester 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42041 Cumberland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42043 Dauphin 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42045 Delaware 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42059 Greene 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42063 Indiana 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42071 Lancaster 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42073 Lawrence 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42075 Lebanon 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000
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Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

PA 42077 Lehigh 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42091 Montgomery 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42095 Northampton 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42101 Philadelphia 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42125 Washington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42129 Westmoreland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42133 York 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51013 Arlington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51059 Fairfax 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51107 Loudoun 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51153 Prince William 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51510 Alexandria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51600 Fairfax City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51610 Falls Church 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51683 Manassas City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51685 Manassas Park City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 2.20 Currently Adopted Sulfur Content and Control Factors for Residual Fuel Oil Combustion 

Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

CT 09001 Fairfield 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

CT 09009 New Haven 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

DE 10003 New Castle 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

DC 11001 Washington 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

MD 24003 Anne Arundel 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24005 Baltimore 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24013 Carroll 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24017 Charles 2.0 2.0 0.5 0.5 0.5 1.000 0.250 0.250 0.250

MD 24021 Frederick 2.0 2.0 0.5 0.5 0.5 1.000 0.250 0.250 0.250

MD 24025 Harford 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24027 Howard 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24031 Montgomery 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24033 Prince Georges 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24043 Washington 2.0 2.0 0.5 0.5 0.5 1.000 0.250 0.250 0.250

MD 24510 Baltimore City 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

NJ 34003 Bergen 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34005 Burlington 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34007 Camden 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34013 Essex 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34015 Gloucester 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34017 Hudson 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34021 Mercer 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34023 Middlesex 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34025 Monmouth 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34027 Morris 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34031 Passaic 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

NJ 34035 Somerset 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34039 Union 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36005 Bronx 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36047 Kings 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36059 Nassau 0.37 0.37 0.37 0.37 0.37 1.000 1.000 1.000 1.000

NY 36061 New York 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36071 Orange 1.5 1.5 0.5 0.5 0.5 1.000 0.333 0.333 0.333

NY 36081 Queens 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36085 Richmond 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36087 Rockland 0.37 0.37 0.37 0.37 0.37 1.000 1.000 1.000 1.000

NY 36103 Suffolk 1 1 0.5 0.5 0.5 1.000 0.500 0.500 0.500

NY 36119 Westchester 0.37 0.37 0.37 0.37 0.37 1.000 1.000 1.000 1.000

PA 42003 Allegheny 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42005 Armstrong 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42007 Beaver 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42011 Berks 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42017 Bucks 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42019 Butler 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42021 Cambria 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42029 Chester 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42041 Cumberland 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42043 Dauphin 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42045 Delaware 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42059 Greene 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42063 Indiana 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42071 Lancaster 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42073 Lawrence 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42075 Lebanon 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Sulfur Content (% S) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

PA 42077 Lehigh 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42091 Montgomery 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42095 Northampton 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42101 Philadelphia 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42125 Washington 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42129 Westmoreland 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42133 York 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

VA 51013 Arlington 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51059 Fairfax 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51107 Loudoun 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51153 Prince William 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51510 Alexandria 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51600 Fairfax City 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51610 Falls Church 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51683 Manassas City 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51685 Manassas Park City 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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3.0 POINT SOURCES 

3.1 POINT SOURCE CATEGORIES 

States were asked to classify units in the 2007 MANE-VU+VA point source emissions 

inventory as either EGU or nonEGU. Most, but not all, units that report hourly emissions 

to USEPA’s Clean Air Markets Division (CAMD) are classified as EGUs. 

CAMD implements USEPA’s rule found in Volume 40 Part 75 of the Code of Federal 

Regulations (CFR), which requires an hourly accounting of emissions from each affected 

unit - i.e., sources participating in an emissions cap and trade program under the Acid 

Rain Control Program, the NOx Budget Trading Program, or the Clean Air Interstate Rule. 

Most of the CAMD sources are traditional power plants that sell electricity to the electrical 

grid. However, there are other types of sources that report to CAMD that are not 

considered to be EGUs, such as petroleum refineries and cement kilns. 

The following criteria was provided to states to classify a unit as an EGU: 

 An EGU sells most of the power generated to the electrical grid; 

 An EGU burns mostly commercial fuel. Commercial fuel in this case means 

natural gas, oil, and coal. Wood is not considered a commercial fuel because some 

states identify wood as renewable. Therefore, to avoid double counting, units that 

burn wood and other renewable sources (depending on each state's own definition) 

should not be considered as an EGU (unless it is already in the CAMD database). 

The following units were not considered EGUs for emission projections: (1) a unit that 

generates power for a facility but occasionally sells to the grid; (2) emergency generators; 

or (3) distributed generation units. 

The emission projection methodology for units classified as nonEGUs is discussed in 

Section 3.3. The emission projection methodology for EGUs is discussed in Section 3.4. 

3.2 2007 INVENTORY DEVELOPMENT 

The emission projections for the 2025 point source were based on Version 3_3 of the 2007 

MANE-VU+VA inventory and are fully documented in the TSD for that effort 

(MARAMA 2012a). The only adjustment to the 2007 Version 3_3 point source source 

inventory was to apply “transport factors” to fugitive dust sources, as described in the 

following subsection. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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3.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections 

As described previously in Section 2.2.1.1, PM2.5 emissions for point sources were 

adjusted using the USEPA PM transport fractions for fugitive dust sources. Exhibit 3.1 

shows the list of nonEGU SCCs for which the transport factor was applied. The major 

source categories included various operations in the mineral products and construction 

industries. Exhibit 2.2 in the previous Section 2 shows the transport fractions for each PM 

nonattainment county. 

Exhibit 3.1 NonEGU Point Source SCCs Affected by PM Transport Fraction 

SCC SCC Description

30300519 Prim Metal Prod: Primary Copper Smelting: Unpaved Road Traffic: Fug Emiss

30300831 Prim Metal Prod: Iron Production: Unpaved Roads: Light Duty Vehicles

30300832 Prim Metal Prod: Iron Production: Unpaved Roads: Med Duty Vehicles

30300833 Prim Metal Prod: Iron Production: Unpaved Roads: Heavy Duty Vehicles

30300834 Prim Metal Prod: Iron Production: Paved Roads: All Vehicle Types

30302321 Prim Metal Prod: Taconite Iron Ore Processing: Haul Road: Rock

30302322 Prim Metal Prod: Taconite Iron Ore Processing: Haul Road: Taconite

30500290 Industrial Processes;Mineral Products;Asphalt Concrete;Haul Roads: General

30501024 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Hauling

30501030 Industrial Processes;Mineral Products;Coal Mining, Cleaning, and Material 

Handling (See 305310);Tops

30501031 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Scrapers: Travel Mode

30501039 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Hauling: Haul Trucks

30501045 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Bulldozing: Overburden

30501046 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Bulldozing: Coal

30501047 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Grading

30501048 Industrial Processes;Mineral Products;Coal Mining, Cleaning, and Material 

Handling (See 305310);Over

30501049 Industrial Processes;Mineral Products;Coal Mining, Cleaning, and Material 

Handling (See 305310);Wind

30501050 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Vehicle Traffic: 

Light/Medium Vehicles

30501090 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Haul Roads: General

30501640 Mineral Products: Lime Manufacture: Vehicle Traffic

30502011 Mineral Products: Stone Quarrying - Processing: Hauling

30502504 Mineral Products: Construction Sand and Gravel: Hauling

30531090 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Haul Roads: General

31100101 Building Const: Construction: Building Contractors: Site Preparation: Topsoil 

Removal

31100102 Building Const: Construction: Building Contractors: Site Prep: Earth Moving (Cut 

and Fill)
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SCC SCC Description

31100103 Building Const: Construction: Building Contractors: Site Prep: Aggregate Hauling 

(On Dirt)

31100205 Building Const: Demolitions/Special Trade Contracts: On-site Truck Traffic

31100206 Building Const: Demolitions/Special Trade Contracts: On-site Truck Traffic

50100401 Waste Disposal;Solid Waste Disposal - Government;Landfill Dump;Unpaved Road 

Traffic

3.3 2025 NONEGU INVENTORY DEVELOPMENT 

3.3.1 NonEGU Growth Factors 

NonEGU point source growth factors were developed using three sets of data: 

 Annual Energy Outlook fuel consumption forecasts; 

 State-level employment projections by NAICS code; and 

 Other state-specific emission projection data. 

The priority for applying these growth factors was to first use the state-supplied projection 

data (if available). If no state-supplied data are available, then we used AEO projection 

factors for fuel consumption sources and employment data for other source categories. 

The AEO fuel consumption forecasts and employment projections by NAICS code used 

for area sources were also used for nonEGU point sources. See Section 2.3.1 of this report 

for a description of these data sets. 

Section 2 described the growth factors used to develop projected future year emissions 

inventories for both area and non-EGU sources. Draft growth and control factors, and a 

draft technical support document, were circulated for review by MARAMA and state 

agencies. During the review, it was noted that several emissions categories show negative 

growth into the future, particularly categories related to fossil fuel combustion and 

manufacturing employment. The AEO forecasts show declining trends for many fuel 

consumption sectors, especially industrial, residential, and commercial distillate fuel oil 

use. Similarly, the employment projections show declines in the predicted number of 

employees for many sectors of the economy. This is particularly true for the 

manufacturing sector, which is of interest because this sector is often associated with 

higher emissions than those for other sectors. By contrast, the employment projections 

show increasing trends in retail and service-related sectors. 

Predicted declines in fuel use and employment resulted in growth factors less than unity 

(i.e., represent negative growth) for many area and non-EGU point source categories. 

Consequently, for some categories, emissions are lower for the projected future years than 
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for the base year, even before the application of control assumptions (i.e., the future 

"growth only" emissions are lower than the base year emissions). The MARAMA 

emissions inventory workgroup met on several occasions via conference calls and email 

exchanges to discuss whether the negative growth projections were realistic, and what 

additional assumptions should be made. A topic of particular concern is negative growth 

for non-EGU point sources versus the treatment of Emissions Reduction Credits (ERCs) in 

the future year inventories. 

A few states cited the importance of the negative growth issue for non-EGUs and how it 

relates to their ERC programs which are critical to new businesses being able to locate in 

those states. Because businesses could apply for and sell ERCs at the level of the base 

year inventory, it would not be realistic to show negative growth for non-EGU point 

sources. During an economic downturn, a facility could shut down and sell its ERCs, 

making the effective level of future year emissions equal to (i.e., no lower than) the base 

year. Therefore, a recommended conservative approach for addressing negative growth for 

non-EGU point sources is to set a minimum growth rate of 1 (no growth). 

During the conference call held on July 23, 2010 to discuss the negative growth issue, state 

agency representatives were polled as to whether or not they felt that the current set of 

proposed growth factors - including the negative growth factors - were realistic for their 

state or district. In reply, some representatives mentioned that they have observed historic 

state-specific data that supports the trends displayed by the proposed growth factors. Other 

representatives mentioned that they feel comfortable with the growth factors and don't 

have a technical basis to change them or suggest others. Some states will supply their own 

factors or make their own assumptions. 

As a result of these discussions, each state provided guidance on how to handle projections 

when negative growth is indicated. Exhibit 3.2 shows the state recommendations for 

nonEGU point sources. 

Exhibit 3.2 State Recommendations to Address Negative Growth 

for the NonEGU Point Source Sector 

State AEO2010 Growth Factors Employment Growth Factors

CT Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use state DOL employment projections by 3-

digit NAICS 

DE Use AEO2010 growth rates For 2013, use state DOL employment 

projections by 3-digit NAICS; 

For 2017 and 2020, use no growth (growth 

factor=1) when employment growth is 
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State AEO2010 Growth Factors Employment Growth Factors

negative; otherwise use employment if 

positive growth

DC Use AEO2010 growth rates Use state 2008-2018 DOL employment 

projections by 3-digit NAICS; no growth when 

employment is projected to decrease

MD Not using AEO2010 growth factors (except for 

the electric power generation SCCs); 

Use MD DOL employment projections for 

industrial and commercial fuel use SCCs, 

unless employment growth rate is negative, in 

which case use no growth (growth factor=1)

Use updated state DOL employment 

projections by 3-digit NAICS; 

For DoD facilities, account for impacts of Base 

Realignment and Closure;

For source that have closed, account for 

emission reduction credits

NJ New Jersey submitted state specific growth 

factors. Used either state specific growth 

factors, no growth (growth factor=1) when 

state AEO growth is negative or AEO if 

positive growth

NJ submitted state specific growth factors. 

Used either state specific factors, no growth 

(growth factor=1) when state DOL 

employment growth is negative or

employment if positive growth

NY Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth

PA Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth

VA Use no growth (growth factor=1) when AEO 

growth is negative; otherwise use AEO2010 if 

positive growth

Use no growth (growth factor=1) when 

employment growth is negative; otherwise use 

employment if positive growth

3.3.2 Emission Reduction Credits 

Mulitple states (Connecticut, Maryland, and New Jersey) added county level records 

account for account emission reduction credits (ERCs) issued to stationary sources 

pursuant to state regulations. States provided ERCs on a county-by-county basis. 

Fictitious facilities with an identifier of “OFFSET99999” were created for each county 

using SCC 23-99-000-000 (miscellaneous industrial processes: not elsewhere classified). 

Stack data were developed that assumed that emissions were released at the county 

centroid with an assumed release height of 10 feet. For the 2017 and 2020 inventories, 

ERC emissions were set to the amount of banked emissions available in 2007. 

Delaware included the banked credits at the specific locations that they were generated. 

New York and Pennsylvania did not explicitly provide any information on ERCs. 

The District of Columbia and Virginia do not have a formal banking and trading program. 

They used growth rates of 1 for those SCCs in the point source emissions inventory that 

showed a negative growth. In addition, for units that have or are projected to have shut 
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down, they preserved the 2007 emissions in the inventory to account for potential use as 

offsets or credits. 

3.3.3 NonEGU Control Factors 

Control factors were developed for both on-the-books regulations and proposed regulations 

and other actions to estimate emission reductions in future years. Control factors were 

considered for the following national or regional control measures: 

 Federal Rules Affecting NonEGU Point Sources 

 OTC 2001 Model Rules 

 OTC 2006 Model Rules 

 MANE-VU Sulfur in Fuel Oil Strategy 

These control programs are discussed in the following subsections. 

3.3.3.1 Federal Actions Affecting NonEGU Point Sources 

USEPA made available its 2020 emissions projections associated with its 2005-based v4 

modeling platform (USEPA 2010a). These categories, and how they were accounted for in 

the MANE-VU+VA emission projection inventories, are described below: 

 MACT Standards - USEPA developed guidance for estimating VOC and NOx

emission changes from MACT Rules (USEPA 2007b). We reviewed the guidance 

to identify nonEGU source controls associated with MACT standards for 

controlling HAPs. The information concerning MACT compliance periods was 

used to determine whether the MACT standard resulted in post-2007 emission 

reductions. Because major source categories had a compliance period of 2007 or 

earlier, we assumed that the emission reductions from the MACT standard should 

be reflected in the baseline year and not as an additional post- 2007 credit. The 

only exception to the above discussion of area source MACT standards pertains to 

the recently promulgated rules for reciprocating internal combustion engines. 

USEPA made available an estimate of the percent reduction in emissions 

attributable to the RICE MACT rule in 2012 and 2014 (USEPA 2010b). These 

reductions by SCC are shown in Exhibit 3.3. The USEPA 2014 estimates were 

used for the MANE-VU+VA 2017, 2020 and 2025 inventories. 

 Industrial, Commercial, and Institutional Boilers and Process Heaters MACT 

Standard - USEPA’ s 2020 control factor file identified a number of solid fuelburning SCCs for which they estimated an 87% reduction in both PM10 and 

PM2.5. These were used for 2025 also for the affected SCCs. 
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 Petroleum refinery enforcement settlements - For the facilities identified by 

USEPA located in New Jersey and Pennsylvania we applied post-2007 estimated 

reductions for NOx, PM10, PM2.5, and SO2 to affected units. 

Exhibit 3.3 USEPA Estimated Percent Reductions for RICE MACT Standard 

SCC NOx PM2.5 SCC Description

20100102 15.14 Electric Generation;Distillate Oil (Diesel);Reciprocating

20100105 15.14 Electric Generation;Distillate Oil (Diesel);Reciprocating: 

Crankcase Blowby

20100107 15.14 Electric Generation;Distillate Oil (Diesel);Reciprocating: 

Exhaust

20100202 12.53 Electric Generation;Natural Gas;Reciprocating

20100207 12.53 Electric Generation;Natural Gas;Reciprocating: Exhaust

20200102 15.14 Industrial;Distillate Oil (Diesel);Reciprocating

20200104 15.14 Industrial;Distillate Oil (Diesel);Reciprocating: Cogeneration

20200107 15.14 Industrial;Distillate Oil (Diesel);Reciprocating: Exhaust

20200202 12.53 Industrial;Natural Gas;Reciprocating

20200204 12.53 Industrial;Natural Gas;Reciprocating: Cogeneration

20200207 12.53 Industrial;Natural Gas;Reciprocating: Exhaust

20200253 37.96 Industrial;Natural Gas;4-cycle Rich Burn

20200301 37.96 Industrial;Gasoline;Reciprocating

20200307 37.96 Industrial;Gasoline;Reciprocating: Exhaust

20201001 12.53 Industrial;Liquified Petroleum Gas (LPG);Propane

20201002 12.53 Industrial;Liquified Petroleum Gas (LPG);Butane

20201702 37.96 Industrial;Gasoline;Reciprocating Engine

20201707 37.96 Industrial;Gasoline;Reciprocating: Exhaust

20300101 15.14 Commercial/Institutional;Distillate Oil (Diesel);Reciprocating

20300105 15.14 Commercial/Institutional;Distillate Oil 

(Diesel);Reciprocating: Crankcase Blowby

20300106 15.14 Commercial/Institutional;Distillate Oil 

(Diesel);Reciprocating: Evaporative Losses 

20300107 15.14 Commercial/Institutional;Distillate Oil 

(Diesel);Reciprocating: Exhaust

20300201 12.53 Commercial/Institutional;Natural Gas;Reciprocating

20300204 12.53 Commercial/Institutional;Natural Gas;Cogeneration

20300207 12.53 Commercial/Institutional;Natural Gas;Reciprocating: 

Exhaust

20300301 37.96 Commercial/Institutional;Gasoline;Reciprocating

20300307 37.96 Commercial/Institutional;Gasoline;Reciprocating: Exhaust

20301001 12.53 Commercial/Institutional;Liquified Petroleum Gas 

(LPG);Propane

20301002 12.53 Commercial/Institutional;Liquified Petroleum Gas 

(LPG);Butane

20400401 37.96 Engine Testing;Reciprocating Engine;Gasoline
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SCC NOx PM2.5 SCC Description

20400402 15.14 Engine Testing;Reciprocating Engine;Diesel/Kerosene

20400403 15.14 Engine Testing;Reciprocating Engine;Distillate Oil: CI: CI: 

VOC 2005cr = 0

31000203 12.53 Oil and Gas Production;Natural Gas 

Production;Compressors

50100421 12.53 Solid Waste Disposal;Landfill Dump;Waste Gas Recovery: 

Internal Combustion Device

3.3.3.2 OTC 2001 Model Rules for NonEGUs 

The OTC developed NOx control measures for industrial, commercial, and institutional 

(ICI) boilers and distributed generation units in 2001 (OTC 2001). We reviewed the 

OTC’s status reports to identify states status in adopting the OTC 2001 model rules (OTC 

2009a). Most states have adopted the OTC model rules with compliance dates in 2007 or 

earlier. As a result, we assumed that the emission reductions from the 2001 OTC model 

rules for nonEGUs are already reflected in the 2007 inventory and no post- 2007 

reductions were applied. 

3.3.3.3 OTC 2006 Model Rules for NonEGUs 

In 2006, the OTC introduced model rules (OTC 2007) for one nonEGU VOC source 

category (adhesives/sealants) and new/more stringent requirements for several NOx source 

categories (asphalt production plants, cement kilns, glass/fiberglass furnaces, and 

industrial, commercial, and institutional {ICI} boilers). We reviewed the OTC’s status 

reports to identify where state status in adopting the OTC 2006 model rules (OTC 2009b). 

To obtain further clarification of each state’s status, states were polled to determine 

whether they have adopted a rule that would achieve reductions equivalent to the OTC 

model rule, whether credit for each rule was already accounted for in the 2007 inventory, 

and whether the estimated reduction in emissions should be applied in 2013, 2017, 2020 

and 2025. The following paragraphs describe the control factors applied for each rule by 

state and future year. 

3.3.3.3.1 OTC 2006 Model Rule for Asphalt Production Plants 

The OTC recommended that member states pursue state-specific rulemakings or other 

implementation methods that would achieve a 35 percent reduction in NOx emissions. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC model rule and whether the estimated reduction in 

NOx emissions should be applied in 2013, 2017, 2020 and 2025. Only New Jersey 

indicated that the reductions should be applied. New York did not provide guidance, and it 
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was assumed that the NOx reductions should be applied in New York for three future 

years. All other states indicated that the NOx reductions should not be applied in the future 

years. For those states that indicated they wanted to include the reductions, a 35 percent 

reduction in NOx emissions was applied for SCC 3-05-002-xx. 

3.3.3.3.2 OTC 2006 Model Rule for Cement Manufacturing Plants 

Cement kilns are located in Maryland, New York, and Pennsylvania. Virginia has one 

cement kiln, which is not located in a PM nonattainment county. The OTC recommended 

state-specific rulemakings or other implementation methods that would result in about a 60 

percent reduction in uncontrolled levels NOx emissions. This emission reduction for 

cement kilns was calculated using the methodology previously developed and documented 

in the OTC report (OTC 2007). Cement kilns are already subject to NOx controls as part 

of Phase I of the NOx SIP call. Emission reductions resulting from the NOx SIP call are 

already accounted for in the 2007 inventory. 

The following methods were used to calculate the additional reductions from the OTC 

2006 Control Measure in each state: 

 Maryland indicated controls will become effective in 2011 for the two facilities in 

the state. Maryland specified a 25 percent reduction for the Holcim facility and a 

40 percent reduction for the Lehigh facility. No reductions were specified for the 

two kilns at the Essroc facility. 

 New York did not provide guidance regarding cement kilns. We used the percent 

reductions previously developed and documented in the previous round of emission 

projections developed for MARAMA (MARAMA 2007). An incremental control 

efficiency of 40 percent was used for New York cement kilns in that inventory. 

 Pennsylvania provided kiln-specific projected future year NOx emissions for 2013, 

2017, and 2020. The 2020 controlled emissions were also used for 2025. A kilnspecific control factor was calculated based on the ratio of the future year emissions 

to the 2007 emissions. 

3.3.3.3.3 OTC 2006 Model Rule for Glass and Fiberglass Furnaces 

The OTC recommended state-specific rulemakings or other implementation methods to 

achieve an approximately 85 percent reduction in NOx emissions from uncontrolled levels. 

Emission reductions for glass and fiberglass furnaces were calculated using the 

methodology previously developed and documented in the OTC report (OTC 2007). Glass 

and fiberglass furnaces are located in Maryland, New Jersey, New York, and Pennsylvania. 

There are no other States with facilities in a PM nonattainment county. 
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The following methods were used to calculate the additional reductions from the OTC 

2006 Control Measure in each state: 

 Maryland indicated that a 48 percent reduction should be applied to the single glass 

manufacturing facility in Maryland. 

 New Jersey indicated that a 50 percent reduction in NOx emissions should be 

applied to glass and fiberglass furnaces in 2013, 2017, 2020 and 2025.

 New York did not provide guidance regarding glass or fiberglass furnaces. We 

used the percent reductions developed and documented in the previous round of 

emission projections developed for MARAMA (MARAMA 2007). An 

incremental control efficiency of 70 percent was used for New York glass and 

fiberglass furnaces in that inventory. 

 Pennsylvania provided furnace-specific projected future year NOx emissions for 

2017 and 2020 for all facilities, including those in Allegheny County. The 2020 

controlled emissions were also used for 2025. A furnace-specific control factor 

was calculated based on the ratio of the future year emissions to the 2007 

emissions. 

 For the three glass manufacturing facilities in Allegheny County, we used the 

percent reductions previously developed and documented in the previous round of 

emission projections developed for MARAMA (MARAMA 2007). An 

incremental control efficiency of 86 percent was used for Allegheny County glass 

and fiberglass furnaces in that inventory. 

3.3.3.3.4 OTC 2006 Model Rule for ICI Boilers 

The OTC recommended that member states pursue state-specific rulemakings or other 

implementation methods to achieve NOx emission reduction for industrial, commercial, 

and institutional (ICI) boilers based on guidelines that varied by boiler size and fuel type. 

States were polled to determine whether they have adopted a rule that would achieve 

reductions equivalent to the 2006 OTC recommendations and whether the estimated 

reduction in NOx emissions should be applied in 2013, 2017, 2020, and 2025. 

Most states have not adopted rules equivalent to the 2006 OTC recommendations. These 

states indicated that they will likely depend on a USEPA national rule for possible 

inclusion in the BOTW inventory. Specifically, the OTC Resolution 10-01 (June, 2010) 

called on USEPA for national regulations for ICI boilers. 

New Jersey provided NOx percent reductions that varied by heat input rate and fuel/boiler 

type and included an 80 percent rule effectiveness adjustment, as shown in Exhibit 3.4. 
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Exhibit 3.4 NonEGU Point Source Emission Reductions from 

New Jersey ICI Boiler NOx Rules 

Heat Input Rate

(mmBtu/hr) Fuel/Boiler Type

Overall % 

Reduction 

2007-2025

at least 5 but < 10 All 20%

at least 10 but < 20 All 20%

at least 25 but < 50 Natural gas only 40%

No. 2 Fuel oil only 40%

Refinery fuel gas and 

other gaseous fuels 40%

Other liquid fuels 40%

Duel Fuel using fuel oil 

and/or natural gas 40%

at least 50 but < 100 Natural gas only 40%

No. 2 Fuel oil only 27%

Other liquid fuels 27%

Duel Fuel using fuel oil 

and/or natural gas 40%

at least 100 or greater No. 2 Fuel oil only 40%

The NIF file submitted by New Jersey for this project did not include the boiler design 

capacity. This data gap was filled using the boiler design capacities previously developed 

for the OTC study in 2006, if available; otherwise the SCC description was used to assign 

a default boiler design capacity. 

New York specified that a 50 percent reduction should be applied in the existing controls 

inventory for all boilers with greater than 25 mmBtu/hour design capacity. The NIF file 

submitted by New York for this project did not include the boiler design capacity. This 

data gap was filled using the boiler design capacities previously developed for the OTC 

study in 2006, if available; otherwise the SCC description was used to assign a default 

boiler design capacity. 

3.3.3.4 MANE-VU Fuel Oil Sulfur Strategy 

MANE-VU developed a low sulfur fuel oil strategy to help states develop Regional Haze 

SIPs (MANE-VU 2007). The sulfur in fuel oil recommendations were previously shown 

in Section 2.3.2.5 and vary by state, fuel oil type, and implementation year. 

3.3.3.5 State-specific NonEGU Control Factors 

The following state-specific nonEGU control factors were provided: 
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 Bellefield Boiler Plant, Allegheny County. Allegheny County indicated that this 

facility changed their fuel source from coal to natural gas in July 2009 and future 

year emissions were changed to reflect the fuel switch. 

 USS Clairton Works, Allegheny County. The facility will remove Batteries 7-9 

and have Battery C operational by 2013, resulting in a change in PM emissions in 

2013. Also, USS Clairton Works will remove Batteries 1-3 and have Battery D 

operational in 2015, resulting in a change in PM emissions in 2017, 2020 and 2025. 

 Chrysler, Delaware. The Chrysler facility (ID 1000300128) shut down in 2009. 

Delaware specified that only a 25 percent reduction should be taken for all 

pollutants as some emissions will be banked for future use by other sources. 

 OSG Ship Management (ID 1000500093), Delaware. Delaware provided sourcespecific growth factors and percent reductions in VOC emissions for 2013, 2017, 

and 2020 from the lightering operations at OSG Ship Management (ID 

1000500093). The 2025 emissions were expected to be the same as the 2020 

emissions. 

 Control Technology Guidance (CTG) Documents, Delaware. Delaware 

determined that VOC emission reductions from new CTG recommendations would 

be very small. Although the new CTGs set up new recommendations for higher 

control efficiencies, the actual VOC reductions would be minimum, if not none, 

because most DE’s existing facilities are not affected by the new requirements and 

emissions from those facilities are relatively small (based on 2002 inventory). 

 Unit Shutdowns, Delaware. Delaware identified several emission units that have 

shut down at the following facilities: Dow Reichhold Specialty latex (ID 

1000100016), SPI Poly-Ols (ID 1000300426), and Invistas (ID 1000500002). 

Emissions for all pollutants were set to zero for these units. 

 Premcor Refinery NOx Plantwide Cap, Delaware. The refinery was sold to the 

Delaware City Refining Company and an agreement was reached with DNREC's 

Secretary that allows plant-wide applicability limit (cap) for NOx. Delaware 

decided to devide the NOx -cap to each stack equally. Delaware estimated a 

plantwide reduction of 10.05 percent in 2013 and 41.22 percent in 2017, 2020 and 

2025. 

 PEPCO Benning Road, District of Columbia. This facility is scheduled for 

deactivation in 2012. All emissions were set to zero in the projection inventories. 
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 2009 New Jersey Rule for NOx for Municipal Solid Waste Incinerators. This 

rule will achieve a 27 percent reduction from one facility - Camden County Energy 

Recovery Associates, L.P. (ID 3400751614). 

 New Jersey Rule for VOC Storage Tanks. New Jersey provided expected VOC 

emission reductions resulting from post-2007 rules for VOC storage tanks. For 

refinery floating roof storage tanks (SCC 4-03-011-xx), the reductions are 75 

percent for 2013, 82 percent for 2017, and 85 percent for 2020. For bulk terminal 

tanks (SCC 4-04-001-xx), the reductions are 20 percent for 2013, 40 percent for 

2017, and 50 percent for 2020. For pipeline breakout stations (SCCs 4-04-002-xx 

and 4-06-005-xx), the reductions are 26 percent for 2013, 52 percent for 2017, and 

65 percent for 2020 and 2025. 

3.4 2025 EGU INVENTORY DEVELOPMENT 

An emission projection methodology for EGUs is being developed as part of an inter-RPO 

coordination effort under the direction of ERTAC. The computer code to implement the 

ERTAC methodology will not be available in time for use in state’s re-designation requests 

or maintenance plans. An interim approach for projecting EGU emissions is discussed in 

the following paragraph. 

Annual 2007 EGU point emissions were grown to 2025 based on electricity generation 

projections that are delineated by region and fuel. Growth factors are based on AEO2011 

Table 96 - Electricity Generation by Electricity Market Module Region and Fuel Source 

(see Appendix F). The 2007 emissions were extracted for those units flagged as EGUs in 

the MANE-VU+VA 2007 inventory. The appropriate AEO2011 growth factor was 

applied to the 2007 emissions to calculate a “growth only” emission value for 2025. The 

following key assumptions were made: 

 Growth beyond unit capacity or permit limits was not considered (e.g., fuel 

consumption was allowed to grow beyond a unit’s physical capacity or permit 

limit); 

 Generation from specific new units that are anticipated to operate in 2025 but did 

not in 2007 is not explicitly accounted for, but instead is assumed to be accounted 

for in the AEO2011 growth forecasts; 

 Similarly, generation from specific units that have or are anticipated to shut down 

after 2007 is not explicitly accounted for, but instead are assumed to be accounted 

for in the AEO2011 growth forecasts. 
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 States indicated where post-2007 controls or shut downs were to be applied on a 

unit by unit basis. The control factors were applied to the grown emissions to 

calculate a “growth and control” emission value for 2025. 

Details on the growth and control factors are provided in the following sections. 

3.4.1 EGU Growth Factors 

Table 96 of the AEO2011 provides electricity generation projections by electricity market 

module region and fuel source for the years 2007 to 2035 (EIA 2011b). AEO2011 

disaggregates generation to 22 sub-regions for electricity planning and dispatch This is a 

new approach started in AEO2011. Disaggregation of the Electricity Market Module 

(EMM) is intended to reduce errors that result from aggregation and averaging, to better 

represent environmental and regional issues, and thus to improve the projections of 

capacity additions and fuels consumed for generation. Exhibit 4.1 identifies the 22 subregions. 

Exhibit 3.5 Electricity Market Module Regions 
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The EIA provided a file that assigns each EGU to an EMM region. Units in the PM 

nonattainment counties included in this analysis reside in one of the following seven EMM 

regions: 

 Northeast Power Coordinating Council / Northeast (NEWE) 

 Northeast Power Coordinating Council / NYC Westchester (NYCW) 

 Northeast Power Coordinating Council / Long Island (NYLI) 

 Northeast Power Coordinating Council / Upstate New York (NYUP) 

 Reliability First Corporation / East (RFCE) 

 Reliability First Corporation / West (RFCW) 

 SERC Reliability Corporation / Virginia Carolina (SRVC) 

Exhibit 3.6 shows the growth factors for electricity generation for coal. The AEO2011 

shows zero generation from coal in the NYC Westchester and Long Island regions. 

Generation from coal is projected to decline significantly in the Northeast and Upstate 

New York regions. Generation from coal is expected to decline slightly in the RFC East, 

RFC West, and SERC Virginia-Carolina regions. 

Exhibit 3.7 shows the growth factors for electricity generation for petroleum. The 

AEO2011 shows that the growth factors vary widely by EMM region. A positive growth 

rate (e.g., growth factor > 1) from 2007 to 2025 is projected for the RFC East and SERC 

Virginia-Carolina regions. In all other EMM regions in the study area, generation from 

petroleum is projected to decline (e.g., growth factor < 1). 

Exhibit 3.8 shows the growth factors for electricity generation for natural gas. The 

AEO2011 shows that the growth factors vary widely by EMM region. A negative growth 

rate (e.g., growth factor < 1) from 2007 to 2025 is projected for the NYC Westchester and 

SERC Virginia-Carolina regions. In all other EMM regions in the study area, generation 

from natural gas is projected to increase (e.g., growth factor > 1). 

Exhibit 3.9 shows the growth factors for electricity generation for renewables. The 

AEO2011 shows that the growth factors vary widely by EMM region. A large increase in 

generation from renewables from 2007 to 2025 is projected for the RFC East, RFC West 

and SERC Virginia-Carolina regions. A more modest increase in renewable is projected 

for the Northeast and Upstate New York regions. A slight decline is projected for the 

NYC Westchester and Long Island regions. 
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Exhibit 3.6 Electricity Generation Growth Factors for Coal 

Exhibit 3.7 Electricity Generation Growth Factors for Petroleum 
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Exhibit 3.8 Electricity Generation Growth Factors for Natural Gas 

Exhibit 3.9 Electricity Generation Growth Factors for Renewables 
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After reviewing the AEO growth factors, New York had doubts about the AEO 

projections. To be conservative, New York specified that a growth factor of 1.0 should be 

used for any unit where AEO growth was projected to be negative. 

3.4.2 EGU Control Factors 

States provided information on post-2007 controls or shut downs to be applied on a unit by 

unit basis for the 2025 inventory. This control information was provided in a format that is 

being used by the ERTAC EGU Projection Methodology (Appendix G UAF NEEDS 

Control FileMASTER92211.xls). 

In addition to the ERTAC control file, the following comments were received: 

 Delaware – The Edge Moor facility (ORIS=593) plans to switch from coal to 

natural gas/# 6 oil. However, the Title V permit is not yet approved. Delaware 

made the decision to assume the facility still is burning coal in 2025 for the 

purposes of this PM re-designation inventory. Delaware may change the EGU 

estimates at a future date when the SIP submittal is written. 

 District of Columbia – The PEPCO Benning Road facility (ORIS=603) is 

scheduled to shut down permanently in 2012 and all future year emissions have 

been set to zero. 

 Maryland – The Healthy Air Act sets unit-specific emission caps (tons/year) for 

SO2 and NOx. Maryland provided unit specific control factors to ensure that the 

future year emissions were equal to the Healthy Air Act emission caps. Affected 

facilities include CP Crane, Herbert A Wagner, R. Paul Smith, Chalk Point, 

Dickerson, Morgantown, and Brandon Shores. 

 New Jersey – Control factors for SO2 and NOx for each unit were calculated based 

on the ratio of the future controlled emission rate (lbs/mmBtu) to the 2007 actual 

emission rate (lbs/mmBtu). Large reductions in SO2 emissions are expected from 

the installation of control equipment at the Hudson and Mercer generating stations. 

NOx controls were also installed at the Hudson generating station in 2010. 

 Pennsylvania – RRI’s Portland Generating Station is under a USEPA Order to 

reduce SO2 emissions. SO2emissions beyond 013 were reduced by 95 percent to 

address the ordered emission reductions. SO2 controls were installed at RRI 

Keystone, PPL Brunner Island, and Allegheny Energy Hatfields Ferry in 2010. 

SO2 controls at the Cheswick Station were installed in 2011. Units 1 and 2 at PPL 

Martins Creek, Units 1 and 2 at Exelon Cromby, and Units 1 and 2 at Exelon 
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Eddystone are or will be permanently shut down by 2013 and the emissions for all 

pollutants were set to zero for 2017/2020/2025. The future operation of Unit 1 at 

Exelon Schuylkill are projected to be about 250 hours, compared to 1,037 hours in 

2007. Future emissions for this unit were reduced by 75 percent to reflect this 

lowered operating capacity. 

 Virginia – Dry scrubbers at the Potomac River Generating Station were installed in 

2008. In 2008, the facility received a federally enforceable facility-wide permit 

that placed limits on the facility’s annual potential to emit of both NOX and SO2. 

3.4.3 Consideration of CSAPR Emission Allowances 

On July 6, 2011, the USEPS finalized the Cross-State Air Pollution Rule (CSAPR) that 

requires 27 states to reduce power plant emissions that contribute to ozone and/or fine 

particle pollution in other states. This final rule replaces the 2005 Clean Air Interstate 

Rule (CAIR). Under the final rule, USEPA distributes a annual SO2 and NOx emission 

allowances to covered units in each state, the sum of which equals the annual SO2 and 

NOx budgets for those states (allowing for a two percent set-aside for new units). 

USEPA provided allocations for each affected unit. States initially considered whether 

these unit-level allocations for SO2 and NOx provided a more realistic estimate of future 

year emissions than the growth and control methodology described in Sections 4.3.1 and 

4.3.2 of this report. However, the United States Court of Appeals for the District of 

Columbia issued an order staying CSAPR on December 31, 2011, pending the resolution 

of an appeal of the rule. Because of the uncertainty regarding implementation of CSAPR, 

states decided to use the growth and control methodology described in Sections 4.3.1 and 

4.3.2 rather than the proposed CSAPR caps for SO2 and NOx. 
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4.0 NONROAD MOBILE SOURCES INCLUDED IN NMIM 

4.1 NONROAD MODEL CATEGORIES 

USEPA’s NONROAD model estimates emissions from equipment such as recreational 

marine vessels, recreational land-based vehicles, farm and construction machinery, lawn 

and garden equipment, aircraft ground support equipment (GSE) and rail maintenance 

equipment. This equipment is powered by diesel, gasoline, compressed natural gas (CNG) 

or liquefied petroleum gas (LPG) engines. 

NMIM was developed by USEPA to develop county-level emission estimates for certain 

types of nonroad equipment. NMIM uses the current version the NONROAD model to 

develop emission estimates and was used to develop the projection inventories discussed 

here. The NMIM national county database contains monthly input data to reflect county 

specific fuel parameters and temperatures. Most of the work associated with executing 

NMIM involved updating the NMIM county database with state-specific information. 

4.2 2007 INVENTORY DEVELOPMENT 

MARAMA used the NMIM model to develop county level emission estimates by SCC for 

2007 (see {MARAMA 2011a} for complete documentation). For this analysis, the 

NMIM2008 software (version NMIM20090504), the NMIM County Database (version 

NCD20090531), and NONROAD2008a (July 2009 version) were used as starting points 

(USEPA 2009a). Changes were made to the NCD20090531 based on state review and 

comment. 

A summary of the major adjustments to the default NMIM County Database for the 2007 

NMIM model runs includes: 

 State review and adjustments to fuel characteristics (Reid Vapor Pressure, sulfur 

and oxygenate fractions) to better represent county-specific fuel characteristics in 

2007; and 

 States identified discrepancies in the housing and population data contained in the 

NONROAD model and these data were updated using 2007 housing information 

and updated 2007 population estimates. 

 The recreational marine vessel populations were revised using population data 

provided by the National Marine Manufacturers Association (NMMA). Total state 

populations for each of the three major categories contained in the NONROAD 

model (outboard, inboard/sterndrive and personal watercraft) were provided. 
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Because the population files used by the NONROAD model (and thus NMIM) 

were configured with population values for various horsepower categories, AMEC 

determined the fraction of the total for each marine vessel type in each horsepower 

category from the NONROAD default population files. These fractions were then 

used to allocate the total state population obtained from NMMA to the various 

horsepower categories. For Version 2 of this report the pleasure craft emissions 

were adjusted for CT for both 2007 and 2025. All state other than CT emissions 

continue to use the the NMIM default pleasure craft populations that were 

calculated for Version 2 of the MARAMA modeling inventory. This choice was 

made by states because they had already rerun NMIM themselves for their states 

using the NMMA populations and had no need for that work to be repeated as part 

of this work. Exhibit 4.1 shows the source of data for each state. 

Exhibit 4.1 State by state data source for NMIM 

2007 NMIM 2025 NMIM

NY

Run by NY and 

provided to 

MARAMA for 

inclusion in this 

report Not Included

MA MARAMA V2 MARAMA V2

ME MARAMA V2 MARAMA V2

VT MARAMA V2 MARAMA V2

NH MARAMA V2 MARAMA V2

RI MARAMA V2 MARAMA V2

CT MARAMA V3 * MARAMA V3 *

NJ MARAMA V2 MARAMA V2

PA MARAMA V2 MARAMA V2

DE MARAMA V2 MARAMA V2

VA MARAMA V3** MARAMA V3**

MD MARAMA V2 MARAMA V2

DC MARAMA V2 MARAMA V2

* Includes the revised Pleasure Craft Population

** Updated fuels from Version 2 but does not include 

revised Pleasure Craft Population
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4.3 2025 INVENTORY DEVELOPMENT 

MARAMA reran the NMIM model for 2025 for VA and CT. One state, New York, did 

their own NONROAD modeling and provided 2025 NMIM results for the affected 

counties. All other NMIM runs reflect those completed by Bill Barnard (AMEC) for the 

initial version of this report. Exhibit 4.1 shows the source of data for each state. 

4.4 REMOVAL OF AIRPORT GROUND SUPPORT EQUIPMENT 

The NMIM/NONROAD model includes emissions from airport ground support 

equipment. Emissions from airport ground support equipment is also included in 

USEPA’s aircraft inventory that was prepared using the Federal Aviation Administration’s 

Emissions and Dispersion Modeling System (EDMS). Correspondence with USEPA 

indicated that USEPA considers the emissions calculated by EDMS to be better than those 

calculated by NONROAD. For this reason, all emissions calculated by NMIM/ 

NONROAD for airport ground support equipment were removed from both the 2007 and 

2025 inventories to avoid double counting emissions. 

4.5 NMIM/NONROAD GROWTH AND CONTROL INFORMATION 

In estimating future year emissions, the NMIM/NONROAD model includes growth and 

scrappage rates for equipment in addition to a variety of control programs. It is not 

possible to separate out the future year emissions due to “growth only” or “control only” in 

a single run. That is, the model run provides a single future year estimate that is a “growth 

and control” scenario. 

The growth data used in the NMIM/NONROAD model is documented in a USEPA report 

(USEPA 2004c). The GROWTH packet of the NONROAD model cross-references each 

SCC to a growth indicator code. The indicator is an arbitrary code that identifies an actual 

predicted value such as human population or employment that is used to estimate the 

future year equipment population. The GROWTH packet also defines the scrappage 

curves used to estimate the future year model year distribution. 

The NMIM/NONROAD model also accounts for all USEPA emission standards for 

nonroad equipment. There are multiple standards that vary by equipment type, rated 

power, model year, and pollutant. Exhibit 4.2 is a summary of the emission control 

programs accounted for in the NMIM/NONROAD model. A complete summary of the 

nonroad equipment emission standards can be found on USEPA’s nonroad emission 

standards reference guide website (USEPA 2011). 
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Exhibit 4.2 Control Programs Included in the NMIM/NONROAD Model 

Regulation Description

Control of Air Pollution; 

Determination of Significance for 

Nonroad Sources and Emission 

Standards for New Nonroad 

Compression Ignition Engines At or 

Above 37 Kilowatts

59 FR 31036

June 17, 1994

This rule establishes Tier 1 exhaust emission standards for 

HC, NOx, CO, and PM for nonroad compression-ignition 

(CI) engines ≥37kW (≥50hp). Marine engines are not 

included in this rule. The start dates and pollutants 

affected vary by hp category as follows:

50-100 hp: Tier 1,1998; NOx only

100-175 hp: Tier 1, 1997; NOx only

175-750 hp: Tier 1, 1996; HC, CO, NOx, PM

>750 hp: Tier 1, 2000; HC, CO, NOx, PM

Emissions for New Nonroad SparkIgnition Engines At or Below 19 

Kilowatts; Final Rule

60 FR 34581

July 3, 1995

This rule establishes Phase 1 exhaust emission standards 

for HC, N NOx Ox, and CO for nonroad spark-ignition 

engines ≤19kW (≤25hp). This rule includes both handheld 

(HH) and non-hand-held (NHH) engines. The Phase 1 

standards become effective in 1997 for :

 Class I NHH engines (<225cc), 

 Class II NHH engines (≥225cc), 

 Class III HH engines (<20cc), and 

 Class IV HH engines (≥20cc and <50cc). 

The Phase 1 standards become effective in 1998 for:

 Class V HH engines (≥50cc) 

Final Rule for New Gasoline SparkIgnition Marine Engines; Exemptions 

for New Nonroad CompressionIgnition Engines at or Above 37 

Kilowatts and New Nonroad SparkIgnition Engines at or Below 19 

Kilowatts

61 FR 52088

October 4, 1996

This rule establishes exhaust emission standards for HC+

NOx for personal watercraft and outboard (PWC/OB) 

marine SI engines. The standards are phased in from 

1998-2006.

Control of Emissions of Air Pollution 

From Nonroad Diesel Engines

63 FR 56967

October 23, 1998

This final rule sets Tier 1 standards for engines under 50 

hp, phasing in from 1999 to 2000. It also phases in more 

stringent Tier 2 standards for all engine sizes from 2001 to 

2006, and yet more stringent Tier 3 standards for engines 

rated over 50 hp from 2006 to 2008. The Tier 2 standards 

apply to NMHC+ NOx, CO, and PM, whereas the Tier 3 

standards apply to NMHC+ NOx and CO. The start dates 

by hp category and tier are as follows:

 hp<25: Tier 1,2000; Tier 2, 2005; no Tier 3

 25-50 hp: Tier 1, 1999; Tier 2, 2004; no Tier 3

 50-100 hp: Tier 2, 2004; Tier 3, 2008

 100-175 hp: Tier 2, 2003; Tier 3, 2007

 175-300 hp: Tier 2, 2003; Tier 3, 2006

 300-600 hp: Tier 2, 2001, Tier 3, 2006

 600-750 hp: Tier 2, 2002; Tier 3, 2006

 >750 hp: Tier 2, 2006, no Tier 3

This rule does not apply to marine diesel engines above 50 

hp.
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Regulation Description

Phase 2: Emission Standards for 

New Nonroad Nonhandheld Spark 

Ignition Engines At or Below 19 

Kilowatts

64 FR 15207

March 30, 1999

This rule establishes Phase 2 exhaust emission standards 

for HC+ NOx for nonroad nonhandheld (NHH) sparkignition engines ≤19kW (≤25hp). The Phase 2 standards 

for Class I NHH engines (<225cc) become effective on 

August 1, 2007 (or August 1, 2003 for any engine initially 

produced on or after that date). The Phase 2 standards for 

Class II NHH engines (≥225cc) are phased in from 2001-

2005.

Phase 2: Emission Standards for 

New Nonroad Spark-Ignition 

Handheld Engines At or Below 19 

Kilowatts and Minor Amendments to 

Emission Requirements Applicable 

to Small Spark-Ignition Engines and 

Marine Spark-Ignition Engines; Final 

Rule

65 FR 24268

April 25, 2000

This rule establishes Phase 2 exhaust emission standards 

for HC+ NOx for nonroad handheld (HH) spark-ignition 

engines ≤19kW (≤25hp). The Phase 2 standards are 

phased in from 2002-2005 for Class III and Class IV 

engines and are phased in from 2004-2007 for Class V 

engines.

Control of Emissions From Nonroad 

Large Spark-Ignition Engines and 

Recreational Engines (Marine and 

Land-Based); Final Rule

67 FR 68241

November 8, 2002

This rule establishes exhaust and evaporative standards 

for several nonroad categories: 

1) Two tiers of emission standards are established for large 

spark-ignition engines over 19 kW. Tier 1 includes exhaust 

standards for HC+ NOx and CO and is phased in from 

2004-2006. Tier 2 becomes effective in 2007 and includes 

exhaust standards for HC+ NOx and CO, as along with

evaporative controls affecting fuel line permeation, diurnal 

emissions and running loss emissions.

2) Exhaust and evaporative emission standards are 

established for recreational vehicles, which include 

snowmobiles, off-highway motorcycles, and all-terrain 

vehicles (ATVs). For snowmobiles, HC and CO exhaust 

standards are phased-in from 2006-2012. For off-highway 

motorcycles, HC+ NOx and CO exhaust emission 

standards are phased in from 2006-2007. For ATVs, 

HC+NOx and CO exhaust emission standards are phased 

in from 2006-2007. Evaporative emission standards for 

fuel tank and hose permeation apply to all recreational 

vehicles beginning in 2008.

3) Exhaust emission standards for HC+ NOx, CO, and PM 

for recreational marine diesel engines over 50 hp begin in 

2006-2009, depending on the engine displacement. These 

are “Tier 2” equivalent standards.

Control of Emissions of Air Pollution 

From Nonroad Diesel Engines and 

Fuel; Final Rule (Clean Air Nonroad 

Diesel Rule – Tier 4)

69 FR 38958

June 29, 2004

This final rule sets Tier 4 exhaust standards for CI engines 

covering all hp categories (except marine and 

locomotives), and also regulates nonroad diesel fuel sulfur 

content.

1) The Tier 4 start dates and pollutants affected vary by hp 

and tier as follows:

 hp<25: 2008, PM only

 25-50 hp: Tier 4 transitional, 2008, PM only; 

 Tier 4 final, 2013, NMHC+ NOx and PM
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Regulation Description

 50-75 hp: Tier 4 transitional, 2008; PM only; 

 Tier 4 final, 2013, NMHC+ NOx and PM 

 75-175 hp: Tier 4 transitional, 2012, HC, NOx, and PM; 

 Tier 4 final, 2014, HC, NOx,PM

 175-750 hp:Tier 4 transitional, 2011, HC, NOx, and PM;

 Tier 4 final, 2014, HC, NOx,PM

 >750 hp: Tier 4 transitional, 2011, HC, NOx, and PM; 

 Tier 4 final, 2015, HC, NOx,PM

2) This rule will reduce nonroad diesel fuel sulfur levels in 

two steps. First, starting in 2007, fuel sulfur levels in 

nonroad diesel fuel will be limited to a maximum of 500 

ppm, the same as for current highway diesel fuel. Second, 

starting in 2010, fuel sulfur levels in most nonroad diesel 

fuel will be reduced to 15 ppm.

Control of Emissions From Nonroad 

Spark-Ignition Engines and 

Equipment; Final Rule (Bond Rule)

73 FR 59034

October 8, 2008

This rule establishes exhaust and evaporative standards 

for small SI engines and marine SI engines:

1) Phase 3 HC+ NOx exhaust emission standards are 

established for Class I NHH engines starting in 2012 and 

for Class II NHH engines starting in 2011. There are no 

new exhaust emission standards for handheld engines. 

New evaporative standards are adopted for both handheld 

and nonhandheld equipment. The new evaporative 

standards control fuel tank permeation, fuel hose 

permeation, and diffusion losses. The evaporative 

standards begin in 2012 for Class I NHH engines and 2011 

for Class II NHH engines. For handheld engines, the 

evaporative standards are phased-in from 2012-2016.

2) More stringent HC+ NOx and CO standards are 

established for marine SI PWC/OB engines beginning in 

2010. In addition, new exhaust HC+ NOx and CO 

standards are established for sterndrive and inboard (SD/I) 

marine SI engines also beginning in 2010. High 

performance SD/I engines are subject to separate HC+

NOx and CO exhaust standards that are phased-in from 

2010-2011. New evaporative standards were also adopted 

for all marine SI engines that control fuel hose permeation, 

diurnal emissions, and fuel tank permeation emissions. 

The hose permeation, diurnal, and tank permeation 

standards take effect in 2009, 2010, and 2011, 

respectively.

Source: USEPA 2010c 
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5.0 MARINE VESSELS, AIRPORTS, AND RAILROADS 

5.1 MAR INVENTORY CATEGORIES 

This category of sources is collectively referred to as the MAR (marine, airports, railroads) 

sector. It includes nonroad engines associated with the following activities: 

 Marine Vessels - The Commercial Marine Vehicle (CMV) sector includes all boats 

and ships used either directly or indirectly in the conduct of commerce or military 

activity. The majority of these vessels are powered by diesel engines that are either 

fueled with distillate or residual fuel oil blends. For the purpose of this inventory it 

is assumed that Category 3 vessels primarily use residual blends, while Category 1 

and 2 vessels typically used distillate fuels. 

 Airports - The aircraft sector includes all aircraft types used for public, private, 

and military purposes. This includes four types of aircraft 1) Commercial; 2) Air 

Taxis; 3) General Aviation; and 4) Military. Ground support equipment (GSE) and 

auxiliary power units (APU) are also included. 

 Railroads - The railroad sector includes railroad locomotives powered by dieselelectric engines. Locomotives are divided into Class I line haul, Class II/III line 

haul, commuter/passenger and Class I yard. 

5.2 2007 INVENTORY DEVELOPMENT 

The emission projections for the 2025 point source were based on Version 3_3 of the 2007 

MANE-VU+VA inventory and are fully documented in the TSD for that effort 

(MARAMA 2012a). There were no adjustment to the 2007 Version 3_3 MAR inventory 

for this analysis. 

5.3 2025 INVENTORY DEVELOPMENT 

Appendix H contains the data that were used to develop growth and control factors for the 

commercial marine vessel, airport, and railroad sectors. 

5.3.1 Commercial Marine Vessels 

For the purpose of emission calculations, marine vessel engines are divided into three 

categories based on displacement (swept volume) per cylinder. Category 1 and Category 2 

marine diesel engines typically range in size from about 500 to 8,000 kW (700 to 11,000 

hp). These engines are used to provide propulsion power on many kinds of vessels 

including tugboats, pushboats, supply vessels, fishing vessels, and other commercial 
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vessels in and around ports. They are also used as stand-alone generators for auxiliary 

electrical power on vessels. Category 3 marine diesel engines typically range in size from 

2,500 to 70,000 kW (3,000 to 100,000 hp). These are very large marine diesel engines used 

for propulsion power on ocean-going vessels such as container ships, oil tankers, bulk 

carriers, and cruise ships. 

The majority of marine vessels are powered by diesel engines that are either fueled with 

distillate or residual fuel oil blends. For the purpose of emission inventories, USEPA has 

assumed that Category 3 vessels primarily use residual blends, while Category 1 and 2 

vessels typically use distillate fuels. 

USEPA developed national emission inventories for Category 1 and 2 vessels and 

Category 3 vessels for calendar years 2002 through 2040 as part of its effort to develop 

emission standards for these vessels. The methodologies used to develop the emission 

projections (for both a baseline and controlled scenario) are documented in three regulatory 

impact assessments (USEPA 2008b, USEPA 2009c, USEPA 2009d). The USEPA data 

and methodologies from these RIAs were used to develop separate growth and control 

factors for Category 1 and 2 vessels (diesel) and Category 3 vessels (residual). 

5.3.1.1 CMV Diesel Growth Factors 

For Category 1 and 2 diesel vessels, USEPA used projection data for domestic shipping 

from the AEO2006 (EIA 2006). The annual growth rate reported in the RIA is 0.9%. 

More recent growth data for domestic shipping is available in the AEO2010 (EIA 2010). 

Because Category 1 and 2 vessels primarily account for activity data for ships that carry 

domestic cargo, we decided to use the recent growth data for domestic shipping available 

in the AEO2010. We used Table A-7 of the AEO2010 for domestic shipping to calculate 

the growth factor for 2007-2025 to be 1.064. This growth factor was used for CMV diesel 

port emissions (SCC 22-80-002-100) and CMV diesel underway emissions (SCC 22-80-

002-200). 

5.3.1.2 CMV Diesel Control Factors 

In developing their emission projections, USEPA developed two scenarios that accounted 

for both the 2004 nonroad diesel rule and the 2008 diesel marine vessel rule: 

 USEPA’s baseline (pre-control) inventory accounted for: 

1. the 0.9 percent annual growth in fuel use based on AEO2006, 

2. the impact of existing engine regulations that took effect in 2008, 

3. the 2004 Clean Air Nonroad Diesel Rule that will decrease the allowable 

levels of sulfur in fuel beginning in 2012, and 

4. fleet turnover. 
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 USEPA’s controlled inventory accounted for: 

1. the 0.9 percent annual growth in fuel use based on AEO2006; 

2. the reductions included in the baseline inventory, and the reductions from 

USEPA’s 2008 rule Final Locomotive-Marine rule for Tier 3 and 4 engines; 

3. The 2008 final rule that includes the first-ever national emission standards 

for existing marine diesel engines, applying to engines larger than 600kW 

when they are remanufactured. The rule also sets Tier 3 emissions 

standards for newly-built engines that are phasing in from 2009. Finally, 

the rule establishes Tier 4 standards for newly-built commercial marine 

diesel engines above 600kW, phasing in beginning in 2014. 

To calculate a control factor that accounts for reductions included in the USEPA controlled 

inventory, it was necessary to first calculate a “growth only” scenario applying USEPA’s 

0.9 percent annual growth rate to the 2007 base emissions. Once the growth rate was 

applied, then a control factor for each pollutant was calculated by dividing the future year 

controlled emissions by the future year “growth only” emissions. Exhibit 5.1 shows the 

control factors for 2013, 2017, 2020, and 2025 for diesel commercial marine vessels. 

Exhibit 5.1 CMV Diesel Control Factors by Year and Pollutant 

Year NOx PM2.5 SO2

2013 0.787 0.747 0.464

2017 0.642 0.550 0.076

2020 0.537 0.460 0.032

2025 0.401 0.353 0.031

5.3.1.3 CMV Residual Oil Growth Factors 

For Category 3 residual oil vessels, data from a USEPA-sponsored study was used to 

develop an annualized growth factor of 4.5 percent for the region. A few states considered 

the growth rate to be extremely high and not reflective of recent economic conditions. 

Because USEPA’s Category 3 vessel inventory is primarily based on activity data for ships 

that carry foreign cargo, we decided to use the recent growth data for international 

shipping available in the AEO2010. We used data from Table A-7 of the AEO2010 for 

international shipping to calculate the growth factor for 2007-2025 to be 0.956. These 

growth factors were used for CMV residual oil port emissions (SCC 22-80-003-100) and 

CMV residual oil underway emissions (SCC 22-80-003-200). 
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5.3.1.4 CMV Residual Oil Control Factors 

On December 22, 2009, USEPA announced final emission standards under the Clean Air 

Act for new marine diesel engines with per-cylinder displacement at or above 30 liters 

(called Category 3 marine diesel engines) installed on U.S.-flagged vessels. The final 

engine standards are equivalent to those adopted in the amendments to Annex VI to the 

International Convention for the Prevention of Pollution from Ships (a treaty called 

"MARPOL"). The emission standards apply in two stages: near-term standards for newlybuilt engines will apply beginning in 2011, and long-term standards requiring an 80 

percent reduction in NOx will begin in 2016. USEPA also adopted changes to the diesel 

fuel program to allow for the production and sale of diesel fuel with no more than 1,000 

ppm sulfur for use in Category 3 marine vessels. The regulations generally forbid 

production and sale of fuels with more than 1,000 ppm sulfur for use in most U.S. waters, 

unless operators achieve equivalent emission reductions in other ways. 

On March 26, 2010, the International Maritime Organization (IMO) officially designated 

waters off North American coasts as an emissions control area (ECA) in which stringent 

international emission standards will apply to ships. In practice, implementation of the 

ECA means that ships entering the designated area would need to use compliant fuel for 

the duration of their voyage that is within that area, including time in port and voyages 

whose routes pass through the area without calling on a port. The North American ECA 

includes waters adjacent the Atlantic extending up to 200 nautical miles from east coast of 

the US. The quality of fuel that complies with the ECA standard will change over time. 

From the effective date in 2012 until 2015, fuel used by vessels operating in designated 

areas cannot exceed 1.0 percent sulfur (10,000 ppm). Beginning in 2015, fuel used by 

vessels operating in these areas cannot exceed 0.1 percent sulfur (1000 ppm). Beginning 

in 2016, NOx after treatment requirements become applicable. 

To calculate a control factor that accounted for reductions included in the USEPA 

controlled inventory, it was necessary to first calculate a “growth only” scenario applying 

USEPA’s 4.5 percent annual growth rate to the 2007 base emissions. Once the growth rate 

was applied, then a control factor for each pollutant was calculated by dividing the future 

year controlled emissions by the future year “growth only” emissions. 

Exhibit 5.2 shows the control factors for 2013, 2017, and 2020 for residual oil commercial 

marine vessels. 
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Exhibit 5.2 CMV Residual Oil Control Factors by Year and Pollutant 

Year NOx PM2.5 SO2

2013 0.736 0.353 0.270

2017 0.654 0.216 0.120

2020 0.597 0.137 0.036

2025 0.480 0.137 0.036

5.3.1.5 Military Vessels Growth and Control Factors 

Virginia reported emissions for military vessels, but did not distinguish between diesel or 

residual fuels. An assumption of “no growth” for military vessel activity and emissions in 

Virginia was made so that emissions remain at 2007 levels in 2025. Virginia was the only 

state to report emission from military vessels. 

5.3.1.6 State-specific CMV Updates for 2025 

New Jersey provided updated CMV emission estimates for 2007, 2013, 2017, 2020, and 

2025, and growth and control factors for 2013, 2017, 2020, and 2025. These data were 

used to replace the emission estimates previously used for the 2007 MANE-VU+VA base 

year inventory and the MANE-VU+VA future year inventories. 

5.3.2 Airports 

Aircraft emissions in the 2007 MANE-VU+VA inventory are available on either a countyby-county or airport-by-airport basis for six types of aircraft operations: 

 Air carrier operations represent landings and take-offs (LTOs) of commercial 

aircraft with seating capacity of more than 60 seats; 

 Commuter/air taxi operations are one category. Commuter operations include 

LTOs by aircraft with 60 or fewer seats that transport regional passengers on 

scheduled commercial flights. Air taxi operations include LTOs by aircraft with 60 

or fewer seats conducted on non-scheduled or for-hire flights; 

 General aviation represents all civil aviation LTOs not classified as commercial; 

 Military operations represent LTOs by military aircraft; 

 Ground Support Equipment (GSE) typically includes aircraft refueling and baggage 

handling vehicles and equipment, aircraft towing vehicles, and passenger buses; 

 Auxiliary power units (APUs) provide power to start the main engines and run the 

heating, cooling, and ventilation systems prior to starting the main engines. 
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5.3.2.1 Airport Growth Factors 

Aircraft operations were projected to future years by applying activity growth using data 

on itinerant (ITN) operations at airports as reported in the Federal Aviation 

Administration’s (FAA) Terminal Area Forecast (TAF) System for 2009-2030 (FAA 

2010). The ITN operations are defined as aircraft take-offs or landings. This information is 

available for approximately 3300 individual airports. Actual LTOs are reported for 2007 

and projected LTOs are provided for all years up to 2030. 

The data was aggregated and applied at the county level for the four operation types: 

commercial, general, air taxi, military. A growth factor was computed for each operation 

type by dividing future-year ITN by 2007-year ITN. Inventory SCCs were assigned 

factors based on the operation type, as shown in Exhibit 5.3. 

Exhibit 5.3 Crosswalk between SCC and FAA Operations Type 

SCC SCC Description FAA Operation Type Used for 

Growth Factor

2265008005 Airport Ground Support Equipment, 4-Stroke Gas Total Itinerant Operations

2267008005 Airport Ground Support Equipment, LPG Total Itinerant Operations

2268008005 Airport Ground Support Equipment, CNG Total Itinerant Operations

2270008000 Airport Ground Support Equipment, Diesel Total Itinerant Operations

2270008005 Airport Ground Support Equipment, Diesel Total Itinerant Operations

2275001000 Aircraft /Military Aircraft /Total Itinerant Military Operations

2275020000 Aircraft /Commercial Aircraft /Total: All Types Itinerant Air Carrier Operations

2275050000 Aircraft /General Aviation /Total Itinerant General Aviation Operations

2275050011 Aircraft /General Aviation /Piston Itinerant General Aviation Operations

2275050012 Aircraft /General Aviation /Turbine Itinerant General Aviation Operations

2275060000 Aircraft /Air Taxi /Total Itinerant Air Taxi Operations

2275060011 Aircraft /Air Taxi /Piston Itinerant Air Taxi Operations

2275060012 Aircraft /Air Taxi /Turbine Itinerant Air Taxi Operations

2275070000 Aircraft /Aircraft Auxiliary Power Units /Total Total Itinerant Operations

Exhibit 5.4 summarizes the region-wide growth factors by FAA operation type. The 

growth factor for individual airports/counties may deviate substantially from these regionwide growth factors. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 5.4 Region-wide Growth Factors from 2007 by FAA Operations Type 

5.3.2.2 Aircraft Control Factors 

The NOx aircraft engine emissions standards adopted by USEPA in November 2005 

(USEPA 2005) were reviewed. The standards are equivalent to the NOx emission 

standards (adopted in 1999 for implementation beginning in 2004) of the United Nations 

International Civil Aviation Organization (ICAO), and will bring the US aircraft standards 

into alignment with the international standards. The standards apply to new aircraft 

engines used on commercial aircraft including small regional jets, single-aisle and twinaisle aircraft, and 747s and larger aircraft. The standards also apply to general aviation and 

military aircraft, which sometimes use commercial engines. For example, small regional jet 

engines are used in executive general aviation aircraft, and larger commercial aircraft 

engines may be used in military transport aircraft. 

Nearly all previously certified or in-production engine models currently meet or perform 

better than the standards USEPA adopted in the November 2005 rule. In addition, 

manufacturers have already been developing improved technology in response to the 

ICAO standards. According to USEPA’s recent analysis for the proposed transport rule 

(USEPA 2010b), this rule is expected to reduce NOx emissions by approximately 2 percent 

in 2015 and 3 percent in 2020. Because of the relatively small amount of NOx reductions, 

our aircraft emission projections do not account for this control program. 

USEPA has also issued an Advance Notice of Proposed Rulemaking (ANPR) on lead 

emissions from piston-engine aircraft using leaded aviation gasoline (USEPA 2010c). 

However, this rule has not yet been adopted and co-benefits for criteria air pollutants are 

likely to be small. Therefore, the effects of this rule were not included in the future-year 

emissions projections. 
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5.3.2.3 State-specific Airport Updates for 2025 

After reviewing the growth factors described in the previous section, Connecticut provided 

state-specific growth factors for 2025 by SCC and county. These state-specific factors 

were used instead of the factors described in the previous section. 

New Jersey provided updated aircraft growth factors and emission estimates for 2007, 

2013, 2017, 2020, and 2025. These data were used to replace the emission estimates 

previously used for the 2007 MANE-VU+VA base year inventory and the MANEVU+VA future year inventories. 

5.3.3 Railroad Locomotives 

Railroad locomotive engine emissions in the 2007 MARAMA inventory are classified into 

the following categories: 

 Class I line haul locomotives are operated by large freight railroad companies and 

are used to power freight train operations over long distances (SCC 22-85-002-

006);

 Class II/III line haul locomotives are operated by smaller freight railroad 

companies and are used to power freight train operations over long distances (SCC 

22-85-002-007); 

 Inter-city passenger train locomotives are operated primarily by Amtrak to provide 

inter-city passenger transport (SCC 22-85-002-008); 

 Independent commuter rail systems operate locomotives that provide passenger 

transport within a metropolitan area (SCC 22-85-002-009); and 

 Yard/switch locomotives are used in freight yards to assemble and disassemble 

trains, or for short hauls of trains that are made up of only a few cars (SCC 22-85-

002-010).

5.3.3.1 Railroad Growth Factors 

In March 2008, USEPA finalized a three part program that will dramatically reduce 

emissions from diesel locomotives of all types -- line-haul, switch, and passenger rail. As 

part of this work USEPA developed a national emission inventory for calendar years 2002 

through 2040. Emission projections methodologies for a baseline and controlled scenario 

were developed and documented (USEPA 2008b). USEPA used projection data from the 

AEO2006 (EIA 2006). Table A-7 of AEO2006 showed that freight rail energy use will 

grow 1.6 percent annually. 
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More recent growth data is available in the AEO2010 which was published in May 2010. 

There are separate projections for passenger rail and freight rail energy use. For the 

MANE VU+VA inventory the more recent AEO2010 growth projections were used. 

Passenger rail data from AEO2010 Table A-7 was used to calculate the growth factor for 

2007-2025 to be 1.241. These growth factors were applied to inter-city passenger train 

locomotives (SCC 22-85-002-008) and independent commuter rail systems (SCC 22-85-

002-009). 

For freight rail, the data from AEO2010 Table A-7 was used to calculate the growth factor 

for 2007-2025 to be 1.098. The freight rail annual growth factors for Class I line haul 

(SCC 22-85-002-006), Class II/III line haul (SCC 22-85-002-007), and yard switch (SCC 

22-85-002-010) locomotives were used. 

5.3.3.2 Railroad Control Factors 

USEPA developed two scenarios that accounted for both the 2004 nonroad diesel rule and 

the 2008 diesel locomotive rule: 

 USEPA’s baseline (pre-control) inventory accounted for 

1. AEO2006 annual growth in fuel use, 

2. The impact of existing regulations for Tier 0, 1, and 2 locomotive engines 

that take effect in 2008, 

3. The 2004 Clean Air Nonroad Diesel Rule that will decrease allowable 

levels of sulfur in locomotives fuel beginning in 2012, and 

4. Fleet turnover. 

 USEPA’s controlled inventory accounted for 

1. AEO2006 annual growth in fuel use, 

2. Reductions included in the baseline inventory, and 

3. Reductions from USEPA’s 2008 rule Final Locomotive-Marine rule for 

Tier 3 and 4 engines. This rule lowered diesel sulfur content and tightened 

emission standards for existing and new locomotives. 

4. Voluntary retrofits under the National Clean Diesel Campaign are not 

included in our projections. 

To calculate a factor that accounted for reductions included in the USEPA controlled 

inventory, it was necessary to first calculate a “growth only” scenario applying USEPA’s 

1.6% annual growth rate to the 2006 base emissions. Once the growth rate was applied, 

then a control factor for each pollutant was calculated by dividing the future year 

controlled emissions by the future year “growth only” emissions. 
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Exhibit 5.5 shows the control factors for 2013, 2017, 2020, and 2025 for the five 

locomotive classifications and pollutants. 

5.3.3.3 State-specific Railroad Updates for 2025 

New Jersey provided updated railroad growth factors, control factors, and emission 

estimates for 2007, 2013, 2017, 2020, and 2025. These data were used to replace the 

emission estimates previously used for the 2007 MANE-VU+VA base year inventory and 

the MANE-VU+VA future year inventories. 

Exhibit 5.5 Rail Control Factors by Year, Pollutant, and SCC 

Year NOx PM2.5 SO2

SCC 22-85-002-006 Line Haul Class I Operations

2013 0.771 0.595 0.003

2017 0.633 0.449 0.003

2020 0.547 0.364 0.003

2025 0.412 0.252 0.003

SCC 22-85-002-007 Line Haul Class II / III Operations

2013 1.000 0.829 0.003

2017 0.960 0.791 0.003

2020 0.920 0.752 0.003

2025 0.852 0.688 0.003

SCC 22-85-002-008 Inter-City Passenger

2013 0.571 0.566 0.003

2017 0.421 0.402 0.003

2020 0.340 0.294 0.003

2025 0.241 0.180 0.003

SCC 22-85-002-009 Commuter Rail

2013 0.571 0.566 0.003

2017 0.421 0.402 0.003

2020 0.340 0.294 0.003

2025 0.241 0.180 0.003

SCC 22-85-002-010 Yard / Switch

2013 0.912 0.777 0.003

2017 0.843 0.712 0.003

2020 0.771 0.650 0.003

2025 0.634 0.534 0.003
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6.0 ONROAD MOBILE SOURCES INCLUDED IN MOVES 

6.1 MOVES MODEL CATEGORIES 

USEPA’s MOVES model estimates emissions from vehicles travel such as cars, trucks, 

buses and motorcycles. These vehicles are powered by diesel, gasoline, and alternative 

fuel formulations. MOVES2010 includes the capability to estimate both vehicle exhaust 

and evaporative emissions (including vehicle refueling emissions) and brake wear and tire 

wear emissions for criteria pollutants and precursors. However, MOVES2010 does not 

include the capability to estimate emissions of re-entrained road dust. Estimates of 

emissions from re-entrained road dust are included in the area source inventory. 

6.2 2007 MOVES MODEL INVENTORY 

MARAMA provided county-level MOVES results for 2007 for CT, DE, DC, and MD. 

Other states (NJ, NY, PA, VA) provided results for affected counties in their states. 

6.3 2025 MOVES MODEL INVENTORY 

MARAMA provided county-level MOVES results for 2025 for CT, DE, DC, and MD. 

Other states (NJ, NY, PA, VA) provided results for affected counties in their states. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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7.0 EMISSION SUMMARIES 

Exhibits 7.1 to 7.12 summarize PM2.5 and PM precursor emissions by PM nonattainment 

area and source sector for 2007 and 2025. Some general observations by pollutant include: 

 PM2.5 emissions are projection to decrease between 2007and 2025 in all PM 

nonattainment areas. The reductions are due to the turnover to cleaner onroad 

vehicles, nonroad engines, and residential wood combustion equipment. The 

PM2.5 emissions shown account for the application of the PM transport factor (see 

discussion in Section 2.2.1.1 of this TSD). 

 NOx emissions decline in all PM nonattainment areas between 2007 and 2025 and 

by more than 50 percent in a few areas. Most of the decline results from the 

turnover of the onroad vehicle fleet to vehicles with improved emission controls 

and fuel efficiency. Reductions in nonroad sources are also substantial. Three 

areas (Baltimore, NY/NJ/CT, and Washington DC/MD/VA) also show substantial 

reductions due to controls on EGUs. 

 SO2 emissions decrease in all PM nonattainment areas. All areas are showing 

reductions due to the lower sulfur contents of fuels used by onroad vehicles and 

nonroad equipment. Additional reductions in areas located in Maryland, New 

Jersey, and New York are due to the lower sulfur content regulations in those state 

for home heating, distillate oil, and residual oil. Connecticut, Delaware, the 

District of Columbia, Pennsylvania, and Virginia did not take credit for any 

reductions for low sulfur fuel oils since they have not adopted the MANE-VU 

recommendations into their regulations (see discussion in Section 2.3.2.5 of the 

TSD). Especially large reductions are found in areas where controls are projected 

to be in place on EGUs (Allentown, Baltimore, Harrisburg, Metro New York, 

Philadelphia, Pittsburgh, Washington DC/MD/VA, and York, PA). 

County-by-county emissions for 2007 and 2025 are available on the MARAMA ftp site. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 7.1 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Allentown, PA 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from from

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,987 1,936 -51 -2.6%

Nonroad MAR 516 277 -239 -46.3%

Nonroad NMIM 2,661 1,007 -1,654 -62.1%

Onroad MOVES 15,652 4,190 -11,462 -73.2%

Point EGU 7,763 5,837 -1,927 -24.8%

Point nonEGU 5,900 2,114 -3,786 -64.2%

34,480 15,362 -19,117 -55.4%

Direct PM2.5

Area 2,150 1,958 -192 -8.9%

Nonroad MAR 26 15 -11 -42.3%

Nonroad NMIM 229 113 -117 -51.0%

Onroad MOVES 528 190 -338 -64.0%

Point EGU 2,264 2,138 -125 -5.5%

Point nonEGU 1,301 1,227 -75 -5.7%

6,498 5,640 -858 -13.2%

Sulfur Dioxide (SO2)

Area 2,552 1,118 -1,434 -56.2%

Nonroad MAR 12 4 -8 -70.4%

Nonroad NMIM 147 4 -143 -97.3%

Onroad MOVES 118 43 -75 -63.2%

Point EGU 48,203 3,962 -44,241 -91.8%

Point nonEGU 5,868 5,875 7 0.1%

56,900 11,005 -45,895 -80.7%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 7.2 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Baltimore, MD 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 4,732 5,167 435 9.2%

Nonroad MAR 16,703 8,521 -8,182 -49.0%

Nonroad NMIM 10,466 4,265 -6,201 -59.2%

Onroad MOVES 43,939 15,900 -28,038 -63.8%

Point EGU 23,572 8,939 -14,634 -62.1%

Point nonEGU 11,981 13,362 1,380 11.5%

111,394 56,154 -55,240 -49.6%

Direct PM2.5

Area 5,004 5,197 193 3.9%

Nonroad MAR 572 201 -371 -64.8%

Nonroad NMIM 969 519 -450 -46.4%

Onroad MOVES 1,503 749 -755 -50.2%

Point EGU 6,677 7,134 456 6.8%

Point nonEGU 2,296 2,366 71 3.1%

17,022 16,166 -855 -5.0%

Sulfur Dioxide (SO2)

Area 2,316 315 -2,001 -86.4%

Nonroad MAR 1,803 268 -1,535 -85.1%

Nonroad NMIM 581 15 -566 -97.4%

Onroad MOVES 375 380 5 1.3%

Point EGU 93,665 18,922 -74,744 -79.8%

Point nonEGU 4,759 4,867 108 2.3%

103,499 24,766 -78,733 -76.1%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 7.3 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Hagerstown Martinsburg, MD-WV 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from from

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 296 339 43 14.5%

Nonroad MAR 289 144 -145 -50.2%

Nonroad NMIM 793 301 -492 -62.0%

Onroad MOVES 5,124 1,966 -3,158 -61.6%

Point EGU 1,398 1,390 -8 -0.6%

Point nonEGU 1,982 1,518 -465 -23.4%

9,883 5,657 -4,225 -42.8%

Direct PM2.5

Area 501 538 37 7.3%

Nonroad MAR 10 3 -7 -68.6%

Nonroad NMIM 74 33 -41 -55.6%

Onroad MOVES 185 69 -117 -62.8%

Point EGU 310 299 -11 -3.5%

Point nonEGU 188 188 0 0.1%

1,269 1,131 -138 -10.9%

Sulfur Dioxide (SO2)

Area 274 83 -191 -69.7%

Nonroad MAR 5 2 -4 -69.4%

Nonroad NMIM 45 1 -44 -97.6%

Onroad MOVES 44 47 3 6.4%

Point EGU 5,536 4,590 -946 -17.1%

Point nonEGU 1,277 1,271 -6 -0.5%

7,182 5,993 -1,189 -16.5%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 

Note: only includes emissions for Washington County, MD; emissions for West Virginia portion of 

the nonattainment area will be provided by Maryland in their SIP submittal. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 7.4 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Harrisburg-Lebanon-Carlisle-York, PA 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 3,874 3,705 -169 -4.4%

Nonroad MAR 1,775 981 -793 -44.7%

Nonroad NMIM 5,329 2,055 -3,274 -61.4%

Onroad MOVES 36,440 9,338 -27,102 -74.4%

Point EGU 15,985 15,531 -454 -2.8%

Point nonEGU 10,965 9,646 -1,319 -12.0%

74,368 41,255 -33,113 -44.5%

Direct PM2.5

Area 5,452 5,201 -251 -4.6%

Nonroad MAR 74 35 -39 -52.3%

Nonroad NMIM 474 211 -263 -55.4%

Onroad MOVES 1,225 346 -879 -71.8%

Point EGU 2,123 2,060 -63 -3.0%

Point nonEGU 923 915 -8 -0.9%

10,272 8,769 -1,503 -14.6%

Sulfur Dioxide (SO2)

Area 4,900 2,763 -2,136 -43.6%

Nonroad MAR 30 15 -15 -50.2%

Nonroad NMIM 293 8 -285 -97.3%

Onroad MOVES 255 89 -165 -64.9%

Point EGU 106,189 5,179 -101,010 -95.1%

Point nonEGU 11,520 11,539 19 0.2%

123,186 19,593 -103,593 -84.1%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 7.5 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Johnstown, PA 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 861 822 -39 -4.5%

Nonroad MAR 1,132 568 -564 -49.8%

Nonroad NMIM 909 366 -543 -59.7%

Onroad MOVES 6,017 1,217 -4,800 -79.8%

Point EGU 41,440 40,004 -1,435 -3.5%

Point nonEGU 932 1,097 165 17.7%

51,291 44,074 -7,216 -14.1%

Direct PM2.5

Area 1,198 1,114 -84 -7.0%

Nonroad MAR 45 18 -27 -60.6%

Nonroad NMIM 84 36 -48 -56.9%

Onroad MOVES 195 43 -152 -78.2%

Point EGU 2,867 2,768 -99 -3.4%

Point nonEGU 231 234 3 1.4%

4,619 4,212 -407 -8.8%

Sulfur Dioxide (SO2)

Area 1,179 593 -586 -49.7%

Nonroad MAR 13 1 -12 -95.9%

Nonroad NMIM 51 1 -50 -97.4%

Onroad MOVES 45 12 -32 -72.3%

Point EGU 143,303 141,481 -1,821 -1.3%

Point nonEGU 30 35 4 14.7%

144,621 142,123 -2,498 -1.7%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 

Note: summary includes emissions for all of Indiana County; however, only part of the county is in 

the nonattainment area. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 7.6 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Lancaster, PA 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,827 1,704 -122 -6.7%

Nonroad MAR 293 140 -153 -52.1%

Nonroad NMIM 2,880 1,170 -1,710 -59.4%

Onroad MOVES 14,163 3,779 -10,384 -73.3%

Point EGU 0 0 0 0.0%

Point nonEGU 1,147 1,383 236 20.5%

20,310 8,177 -12,133 -59.7%

Direct PM2.5

Area 1,827 1,704 -122 -6.7%

Nonroad MAR 293 140 -153 -52.1%

Nonroad NMIM 2,880 1,170 -1,710 -59.4%

Onroad MOVES 14,163 3,779 -10,384 -73.3%

Point EGU 0 0 0 0.0%

Point nonEGU 1,147 1,383 236 20.5%

20,310 8,177 -12,133 -59.7%

Sulfur Dioxide (SO2)

Area 3,030 1,766 -1,264 -41.7%

Nonroad MAR 4 0 -3 -87.6%

Nonroad NMIM 144 5 -139 -96.8%

Onroad MOVES 104 38 -66 -63.4%

Point EGU 0 0 0 0.0%

Point nonEGU 102 120 18 17.5%

3,384 1,929 -1,454 -43.0%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 7.7 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Metro New York/Northern New Jersey/Long Island NY/NJ/CT 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 64,044 56,873 -7,170 -11.2%

Nonroad MAR 46,842 31,820 -15,023 -32.1%

Nonroad NMIM 70,841 13,603 -57,238 -80.8%

Onroad MOVES 252,723 74,474 -178,249 -70.5%

Point EGU 36,928 33.841 -3,087 -8.4%

Point nonEGU 20,117 20,881 765 3.8%

491,675 231,660 -260,014 -52.9%

Direct PM2.5

Area 18,512 19,318 805 4.4%

Nonroad MAR 1,705 755 -950 -55.7%

Nonroad NMIM 5,873 1,534 -4,339 -73.9%

Onroad MOVES 10,189 4,878 -5,311 -52.1%

Point EGU 6,267 4,274 -1,994 -31.8%

Point nonEGU 1,530 1,704 174 11.4%

44,131 32,457 -11,674 -26.5%

Sulfur Dioxide (SO2)

Area 42,122 10,353 -31,768 -75.4%

Nonroad MAR 11,823 1,957 -9,865 -83.4%

Nonroad NMIM 3,720 56 -3664 -98.5%

Onroad MOVES 1,750 1,564 -186 -10.6%

Point EGU 63,236 44,139 -19,097 -30.2%

Point nonEGU 5,293 5,351 59 1.1%

126,427 63,420 -63,005 -43.7%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 

Note: 2025 NMIM emissions for New York counties are missing from the above summaries. 

Note 2: New Jersey made changes to Point EGU values in this table after AMEC finalized the 

project. The changes were made by MARAMA. 

Note 3: GSE Emissions were removed from 2025 total for consistency. 

Note 4: 2007 and 2025 Connecticut NMIM was updated with runs that use Version 3 inputs, 

including revisions to the Pleasurecraft population file. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 7.8 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Philadelphia-Wilmington, PA/DE/NJ 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 18,043 17,741 -302 -1.7%

Nonroad MAR 12,271 9,357 -2,913 -23.7%

Nonroad NMIM 19,579 8,305 -11,274 -57.6%

Onroad MOVES 106,315 26,648 -79,668 -74.9%

Point EGU 12,616 4,873 -7,743 -61.4%

Point nonEGU 19,143 14,944 -4,199 -21.9%

187,967 81,869 -106,099 -56.4%

Direct PM2.5

Area 13,811 12,983 -829 -6.0%

Nonroad MAR 658 299 -360 -54.7%

Nonroad NMIM 1,808 1,059 -749 -41.4%

Onroad MOVES 3,795 1,443 -2,352 -62.0%

Point EGU 1,048 813 -236 -22.5%

Point nonEGU 3,524 3,062 -462 -13.1%

24,644 19,657 -4,987 -20.2%

Sulfur Dioxide (SO2)

Area 16,763 9,756 -7,007 -41.8%

Nonroad MAR 5,136 677 -4,459 -86.8%

Nonroad NMIM 998 32 -966 -96.7%

Onroad MOVES 773 422 -351 -45.4%

Point EGU 20,665 4,563 -16,102 -77.9%

Point nonEGU 14,370 8,990 -5,380 -37.4%

58,705 24,440 -34,265 -58.4%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

Page 90

Exhibit 7.9 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Pittsburgh-Beaver Valley, PA 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 8,608 8,613 5 0.1%

Nonroad MAR 14,258 7,116 -7,142 -50.1%

Nonroad NMIM 9,827 4,223 -5,605 -57.0%

Onroad MOVES 56,652 12,725 -43,927 -77.5%

Point EGU 82,657 84,453 1,795 2.2%

Point nonEGU 20,217 18,760 -1,456 -7.2%

192,219 135,890 -56,330 -29.3%

Direct PM2.5

Area 7,562 6,835 -728 -9.6%

Nonroad MAR 467 196 -271 -58.1%

Nonroad NMIM 880 432 -448 -50.9%

Onroad MOVES 1,905 531 -1,374 -72.1%

Point EGU 6,293 6,348 55 0.9%

Point nonEGU 5,108 5,109 1 0.0%

22,216 19,450 -2,766 -12.4%

Sulfur Dioxide (SO2)

Area 13,589 10,791 -2,798 -20.6%

Nonroad MAR 260 95 -165 -63.4%

Nonroad NMIM 529 15 -514 -97.2%

Onroad MOVES 419 141 -278 -66.4%

Point EGU 429,186 93,130 -336,056 -78.3%

Point nonEGU 13,247 13,699 451 3.4%

457,230 117,871 -339,359 -74.2%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 

Note: summary includes emissions for all of Allegheny, Armstrong, Greene and Lawrence counties; 

however, only parts of those counties are in the nonattainment area. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

Page 91

Exhibit 7.10 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Reading, PA 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,289 1,114 -175 -13.6%

Nonroad MAR 621 307 -314 -50.5%

Nonroad NMIM 1,911 696 -1,215 -63.6%

Onroad MOVES 11,370 2,831 -8,538 -75.1%

Point EGU 2,506 2,432 -74 -2.9%

Point nonEGU 3,288 1,919 -1,369 -41.6%

20,983 9,298 -11,685 -55.7%

Direct PM2.5

Area 1,859 1,727 -132 -7.1%

Nonroad MAR 30 15 -15 -51.5%

Nonroad NMIM 161 72 -88 -54.9%

Onroad MOVES 379 96 -284 -74.7%

Point EGU 947 921 -26 -2.7%

Point nonEGU 325 331 6 1.8%

3,701 3,161 -540 -14.6%

Sulfur Dioxide (SO2)

Area 2,389 1,223 -1,166 -48.8%

Nonroad MAR 7 1 -7 -92.6%

Nonroad NMIM 99 3 -96 -97.1%

Onroad MOVES 81 27 -53 -66.3%

Point EGU 14,491 13,990 -501 -3.5%

Point nonEGU 649 660 11 1.7%

17,716 15,903 -1,812 -10.2%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Exhibit 7.11 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: Washington DC/MD/VA 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 8,936 9,342 406 4.5%

Nonroad MAR 6,700 6,711 11 0.2%

1. Nonroad 

NMIM 2. 20,097 3. 8,000 4. -12,097 5. -60.2%

Onroad MOVES 42,971 14,067 -28,904 -67.3%

Point EGU 29,029 13,919 -15,109 -52.0%

Point nonEGU 8,826 11,253 2,427 27.5%

116,643 63,295 -53,348 -45.7%

Direct PM2.5

Area 9,528 9,725 198 2.1%

Nonroad MAR 201 160 -40 -20.2%

6. Nonroad 

NMIM 7. 2,005 8. 1,110 9. -895 10. -44.7%

Onroad MOVES 1,467 728 -739 -50.4%

Point EGU 4,984 4,996 12 0.2%

Point nonEGU 563 594 32 5.6%

18,746 17,316 -1,430 -7.6%

Sulfur Dioxide (SO2)

Area 5,733 3,862 -1,871 -32.6%

Nonroad MAR 416 488 72 17.3%

11. Nonroad 

NMIM 12. 1,233 13. 28 14. -1,205 15. -97.8%

Onroad MOVES 387 347 -40 -10.4%

Point EGU 179,243 24,694 -154,549 -86.2%

Point nonEGU 4,206 3,570 -636 -15.1%

191,215 32,990 -158,225 -82.7%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 

Note: 2007 and 2025 MOVES onroad emissions for Virginia counties are missing from the above 

summaries. 

Note2: GSE Emissions were removed from 2025 total for consistency. 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

Page 93

Exhibit 7.12 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions 

Nonattainment Area: York, PA 

Annual Annual Change (tpy) Change (%)

(tons) (tons) from From

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,680 1,678 -2 -0.1%

Nonroad MAR 198 104 -93 -47.2%

Nonroad NMIM 2,463 836 -1,627 -66.1%

Onroad MOVES 10,519 2,740 -7,779 -74.0%

Point EGU 15,760 15,226 -534 -3.4%

Point nonEGU 6,404 6,431 28 0.4%

37,024 27,015 -10,008 -27.0%

Direct PM2.5

Area 2,394 2,325 -69 -2.9%

Nonroad MAR 13 7 -6 -48.7%

Nonroad NMIM 189 77 -112 -59.4%

Onroad MOVES 348 121 -227 -65.2%

Point EGU 2,098 2,026 -72 -3.4%

Point nonEGU 364 365 1 0.3%

5,407 4,921 -486 -9.0%

Sulfur Dioxide (SO2)

Area 1,684 1,059 -625 -37.1%

Nonroad MAR 2 0 -2 -88.4%

Nonroad NMIM 132 3 -129 -97.5%

Onroad MOVES 79 28 -50 -63.8%

Point EGU 106,158 5,136 -101,021 -95.2%

Point nonEGU 9,743 9,749 6 0.1%

117,798 15,977 -101,821 -86.4%

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 

Onroad MOVES – includes emissions calculated by USEPA’s MOVES model 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

Page 94

8.0 DELIVERABLES 

Files are stored on MARAMA ftp site: 

Address: ftp.marama.org 

Login ID: regionalei 

Password: marama2007 

Folder: /2025/Final 2025 (Version 3_3) 

Exhibit 8.1 lists the file names for all final deliverables. 

Exhibit 8.1 Final Deliverables

File Name Description

TSD V3_3 MANE-VU 2025 Inventory PM 

Nonattainment Counties.docx

Technical Support Document for 2025 emission 

inventory for PM nonattainment counties

Appendix A1 AEO2010 New England.xls AEO2010 Energy Consumption by Sector and 

Source for New England Region (CT, MA, ME, 

NH, RI, VT) and calculated growth factors

Appendix A2 AEO2010 Mid Atlantic.xls AEO2010 Energy Consumption by Sector and 

Source for Mid-Atlantic Region (NJ, NY, PA) 

and calculated growth factors

Appendix A3 AEO2010 South Atlantic.xls AEO2010 Energy Consumption by Sector and 

Source for South Atlantic Region (DC, DE, MD, 

VA) and calculated growth factors

Appendix A4 AEO2011 New England.xls AEO2011 Energy Consumption by Sector and 

Source for New England Region (CT, MA, ME, 

NH, RI, VT) and calculated growth factors

Appendix A5 AEO2011 Mid Atlantic.xls AEO2011 Energy Consumption by Sector and 

Source for Mid-Atlantic Region (NJ, NY, PA) 

and calculated growth factors

Appendix A6 AEO2011 South Atlantic.xls AEO2011 Energy Consumption by Sector and 

Source for South Atlantic Region (DC, DE, MD, 

VA) and calculated growth factors

Appendix A7 AEO2010 vs AEO2011 

Comparison.docx

Technical Memorandum comparing AEO2010 

and AEO2011 energy consumption projections

Appendix B Population_Factors.xls County-level population growth factors as 

provided by states
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

Page 95

File Name Description

Appendix C Employment_Factors.xls State-level employment growth factors provided 

by states

Appendix D VMT GF Nonattainment 

Counties.xls

County-level VMT for 2007 and 2025

Appendix E EPA2020 Res Wood.xls USEPA growth factor formulas by SCC for 

residential wood combustion

Appendix F AEO2011-Electricity Generation by

EMM.xlsx

AEO 2011 Electricity Generation by Electricity 

Market Module Region and Source, Reference 

case, and associated growth factors

Appendix G UAF NEEDS Control 

FileMASTER92211.xls

State information on future EGU controls and 

emission rates

Appendix H MAR Growth and Control.xls USEPA and FAA data used to develop growth 

and control factors for commercial marine 

vessels, airports, and railroads

V3_3 Area_07_25 PM Nonattainment.xlsx County and SCC-level emissions and 

growth/control factors for area sources

V3_3 EGU_07_25 PM Nonattainment.xlsx Unit level emissions and growth/control factors 

for EGUs

V3_3 MAR_07_25 PM Nonattainment.xlsx County and SCC-level emissions and 

growth/control factors for commercial marine 

vessels, airports, and railroad locomotives

V3_3 MOVES_07_25 PM Nonattainment.xlsx County level emissions for onroad vehicles 

included in USEPA’s MOVES model

V3_3 NMIM_07_25 PM Nonattainment.xlsx County and SCC-level emissions for nonroad

equipment included in USEPA’s 

NMIM/NONROAD model

V3_3 NonEGU_07_25 PM Nonattainment.xlsx Unit level emissions and growth/control factors 

for nonEGUs

V3_3 Summaries_ 07_25 PM 

Nonattainment.xlsx

Emission summaries by county and 

nonattainment area
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

Page 96

9.0 REFERENCES 

EIA 2006. U.S. Department of Energy, Energy Information Administration. Annual 

Energy Outlook with Projections to 2030 (AEO2006). DOE/EIA-0383(2006). February 

2006. http://www.eia.doe.gov/oiaf/archive/aeo06/pdf/0383(2006).pdf

EIA 2010. U.S. Department of Energy, Energy Information Administration. Annual 

Energy Outlook with Projections to 2035 (AEO2010); DOE/EIA-0383(2010). April 2010. 

http://www.eia.doe.gov/oiaf/aeo/assumption/pdf/0554(2010).pdf 

EIA 2011a. U.S. Department of Energy, Energy Information Administration. Annual 

Energy Outlook with Projections to 2035 (AEO2011); DOE/EIA-0383(2011). April 2011. 

http://www.eia.gov/forecasts/aeo/pdf/0383(2011).pdf 

EIA 2011b. U.S. Department of Energy, Energy Information Administration. Annual 

Energy Outlook with Projections to 2035 (AEO2011) – Table 96 Electricity Generation by 

Electricity Market Module Region and Source, Reference case; DOE/EIA-0383(2011). 

April 2011. http://www.eia.gov/forecasts/aeo/pdf/0383(2011).pdf 

FAA 2010. Federal Aviation Administration. Terminal Area Forecast 2009-2030. 

Database file (APO100_TAF_Final_2010.zip) downloaded July 2010. 

http://aspm.faa.gov/main/taf.asp 

MANE-VU 2007. Mid-Atlantic / Northeast Visibility. Statement of the MidAtlantic/Northeast Visibility Union Concerning a Course of Action within MANE-VU 

Toward Assuring Reasonable Progress. June 20, 2007. 

http://www.otcair.org/manevu/document.asp?fview=Formal%20Actions 

MARAMA 2007. Prepared by MACTEC Federal Programs, Inc. for the Mid-Atlantic 

Regional Air Management Association. Development of Emissions Projections for 2009, 

2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region. 

February 2007. http://www.marama.org/technical-center/emissions-inventory/2002-

inventory-and-projections/mane-vu-future-year-emissions-inventory

MARAMA 2011a. Prepared by MACTEC Engineering and Consulting, Inc. for the MidAtlantic Regional Air Management Association. Technical Support Document for the 

Development of the 2007 Emission Inventory for Regional Air Quality Modeling in the 

Northeast / Mid-Atlantic Region. February 27, 2011. 

MARAMA 2011b. Prepared by MACTEC Engineering and Consulting, Inc. for the MidAtlantic Regional Air Management Association. Technical Support Document for the 
Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region January 23, 2012 

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Development of the 2013/2017/2020 Emission Inventories for Regional Air Quality 

Modeling in the Northeast / Mid-Atlantic Region. February 27, 2011. 

MARAMA 2012a. Prepared by AMEC Environment and Infrastructure and SRA 

International for the Mid-Atlantic Regional Air Management Association. Technical 

Support Document for the Development of the 2007 Emission Inventory for Regional Air 

Quality Modeling in the Northeast / Mid-Atlantic Region Version 3_3. January 23, 2012. 

MARAMA 2012b. Prepared by AMEC Environment and Infrastructure and SRA 

International for the Mid-Atlantic Regional Air Management Association. Technical 

Support Document for the Development of the 2013/2017/2020 Emission Inventories for 

Regional Air Quality Modeling in the Northeast / Mid-Atlantic Region Version 3_3. 

January 23, 2012 

OTC 2001. Prepared by E.H. Pechan & Associates, Inc. for the Ozone Transport 

Commission. Control Measure Development Support Analysis of Ozone Transport 

Commission Model Rules. March 31, 2001. 

http://www.otcair.org/Document.asp?fview=Report#

OTC 2007. Prepared by MACTEC Federal Programs, Inc. for the Ozone Transport 

Commission. Identification and Evaluation of Candidate Control Measures – Final 

Technical Support Document. February 28, 2007. 

http://www.otcair.org/Document.asp?fview=Report#

OTC 2009a. Ozone Transport Commission. Status Report on OTC States’ Efforts to 

Promulgate Regulations Based on OTC 2001 Model Rules. October 19, 2009. 

http://www.otcair.org/interest.asp?Fview=stationary 

OTC 2009b. Ozone Transport Commission. Status Report on OTC States’ Efforts to 

Promulgate Regulations Based on OTC 2006 Model Rules. October 19, 2009. 

http://www.otcair.org/interest.asp?Fview=stationary 

USEPA 2004a. E.H. Pechan & Associates, Inc. for the U.S. Environmental Protection 

Agency Crosswalk Between Source Classification Code (SCC)and Emission Activity 

Growth Factors – Final Technical Memorandum. September 9, 2004. 

http://www.epa.gov/ttn/ecas/SCCcrosswalk.pdf 

USEPA 2004b. E.H. Pechan & Associates, Inc. for the U.S. Environmental Protection 

Agency Crosswalk Between Standard Industrial Classification (SIC) Codes and Emission 

Activity Growth Factors – Final Technical Memorandum. September 9, 2004. 

http://www.epa.gov/ttn/ecas/SICcrosswalk.pdf 
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USEPA 2004c. U.S. Environmental Protection Agency. Nonroad Engine Growth 

Estimates. EPA-420/P-04-08. April 2004. 

http://www.epa.gov/otaq/models/nonrdmdl/nonrdmdl2004/420p04008.pdf

USEPA 2005a. U.S. Environmental Protection Agency. Control of Air Pollution From 

Aircraft and Aircraft Engines; Emission Standards and Test Procedures: Final Rule.

November 17, 2005. http://www.epa.gov/fedrgstr/EPA-AIR/2005/November/Day17/a22704.pdf 

USEPA 2007a. U.S. Environmental Protections Agency. Emissions Modeling 

Clearinghouse - Fugitive Dust Fractions. February 2007. 

http://www.epa.gov/ttn/chief/emch/dustfractions ) 

USEPA 2007b. U.S. Environmental Protection Agency. Guidance for Estimating VOC 

and NOx Emission Changes from MACT Rules. EPA-457/B-07-001. May 2007. 

http://www.epa.gov/ttn/naaqs/ozone/o3imp8hr/documents/guidance/200705_epa457_b-07-

001_emission_changes_mact_rules.pdf 

USEPA 2008a. U.S. Environmental Protection Agency. Control Techniques Guidelines. 

http://www.epa.gov/ttncaaa1/t1ctg.html

USEPA 2008b. U.S. Environmental Protection Agency. Regulatory Impact Analysis: 

Control or Emissions of Air Pollution from Locomotive Engines and Marine Compression 

Engines Less than 30 Liters Per Cylinder. EPA420-R-08-001a. May 2008.

http://www.epa.gov/otaq/regs/nonroad/420r08001a.pdf 

USEPA 2009a. U.S. Environmental Protection Agency. National Mobile Inventory 

Model. http://www.epa.gov/otaq/nmim.htm

USEPA 2009c. U.S. Environmental Protection Agency. Regulatory Impact Analysis: 

Control of Emissions of Air Pollution from Category 3 Marine Diesel Engines. EPA420-R09-019. December 2009. http://www.epa.gov/otaq/regs/nonroad/marine/ci/420r09019.pdf 

USEPA 2009d. U.S. Environmental Protection Agency. Proposal to Designate an 

Emissions Control Area for Nitrogen Oxides, Sulfur Oxides, and Particulate Matter. EPA420-R-09-007. April 2009. http://www.epa.gov/otaq/regs/nonroad/marine/ci/420r09007-

chap2.pdf 

USEPA 2010a. U.S. Environmental Protection Agency. 2020 Emissions Data from 

EPA’s 2005-based V4 Modeling Platform; Projection and Control Factors. Provided by 

Rich Mason on April 15, 2010. 

ftp://ftp.epa.gov/EmisInventory/2005v4/projection_control_packets 
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Page 99

USEPA 2010b. U.S. Environmental Protection Agency. Transport Rule Emission 

Inventories Notice of Data Availability (NODA). Docket ID No. EPA-HQ-OAR-2009-

0491. October 27, 2010. TR_EI_NODA_relevant_CoSTpackets_and_inventories.xls 

ftp://ftp.epa.gov/EmisInventory/2005v4/tr_ei_noda

USEPA 2010c. U.S. Environmental Protection Agency. Advance Notice of Proposed 

Rulemaking on Lead Emissions from Piston-Engine Aircraft Using Leaded Aviation 

Gasoline. April 2010. http://www.epa.gov/oms/regs/nonroad/aviation/420f10013.pdf 

USEPA 2011. U.S. Environmental Protection Agency. Emission Standards Reference 

Guide. http://www.epa.gov/otaq/standards/index.htm
APPENDIX C4

Technical Memo 

Emission Factors for Condensable PM 

Bureau of Air Quality 

Department of Environmental Protection 
[This page intentionally left blank.] 
 MACTEC Federal Programs, Inc. 

 P.O. Box 12077, Research Triangle Park, NC 27709-2077 • Phone: 919-941-0333 • Fax: 919-941-0234

DATE: August 20, 2008 

TO: Julie R. McDill 

Senior Engineer 

Mid-Atlantic Regional Air Management Association, Inc. 

8600 LaSalle Road Suite 636 

Baltimore, MD 21286 

FROM: Arthur Werner, MACTEC 

William Hodan, MACTEC 

Scott Justice, MACTEC 

MACTEC Project 827008G233 

SUBJECT: Emissions Factors for Condensable Particulate Matter Emissions from Electric 

Generating Units 

Introduction 

Accurate emissions factors are needed to model the effect of condensable emissions on regional 

haze in the MANE VU region. Particulate matter smaller than 2.5 micrometers in diameter 

(PM2.5) emitted from stationary sources has two components, particles that are solid regardless of 

stack temperature (filterable) and gases that condense shortly after exiting the stack 

(condensable). For electric generating units (EGUs) burning oil or natural gas, condensable 

particulate matter (CPM) emissions can be greater than filterable emissions. However, there is a 

great deal of uncertainty about the best way to measure condensable emissions. Essentially all 

CPM emissions factors in EPA’s WebFIRE (the database containing AP-42 emissions factors) 

and CPM emissions data collected recently were measured using EPA Reference Method 202. 

In Method 202, an effluent gas stream, after passing through a filter to remove solid particulate, 

is bubbled through a series of impingers to collect CPM. In measuring CPM from combustion of 

fuels containing sulfur, it has been shown by EPA that SO2 collected in the impingers can be 

oxidized to sulfate and produce a variable sulfate artifact that results in overestimation of 

condensable emissions. In this example, if impingers are not purged with nitrogen, errors 

associated with the sulfate artifact may be inflated. The emissions factors in WebFIRE were 

developed from source test data that are more than 10 years old and may not represent newer 

refinements to Method 202. See the following link for more information on Method 202 and the 

nitrogen purge: http://www.epa.gov/ttn/emc/methods/method202.html. 

Because of these and other uncertainties, condensable emissions were not calculated uniformly 

across all states in the MANE-VU region in the 2002 emissions inventory. For the future year 

MANE VU (2009, 2012, and 2018) emissions inventories, MARAMA has requested that 

MACTEC evaluate available data on condensable emissions from EGUs and recommend 

emissions factors to be used for the future year inventories. 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 2 

Summary of Existing AP-42 CPM Emissions Factors 

To establish a baseline for the condensable emissions factors used in the 2002 MANE VU 

emissions inventory and to compare the existing AP-42 emissions factors with emissions factors 

developed from recent source tests, we first reviewed EPA’s FIRE (version 6.25) to identify all 

EGU source/fuel/control device combinations for which AP-42 emissions factors and other 

factors are provided for CPM and PM2.5. These emissions factors are attached in an ACCESS 

database (Attachment 1). The attached database contains all 121 CPM and 51 PM2.5 emissions 

factors that are in the most recent version of FIRE (version 6.25). FIRE 6.25 contains all 

emissions factors published in AP-42 prior to October 2004. This includes the most recent 

updates to AP-42 Chapters 1 and 3, which contain all the external and internal combustion 

emissions factors associated with EGUs and other large combustion sources. The 121 CPM and 

51 PM2.5 EGU emissions factors in FIRE 6.25 are based on only 16 unique emissions factors (14 

from AP-42 and 2 others). The 172 emissions factors were assigned by assuming that each 

unique factor can be applied to a large number of source classification codes (SCCs) similar to 

the one for which the factor was actually developed. 

The 121 CPM EGU emissions factors represent 14 unique emissions factors from the following 

AP-42 sections (number of unique emission factors in parentheses): 

 AP-42 Section 1.1: Bituminous and Subbituminous Coal Combustion (3) 

 AP-42 Section 1.2: Anthracite Coal Combustion (1) 

 AP-42 Section 1.3: Fuel Oil Combustion (2) 

 AP-42 Section 1.4: Natural Gas Combustion (1) 

 AP-42 Section 1.6: Wood Residue Combustion in Boilers (1) 

 AP-42 Section 1.7: Lignite Combustion (3) 

 AP-42 Section 3.1: Stationary Gas Turbines (2) 

 AP-42 Section 3.2: Natural Gas-fired Reciprocating Engines (1) 

For those factors for which information was provided, each FIRE 6.25 emissions factor was 

calculated from data reported in from 2 to 36 test reports. In some cases, no information was 

provided on the number of tests forming the basis for the CPM factor. In addition to the 14 

unique emissions factors from AP-42, there are 2 CPM emissions factors in FIRE 6.25 from 

single independent test reports (not included in AP-42). The assigned quality ratings of the 

factors vary from grade “A” to “E”, with some quality ratings designated as “U” for “Unknown”. 

The A ratings are likely due to the large number of tests conducted for some factors. It appears 

that the data were graded on the number of tests that were conducted to measure PM or PM10, 

and then the corresponding grade was associated with the CPM emissions factors as well. The 

14 unique emission factors were then assigned to many related SCCs, resulting in the 121 CPM 

emissions factors in FIRE 6.25. This information is reflected in the attached database, which 

contains identical emissions factors associated with many SCCs. 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 3 

In addition, for each CPM emissions factor, Attachment 1 also contains the following 

information: 

 SCC 

 SCC Description 

 Control description (if applicable) 

 Fuel heat content (assumed value, based on type of fuel and used to convert 

factors from a mass basis to an energy basis) 

 Notes, reference information, formulae, factor identification number, date and 

description of any assumptions associated with the emissions factor. 

The data in Exhibits 1 and 2 summarize the FIRE 6.25 information in Attachment 1. The 

exhibits list the emissions factors for coal, natural gas, and oil as they have been assigned in 

FIRE 6.25, by fuel type. Because unique emissions factors were assigned multiple times to 

many SCCs associated with the same fuel, we have only represented each unique emission factor 

one time per fuel. In this way, we have prevented the average emissions factors from becoming 

biased due to the number of assignments. We have indicated the emissions factors that have 

been calculated from FIRE 6.25 formulae with fuel sulfur content as the variable. Investigation 

of typical sulfur values for the different grades of coal showed that the sulfur content is best 

represented as a range for all the coal types except for lignite coal. We calculated the emissions 

factors based on established ranges of sulfur content for anthracite, bituminous, and 

subbituminous coal. We then averaged the high and low range value to calculate the emissions 

factor. Please refer to Attachment 1 for additional details on these emissions factors. 

Exhibit 1: FIRE 6.25 Unique CPM Emissions Factors by Coal Type 

Coal Type Anthracite Bituminous Subbituminous Lignite

(units) (lb/MMBtu) (lb/MMBtu) (lb/MMBtu) (lb/MMBtu)

0.0385(1) 0.225(1) 0.125(1) 0.01(2)

0.049(1) 0.02(3) 0.02(3) 0.02(3)

0.04(3) 0.04(3) 0.04(3)

0.026

AVERAGE 0.044 0.095 0.053 0.023

(1) Emissions factor value was calculated by averaging the low and high range CPM emission estimate that 

 resulted from the assignment of a high and low sulfur value in the emissions factor formula. 

(2) Emissions factor value was calculated by assigning a single value (no range) to the sulfur variable in the 

 emissions factor formula. 

(3) Emissions factors applicable to bituminous, subbituminous, and lignite. 

Exhibit 2: FIRE 6.25 CPM Emissions Factors for Natural Gas and Fuel Oil 

Fuel Type Natural Gas Fuel Oil

(units) (lb/MMBtu) (lb/MMBtu)

0.0059 0.01

0.0047 0.0093

0.00991 0.0072

AVERAGE 0.0068 0.0088
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 4 

Updated CPM Emissions Factors from Recent Emissions Test Reports 

To develop CPM emissions factors from recent compliance tests, MACTEC evaluated source 

test reports beginning in 2002 for PM and CPM emissions from utility boilers and turbines firing 

coal, oil, or natural gas from six states: Delaware, Minnesota, New Jersey, North Carolina, 

Pennsylvania, and Wisconsin. We reviewed 162 tests from 83 test reports to obtain CPM test 

data. Additional test reports were reviewed, but did not contain CPM data. [Note that each 

FIRE 6.25 emissions factor consists of data from 2 to 36 test reports.]. All tests for CPM were 

conducted using EPA Method 202 which, as described above, uses water-filled impingers to 

collect condensable gases and aerosols after the filter. A key discriminator of artifact formation 

in Method 202 is the use of a nitrogen gas purge after sample collection to drive out excess SO2

before oxidation to sulfate. Thus, in addition to extracting condensable emissions data and

process information from each test report, we collected whatever details were provided on the 

application of Method 202. MACTEC extracted data from the 162 tests and entered the data in 

the WebFIRE data template (with emphasis on the use of the nitrogen purge). For each test we 

calculated the emissions factor from the emissions data and the process information. The 

condensable emissions factors were sorted by SCC and compared to the condensable emissions 

factors in WebFIRE. 

Exhibit 3 is a breakdown of the number of test reports by state and fuel. Exhibit 4 further breaks 

down the coal test reports by type of coal. As noted above, a key difference in CPM measured 

by EPA Method 202 is whether or not the impingers were purged with nitrogen, Exhibit 5 

provides a summary of the number of tests where impingers were purged, not purged, or not 

specified. 

Exhibit 3: Tests by State and Fuel Type 

State/Fuel Coal Oil Gas

Delaware 3 0 0

Minnesota 16 0 1

New Jersey 10 0 0

North Carolina 27 1 1

Pennsylvania 23 18 19

Wisconsin 32 8 3

Total 111 27 24
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 5 

Exhibit 4: Tests by State and Type of Coal 

State/Fuel Coal* Bituminous Subbituminous

Delaware 3 0 0

Minnesota 7 0 9

New Jersey 7 3 0

North Carolina 26 1 0

Pennsylvania 14 9 0

Wisconsin 32 0 0

Total 89 13 9

(*) Type of coal unspecified. 

Exhibit 5: Tests by State and Nitrogen Purge 

State/Purge Purged Not purged Not specified

Delaware 3 0 0

Minnesota 15 2 0

New Jersey 0 0 10

North Carolina 29 0 0

Pennsylvania 1 25 34

Wisconsin 28 6 9

Total 76 33 53

Exhibits 6 through 9 summarize the results of the CPM and FPM data collected from the 162

tests. The data extracted from the reports and the analyses used to generate the graphs in 

Exhibits 6 through 9 are available in Attachment 2 to this memorandum. Exhibit 6 shows the 

average emissions factors for each fuel from all test reports. The average coal CPM emissions 

factor is 0.023 ± 0.006 lb/MMBtu (95% confidence interval for 111 data points). Most of the 

test reports did not specify the type of coal fired, but based on DOE monthly coal-use data for 

the United States, the majority of coal burned in the United States is either bituminous or 

subbituminous. The average fuel oil CPM emissions factor is 0.013 ± 0.006 lb/MMBtu (95% 

confidence interval for 27 data points), and the average natural gas CPM emissions factor is 

0.005 ± 0.001 lb/MMBtu (95% confidence interval for 24 data points). 

The effect of the nitrogen purge can be seen from comparison of the CPM emissions factor 

results in Exhibits 7 through 9. CPM results from tests for which no nitrogen purge was done are 

noticeably higher than the results from the tests for which the purge was done. A comparison of 

Exhibits 7 and 8 demonstrates the magnitude of the sulfate artifact. The average of the CPM 

emissions resulting from the non-purged tests are 3 times higher than the results of the purged 

tests for coal based on the comparison of 11 non-purged and 66 purged data points. The average 

of the CPM emissions resulting from the non-purged tests are twice the results of the purged tests 

for fuel oil based on the comparison of 12 non-purged and 6 purged data points. For natural gas, 

average CPM emissions resulting from non-purged tests are 3 times higher than the purged tests 

based on comparison of 12 non-purged and 6 purged data points. 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 6 

Exhibit 6: Average Emission Factors By Fuel – All Tests 

Average Emission Factor Comparison by Fuel - All Tests

0

0.02

0.04

0.06

0.08

0.1

0.12

0.14

0.16

Emission Factors (lb/mmBtu)

FPM

CPM

Fuel Type

Total Coal Sub-bituminous

Coal

Bituminous 

Coal

Natural Gas Fuel Oil

Exhibit 7: Emission Factor Comparisons, Purged 

Emission Factor Comparison, Purged

0

0.02

0.04

0.06

0.08

0.1

0.12

0.14

0.16

Emission Factors (lb/mmBtu)

FPM

CPM

Fuel Type

Total Coal Sub-bituminous

Coal

Natural

Gas

Fuel Oil
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 7 

Exhibit 8: Emission Factor Comparisons, Non-Purged 

Emission Factor Comparison, Non-Purged

0

0.02

0.04

0.06

0.08

0.1

0.12

0.14

0.16

Average Emission Factors (lb/mmBtu)

FPM

CPM

Fuel Type

Total Coal Natural Gas Fuel Oil

Exhibit 9: Emission Factor Comparisons, Unknown Purge 

Emission Factor Comparison, Unknown Purge

0

0.02

0.04

0.06

0.08

0.1

0.12

0.14

0.16

Emissions Factors (lb/mmBtu)

FPM

CPM

Fuel Type

Total Coal Bituminous Coal Natural Gas Fuel Oil
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 8 

In addition to categorization by fuel type, we reviewed the available information for each of the 

162 tests, and made assignments of the data points to SCCs for direct comparison to existing 

AP-42 emissions factors. Using the available information and considering the limited number of 

data points (162 total), we decided that the most effective analysis would result from assignment 

of the data points to the 6-digit SCC level. Assignment at the SCC 8-digit level was not possible 

for most test data because the information supplied in most test reports did not indicate the 

specific boiler/turbine type. After the assignments were made, additional calculations were 

completed to calculate the emissions factors by 6-digit SCC. Exhibit 10 contains a summary of 

these data, and the assignments. Complete calculations are provided in Attachment 3 to this 

memorandum. 

Exhibit 10: Summary of CPM Emissions Factors by SCC (6-digit) 

SCC (6-digit) SCC (6-digit)

Description

Number of 

Tests

Average CPM 

Emissions Factor

(lb/MMBtu)

95% Confidence 

Interval

(lb/MMBtu)

1-01-001 Boiler / EGU / Anthracite Coal 1 0.0084 N/A

1-01-002 – all tests Boiler / EGU / 

Bituminous/Subbituminous Coal

102 0.022 ± 0.006

1-01-002 (purged 

only)

Boiler / EGU / 

Bituminous/Subbituminous Coal

63 0.013 ± 0.002

1-01-003 – all tests Boiler / EGU / Lignite 6 0.039 ± 0.029

1-01-005 – all tests Boiler / EGU / Fuel Oil 10 0.014 ± 0.007

1-01-006 – all tests Boiler / EGU / Natural Gas 1 0.00249 N/A

1-01-008 – all tests Boiler / EGU / Petroleum Coke 2 0.05 ± 0.03

2-01-001– all tests Internal Combustion Engine / EGU/ 

Fuel Oil

17 0.013 ± 0.005

2-01-001 (purged 

only)

Internal Combustion Engine / EGU/ 

Fuel Oil

3 0.010 ± 0.004

2-01-002 – all tests Internal Combustion Engine / EGU/ 

Natural Gas

23 0.005 ± 0.001

2-01-002 (purged 

only)

Internal Combustion Engine / EGU/ 

Natural Gas

3 0.0015 ± 0.0002

Summary of Results from Emissions Factors Data Analysis 

In accordance with EPA guidance that CPM emissions determined from Method 202 tests that 

apply nitrogen purging are more reliable than results from tests where purging was not used, we 

will only consider categories where purging was used. Based on the high level of agreement 

among the 63 test data points for the nitrogen purged tests for SCC “1-01-002”in Exhibit 10 

(third row), the CPM emissions factor of 0.013 ± 0.002 lb/MMBtu for bituminous and/or 

subbituminous coal is considered to be a high quality estimate of the CPM emissions factor in 

EGU boilers and we recommend its use. One should be careful in comparing the emissions 

factors in Exhibit 10 with those in Exhibit 1 because the emissions factors in Exhibit 1 for coal 

combustion are averaged over a range of fuel sulfur content and the factors in Exhibit 10 are 

averaged over tests without regard to fuel sulfur. Nevertheless, it should be noted that the 

nitrogen purged CPM emissions factor in Exhibit 10 for combustion of bituminous and 

subbituminous coal are lower than the older emissions factors in FIRE 6.25 by a factor of about 7 

and 4 for bituminous and subbituminous coal, respectively Additionally, because nearly all coal 

fired in the United States is bituminous or subbituminous coal, application of this emissions 

factor for all combustion of bituminous and/or subbituminous coal should greatly improve 

emissions estimates from EGUs. 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 9 

Based on the small sample size of nitrogen purged tests for anthracite and lignite coals, natural 

gas and fuel oil as shown in Exhibit 10, we do not recommend any revisions to FIRE 6.25 

emissions factors. It should be noted that while these data have been shared with EPA, EPA has 

not yet added the data to WebFIRE. 

Comments from state agency review of this technical memorandum 

This technical memorandum was circulated to state agency staff for their review. A number of 

technical changes were made as a result of those comments. In addition, Pennsylvania provided 

the following comments: 

 Pennsylvania DEP is requiring EGU owners/operators in Pennsylvania to conduct source 

testing by June 30, 2009 to determine actual condensable PM emission. 

 The measurement method for CPM has now been updated. EPA's recently developed dry 

impinger method (OTM-028) was not used in the tests used in this study, rather the 

method that was used (Method 202) produces results that are biased high. 

 A follow-up study would be desirable to determine if testing methods affect the 

CPM/TPM ratio. 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 10

APPENDIX A 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 11

Delaware 

NRG Indian River Generating Station, Unit 4, October 31, 2002 

NRG Indian River Generating Station, Unit 2, October 16, 2002 

NRG Indian River Generating Station, Unit 1, October 16, 2002 

Minnesota

Otter Tail Power Company’s Hoot Lake Facility, No. 1 Boiler, Fergus Falls, MN, December 19, 

2006 

Minnesota Power’s Boswell Energy Center, Unit 4, Cohasset, MN, August 26-28, 2002 

Xcel Energy’s Riverside Generating Plant, Units 6, 7 and 8, Minneapolis, MN, October 3-4, 

2006

Xcel Energy Sherburne County Generating Plant, Unit 1/2 Common Stack, Becker, MN, June 

15-16, 2004 

Xcel Energy Sherburne County Generating Plant, Boilers 1 and 2 Common Stack/EP #001, 

Becker, MN, August 28, 2001 

Xcel Energy Sherburne County Generating Station, Unit #3 Exhaust Stack, Becker, MN, 

September 28, 2005 

Xcel Energy Sherburne County Generating Plant, EU001 & EU002/SV001, Becker, MN, April 

27, 2007 

Minnesota Power Laskin Energy Center, Boilers 1 and 2, Hoyt Lakes, MN, February 27, 2007 

and July 24, 2007 

Otter Tail Power Company’s Hoot Lake Facility, Unit 3 Boiler, Fergus Falls, MN, December 20, 

2006

Otter Tail Power Hoot Lake Facility, Unit 3 Boiler, Fergus Falls, MN, August 24, 2006 

Xcel Energy Black Dog Unit #5 Repowering Project, Combustion Turbine #5, Burnsville MN, 

June 26-July 2, 2002 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 12

North Carolina 

Carolina Power & Light Lee Plant, Unit 1, Goldsboro, NC, May 2, 2002 

Carolina Power & Light Lee Plant, Unit 3, Goldsboro, NC, May 1, 2002 

Carolina Power & Light Mayo Plant, Unit 1, Roxboro, NC, May 9, 2002 

Carolina Power & Light L.V. Sutton Steam Electric Plant, Unit No. 1, Wilmington, NC, June 15, 

2002

Carolina Power & Light L.V. Sutton Steam Electric Plant, Unit No.2, Wilmington, NC, June 16, 

2002

Carolina Power & Light L.V. Sutton Steam Electric Plant, Unit No.3, Wilmington, NC, June 13, 

2002

Carolina Power & Light Roxboro Plant, Unit 1, Roxboro, NC, July 23, 2002

Carolina Power & Light Roxboro Plant, Unit 2, Roxboro, NC, May 22, 2002 

Carolina Power & Light Roxboro Plant, Unit 3, Roxboro, NC, July 24, 2002 

Carolina Power & Light WH Weatherspoon Plant, Units 1 & 2, Lumberton, NC, February 13-14, 

2002

Carolina Power & Light WH Weatherspoon Plant, Unit3, Lumberton, NC, March 6, 2002 

Carolina Power & Light WH Weatherspoon Plant, Unit3, Lumberton, NC, September 24, 2002 

Duke Energy Allen Steam Station, Unit 1, Gaston County, NC, August 13, 2002 

Duke Energy Allen Steam Station, Unit 3, Gaston County, NC, August 14, 2002 

Duke Energy Allen Steam Station, Unit 4, Gaston County, NC, August 15, 2002 

Duke Energy Riverbend Steam Station, Unit 4 Boiler 7, Gaston County, NC, October 8, 2002 

Duke Energy Riverbend Steam Station, Unit 5 Stacks A & B, Gaston County, NC, October 9, 

2002

Duke Power Company, Buck Steam Station, Unit No. 3, Spencer, NC, September 11, 2003 

Duke Power Company, Buck Steam Station, Unit No. 5, Spencer, NC, September 10, 2003 

Duke Power Company, Cliffside Steam Station, Unit No. 5, Rutherford County, NC, August 1, 

2002
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 13

Duke Power Company Dan River Steam Station, Unit 2, Eden, NC, May 1, 2002 

Duke Power Company Dan River Steam Station, Unit 1, Eden, NC, April 30, 2002 

Progress Energy Carolina’s Mayo Plant, Unit 1, Roxboro, NC, June 16, 2004 

Progress Energy Asheville Generating Station, Unit T4, Asheville, NC, May 6-9, 2008 

Carolina Power and Electric Roxboro Electric Generating Plant, Unit 1, Roxboro, NC, October 

16, 2001 

Pennsylvania 

Allegheny Energy Supply Company Hatfield’s Ferry Power Station, Stacks 1 & 2, Masontown, 

PA, March 23 and 26, 2007 

Allegheny Energy Supply Company Hatfield’s Ferry Power Station, Stacks 1 & 2, Monongahela 

Township, PA, June 12, 2007 

Reliant Energy Newcastle Plant, Boilers 3 & 5, Taylor Township, PA, March 22, 2005 

Reliant Energy Newcastle Plant, Boiler 4, Taylor Township, PA, May 18, 2005 

Reliant Energy Newcastle Plant, Boilers 3, 4 & 5, Taylor Township, PA, February 27, 2007 

Northampton Generating Company, Northampton, PA, August 23-24, 2005 

PPL Brunner Island, Unit 3 ESP, East Manchester Twp., PA, January 10, 2007 

PPL Brunner Island S.E.S., Unit 1 Exhaust Stack, York Haven, PA, May 15, 2007 

Reliant Energy Elrama Power Plant, Boilers 1-4, Elrama, PA, August 3, 2005 

Reliant Energy Elrama Power Plant, Baghouse Stack, Elrama, PA, November 18, 2005 

Reliant Energy Elrama Power Plant, Elrama, PA, April 12 & 16, 2007 

Reliant Energy Elrama Power Plant, Boilers 1-4, Union Township, PA, December 17, 2007 

PPL Martins Creek Station, Northampton County, 2007 

PPL Generation Montour Steam Electric Station, Boiler 1, Washingtonville, PA, May 16, 2006 

PPL Generation Montour Steam Electric Station, Boiler 2, Washingtonville, PA, April 4, 2007 

Reliant Energy Mid-Atlantic Power Seward Station, Boilers 1 & 2, East Wheatfield Twp., PA, 

December 5, 2004 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 14

Conectiv Bethlehem, Combined Cycle Electric Generation Facility, Combustion Turbines 1-3, 

Bethlehem and Lower Saucon Twp., PA, January 29-March 26, 2003 

Conectiv Bethlehem, Combined Cycle Electric Generation Facility, Combustion Turbines 1-3, 

Bethlehem and Lower Saucon Twp., PA, May20-June 2, 2003 

Conectiv Energy Bethlehem Power Plant, Units 2 & 3, Bethlehem, PA, February 3,4 7,8 & 10, 

2003

Conectiv Energy Bethlehem Power Plant, Unit 2, Bethlehem, PA, May 27-29, 2003 

Conectiv Energy Bethlehem Power Plant, Unit 3, Bethlehem, PA, May 30,31 & June 2, 2003 

Conectiv Energy Bethlehem Power Plant, Unit 1, Bethlehem, PA, January 28-30, 2003 

Conectiv Energy Bethlehem Power Plant, CT 2, Bethlehem & Lower Saucon Twp., PA, 

December 30, 2003 

Conectiv Energy Bethlehem Power Plant, Unit 5, Bethlehem & Lower Saucon Twp., PA, March 

22, 24 2003 

Conectiv Energy Bethlehem Power Plant, CT 3, Bethlehem & Lower Saucon Twp., PA, 

February 8, 10, 2003 

Conectiv Energy Bethlehem Power Plant, CT 7, Bethlehem & Lower Saucon Twp., PA, 

September 25-26, 2003 

Conectiv Energy Bethlehem Power Plant, Unit 5, Bethlehem & Lower Saucon Twp., PA, 

September 15-17, 2003 

Reliant Energy Did Atlantic Power Holding Portland Station, Combustion Turbine #5, Upper 

Mt. Bethel Township, PA, September 24, 2002 

Conectiv Energy Bethlehem Power Plant, CT 6, Bethlehem & Lower Saucon Twp., PA, 

September 22-23, 2003 

New Jersey 

Carney’s Point Generating Plant, Boilers 1 & 2 Carney’s Point, NJ, January 19-29, 2004 

PSEG Hudson Generating Station, Unit No. 2, Hudson, NJ, June 20 & 23, 2003 

Logan Generating Station, Swedesboro, NJ, October 27-28, 2004 

Wisconsin 

Dairyland Power Cooperative Genoa 3 Station, No. 1 Boiler, Genoa, WI, August 3, 2004 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 15

Dairyland Power Cooperative J.P. Madgett Station, No. 1 Boiler, Alma, WI, April 9, 2002 

Dairyland Power Cooperative J.P. Madgett Station, No. 1 Boiler, Alma, WI, May 18, 2006 

Dairyland Power Cooperative J.P. Madgett Station, Baghouse Stack (Main Boiler B25, S11), 

Alma, WI, December 18-19, 2007 

Wisconsin Public Service Corporation J.P. Pulliam Power Plant, Units 3/4 Common Stack, 

Green Bay, WI, July7, 2004 

Madison Gas and Electric Company Blount Generating Station, Unit 7 Outlet Duct, Madison, 

WI, November 6, 2003 

Madison Gas and Electric Company Blount Generating Station, Unit 8 Precipitator Outlet, 

Madison, WI, April 15, 2004 

Manitowoc Public Utilities MPU Power Plant, Boilers B25 and B28, Manitowoc, WI, June 10 

and July 9, 2003 

Manitowoc Public Utilities MPU Power Plant, Boilers B25 and B28, Manitowoc, WI, March 6-

9, 2006 

Wisconsin Electric Power Company Valley Power Plant, Boilers 1 and 2 Inlet and Outlet Ducts, 

October 24 and 26, 2001 

Wisconsin Public Service Corporation Weston Power Plant, Unit 1 Stack, Rothschild, WI, 

December 21, 2005 

We Energies Oak Creek Station, Unit 8 Precipitator Outlet, East and West Inlets, Oak Creek, WI, 

September 4, 2003 

We Energies Valley Power Plant, Boilers 3 and 4 Inlet and Outlet Ducts, Milwaukee, WI, July 

28 and 29, 2003 

Alliant Energy Columbia Station, Unit 1 Stack, Pardeeville, WI, September 4, 2003 

Dairyland Power Alma Station, No. 105 Boiler Stack, Alma, WI June 1, 2006 

Dairyland Power Cooperative Genoa 3 Station, No. 1 Boiler Baghouse Stack, Genoa, WI, July 

24-25, 2007 

We Energies Pleasant Prairie Power Plant, Unit 1 FGD Scrubber Stack, Pleasant Prairie, WI, 

January 24 and 25, 2007 

We Energies Pleasant Prairie Power Plant, Unit 2 FGD Scrubber Stack, Pleasant Prairie, WI, 

May 23 and 24, 2007 
Technical Memorandum: Emissions Factors for Condensable Particulate Matter Emissions from EGUs 

August 20, 2008 Page 16

Northern Wisconsin Center, #3 Boiler Exhaust Stack, Chippewa Falls, WI, March 15, 2005 

Wisconsin Public Service Corporation Weston Power Plant, Unit 4 Auxiliary Boiler Stack, 

November 27, 2007 

Alliant Energy Edgewater Generating Station, Unit 4 Outlet Duct, Sheboygan, WI, March 19, 

2002

Mendota mental Health heating Plant, #2 Boiler Exhaust, Madison, WI, March 21, 2003 

Wisconsin Power and Light Nelson Dewey Generation Station Cassville, Units 1 and 2, 

Cassville, WI, February 22 and 24, 2005 

Manitowoc Public Utilities Custer Plant, Combustion Turbine Stack, Manitowoc, WI, October 2-

5, 2001 

We Energies Port Washington Power Plant, Combustion Turbine 21, Port Washington, WI, 

October 10-11, 2005 

Wisconsin Public Service Corporation Weston Power Plant, Combustion Turbine 32 South 

Stack, Rothschild, WI, December 29-30, 2005 

Madison Gas and Electric Company West Campus Cogeneration Facility, Unit 2, Madison, WI, 

April 11, 12, 15,16, 2005 

Madison Gas and Electric Company West Campus Cogeneration Facility, Unit 1 and the Diesel 

Engine Backup Generator, Madison, WI, February 21 and 22, 2006 

Wisconsin Public Service Corporation Petenwell Dam Hydro Site, Simple Cycle Combustion 

Turbine, Necedah, WI, September 2-5, 2003 

Arcadia Municipal Electric Utility, No. 7 Diesel Engine Outlet, Arcadia, WI, July 31, 2002 

Wisconsin Public Service Corporation Weston Power Plant, Unit 4 Main Diesel Fire Pump, 

Rothschild, WI, January 23, 2007 

Wisconsin Public Service Corporation Weston Power Plant, Unit 4 Diesel Booster Fire Pump, 

February 26, 2008