MARYLAND DEPARTMENT OF THE ENVIRONMENT

1800 Washington Boulevard • Baltimore MD 21230

410-537-3000 • 1-800-633-6101 • www.mde.state.md.us

Martin O'Malley

Governor

Anthony G. Brown

Lieutenant Governor

Robert M. Summers, Ph. D. 

Secretary

Baltimore Nonattainment Area

PM2.5 

Redesignation Request 

SIP Number: 13-10

May 28, 2013

Prepared for:

U.S. Environmental Protection Agency

Prepared by: 

Maryland Department of the Environment
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Baltimore, MD Redesignation Request

Table of Contents

1. Introduction.............................................................................................................................. 1

2. Background.............................................................................................................................. 1

2.1 Health Effects..................................................................................................................... 1

2.2 Baltimore, MD Nonattainment Designation...................................................................... 2

3. USEPA Requirements for Redesignation ................................................................................ 4

3.1 Attainment of the Standard ................................................................................................ 4

3.1.1 PM2.5 Monitoring Data Analysis Requirements ....................................................... 5

3.1.2 Baltimore Area PM2.5 Ambient Air Monitoring Network ........................................ 5

3.1.3 Baltimore Area PM2.5 Annual Concentration Data .................................................. 6

3.1.4 Missing Data under the 1997 Annual PM2.5 Standard.............................................. 9

3.1.5 Quality Assurance..................................................................................................... 10

3.1.6 Continued Monitoring Commitment......................................................................... 10

3.1.7 Clean Data Determination......................................................................................... 10

3.2 Implementation Plan Approval........................................................................................ 11

3.3 Permanent and Enforceable Emission Reductions .......................................................... 11

3.3.1 On-Road Emission Reduction Requirements ........................................................... 11

3.4 Maintenance Plan............................................................................................................. 13

3.5 Section 110 and Part D Requirements............................................................................. 14

3.5.1 Demonstration of Compliance .................................................................................. 14

List of Figures 

Figure 2-1: Baltimore, MD PM2.5 NAAQS Nonatttainment Area.................................................. 3

Figure 3-1: Baltimore, MD Nonattainment Area PM2.5 Monitoring Sites..................................... 6

Figure 3-2: Baltimore Area Annual PM2.5 Data Trends ................................................................ 9

List of Tables

Table 2-1: Baltimore, MD Nonattainment Area with FIPS Codes................................................ 2

Table 3-1: Baltimore, MD Annual PM2.5 Design Values.............................................................. 8

Table 3-2: On-Road Emission Reductions for the Baltimore Area, 2002-2007.......................... 13

Table 3-3: Infrastructure Submittals for Maryland...................................................................... 15
Baltimore, MD PM2.5 Redesignation Request

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Baltimore, MD PM2.5 Redesignation Request Page 1

1. Introduction 

The State of Maryland requests that the United States Environmental Protection Agency 

(USEPA) redesignate the Baltimore, MD 1997 fine particulate (PM2.5) nonattainment area to 

attainment for this standard pursuant to the provisions under § 107 of the federal Clean Air Act 

(CAA). Since the designations for the National Ambient Air Quality Standards (NAAQS) for 

this pollutant were published (Federal Register, Vol. 70, No. 3, 1/5/2005), the area’s PM2.5 air 

quality has improved due to permanent and enforceable emission reductions. Air quality in the 

area is significantly better than required by this standard. Due to the improvement in PM2.5 air 

quality, the USEPA finalized a clean data determination for the Baltimore area on May 22, 2012

(Federal Register, Vol. 77, No. 99, 5/22/2012). The State of Maryland is also requesting that 

USEPA concurrently approve, as a revision to the state implementation plan (SIP), the related 

§ 175A maintenance plan. This plan ensures that good PM2.5 air quality will be maintained 

through 2025.

2. Background 

2.1 Health Effects 

PM2.5, also known as fine particulate matter or fine particles, is defined as any airborne 

particle of solid or liquid matter that is less than or equal to 2.5 micrometers in diameter. PM2.5 is 

not a single pollutant but a sum of all pollutants that have diameters less than 2.5 micrometers, 

which is 1/30th the diameter of a human hair. 

Sources of PM2.5 and PM2.5 precursors include, most significantly, coal-fired power 

plants and other combustion sources, fires, emissions from motor vehicles, windblown dust, and 

natural emissions from trees and the oceans. These sources can be divided up into two types of 

sources, primary and secondary. Primary sources directly emit fine particulate matter into the 

atmosphere without any chemical change occurring to the pollutant. Secondary sources are 

sources from which precursor chemical species are released into the atmosphere and then react 

with other chemical species in the atmosphere to create fine particulate matter. Some species 

which comprise fine particulate matter are sulfates, ammonium nitrate, soot, sea salt, organic 

carbon, and metals (crustal metals, transitional metals, and potassium).

Exposure to high levels of PM2.5 adversely affects human health. The main impacts of 

PM2.5 on human health are on the respiratory system and the cardiovascular system. Children, 

the elderly, and individuals with pre-existing pulmonary or cardiac disease are the most 

susceptible to PM2.5 pollution. Complications that can arise from exposure to elevated levels of 

PM2.5 include decreased lung function, chronic bronchitis, respiratory symptoms such as asthma 

attacks and difficulty breathing, nonfatal heart attacks, irregular heartbeat, and premature death 

in individuals with pulmonary or cardiac disease.
Baltimore, MD PM2.5 Redesignation Request Page 2

2.2 Baltimore, MD Nonattainment Designation 

The CAA requires each state with areas failing to meet the 1997 PM2.5 NAAQS to develop 

SIPs to expeditiously attain and maintain the standards. The USEPA revised the NAAQS for 

particulate matter in July 1997 (Federal Register, Vol. 62, No. 138, 7/18/1997). The USEPA 

issued a new primary (health-based) PM2.5 standard and retained the primary PM10 standard. 

The standards include an annual standard set at 15.0 micrograms per cubic meter (μg/m3), based 

on the 3-year average of annual mean PM2.5 concentrations, and a 24-hour standard of 65 μg/m3, 

based on the 3-year average of the 98th percentile of 24-hour concentrations. 

On December 17, 2004, the USEPA administrator signed the final rule regarding the initial 

PM2.5 nonattainment areas designations for the PM2.5 standards across the country. The final rule 

became effective on April 5, 2005 (Federal Register, Vol. 70, No. 3, 1/5/2005). The Baltimore, 

MD area was originally designated nonattainment for the 1997 PM2.5 NAAQS based on air 

quality data showing that the area did not meet the 15.0 μg/m3 annual standard. Unlike Subpart 2 

of the CAA that defined five ozone nonattainment classifications for the areas that exceed the 

NAAQS based on the severity of the ozone levels, PM2.5 nonattainment designations are simply 

labeled “nonattainment”. The CAA required states with PM2.5 nonattainment areas to submit an 

attainment plan within three years of the effective date of the designations (April 5, 2008) 

detailing how the PM2.5 standards will be attained by April 5, 2010. The attainment plans were 

submitted in a timely manner. 

The area designated nonattainment for the 1997 PM2.5 NAAQS is defined in Table 2-1 and 

depicted in Figure 2-1.

Table 2-1: Baltimore, MD Nonattainment Area with FIPS Codes

Baltimore, MD PM2.5 Nonattainment Jurisdictions

Anne Arundel County (24-003)

Baltimore County (24-005)

Carroll County (24-013)

Harford County (24-025)

Howard County (24-027)

Baltimore City (24-510)
Baltimore, MD PM2.5 Redesignation Request Page 3

FIGURE 2-1: BALTIMORE, MD PM2.5 NAAQS NONATTTAINMENT AREA

(PURPLE AREA ON MAP)

Baltimore, MD

Hagerstown-Martinsburg, MD-WV

Washington, DC-MD-VA

Fine Particulate Matter (PM2.5) Non-Attainment 

Areas in Maryland and Surrounding Jurisdictions

FRM PM-Fine Monitors in Maryland

Baltimore, MD

Hagerstown-Martinsburg, MD-WV

Washington, DC-MD-VA

Fine Particulate Matter (PM2.5) Non-Attainment 

Areas in Maryland and Surrounding Jurisdictions

FRM PM-Fine Monitors in Maryland
Baltimore, MD PM2.5 Redesignation Request` Page 4 

3. USEPA Requirements for Redesignation 

The CAA provides a process whereby a state may petition USEPA to redesignate a 

nonattainment area as attainment. The CAA lists five obligations that the USEPA must meet 

during the redesignation process. Section 107(d)(3)(E) states:

The Administrator may not promulgate a redesignation of a nonattainment

area (or portion thereof) to attainment unless –

(i) the Administrator determines that the area has attained the national

ambient air quality standard;

(ii) the Administrator has fully approved the applicable

implementation plan for the area under section 110(k);

(iii) the Administrator determines that the improvement in air quality is

due to permanent and enforceable reductions in emissions resulting

from implementation of the applicable implementation plan and

applicable Federal air pollutant control regulations and other

permanent and enforceable reductions;

(iv) the Administrator has fully approved a maintenance plan for the

area as meeting the requirements of section 175A; and

(v) the State containing such area has met all requirements applicable

to the area under section 110 and part D.

This document addresses each of these requirements and provides additional information 

to support continued compliance with the 1997 PM2.5 NAAQS. USEPA has published detailed 

guidance in a memorandum from John Calcagni, Director, Air Quality Management Division, 

entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation 

guidance), issued September 4, 1992, to Regional Air Directors.2 40 CFR Part 51, Subpart Z, 

entitled Provisions for Implementation of PM2.5 National Ambient Air Quality Standards

(implementation rule) provides additional information. The State of Maryland has based this 

redesignation request and its associated maintenance plan on the redesignation guidance and the 

implementation rule, supplemented with additional guidance received from staff of USEPA

Region III.

3.1 Attainment of the Standard 

The Baltimore, MD federal reference monitors have demonstrated compliance with the 

65 μg/m3 daily standard since the inception of the PM2.5 monitoring program and thus the focus 

of the attainment demonstration will be on the annual standard. 

A state requesting redesignation must show that the area is attaining the applicable 

NAAQS. The 1997 annual PM2.5 NAAQS is met when the annual design value is less than or 

equal to the 15.0 micrograms per cubic meter (μg/m3). This section presents information that 

demonstrates the Baltimore, MD nonattainment area has attained the NAAQS for PM2.5.

This demonstration is based on three years of quality assured monitoring data as specified 

 2 See http://www.epa.gov/ttn/oarpg/t5/memoranda/redesignmem090492.pdf, accessed April 27, 2012.
Baltimore, MD PM2.5 Redesignation Request` Page 5 

in 40 CFR Part 58.

3.1.1 PM2.5 Monitoring Data Analysis Requirements 

In 1992 the USEPA published “Procedures for Processing Request to Redesignate Areas 

to Attainment”. This is a guidance document that details requirements nonattainment areas 

(NAA) must meet to be redesignated to attainment.

The following are the requirements regarding ambient air monitoring data and attainment:

• Monitoring data must show that the non-attainment area is attaining the NAAQS

• The data should be collected and quality assured in accordance with 40 CFR 58 

and recorded in the USEPA Air Quality System (AQS) database in order for it to 

be available to the public for review.

The monitoring data analysis below illustrates how each of the requirements has been addressed.

3.1.2 Baltimore Area PM2.5 Ambient Air Monitoring Network 

There are currently thirteen (13) sites that monitor PM2.5 in the Baltimore Region. The 

PM2.5 monitoring sites are shown in Figure 3-1. MDE uses both manual gravimetric and 

automated monitors to measure PM2.5 mass concentrations in the Maryland network. A filter 

attached to the inlets of these monitors excludes particles having diameters greater than 2.5 

microns. The PM2.5 Beta Attenuation Monitor (BAM) automatically measures and records dust 

concentrations with built-in data logging. It uses the principal of beta ray attenuation to provide a 

simple determination of mass concentration. An external pump pulls a measured amount of air 

through a filter tape for a one-hour period. The filter tape, impregnated with ambient dust, is 

placed between the source and the detector thereby causing the attenuation of the measured betaparticle signal. The degree of attenuation of the beta-particle signal is used to determine the mass 

concentration of particulate matter on the filter tape and hence the hourly volumetric 

concentration of particulate matter in the ambient air. MDE uses MetOne SuperSAAS samplers 

and IMPROVE samplers for the collection of samples for the chemical speciation of PM2.5. The 

samplers collect 3 to 4 filter samples simultaneously every third or sixth day for a period of 24 

hours. These samples are then sent to an USEPA contract laboratory for chemical analyses. 

There are over 50 species consisting of ions, metals and carbon species quantified by the 

analyses. 
Baltimore, MD PM2.5 Redesignation Request` Page 6 

FIGURE 3-1: BALTIMORE, MD NONATTAINMENT AREA PM2.5 MONITORING 

SITES

3.1.3 Baltimore Area PM2.5 Annual Concentration Data 

To determine whether or not a site is in compliance with the 1997 annual PM2.5 NAAQS, 

the three-year average of annual average PM2.5 concentrations must be calculated and compared 

to the standard of 15.0 μg/m3. For an area to be in compliance with the 1997 PM2.5 NAAQS, all 

sites within that area must be in compliance with the annual NAAQS. Even if there is only one 

station that is not in compliance, that one station makes the entire area a nonattainment area for 

that standard. 

The Baltimore, MD region’s federal reference monitors have demonstrated compliance 

with the 65 μg/m3 daily standard since the inception of the PM2.5 monitoring programs within the 

states. The federal reference monitors have demonstrated compliance with the 15.0 μg/m3

annual standard since 2008. The most recent design value for the annual standard, based on 

2010-2012 data, is 11.0 μg/m3. 

All PM2.5 ambient monitoring data through 2012 have been quality assured in accordance 

with 40 CFR 58.10, recorded in USEPA’s AQS, and made available for public review. The 

2005-2007 design value has been chosen as the attainment year for this area, and therefore the 

Baltimore Nonattainment Area

PM2.5 Monitor PM2.5 Monitor
Baltimore, MD PM2.5 Redesignation Request` Page 7 

attainment year inventory used within this redesignation request and the Section 175A 

maintenance plan is based on the year 2007. 

The state commits to continuing the operation of an appropriate PM2.5 air quality 

monitoring network to verify the maintenance of the attainment status. 

Table 3-1, presented below, shows the PM2.5 design values for the monitoring sites in the 

Baltimore, MD nonattainment area. Note that only valid PM2.5 concentrations were used to 

calculate design values and that all data used in the design value calculations was certified by the 

state and sent to the Director to USEPA, April, 2013.
Baltimore, MD PM2.5 Redesignation Request` Page 8

Page 8

Table 3-1: Baltimore, MD Annual PM2.5 Design Values3

AIRS ID

Site Name

Jurisdiction Date Site 

Started

Sampling 

Ended

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

24-003-0014 

Davidsonville

ANNE 

ARUNDEL 

6/6/1980 12.9 12.1 12.1 11.9 12.2 12

24-003-0019 

Fort Meade

ANNE 

ARUNDEL 

2/1/1980 12/31/2004 13.9 13 12.8 12.7 13.2

24-003-1003 

Glen Burnie

ANNE 

ARUNDEL 

1/1/1965 15.7 15.3 15.2 15.3 14.9 14.3 13.3 12.3 11.5 10.9 10.7

24-003-2002 

Riviera Beach

ANNE 

ARUNDEL 

1/1/1968 12/31/2005 14.4 14.2 14.1 14.6 15.1 15.7

24-005-1007 

Padonia

BALTIMORE 1/1/1979 14.6 14.2 13.8 14 13.7 13.6 12.6 11.8 10.8 10.1 9.6

24-005-3001 

Essex

BALTIMORE 4/1/1967 15 15.2 14.9 15.1 14.8 14.5 13.6 12.6 11.7 11.1 11.0

24-025-1001 

Edgewood

HARFORD 1/1/1980 13.8 12.8 12.5 12.9 12.6 12.4 11.7 11 10.1 9.8 10.3

24-510-0006 

NE Police 

Station

BALTIMORE 1/1/1970 14.9 14.1 14.1 14.4 14.2 13.8 12.8 11.8 10.8 10 10.0

24-510-0007 

NW Police 

Station

BALTIMORE 1/1/1970 15.4 15 14.7 15 14.3 13.9 12.9 12 11 10.2 9.9

24-510-0008

Fire Dept. 20

BALTIMORE 1/1/1970 17.4 16.5 15.3 15.9 15.9 15.6 14 12.9 11.6 10.9 10.4

24-510-0035 

Fairfield FMC

BALTIMORE 1/1/1980 8/18/2008 16.4 15.9 15.8 16.2 15.7 15.1 14.5**

24-510-0040

Old Town

BALTIMORE 1/1/1981 16.9 16.6 16.3 16.6 16 15.2 14 12.7 11.7 11.3 11.1

24-510-0049 

Westport E S

BALTIMORE 7/1/1990 12/31/2005 15.3 15.4 15.3 15.6 15.8 16.1

Baltimore NAA annual design value* 17.4 16.5 15.8 16.2 15.9 16.1 14 12.9 11.7 11.1 11.0

*The site, “Old Town,” AIRS ID 24-510-0040, should not be used for planning attainment of the annual NAAQS, because it measures the ‘middle-scale’ near a busy 

downtown intersection.

**For 2008, the site "Fairfield FMC" AIRS ID 24-510-0035 was shut down in August and did not report enough data to calculate a valid design value. Therefore this value 

was not used in the Baltimore non-attainment area design value designation. 

 3 Report of Maryland PM2.5 Design Values, MDE Air Monitoring Program
Baltimore, MD PM2.5 Redesignation Request` Page 9 

Figure 3-2 shows a decreasing trend in the annual PM2.5 design value as well. For each 

year from 2002 to 2012, the annual PM2.5 design value decreased for the Baltimore, MD 1997 

PM2.5 NAAQS nonattainment area. Over this time period, the annual PM2.5 design value 

improved dramatically.

FIGURE 3-2: BALTIMORE AREA ANNUAL PM2.5 DATA TRENDS4

3.1.4 Missing Data under the 1997 Annual PM2.5 Standard 

Annual PM2.5 attainment is determined according to federal procedures cited in Appendix 

N to Part 50—Interpretation of the National Ambient Air Quality Standards for PM2.5. For a 

single site, 3 years of valid annual means are required to produce a valid annual standard design 

value.

A year meets data completeness requirements when at least 75 percent of the scheduled 

sampling days for each quarter have valid data. Quarterly data capture rates (expressed as a 

percentage) are specifically calculated as the number of creditable samples for the quarter 

 4 PM2.5 Design Values, MDE Air Monitoring Program
Baltimore, MD PM2.5 Redesignation Request` Page 10 

divided by the number of scheduled samples for the quarter, the result then multiplied by 100 and 

rounded to the nearest integer. Years with at least 11 samples in each quarter can be considered 

valid, as long as the quarters meet the capture requirements, if certain requirements are met. (See 

abovementioned CFR for further information.) If these criteria are not met, then compliance 

with the annual PM2.5 standard cannot be established. To date, acceptable monitoring has been 

maintained and exceeded in the State of Maryland for the annual PM2.5 standard.

3.1.5 Quality Assurance 

The Maryland ambient air monitoring data used in the above analysis has been quality 

assured in accordance with 40 CFR Part 58 and Maryland’s Quality Assurance Project Plan 

(QAPP) for particulate matter. Maryland’s QAPP is a detailed description of the state’s actions

to assure the collection of ambient air monitoring measurements of sufficient quality and 

quantity. In addition, the ambient air monitoring network is reviewed annually through the 

Annual Ambient Air Monitoring Network Plans, in accordance with 40 CFR Park 58.10. A site 

can be discontinued or relocated based on the annual review and with approval from the USEPA 

Regional Administrator. The Maryland quality assured ambient air monitoring data is submitted 

into the AQS database and is available to the public.

3.1.6 Continued Monitoring Commitment 

The State of Maryland is committed to continue monitoring PM2.5 concentrations in the 

Baltimore area and throughout the state in accordance with 40 CFR Part 58 and USEPA 

approved Annual Monitoring Plans. Maryland will continue to quality assure the ambient air 

monitoring data in accordance with 40 CFR 58 and submit the data into the AQS in a timely 

fashion.

The State of Maryland commits to continue working with the USEPA to ensure that the 

PM2.5 monitoring network is sufficiently meeting the monitoring requirement of 40 CFR 58 and 

its monitoring objectives.

3.1.7 Clean Data Determination 

On November 23, 2011, USEPA published a proposed rule in the Federal Register stating 

that the Baltimore, MD PM2.5 nonattainment area has attained the 1997 annual PM2.5 standard

based on three years of quality assured ambient air quality data (Federal Register Vol. 76, No. 

226, 11/23/2011). The USEPA finalized this clean data determination for the Baltimore area on 

May 22, 2012 (Federal Register, Vol. 77, No. 99). 
Baltimore, MD PM2.5 Redesignation Request` Page 11 

3.2 Implementation Plan Approval 

The area must have a fully approved PM2.5 implementation plan. The State of Maryland 

Plan for PM2.5 and Attainment Demonstration for the Baltimore, MD Nonattainment Area was 

proposed for public hearing on April 30, 2008, and was submitted to USEPA in June 2008. 

Section 110(k) of the CAA established criteria that any plan submission must meet before 

USEPA is required to act on the submission. This PM2.5 SIP was deemed to be complete (except 

for the PM2.5 Nonattainment NSR) on December 8, 2008. In that plan, Maryland adopted 

several regulations and programs as needed to reduce PM2.5 and precursors.

3.3 Permanent and Enforceable Emission Reductions 

As noted in § 107(d)(3)(E)(iii) and in the redesignation guidance, a state must be able to 

reasonably attribute its air quality improvements to PM2.5 precursor and direct PM2.5 emission 

reductions that are both permanent and enforceable. Attainment resulting from temporary 

reductions in emission rates (such as reduced production or shutdown due to temporary adverse 

economic conditions) or unusually favorable meteorological conditions does not qualify.

In making this showing, the state should estimate the percent reduction (from the year 

that was used to determine the design value for designation and classification) achieved from 

federal and state measures. Estimates should consider factors such as emission rates and 

production capacities in order to show that the improvements are the result of implemented 

controls. The analysis should assume that sources are operating at permitted levels (or historic 

peak levels), unless evidence is presented that such an assumption is unrealistic.

For this redesignation request and the associated maintenance plan, ammonia and volatile 

organic compounds (VOC) are precursors, however, they are not considered significant overall 

contributors to PM2.5 air quality issues, as noted in the PM2.5 implementation rule at 40 CFR 

51.1002(c)(3). Therefore, this maintenance demonstration focuses on SO2, direct PM2.5, and 

NOX. Although the focus of the redesignation request and maintenance plan is on the dominant 

PM2.5 precursors (SO2, direct PM2.5, and NOX), all PM2.5 precursors (ammonia and volatile 

organic compounds included) are evaluated in Appendix G of the Maintenance Plan. 

Permanent and enforceable reductions of PM2.5, NOX, and SO2 from a variety of state and

federal measures have contributed to the attainment of the standard for fine particles. Measures 

that have contributed to fine particulate air quality improvement include, but are not limited to, a 

variety of on-road emissions control programs and the Healthy Air Act.

3.3.1 On-Road Emission Reduction Requirements 

A variety of federal vehicle control programs have contributed to reduced on-road 

emissions of PM2.5, NOX, and SO2 in the Baltimore, MD nonattainment area between 2002 and 

2007. These programs include:
Baltimore, MD PM2.5 Redesignation Request` Page 12 

• Federal Tier 1 New Vehicle Emission and New Federal Evaporative Emission Standards: 

Under § 202, USEPA established federal motor vehicle emission standards (Tier I 

standards), which were phased in beginning with model year 1994. The benefits of this 

program are reflected in the 2002 base year inventory and the 2007 attainment year 

inventory. This federally implemented program affects light duty vehicles and light duty 

trucks. The regulations require more stringent exhaust emission standards as well as a 

uniform level of evaporative emission controls.

• National Low Emission Vehicle Program: Under the National Low Emission Vehicle 

program, automobile manufacturers agreed to comply with tailpipe standards that were 

more stringent than USEPA could mandate prior to model year 2004. Once 

manufacturers committed to the program, the standards became enforceable in the same 

manner in which other federal motor vehicle emission control requirements were 

enforceable. The program was in place nationwide for model year 2001, and the benefits 

of this program are reflected in the 2002 base year inventory and the 2007 attainment 

year inventory.

• Tier 2 Motor Vehicle Emission Regulations: On February 10, 2000 (65 FR 6698), 

USEPA promulgated a rule requiring more stringent tailpipe emissions standards for all 

passenger vehicles, including sport utility vehicles, minivans, vans, and pick-up trucks. 

These regulations also required lower levels of sulfur in gasoline, which ensured the 

effectiveness of low emission control technologies in vehicles and reduced harmful air 

pollution. The tailpipe and sulfur standards required passenger vehicles to be 77 to 95 

percent cleaner than those built before the rule was promulgated and reduced the sulfur 

content of gasoline by up to 90 percent by 2006. The benefits of this program are 

reflected in the 2007 attainment year on-road mobile inventory.

• Heavy Duty Diesel Engine Rule: This federal rule (66 FR 5002) required truck 

manufacturers to comply with more stringent tailpipe standards by 2004 and 2007. The 

rule also mandated use of ultra-low sulfur diesel fuel to enable modern pollution control 

technology on trucks and buses. Refiners began producing the cleaner-burning diesel 

fuel for use in highway vehicles beginning June 1, 2006. The benefits of this program are 

reflected in the 2007 attainment year inventory for on-road mobile sources. 

The reductions in emissions from the on-road sector between 2002 and 2007 are 

presented in Table 3-2.. These emissions estimates are derived using the Motor Vehicle 

Emissions Simulator (MOVES2010a), Travel Demand Model Version 2.3, and the most recent 

planning assumptions as updated in the Baltimore Metropolitan Council Forecast. To calculate 

incremental benefits from the implementation of the individual control measures listed above is 

very difficult. Therefore, the information presented summarizes the combined benefits of these 

rules. More information on the development of these emissions estimates may be found in the 

Technical Support Document (see the Baltimore Nonattainment Area PM2.5 Maintenance Plan, 

“Appendix D: Emission Inventory Documentation)”.
Baltimore, MD PM2.5 Redesignation Request` Page 13 

Table 3-2: On-Road Emission Reductions for the Baltimore Area, 2002-2007

2002 On-Road Emissions 2007 On-Road Emissions

2002-2007

% On-Road Reduction, 

Area-Wide

SO2 On-Road Emissions, tpy

2,025.51 385.34 80.98%

NOX On-Road Emissions, tpy

76,060.01 49,140.12 35.39%

PM2.5 On-Road Emissions, tpy

2,344.86 1,789.28 23.69%

3.4 Maintenance Plan 

Section 107(d)(3)(E) of the CAA stipulates that for an area to be redesignated, USEPA 

must fully approve a maintenance plan that meets the requirements of § 175(A). States may 

submit both the redesignation request and the maintenance plan at the same time, and rulemaking 

on both may proceed on a parallel track. All applicable nonattainment area requirements remain 

in place. The maintenance plan will constitute a SIP revision and must provide for maintenance 

of the relevant NAAQS in the area for at least 10 years after redesignation. Section 175(A) 

further states that the plan shall contain such additional measures, if any, as may be necessary to 

ensure such maintenance. States must also submit a SIP revision eight years after the original 

redesignation request is approved to provide for maintenance of the NAAQS for an additional 10 

years following the first 10-year period.

USEPA requires the following provisions to ensure maintenance of the NAAQS:

• The state must develop an attainment emissions inventory to identify the level of 

emissions in the area which is sufficient to attain the NAAQS.

• A state may generally demonstrate maintenance by showing that future emissions of a 

pollutant or its precursors will not exceed the level of the attainment inventory over the 

10-year period following redesignation.

• Once an area has been redesignated, the state must continue to operate an appropriate air 

quality monitoring network in order to verify the area's attainment status.

• The state must ensure that it has the legal authority to implement and enforce all 

measures necessary to attain and maintain the NAAQS. Continued attainment must be 

verified by the state by indicating how maintenance plan progress will be tracked.

• Contingency measures must be available to promptly correct any NAAQS violation. At a 

minimum, the contingency measures must include a requirement that the state will 

implement all measures contained in the nonattainment SIP prior to redesignation. 
Baltimore, MD PM2.5 Redesignation Request` Page 14 

An appropriate maintenance plan for the area meeting all federal requirements is being 

submitted along with this redesignation request. This maintenance plan relies upon programs 

such as the Healthy Air Act, New Source Review permitting, Tier II vehicle emission standards, 

and other on-road and nonroad engine standards, to demonstrate that air quality will be 

maintained at least 10 years into the future. The plan contains contingency measures to be 

implemented in case of worsening air quality and mobile vehicle emission budgets for 

transportation conformity purposes.

The State of Maryland’s PM2.5 Maintenance Plan for the Baltimore, MD area is provided 

as a separate document, titled Baltimore Nonattainment Area PM2.5 Maintenance Plan.

3.5 Section 110 and Part D Requirements 

States must provide assurances that the applicable implementation plan has been fully 

approved by USEPA under § 110(k) and must satisfy all requirements that apply to the area. 

Approval action on SIP elements and the redesignation request may occur simultaneously. An 

area cannot be redesignated if a required element of its plan is the subject of a disapproval; a 

finding of failure to submit or to implement the SIP; or partial, conditional, or limited approval. 

For purposes of redesignation, states must meet all requirements of § 110 and Part D of 

the CAA that were applicable prior to submittal of the complete redesignation request. Subpart 1 

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

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

requirements applicable to particulate matter (specifically to address PM10). However, for the 

purpose of implementing the 1997 PM2.5 standard, the USEPA’s implementation rule stated 

Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM2.5 (Federal 

Register, Vol.72, No. 79, 4/25/2007).

3.5.1 Demonstration of Compliance 

The Baltimore, MD area has had few SIP submittal requirements in the past since the 

area has not been a persistent nonattainment area for PM2.5. Since the area’s air quality 

improved so that the area met the 1997 PM2.5 NAAQS well prior to the 2010 compliance date, 

most requirements, other than those associated with major new source review permitting and 

conformity, were limited.

Section 110(a) of the CAA contains the general requirements for a SIP. Section 

110(a)(2) provides that the implementation plan submitted by a state must have been adopted by 

the state after reasonable public notice and hearing, and that, among other things, it must:

• Include enforceable emission limitations and other control measures, means or techniques 

necessary to meet the requirements of the CAA; 

• Provide for establishment and operation of appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 
Baltimore, MD PM2.5 Redesignation Request` Page 15 

• Provide for implementation of a source permit program to regulate the modification and 

construction of any stationary source within the areas covered by the plan; 

• Include provisions for the implementation of Part C, prevention of significant 

deterioration (PSD) and Part D, NSR permit programs; 

• Include criteria for stationary source emission control measures, monitoring, and 

reporting; 

• Include provisions for air quality modeling; and 

• Provide for public and local agency participation in planning and emission control rule 

development.

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

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

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

not attaining the standard. The requirements for an emissions inventory were satisfied by the 

information in Chapter 3 and Appendix A of the Baltimore Nonattainment Area PM2.5 State 

Implementation Plan and Base Year Inventory (SIP Number: 08-04), which was submitted to 

USEPA on June 6, 2008.

The SIP contains provisions that are consistent with the § 176(c)(4) conformity

requirements. For Maryland’s SIP, both general conformity requirements and transportation 

conformity requirements are contained in COMAR 26.11.26.
MARYLAND DEPARTMENT OF THE ENVIRONMENT

1800 Washington Boulevard • Baltimore MD 21230

410-537-3000 • 1-800-633-6101 • www.mde.state.md.us

Martin O'Malley

Governor

Anthony G. Brown

Lieutenant Governor

Robert M. Summers, Ph. D. 

Secretary

Baltimore Nonattainment Area

PM2.5 

Maintenance Plan

SIP Number: 13-10

May 27, 2013

Prepared for:

U.S. Environmental Protection Agency

Prepared by: 

Maryland Department of the Environment
This Page Left Intentionally Blank
Baltimore, MD PM2.5 Maintenance Plan – Table of Contents

Table of Contents

1. Introduction ......................................................................................... 1

1.1 National Ambient Air Quality Standard (NAAQS) for Fine Particulate Matter............ 1

2. Background .......................................................................................... 2

2.1 Health Effects from Elevated Concentrations of PM2.5 .................................................. 2

2.2 Geographical Description of the Baltimore, MD PM2.5 Nonattainment Area................ 3

3. U.S. EPA Redesignation and Maintenance Plan Requirements ............... 5

3.1 Attainment of the Standard ............................................................................................. 5

3.2 Implementation Plan Approval....................................................................................... 6

3.3 Permanent and Enforceable Improvement...................................................................... 6

3.4 Maintenance Plan............................................................................................................ 6

3.5 Commitment to Revise Plan ........................................................................................... 8

3.6 Public Participation......................................................................................................... 8

3.7 Legal Authority to Implement and Enforce.................................................................... 8

4. Maintenance Plan Development ............................................................ 9

4.1 Attainment Inventory...................................................................................................... 9

4.1.1 Summary...............................................................................................................10

4.2 Projection Inventory ..................................................................................................... 10

4.2.1 Summary...............................................................................................................11

4.3 Demonstration of Maintenance..................................................................................... 11

4.3.1 Projected	Emissions	below	Attainment	Year	Emissions.......................................12

4.3.2 Control	Measures	for	Maintenance	of	Good	Air	Quality......................................12

4.3.2.1 Point Sector Controls........................................................................................ 13

4.3.2.2 Nonroad Diesel Emission Reduction Programs................................................ 15

4.3.2.3 On-Road Emission Reduction Programs.......................................................... 15

4.4 Commitment to Operate Air Quality Monitoring Network .......................................... 16

4.5 Legal Authority – Verify Continued Attainment.......................................................... 17

4.6 Transportation Conformity and Mobile Source Emissions Budgets............................ 18

4.6.1 Budget	Level	for	On-Road	Mobile	Source	Emissions............................................21

4.7 Contingency Measures.................................................................................................. 23

4.7.1 Exceedance	of	the	Attainment	Year	Emissions	Inventory ....................................24

4.7.2 Near	Term	Contingency	Measures	for	Air	Quality	Exceedances ..........................24

4.7.3 Long	Term	Contingency	Measures .......................................................................24

4.7.4 Contingency	Measure	Implementation	Schedule ................................................25

Appendices ............................................................................................... 26
Baltimore, MD PM2.5 Maintenance Plan List of Figures and Tables

List of Figures 

Figure 2-1: Baltimore, MD 1997 PM2.5 NAAQS Nonattainment Area (purple on map).............. 4

Figure 4-1: Large EGUs in the Baltimore, MD Area .................................................................. 14

Figure 4-2: Baltimore, MD PM2.5 Monitoring Sites .................................................................. 17

Figure 4-3: Baltimore, MD Annual PM2.5 Trend......................................................................... 21

List of Tables

Table 2-1: Baltimore, MD Nonattainment Area with FIPS Codes................................................. 3

Table 4-1: 2007 Baltimore, MD Attainment Year Inventory ...................................................... 10

Table 4-2: Growth Assumptions Used in Emission Inventory Projections................................. 11

Table 4-3: Baltimore, MD NOx, SO2, & Primary PM2.5 Emissions, 2007 to 2025 ..................... 12

Table 4-4: Comparison of SO2 Emissions from On-Road Sources to the Total SO2 Inventory.. 20

Table 4-5: Baltimore, MD Maintenance Plan On-Road Mobile Source Emissions Budgets...... 22

Table 4-6: Baltimore, MD NOx, SO2, & Primary PM2.5 Emissions, 2007 to 2025 with Mobile 

Budgets ......................................................................................................................................... 22

Table 4-7: Contingency Control Measures.................................................................................. 24
Baltimore, MD PM2.5 Maintenance Plan Page 1

1. Introduction

The State of Maryland is submitting this maintenance plan for the Baltimore, MD 1997 fine 

particulate (PM2.5) nonattainment area to the United States Environmental Protection Agency 

(USEPA) in support of the Baltimore, MD redesignation request for that standard. This 

document demonstrates that PM2.5 air quality in the Baltimore, MD area will remain 

compliant with the 1997 PM2.5 NAAQS, as measured by a monitoring network that meets all 

federal requirements. This plan includes mobile vehicle emissions budgets for the interim 

year of 2017 and the out year of 2025. It also contains contingency measures that will be 

implemented in the unlikely event that the area experiences an exceedance of the 1997 PM2.5

NAAQS. 

1.1 National Ambient Air Quality Standard (NAAQS) for Fine Particulate Matter

When USEPA establishes a NAAQS, this standard applies to the concentration of a pollutant 

in ambient outdoor air. Ambient air is considered to be the air that someone in the general 

public would breathe. If the air quality in a geographic area meets or is cleaner than the 

national standard, it is designated an attainment area; areas that do not meet the national 

standard or contribute to another area that violates the air quality standard are designated as 

nonattainment areas.

Fine particulate matter, or PM2.5, is a mixture of microscopic solids and liquid droplets 

suspended in air. PM2.5 describes particulate matter that is 2.5 micrometers in diameter and 

smaller, 1/30th the diameter of a human hair. Fine particles are generally emitted from 

activities such as industrial and residential combustion and from vehicle exhaust. Fine 

particles are also formed in the atmosphere when gases such as sulfur dioxide, nitrogen 

oxides, and volatile organic compounds are chemically transformed into particles.

USEPA established the fine particle standards in July of 1997 after evaluating health studies

and conducting an extensive peer review process. The 1997 annual standard was established 

at a level of 15 micrograms per cubic meter, based on the 3-year average of annual mean 

PM2.5 concentrations.
Baltimore, MD PM2.5 Maintenance Plan Page 2

2. Background

In 1997, USEPA established two new PM2.5 standards: an annual standard of 15.0 μg/m3 and 

a 24-hour standard of 65 μg/m3. USEPA designated the Baltimore, MD area as nonattainment 

for the 1997 PM2.5 NAAQS with an effective date of April 5, 2005 (Federal Register, Vol. 70, 

No. 3, 1/05/2005). 

Since this designation was made, PM2.5 air quality in the Baltimore, MD area has improved 

such that the air quality is significantly better than required by the 1997 PM2.5 NAAQS. The 

Baltimore, MD region’s federal reference monitors have demonstrated compliance with the 

65 μg/m3 daily standard since the inception of the PM2.5 monitoring programs within each 

state. The federal reference monitors have demonstrated compliance with the 15.0 μg/m3

annual standard since 2008. The most recent design value for the 24-hour standard, based on 

2009-2011 data, is 29 μg/m3, and the most recent design value for the annual standard, based 

on 2009-2011 data, is 11.1 μg/m3. 

These improvements in air quality are due to permanent and enforceable emissions reductions 

of sulfur dioxide (SO2) and nitrogen oxides (NOX), the precursors to PM2.5, and also in 

reductions of primary PM2.5 emissions. This document provides a maintenance plan, as 

required under Section 175A of the federal Clean Air Act (CAA), to ensure that the citizens of 

the Baltimore, MD area enjoy the benefits of healthy air quality that complies with the 1997 

PM2.5 NAAQS for a minimum of 10 years, through 2025. This maintenance plan supports the 

redesignation request that the State of Maryland is submitting to USEPA concurrently with 

this document. 

2.1 Health Effects from Elevated Concentrations of PM2.5

Health studies have shown a significant association between exposure to fine particles and 

premature death from heart or lung disease. Fine particles can aggravate heart and lung 

diseases and have been linked to effects such as: cardiovascular symptoms; cardiac 

arrhythmias; heart attacks; respiratory symptoms; asthma attacks; and bronchitis. These 

effects can result in increased hospital admissions, emergency room visits, absences from

school or work, and restricted activity days.

Roughly one out of every three people in the United States is at a higher risk of experiencing 

PM2.5 related health effects. One group at high risk is active children because they often spend 

a lot of time playing outdoors at times when concentrations of fine particles are higher. In 

addition, children’s bodies are still developing and they breathe more air per pound of body 

weight than adults do. The elderly population is often at high risk due to reduced lung 

capacity or preexisting medical conditions. People of all ages who are active outdoors are at 

increased risk because during physical activity, PM2.5 penetrates deeper into the parts of the 

lungs that are more vulnerable to injury.
Baltimore, MD PM2.5 Maintenance Plan Page 3

2.2 Geographical Description of the Baltimore, MD PM2.5 Nonattainment Area

USEPA designated the Baltimore, MD area as nonattainment for the 1997 PM2.5 NAAQS 

with an effective date of April 5, 2005 (Federal Register, Vol. 70, No. 3, 1/05/2005). Table 

2-1 provides the jurisdictions within the Baltimore, MD 1997 PM2.5 nonattainment area, and 

Figure 2-1 depicts the map of the area.

Table 2-1: Baltimore, MD Nonattainment Area with FIPS Codes

County Name State/County FIPS

Anne Arundel County 24003

Baltimore County 24005

Carroll County 24013

Harford County 24025

Howard County 24027

Baltimore City 24510
Baltimore, MD PM2.5 Maintenance Plan Page 4

Figure 2-1: Baltimore, MD 1997 PM2.5 NAAQS Nonattainment Area (purple on map)

Baltimore, MD

Hagerstown-Martinsburg, MD-WV

Washington, DC-MD-VA

Fine Particulate Matter (PM2.5) Non-Attainment 

Areas in Maryland and Surrounding Jurisdictions

FRM PM-Fine Monitors in Maryland

Baltimore, MD

Hagerstown-Martinsburg, MD-WV

Washington, DC-MD-VA

Fine Particulate Matter (PM2.5) Non-Attainment 

Areas in Maryland and Surrounding Jurisdictions

FRM PM-Fine Monitors in Maryland
Baltimore, MD PM2.5 Maintenance Plan Page 5

3. U.S. EPA Redesignation and Maintenance Plan Requirements

An area designated as nonattainment for a pollutant can be redesignated to attainment if

specific conditions are met. Maryland followed the USEPA published memorandum entitled 

“Procedures for Processing Requests to Redesignate Areas to Attainment” (September 4, 

1992) in preparing the redesignation demonstration and the maintenance plan. The 

memorandum provides guidance regarding the processing of requests for redesignation of 

nonattainment areas to attainment for ozone, carbon monoxide, particulate matter, sulfur 

dioxide, nitrogen dioxide, and lead.

Furthermore, the CAA lists five obligations that the USEPA must meet during the 

redesignation process. Section 107(d)(3)(E) states:

The Administrator may not promulgate a redesignation of a nonattainment area

(or portion thereof) to attainment unless –

(i) the Administrator determines that the area has attained the national

ambient air quality standard;

(ii) the Administrator has fully approved the applicable implementation plan

for the area under section 110(k);

(iii) the Administrator determines that the improvement in air quality is due to

permanent and enforceable reductions in emissions resulting from

implementation of the applicable implementation plan and applicable

Federal air pollutant control regulations and other permanent and 

enforceable reductions;

(iv) the Administrator has fully approved a maintenance plan for the

area as meeting the requirements of section 175A; and

(v) the State containing such area has met all requirements applicable to the area

under section 110 and part D.

These 5 obligations must be met before redesignation to attainment status; however, a state 

may submit both the redesignation request and the maintenance plan at the same time so that 

rulemaking on both may proceed on a parallel track. This document outlines Maryland’s

redesignation request and demonstrates how the state supports EPA’s promulgation 

obligations towards the redesignation of the Baltimore nonattainment area under the 1997 

PM2.5 NAAQS.

3.1 Attainment of the Standard

A state requesting redesignation must show that the area is attaining the applicable NAAQS. 

EPA, in turn, must determine that the annual PM2.5 NAAQS in ambient air is demonstrated if 

the design value based on the last three (3)-year annual mean is less than the 15.0 microgram 

per cubic meter level of the NAAQS. In Maryland’s redesignation request, Maryland presents 

information that demonstrates that the Baltimore, MD region has attained the NAAQS for 

PM2.5. This demonstration is based on three years of quality assured monitoring data as 

specified in 40 CFR 58. On November 23, 2011, USEPA published a proposed rule in the 

Federal Register stating that the Baltimore, MD PM2.5 nonattainment area had attained the 
Baltimore, MD PM2.5 Maintenance Plan Page 6

1997 annual PM2.5 standard based on three years of quality assured ambient air quality data 

(76 FR 72374, November 23, 2011). On May 22, 2012, EPA published a final rule in the 

Federal Register stating that the Baltimore, Maryland fine particulate (PM2.5) nonattainment

area has attained the 1997 annual PM2.5 standard based on three years of quality assured 

ambient air quality data (77 FR 30208). Due to this improvement in PM2.5 air quality, the 

Baltimore, MD nonattainment area is currently operating under a clean data determination 

(Federal Register, Vol. 77, No. 99, Tuesday, May 22, 2012).

3.2 Implementation Plan Approval

The area must have a fully approved PM2.5 implementation plan. The State of Maryland State 

Implementation Plan and Attainment Demonstration for PM2.5 for the Baltimore, MD 

Nonattainment Area was presented for public hearing on April 30, 2008 and was submitted to 

USEPA in June 2008. Section 110(k) of the CAA established criteria that any plan 

submission must meet before USEPA is required to act on the submission. This PM2.5 SIP

was deemed to be complete on December 8, 2008. In that plan, Maryland adopted several 

regulations and programs as needed to reduce PM2.5 and precursors.

3.3 Permanent and Enforceable Improvement

The USEPA must show that the improvement in air quality between the year when violations

occurred and the attainment year is attributed to permanent and enforceable emission 

reductions. Section 4 of this document presents the reduction that was achieved from federal 

and state measures. The emission reduction is not based on temporary shutdowns or adverse 

economic conditions, but due to permanent and enforceable control measures. Section 4.3.2

of this document includes an outline of the control measures that have brought the area into 

attainment of the PM2.5 standard. This plan includes a state commitment to continue to 

enforce all applicable requirements of past revisions to the SIP after the PM2.5 nonattainment 

area is redesignated to attainment.

3.4 Maintenance Plan

The redesignation process provides that a state may petition USEPA to redesignate a 

nonattainment area as attainment and that USEPA may approve the redesignation subject to 

certain criteria being met. Section 107(d)(3)(D) states:

(D) The Governor of any State may, on the Governor’s own motion, submit to the Administrator a 

revised designation of any area or portion thereof within the State. Within 18 months of receipt of 

a complete State redesignation submittal, the Administrator shall approve or deny such 

redesignation. The submission of a redesignation by a Governor shall not affect the effectiveness 

or enforceability of the applicable implementation plan for the State. 

Section 107(d)(3)(E) stipulates one of these criteria, that USEPA must fully approve a 

maintenance plan that meets the requirements of § 175A. A state may submit both the 

redesignation request and the maintenance plan at the same time, and rulemaking on both may 

proceed on a parallel track. All applicable nonattainment area requirements must remain in 
Baltimore, MD PM2.5 Maintenance Plan Page 7

place. The maintenance plan constitutes a SIP revision and must provide for maintenance of 

the relevant NAAQS in the area for at least 10 years after redesignation, including additional 

measures to ensure prompt correction of any violation of the NAAQS. The state must also 

submit a SIP revision 8 years after the original redesignation request is approved to provide 

for maintenance of the NAAQS for an additional 10 years following the first 10-year period. 

USEPA provided guidance dated September 4, 1992 on the redesignation request and 

maintenance plan process in the memorandum from John Calcagni, Director, Air Quality 

Management Division to Regional Air Directions entitled Procedures for Processing 

Requests to Redesignate Areas to Attainment (redesignation guidance).1 Other requirements 

are provided in 40 CFR 51 Subpart Z, entitled Provisions for Implementation of PM2.5

National Ambient Air Quality Standards (implementation rule). Additional guidance was 

received in the development of this maintenance plan from USEPA regional staff. 

The Maintenance Plan must contain the following elements:

• A comprehensive “attainment year” emissions inventory of primary PM2.5 and the 

precursors of secondary PM2.5: oxides of nitrogen (NOx) and sulfur dioxide (SO2). In

the Clean Air Fine Particle Implementation Rule (72 FR 20586, April 25, 2007), EPA

did not make a finding that all precursors should be evaluated in each nonattainment 

area. Fine particulate matter, SO2, and NOx were required to be evaluated, however 

ammonia and volatile organic compounds were not;

• A projection of the emissions inventory forward to a year at least ten years after 

redesignation and a demonstration that the projected level of emissions is sufficient to 

maintain attainment of the PM2.5 NAAQS;

• A demonstration of maintenance by showing that future emissions of a pollutant or its 

precursors will not exceed the level of the attainment inventory over the 10-year period 

following redesignation;

• A commitment that, once redesignated, the state will continue to operate an appropriate 

monitoring network to verify maintenance of the attainment status;

• A demonstration of legal authority to implement and enforce all control measures 

contained in the SIP;

• Provisions for future updates of the inventory to enable tracking of emissions levels, 

including an annual emissions statement from major sources;

• Motor vehicle emissions budgets for transportation conformity for the ten-year 

maintenance period;

• A commitment to submit a revised Maintenance Plan eight years after redesignation;

 1 See http://www.epa.gov/ttn/oarpg/t5/memoranda/redesignmem090492.pdf, accessed April 27, 2012.
Baltimore, MD PM2.5 Maintenance Plan Page 8

• A commitment to enact and implement additional contingency measures expeditiously in 

the event that future violations of the NAAQS occur; and

• A list of potential contingency measures that would be implemented in such an event. 

On January 4, 2013, in Natural Resources Defense Council v. EPA, the D.C. Circuit Court 

remanded to EPA the PM2.5 implementation rule. Appendix G: Information Addressing 

NRDC v. EPA, Case No. 08-1250 includes the 2007, 2017, and 2025 VOC and NH3

inventories and an assessment of their roles in demonstrating continued maintenance in 

this area. 

This Maintenance Plan has been prepared in accordance with the requirements specified in 

EPA’s guidance document and additional guidance received from USEPA staff. The 

following subsections of this document describe how EPA’s requirements for a maintenance 

plan have been met.

3.5 Commitment to Revise Plan

Under Section 175A of the Clean Air Act, an area designated as maintenance for a NAAQS is 

required to submit a second maintenance plan eight (8) years after redesignation of any area 

as an attainment area under Section 107(d). This second maintenance plan is intended to 

maintain the NAAQS for ten (10) years after the expiration of the initial ten year period. The

Department recognizes the importance of an up-to-date, current maintenance plan, and 

commits to updating it as necessary.

3.6 Public Participation

In accordance with Section 110(a)(2) of the CAA, the Maryland is required to hold a public 

hearing prior to adoption of this maintenance plan and the subsequent submittal to the EPA.

The Department will notify the public and other interested parties of an upcoming public 

hearing and comment period thirty (30) days prior to holding such hearing for this 

maintenance plan. 

3.7 Legal Authority to Implement and Enforce

The Maryland Department of the Environment has the legal authority to develop, implement 

and enforce regulations regarding air pollution including the requirements of this SIP 

submittal. 
Baltimore, MD PM2.5 Maintenance Plan Page 9

4. Maintenance Plan Development

The State of Maryland has developed a maintenance plan that meets all USEPA requirements 

and demonstrates that because of permanent and enforceable measures, emissions over the 10 

years following redesignation approval will remain below the 2007 attainment year levels 

while allowing for growth in population and vehicle miles traveled. The period covered by 

this maintenance plan is 2007 through 2025.

The State of Maryland has developed an emissions inventory, in accordance with USEPA 

guidance, that identifies the level of emissions sufficient to achieve the 1997 PM2.5 NAAQS. 

This attainment inventory consists of the actual emissions for a year, during the three-year 

period associated with the monitoring data, showing attainment of the 1997 PM2.5 NAAQS. 

The year is 2007. The plan includes a demonstration that emissions will remain beneath the 

2007 levels for a 10-year period by keeping in place key elements of the current federal and 

state regulatory programs and putting in place additional controls. The state has the legal 

authority to implement and enforce specified measures necessary to attain and maintain the 

NAAQS.

In addition to maintaining key elements of regulatory programs, the State of Maryland will 

acquire air quality and source emissions data to track attainment and maintenance. The State 

of Maryland will continue to operate and maintain its air quality monitoring network. 

The maintenance plan includes contingency measures, as necessary, to promptly correct any 

NAAQS violation that occurs after redesignation of the area. 

The following sections provide detail on each of the requirements, and the State of 

Maryland’s approach to meeting each requirement.

4.1 Attainment Inventory

The State of Maryland must develop an attainment year emissions inventory to identify the 

level of emissions sufficient to achieve the 1997 PM2.5 NAAQS. The attainment inventory 

consists of the actual emissions for the year during the three-year period associated with the 

monitoring data showing attainment of the 1997 PM2.5 NAAQS. In this case, the year is 

2007. The 2007 inventory is appropriate to use because it represents the typical inventory for 

the three-year period demonstrating attainment of the standard. 

The 2007 inventory is consistent with USEPA guidance; is based on annual emissions of SO2, 

NOX, and primary PM2.5 during 2007; and contains a list of sources and emissions in tons per 

year. Volatile Organic Compounds (VOC) and ammonia (NH3) were determined to be 

insignificant for the PM2.5 NAAQS for the Baltimore, MD PM2.5 nonattainment area and for 

this reason they are not included in the attainment inventory.2 This determination was based 

on USEPA’s policy regarding VOC and NH3 as they relate to fine particle formation in the 

 2 See Appendix G.
Baltimore, MD PM2.5 Maintenance Plan Page 10

atmosphere as noted in the implementation rule (FR Vol.72, No. 79, 4/25/2007, section IIA 

(precursors and pollutants contributing to fine particle formation), pp.20591-20593). 

4.1.1 Summary

A summary of the 2007 Attainment Year Inventory is presented in Table 4-1: 2007 

Baltimore, MD Attainment Year Inventory. 

A more detailed accounting of the inventory is contained in Appendix A. A description of the 

procedures and methods used to develop the attainment year inventory is contained in 

Appendix D. A detailed emission inventory spreadsheet is presented in Appendix E.

Table 4-1: 2007 Baltimore, MD Attainment Year Inventory

Category

Pollutant

NOX

(tpy)

SO2

(tpy)

PM2.5-PRI3

(tpy)

Point 35,553.82 98,424.42 8,973.22

Area 4,732.44 2,315.81 6,701.79

Non-Road Mobile 27,168.92 2,383.98 1,540.88

On-Road Mobile 49,140.10 385.30 1,789.30

TOTAL4 116,595.28 103,509.50 19,005.19

4.2 Projection Inventory

A Maintenance Plan must contain a demonstration that the levels of emissions projected for 

the ten-year period following redesignation are sufficient to maintain the NAAQS.

Accordingly, the MDE has projected PM2.5, NOx, and SO2 emissions for the Baltimore, MD 

PM2.5 nonattainment area for 2025, as well as an interim year, 2017. Emissions for these 

projection years are compared to emissions levels in 2007 to determine if emissions are 

sufficient to maintain the NAAQS during this period.

The projected inventories are derived by applying the appropriate growth factors to the 2007 

Attainment Year Emissions Inventory. USEPA guidance describes four typical indicators of 

growth. In order of priority, these are as follows: (1) product output, (2) value added, (3) 

earnings, and (4) employment. Surrogate indicators of activity; for example, population 

growth, are also acceptable methods. 

Projected emissions for electric generating unit (EGU) point sources were developed 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 

 3 PRI refers to primary particulate matter, which is directly released into the environment from human activities and 

natural sources, as compared with secondary particulate matter, which forms via chemical reactions in the 

environment.

4 Sums in the “Total” column may reflect rounding errors.
Baltimore, MD PM2.5 Maintenance Plan Page 11

and Fuel Source.

Projected emissions for non-EGU unit point sources were developed using state-level 

employment projections by NAICS code (unless employment growth rate is negative, in 

which case use “no growth”) and other state-specific emission projection data. 

Projected emissions for on-road mobile sources were developed using USEPA’s 

MOVES2010a mobile source inventory model. These estimates are based on vehicle-specific 

registration data obtained from each jurisdiction. Mobile source emission projections 

included the National Low Emission Vehicle Program (NLEV); the 2004 Tier 2 and Low 

Sulfur Gasoline Rule; the 2004 and 2007 Heavy-Duty Diesel Vehicle (HDDV) Rules; and the 

2006 Low Sulfur Diesel Rule. All jurisdictions were modeled with Phase II Reformulated 

Gasoline (RFG) and an enhanced I/M program for all analysis years. 

Projected emissions for non-road vehicles and equipment except for marine, air, and railway 

locomotives were developed using NMIM2008 (version NMIM20090504), which used 

NONROAD2008a model (version July 2009). This version of NONROAD2008a is USEPA’s 

most recently approved emissions estimation tool for the above-mentioned nonroad sources. 

Projected emissions for non-point (area), marine, air, and railway locomotive sources were 

calculated using the most updated practices and inputs, such as the demographic forecasts 

(population, household, and employment projections), endorsed by the Baltimore Regional 

Transportation Board (BRTB). BRTB is the federally designated Metropolitan Planning 

Organization (MPO) for the Baltimore region.

A more detailed accounting of the 2017 and 2025 projection inventories are contained in 

Appendix B and Appendix C, respectively. A description of the procedures and methods used 

to develop the attainment year inventory is contained in Appendix D. A detailed emission 

inventory spreadsheet is presented in Appendix E.

4.2.1 Summary

Table 4-2: Growth Assumptions Used in Emission Inventory Projections

Category Level of Detail Source

Stationary/Industrial Source Growth Source/Unit/Process Specific AEO

State/Federal Requirements

Area and Non-Road Mobile Source Growth Category Specific Cooperative Forecast

Vehicle Miles Traveled Growth Jurisdiction-specific Baltimore Metropolitan Council

and MDE

4.3 Demonstration of Maintenance

States may demonstrate maintenance of the NAAQS by showing that future emissions of a 

pollutant or its precursors will not exceed the level of the attainment inventory. The 

demonstration should be for a period of 10 years following the redesignation. The projected 
Baltimore, MD PM2.5 Maintenance Plan Page 12

inventory should consider future growth, including population and industry. It should also be 

consistent with the attainment inventory, and it should document data inputs and assumptions. 

All elements of the demonstration should be consistent with current USEPA guidance. 

Enforceability through regulations must also be demonstrated.

Any assumptions concerning emission rates must reflect permanent, enforceable measures. 

States generally cannot take credit for reductions unless there are regulations in place 

requiring those reductions or the reductions are otherwise shown to be permanent. Therefore, 

states are expected to maintain the implemented control strategy despite redesignation to 

attainment unless such measures are shown to be unnecessary for maintenance or are replaced 

with measures that achieve equivalent reductions. Emission reductions from source 

shutdowns can be considered permanent and enforceable to the extent that those shutdowns 

have been reflected in the SIP and all applicable permits have been modified accordingly.

4.3.1 Projected Emissions below Attainment Year Emissions

Table 4-3 demonstrates how future emissions of SO2, NOX, and primary PM2.5 will not

exceed the levels of the Baltimore, MD attainment inventory for a minimum of 10 years 

following redesignation. The projected emissions reflect the expected annual emissions based 

on the best available growth rates and projections, as noted in Table 4-3.

Table 4-3: Baltimore, MD NOx, SO2, & Primary PM2.5 Emissions, 2007 to 2025

SOURCE 

CATEGORY

BNAA BNAA BNAA

NOX SO2 PM2.5-PRI

2007 2017 2025 2007 2017 2025 2007 2017 2025

Point 35,553.82 22,170.09 22,300.20 98,424.42 23,818.42 23,788.38 8,973.22 9,286.94 9,500.15

Area 4,732.44 4,964.77 5,167.45 2,315.81 305.16 315.02 6,701.79 5,116.71 5,197.30

Non-Road Mobile 27,168.92 17,213.18 12,785.60 2,383.98 353.69 283.18 1,540.88 959.79 720.31

On-Road Mobile 49,140.10 24,910.01 17,995.80 385.300 236.87 233.06 1789.28 1010.31 786.75

TOTAL 116,595.28 69,258.05 58,249.06 103,509.50 24,714.15 24,619.64 19,005.19 16,373.75 16,204.50

∆ (2017-2007) -47,337.25 -78,795.39 -2,631.42

∆ (2025-2007) -58,346.24 -78,889.90 -2,800.67

4.3.2 Control Measures for Maintenance of Good Air Quality

Point, non-road, and on-road emission projections for 2017 and 2025 include a variety of 

control strategies that will reduce emissions of PM2.5, NOX, and SO2 in the future years. The 

sections below describe the major control programs in each category. Many of these 

programs are federal programs that are enforced on a regional or national level. In cases 

where the programs are delegated programs or state programs, the State of Maryland commits

to the continuation of each program, to include compliance and enforcement mechanisms as 

appropriate to ensure that reductions assumed in 2017 and 2025 will be achieved. 
Baltimore, MD PM2.5 Maintenance Plan Page 13

4.3.2.1 Point Sector Controls

Point source emissions of PM2.5, SO2, and NOX are dominated in the Baltimore, MD region 

by the emissions from electrical generating units (EGU). The EGUs located in the Baltimore, 

MD nonattainment area are the Herbert A. Wagner Station in Anne Arundel County (ORIS 

1554); the Brandon Shores Station in Anne Arundel County (ORIS (602); Riverside in 

Baltimore County (ORIS 1559), C.P. Crane Station in Baltimore County (ORIS 1552); the 

Perryman Power Plant in Harford County (ORIS 1556), and the Westport Station in Baltimore 

City (ORIS 1560). These facilities are subject to a variety of federal and state-enforceable 

mechanisms that have reduced emissions at these units since 2007 and will continue to reduce 

emissions into the future.

4.3.2.1.1 Maryland Healthy Air Act

The Maryland Healthy Air Act (HAA) regulations became effective on July 16, 2007 and 

required reductions in NOX, SO2, and mercury emissions from large coal burning power 

plants in Maryland. Specifically, this program limits emissions from the Brandon Shores

Generating Plant, the Herbert A. Wagner Generating Plant, and the C.P. Crane Generating 

Plant, all of which are coal-fired power plants located within the Baltimore, MD 

nonattainment area. Emission reductions from the HAA are phased. The first phase required 

reductions in the 2009/2010 timeframe. The second phase of emission controls will occur in 

the 2012/2013 time frame. At full implementation, the HAA will reduce NOX emissions for 

the affected units by approximately 65 percent from 2002 levels and SO2 emissions by 

approximately 80 percent from 2002 levels resulting in the removal of approximately 15,000 

and 75,000 tons per year of NOX and SO2, respectively. The first phase of the HAA was 

successfully implemented, and the second phase of the program is expected to be 

implemented in a timely manner.
Baltimore, MD PM2.5 Maintenance Plan Page 14

Figure 4-1: Large EGUs in the Baltimore, MD Area

4.3.2.1.2 Future Point Source Emission Reduction Programs 

Three federal regulations may reduce emissions of SO2 even further than is already estimated 

by the 2017 and 2025 inventory shown in Table 4-3 for the Baltimore, MD area. These rules 

were not yet finalized as of the time of the development of the projection inventory and 

therefore were not considered in the 2017 and 2025 estimates included in this document. If 

these regulations are finalized, each should prompt significant further reductions, both within 

and outside the Baltimore, MD area.

• Mercury and Air Toxics Rule: On February 16, 2012, USEPA published the final

Mercury and Air Toxics Rule to reduce emissions of toxic air pollutants from new and 

existing coal and oil-fired EGUs (Federal Register, Vol. 77, No. 32, 2/16/2012). The rule 

establishes numerical emission limits for hydrogen chloride (HCl) as a surrogate for toxic 

acid gases or alternative standards for SO2. USEPA has estimated that this rule will

affect approximately 1,200 coal-fired units nationwide and will reduce SO2 emissions 

from power plants by 55 percent. Existing sources may be required to demonstrate 

compliance with applicable standards by 2015.

• 2010 SO2 NAAQS: On June 2, 2010, USEPA strengthened the primary NAAQS for SO2

by revising the primary SO2 standard to 75 ppb averaged over one hour. This short term 

standard is significantly more stringent than the revoked standards of 140 ppb averaged 
Baltimore, MD PM2.5 Maintenance Plan Page 15

over 24 hours and 30 ppb averaged annually. Under the new standard’s proposed 

guidance, facilities emitting more than 100 tpy of SO2, many of which are EGUs, will be 

required to demonstrate compliance with the standard no later than 2017. 

• Industrial/Commercial/Institutional (ICI) Boiler Maximum Achievable Control 

Technology (MACT) Standard: USEPA finalized the revised ICI Boiler MACT on 

February 21, 2011, although portions of the rule are under reconsideration. USEPA 

estimates that implementation of the revised rulemaking will reduce emissions 

nationwide from major source boilers and process heaters by 47,000 tpy of PM, 440,000 

tpy of SO2, and 7,000 tpy of VOCs.

4.3.2.2 Nonroad Diesel Emission Reduction Programs

Under 40 CFR Part 89, U.S. EPA adopted standards for emissions of NOX, hydrocarbons, and 

carbon monoxide (CO) from several groups of nonroad engines, including industrial sparkignition engines and recreational nonroad vehicles. Industrial spark-ignition engines power 

commercial and industrial applications and include forklifts, electric generators, airport 

baggage transport vehicles, and a variety of farm and construction applications. Nonroad 

recreational vehicles include snowmobiles, off-highway motorcycles, and all-terrain vehicles. 

These rules were initially effective in 2004 and will be fully phased in by 2012.

The nonroad diesel rule sets standards that reduced emissions by more than 90 percent from 

nonroad diesel equipment and, beginning in 2007, the rule reduced fuel sulfur levels by 99 

percent from previous levels. The reduction in fuel sulfur levels applied to most nonroad 

diesel fuel in 2010 and will apply to fuel used in locomotives and marine vessels in 2012. 

This program will continue to provide emission reductions of NOX as new equipment is 

purchased and older equipment is scrapped. Additionally, SO2 emissions from the 

combustion of nonroad diesel fuel and locomotive and marine diesel fuel will continue to be 

reduced through 2012.

4.3.2.3 On-Road Emission Reduction Programs

In the 2007 heavy-duty highway rule, which is codified in 40 CFR Part 86, Subpart P, 

USEPA set a PM emission standard of 0.01 grams per brake horsepower-hour (g/bhp-hr) for 

new heavy-duty engines. This standard took full effect for diesel engines in the 2007 model 

year. This rule included the following standards for NOX and non-methane hydrocarbons 

(NMHC): 0.20 g/bhp-hr and 0.14 g/bhp-hr, respectively. These diesel engine NOX and 

NMHC standards were successfully phased in together between 2007 and 2010. The rule also 

required that sulfur in diesel fuel be reduced to facilitate the use of modern pollution control 

technology on these trucks and buses. USEPA required a 97 percent reduction in the sulfur 

content of highway diesel fuel -- from levels of 500 parts per million (ppm) for low sulfur 

diesel to 15 ppm for ultra-low sulfur diesel. The reductions in sulfur content engendered 

similar reductions in SO2 emissions. These requirements were successfully implemented on 

the timeline in the regulation.
Baltimore, MD PM2.5 Maintenance Plan Page 16

The Tier 2 vehicle and gasoline sulfur program, as codified in Subpart H of 40 CFR Part 80, 

40 CFR Part 85, and 40 CFR Part 86, became effective in the 2005 model year. This program 

for fleet averaging of on-road vehicles is modeled after the California LEV II standards. The 

Tier 2 program allows manufacturers to produce vehicles with emissions ranging from 

relatively dirty to very clean, but the mix of vehicles that a manufacturer sells each year must 

have average NOX emissions below a specified value. Mobile emissions continue to show 

reductions from this program as motorists replace older, more polluting vehicles with cleaner 

vehicles. 

In additional to the federal Tier 2 program and the federal 2007 heavy duty highway rule, the 

State of Maryland has instituted enhanced vehicle emissions inspection and maintenance 

(enhanced I/M) requirements. The requirements involve mandating regional vehicle 

emission I/M programs that are stricter than basic programs, as required under Sections 182 

and 202 of the CAA. Before 1994, basic automobile emissions testing checked only tailpipe 

emissions while idling and sometimes at 2,500 rpm. Enhanced I/M procedures include the 

use of On Board Diagnostic (OBD) system evaluations, a wider range of vehicles tested, and 

may include a dynamometer (treadmill) test that checks the car’s emissions under driving 

conditions. The OBD evaluations provide a more complete inspection, checking for excess 

evaporative emissions and other issues that might affect emissions from the vehicle. 

4.4 Commitment to Operate Air Quality Monitoring Network

Once an area has been redesignated, the states must continue to operate an appropriate air 

quality monitoring network in accordance with 40 CFR Part 58, to verify the area's attainment 

status. In cases where measured mobile source parameters (for example, vehicle miles 

traveled) have changed over time, the state may also need to perform a saturation monitoring 

study to determine the need for and location of additional permanent monitors.

The State of Maryland operates a monitoring network that is significantly more robust than 

required by federal regulation. Figure 4-2Error! Reference source not found. provides a 

map showing the locations of the various PM2.5 monitoring sites in the current network.

The State of Maryland commits to operating and maintaining an air quality network for PM2.5

monitoring that meets all federal requirements. Should measured mobile source parameters 

change significantly over time, the State of Maryland will perform a saturation monitoring 

study to determine the need for and location of PM2.5 monitors.
Baltimore, MD PM2.5 Maintenance Plan Page 17

Figure 4-2: Baltimore, MD PM2.5 Monitoring Sites

4.5 Legal Authority – Verify Continued Attainment

States must ensure that they have the legal authority to implement and enforce all measures 

necessary to attain and maintain the NAAQS. Sections 110(a)(2)(B) and (F) of the CAA, and 

regulations promulgated in 40 CFR 51.110(k) suggest that one such measure is the acquisition 

of air quality and source emission data to demonstrate attainment and maintenance. The 

submittal must indicate how the states will track the progress of the maintenance plan. This is 

necessary due to the fact that the emission projections made for the maintenance 

demonstration depend on assumptions of point, area, and mobile source growth.

One option for tracking the progress of the maintenance demonstration would be for the states 

to periodically update the emissions inventory. In this case, the maintenance plan should 

specify the frequency of any planned inventory updates. Such an update could be based, in 

part, on the annual update of the USEPA Aerometric Information Retrieval System (AIRS) 

and could indicate new source growth and other changes from the attainment inventory (such 

as changes in vehicle miles traveled or in traffic patterns). As an alternative to a complete 

update of the inventory, states may choose to do a comprehensive review of the factors that 
Baltimore, MD PM2.5 Maintenance Plan Page 18

were used in developing the attainment inventory to show no significant change. If this 

review does show a significant change, states should then perform an update of the inventory.

The State of Maryland has the legal authority to implement and enforce specified measures 

necessary to attain and maintain the NAAQS. Key regulatory elements that the State will 

keep in place to maintain attainment are as follows:

• Shutdown requirements, permitting requirements, and regulatory requirements

• I/M program requirements.

In addition to maintaining key elements of its regulatory program, the state will acquire 

ambient and source emission data to track attainment and maintenance. The state will track 

the progress of the maintenance demonstration by periodically updating the emissions 

inventory. This tracking will consist of annual and periodic evaluations. The annual 

evaluation will consist of checks on key emissions trend indicators such as the annual 

emissions update of stationary sources, the Highway Performance Monitoring System 

(HPMS) vehicle miles traveled data reported to the Federal Highway Administration, and 

other growth indicators. These indicators will be compared to the growth assumptions used in 

the plan to determine if the predicted versus the observed growth remains relatively constant. 

The state will also develop and submit to the USEPA comprehensive tracking inventories 

every three years or as required by federal regulation during the maintenance plan period. 

4.6 Transportation Conformity and Mobile Source Emissions Budgets

Transportation conformity is a way to ensure that federal funding and approval are given to 

those transportation activities that are consistent with air quality goals. Transportation 

activities should not worsen air quality or interfere with an area’s continued compliance in 

regards to the 1997 PM2.5 NAAQS. The federal transportation conformity rule is codified in 

40 CFR Part 93, subpart A, entitled Determining Conformity of Federal Actions to State or 

Federal Implementation Plans (transportation conformity rule). This rule applies to areas 

designated as nonattainment for one or more NAAQS or that have been redesignated to

attainment with federally approved air quality maintenance plans. 

Transportation conformity is required under CAA Section 176(c) (42 U.S.C. 7506(c)) to 

ensure that transportation plans, transportation improvement programs (TIPs) and federally 

supported highway transit project activities are consistent with (“conform to”) the purpose of 

the state air quality implementation plan (SIP). “Conform to the purpose of the SIP” means 

that transportation activities will not cause new air quality violations, worsen existing 

violations, or delay timely attainment of the relevant NAAQS or any interim milestones. 

These requirements are found in Clean Air Act Section 176(c)(B)(i), (ii), and (iii), which 

states: “Conformity to an implementation plan means—... That such activities will not cause 

or contribute to any new violation of any standard in any area; increase the frequency or 

severity of any existing violation of any standard in any area; or delay timely attainment of 

any standard or any required interim emissions reductions or other milestones in any area.” 

The federal transportation conformity rule is codified in 40 CFR Part 93, subpart A, entitled 

Determining Conformity of Federal Actions to State or Federal Implementation Plans 
Baltimore, MD PM2.5 Maintenance Plan Page 19

(transportation conformity rule). Transportation conformity applies to areas that are 

designated nonattainment, and those areas redesignated to attainment after 1990 

(“maintenance areas”) for transportation-related criteria pollutants: Carbon monoxide (CO), 

ozone, nitrogen dioxide (NO2) and particulate matter (PM2.5 and PM10).

As stated in 40 CFR 93.102, for PM2.5 areas, transportation conformity applies to directly 

emitted PM2.5. In addition, it applies to NOx in these areas, unless both the USEPA Regional 

Administrator and the director of the state air agency have made a finding that transportationrelated emissions of NOx within the nonattainment area are not a significant contributor to the 

PM2.5 nonattainment problem. Such a finding has not been made for the Baltimore, MD 

annual PM2.5 nonattainment area. Therefore, mobile source emission budgets for both PM2.5

and NOx are proposed in this maintenance plan.

40 CFR 93.102 further specifies that in PM2.5 areas, transportation conformity applies to 

VOC, SO2, and/or ammonia as PM2.5 precursors, as well as re-entrained road dust, if the 

USEPA Regional Administrator or the director of the state air agency has made a finding that 

transportation-related emissions of any of these precursors or re-entrained road dust within the 

nonattainment area are a significant contributor to the PM2.5 nonattainment area. Such a 

finding has not been made for any of these precursors or for re-entrained road dust for the 

Baltimore, MD PM2.5 nonattainment area. For these pollutants and precursors, the highway

contribution to those emissions may be insignificant. In that case, the transportation 

conformity rule allows such pollutants and precursors to be exempt from conformity analysis 

under certain circumstances:

40 CFR93.109 (k) Areas with insignificant motor vehicle emissions. 

Notwithstanding the other paragraphs in this section, an area is not 

required to satisfy a regional emissions analysis for §93.118 and/or 

§93.119 for a given pollutant/precursor and NAAQS, if EPA finds 

through the adequacy or approval process that a SIP demonstrates that 

regional motor vehicle emissions are an insignificant contributor to the 

air quality problem for that pollutant/precursor and NAAQS. The SIP 

would have to demonstrate that it would be unreasonable to expect that 

such an area would experience enough motor vehicle emissions growth 

in that pollutant/precursor for a NAAQS violation to occur. Such a 

finding would be based on a number of factors, including the percentage 

of motor vehicle emissions in the context of the total SIP inventory, the 

current state of air quality as determined by monitoring data for that 

NAAQS, the absence of SIP motor vehicle control measures, and 

historical trends and future projections of the growth of motor vehicle 

emissions. . . 

For this reason, VOC, SO2, ammonia and re-entrained road dust are not addressed in this 

maintenance plan for transportation conformity purposes. In fact the State of Maryland is 

herein making a finding that regional highway emissions of SO2 are insignificant contributors 

to the PM2.5 air quality of the Baltimore, MD area. The finding will become final if USEPA 

concurs and approves this maintenance plan. This finding is due to the fact that the regional 

highway SO2 emissions inventory constitutes a very small fraction of the overall emissions 
Baltimore, MD PM2.5 Maintenance Plan Page 20

inventory in the Baltimore, MD area as shown in Table 4-4.

Table 4-4: Comparison of SO2 Emissions from On-Road Sources to the Total SO2 Inventory

Year

BNAA

Total SO2

Emissions

tpy

On-Road SO2

Emissions

tpy

% On-Road

SO2

Emissions

2007 103,509.54 385.34 0.37%

2017 24,714.15 236.87 0.96%

2025 24,619.64 233.06 0.95%

Additionally, PM2.5 air quality in the region is good and getting better. Figure 4-3 provides

the regional trends in PM2.5 air quality for the federal reference method monitoring sites. The 

design value for the 1997 PM2.5 annual standard for the Baltimore, MD region is 11.0 μg/m3

for years 2010-2012. The contribution of on-road mobile SO2 emissions remains 

proportionally small in both the interim year and projection year. Therefore, it is highly 

unlikely that any increase in growth assumptions or activity data, beyond those already 

included in the on-road SO2 emissions estimation methodology, could account for an 

exceedance or violation of the 1997 PM2.5 NAAQS annual standard. For these same reasons, 

the likelihood of on-road emissions of SO2 contributing to an exceedance of the 1997 PM2.5

24-hour standard is even smaller.
Baltimore, MD PM2.5 Maintenance Plan Page 21

Figure 4-3: Baltimore, MD Annual PM2.5 Trend5

4.6.1 Budget Level for On-Road Mobile Source Emissions 

As part of the development of this SIP revision, the MDE formally establishes annual mobile 

source emissions budget for NOX and PM2.5. The mobile emissions budgets are based on the 

projected mobile source emissions accounting for all mobile control measures. This budget 

will be the benchmark used to determine if the region's twenty-year long-range transportation 

plan (LRTP) and three-year transportation improvements program (TIP) conform to the SIP. 

These budgets represent the level of mobile source emissions that can be emitted in the area 

while supporting the air quality plan

For NOx and PM2.5, initial, interim and final mobile source budgets have been developed to 

accommodate the fluctuation in mobile source emissions estimates over time. In the near term, 

mobile source emissions are rapidly decreasing due to the implementation of the NLEV, Tier 2, 

and Heavy-Duty Diesel Vehicle (HDDV) rules, even as vehicle miles travelled (VMT) 

continues to grow. Once these rules have sufficiently penetrated the fleet, growth in VMT 

becomes more pronounced and eventually pushes mobile emissions back on an upward trend. 

 5 PM2.5 Design Values, MDE Ambient Air Quality Monitoring Program
Baltimore, MD PM2.5 Maintenance Plan Page 22

Table 4-5 contains the motor vehicle emissions budgets for the Baltimore area.

Table 4-5: Baltimore, MD Maintenance Plan On-Road Mobile Source Emissions Budgets

Year

NOX

On-Road 

Emissions Budget

(tpy)

PM2.5

On-Road 

Emissions Budget

(tpy)

2007 Attainment Year 49,140.10 1,789.28

2017 Interim Budget 29,892.01 1,218.60

2025 Final Budget 21,594.96 1,051.39

The above budgets for the Baltimore area, agreed upon as part of the interagency consultation 

process, include the emission estimates calculated for 2017 and 2025 with an additional margin 

of safety allocated to PM2.5 and NOX in 2017 and 2025. Safety margins are explicitly defined 

and provided for in EPA’s Conformity Regulations, and the use of such safety margins is 

common practice in maintenance plans approved by EPA. Because of significant declines 

projected in both precursor NOX and primary PM2.5 emissions from motor vehicles over the 2007 

through 2025 period of the maintenance plan, these recommended safety margins can be 

included in the plan while still ensuring maintenance of the PM2.5 standard for the region. 

Table 4-6 shows the maintenance of the PM2.5 standard with the margin of safety included in 

the on-road mobile emissions.

Table 4-6: Baltimore, MD NOx, SO2, & Primary PM2.5 Emissions, 2007 to 2025 with Mobile Budgets

SOURCE 

CATEGORY

BNAA BNAA BNAA

NOX SO2 PM2.5-PRI

2007 2017 2025 2007 2017 2025 2007 2017 2025

Point 35,553.82 22,170.09 22,300.20 98,424.42 23,818.42 23,788.38 8,973.22 9,286.94 9,500.15

Area 4,732.44 4,964.77 5,167.45 2,315.81 305.16 315.02 6,701.79 5,116.71 5,197.30

Non-Road Mobile 27,168.92 17,213.18 12,785.60 2,383.98 353.69 283.18 1,540.88 959.79 720.31

On-Road Mobile 49,140.10 29,892.01 21,594.96 385.300 236.87 233.06 1789.28 1218.60 1,051.39

TOTAL 116,595.28 74,240.05 61,848.22 103,509.50 24,714.15 24,619.64 19,005.19 16,582.04 16,469.14

∆ (2017-2007) -42,355.25 -78,795.39 -2,423.13

∆ (2025-2007) -54,747.08 -78,889.90 -2,536.03
Baltimore, MD PM2.5 Maintenance Plan Page 23

4.7 Contingency Measures

Section 175(A) of the Clean Air Act specifies the requirements for maintenance plans. In 

addition to providing a plan for the maintenance of the NAAQS for at least ten (10) years 

after the redesignation, the plan shall also include a list of contingency measures to correct 

any violation of the fine particulate matter NAAQS after redesignation to attainment. The 

plan should also provide a commitment to submit a revised maintenance plan eight years after 

redesignation to ensure continued maintenance for the next ten year maintenance period.

Contingency measures are to be used to further reduce emissions if a violation of the fine 

particulate matter NAAQS occurs after redesignation to attainment. While these measures do 

not need to be fully adopted by the Maryland Department of the Environment prior to the 

occurrence of a NAAQS violation, the contingency measures are expected to be implemented 

as expeditiously as possible once a triggering event occurs. The maintenance plan must 

identify the triggers that determine when contingency measures will be adopted, and the 

measures that the state will consider.

The maintenance plan must include contingency measures, as necessary, to promptly correct 

two future situations. The first situation is an inventory estimate that indicates the Baltimore, 

MD area had actual emissions of either SO2, NOX, or PM2.5 in any future year that were 

greater than that of the attainment year inventories listed in Table 4-1. The second situation 

is any NAAQS violation that occurs after redesignation of an area. The plan should include 

measures to be adopted, a schedule and procedures for adoption and implementation, and a 

specific time limit for action. Specific triggers that would put the plan into motion must be 

identified. This plan is considered to be an enforceable part of the SIP and should ensure that 

the contingency measures are adopted explicitly once they are triggered.

The ability of the Baltimore, MD nonattainment area to stay in compliance with the 1997 

PM2.5 NAAQS depends at least partially on the level of NOX, SO2, and primary PM2.5

emissions in the region. Emissions are projected to stay well below the 2007 attainment year 

levels, through 2025. However, if emissions increase, the area may experience a PM2.5

violation. To address this unlikely situation, the State of Maryland has developed a 

contingency plan. The situations described below would trigger the implementation of the 

contingency measures as described in Section 4.7.1, Section 4.7.2, or Section 4.7.3.

• Annual actual emissions of SO2, NOX, or PM2.5 exceeding the attainment year inventories 

in Table 4-1.

• Any annual exceedance (annual average for one year at any federal reference method 

monitor in the Baltimore, MD nonattainment area) of 15.0 μg/m3 or greater.

• Any violation (three year average of the annual average at any federal reference method 

monitor in the Baltimore, MD nonattainment area) of 15.0 μg/m3 or greater.
Baltimore, MD PM2.5 Maintenance Plan Page 24

4.7.1 Exceedance of the Attainment Year Emissions Inventory

Should any future year emissions inventory data indicate that the Baltimore, MD area’s total 

emissions of SO2, NOX, or PM2.5 exceeded the levels in Table 4-1, the State of Maryland, 

would first undertake an audit to determine whether inventory refinements were needed. This 

audit may include, but would not be limited to, a determination that appropriate models, 

control strategies, monitoring strategies, planning assumptions, industrial throughput, and 

production data were used in the attainment year and future year estimates. If this audit does 

not reconcile the originally estimated emissions exceedances, then the State of Maryland 

commits to implementing one or more of the programs listed in Table 4-7 so that future total 

emission estimates for the Baltimore, MD area will not exceed those listed in Table 4-1.

4.7.2 Near Term Contingency Measures for Air Quality Exceedances

The Maryland Healthy Air Act’s second phase, began in January 2013, will provide 

significant emissions reductions of precursors to PM2.5. This regulation, included in COMAR 

26.11.27, requires additional SO2 reductions beginning January 1, 2013, for applicable coalfired power plants in Maryland. These applicable units include coal-fired boilers located at 

the C.P. Crane Power Plant, the Herbert A. Wagner Power Plant, and the Brandon Shores

Power Plant in the Baltimore, MD nonattainment area. In 2013 the allowable tonnage cap for 

the units at these facilities was reduced from 23,407 tpy of SO2 to 17,926 tpy of SO2, a 

reduction of over 23 percent. This regulation has the added benefit of already being codified; 

these reductions began in January of 2013 without further action by the State of Maryland.

4.7.3 Long Term Contingency Measures

If an annual exceedance of 15.0 μg/m3occurs after January 1, 2013, the State of Maryland 

commits to implementing one of the programs listed in Table 4-7 to garner additional 

emission reductions for air quality improvement.

If an annual violation occurs after January 1, 2013, the State of Maryland commits to 

implementing two or more of the programs listed in Table 4-7 to garner additional emission 

reductions for air quality improvement.

Table 4-7: Contingency Control Measures

PM2.5 Reasonable Available Control Measure (RACM) Determination

NOX RACM Determination

Non Road Diesel Emission Reduction Strategies

Low Sulfur Home Heating Oil Requirements

Alternative Fuel and Diesel Retrofit Programs for Fleet Vehicle Operations

Concrete Manufacturing – Wet Suppression Upgrade Requirements
Baltimore, MD PM2.5 Maintenance Plan Page 25

4.7.4 Contingency Measure Implementation Schedule

The State of Maryland commits to the implementation of any long term contingency measure 

on the following schedule:

• Schedule onset: notification received from USEPA that a contingency measure must be 

implemented, or three months after quality assured data determine that an exceedance or 

violation occurred within the previous year.

• Applicable regulation or program to be adopted six months after this date.

• Applicable regulation to be implemented six months after adoption.

• Compliance with regulation, or full program implementation, to be achieved within 12 

months of adoption.
Baltimore, MD PM2.5 Maintenance Plan Page 26

Appendices

Appendix A – 2007 Attainment Year Inventory

Appendix A-1 – 2007 Point Source Emissions

Appendix A-2 – 2007 Area Source Emissions

Appendix A-3 – 2007 On-Road Mobile Source Emissions

Appendix A-4 – 2007 Off-Road Mobile Source Emissions

Appendix B – 2017 Interim Year Projection Year Inventory

Appendix B-1 – 2017 Point Source Emissions

Appendix B-2 – 2017 Area Source Emissions

Appendix B-3 – 2017 On-Road Mobile Source Emissions

Appendix B-4 – 2017 Off-Road Mobile Source Emissions

Appendix C – 2025 Projection Year Inventory

Appendix C-1 – 2025 Point Source Emissions

Appendix C-2 – 2025 Area Source Emissions

Appendix C-3 – 2025 On-Road Mobile Source Emissions

Appendix C-4 – 2025 Off-Road Mobile Source Emissions

Appendix D – Emission Inventory Documentation

Appendix E – Emission Inventory Detail Spreadsheet

Appendix F – Onroad Mobile MOVES Documentation, Conformity Data and Budgets

Appendix G – Information Addressing NRDC v. EPA, Case No. 08-12150

 
 MARYLAND DEPARTMENT OF THE ENVIRONMENT

 1800 Washington Boulevard • Baltimore MD 21230

 410-537-3000 • 1-800-633-6101 • www.mde.state.md.us

 Recycled Paper www. mde.state.md.us TTY Users 1-800-735-2258

Via Maryland Relay Service

Robert M. Summers, Ph.D.

Secretary

 

Martin O’Malley

Governor

Anthony G. Brown

Lieutenant Governor

Notice of Public Hearing on Air Quality Plan

The Maryland Department of the Environment (MDE) gives notice of a public hearing concerning the Baltimore 

Nonattainment Area PM2.5 Redesignation Request and Maintenance Plan.

A public hearing will be held on Monday, October 7, 2013, at the Maryland Department of the Environment, 1800 

Washington Boulevard, Baltimore, Maryland 21230 – First Floor Conference Room – 1:00 P.M.

The State of Maryland requests that the United States Environmental Protection Agency (USEPA) redesignate the 

Baltimore, MD 1997 fine particulate (PM2.5) nonattainment area to attainment for this standard pursuant to the 

provisions under § 107 of the federal Clean Air Act (CAA). Since the designations for the National Ambient Air 

Quality Standards (NAAQS) for this pollutant were published (Federal Register, Vol. 70, No. 3, 1/5/2005), the area’s 

PM2.5 air quality has improved due to permanent and enforceable emission reductions. Air quality in the area is 

significantly better than required by this standard. Due to the improvement in PM2.5 air quality, the USEPA finalized a 

clean data determination for the Baltimore area on May 22, 2012 (Federal Register, Vol. 77, No. 99, 5/22/2012). The 

State of Maryland is also requesting that USEPA concurrently approve, as a revision to the state implementation plan 

(SIP) for each state, the related § 175A maintenance plan. This plan ensures that good PM2.5 air quality will be 

maintained through 2025.

The public hearing will be held as required by federal law (Clean Air Act at 42 U.S.C. 7410 (a) and 40 CFR 51.102).

After consideration of comments received, the plan will be finalized and submitted to the United States 

Environmental Protection Agency (EPA) for approval.

The proposed plan document has been made available on the Maryland Department of the Environment's website at

http://www.mde.state.md.us/programs/Air/AirQualityPlanning/Pages/programs/airprograms/air_planning/index.aspx 

Note: the public library systems in the region can be used for Internet access to view the document.

Copies of the document can be viewed at the offices of the Maryland Department of the Environment, Air and 

Radiation Management Administration, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland. For more 

information, contact Mary Jane Rutkowski at (410) 537-3240.

Comments may be sent to Mary Jane Rutkowski, Maryland Department of the Environment, Air and Radiation 

Management Administration, 1800 Washington Boulevard, Suite 730, Baltimore, MD, 21230; emailed to 

MaryJane.Rutkowski@Maryland.gov; or faxed to (410) 537-3203,

attn: Mary Jane Rutkowski. Comments must be received by 5:00 P.M. on October 7, 2013, or be submitted at the 

hearing.

Persons in need of special accommodations should contact the Department's Office of Fair Practices at (410) 537-

3964 at least five (5) business days in advance of the hearing. TTY users should contact the Department through the 

Maryland Relay Service at 1-(800) 735-2258.

For more information, contact Mary Jane Rutkowski at (410) 537-3240 (Toll free in Maryland call

1-(800) 633-6101 ext. 3240), or via email at MaryJane.Rutkowski@Maryland.gov.
MARYLAND DEPARTMENT OF THE ENVIRONMENT 

1800 Washington Boulevard  Baltimore MD 21230 

410-537-3000  1-800-633-6101 

 Robert M. Summers, Ph.D. Secretary 

 Recycled Paper www.mde.state.md.us TTY Users 1-800-735-2258 

 Via Maryland Relay Service 

 

Martin O’Malley 

Governor 

Anthony G. Brown 

Lieutenant Governor 

 September 6, 2013 

CERTIFICATE OF PUBLICATION 

This is to certify that public hearing notices concerning "PM2.5 Redesignation Requests & Maintenance 

Plans" for the Baltimore and Washington County Nonattainment Areas were published on MDE’s web site on 

September 6, 2013. They will remain posted on the at least site until October 9, 2013. The notices in full with 

links to supporting documents may be found in the following web address: 

http://www.mde.state.md.us/programs/Air/AirQualityPlanning/Pages/

programs/airprograms/air_planning/index.aspx

Web publication of the notices was at the request of Mary Jane Rutkowski of the Air and Radiation 

Management Administration of MDE. 

 By: 

 DIANA ALEGRE 

 MDE Webmaster 

 

Attachments: 

Copy of web page as published. 
Air Quality Planning

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Sign In

Air and Radiation

Air Quality

Planning

Air Quality Planning Program

Maryland's Air Quality Planning Program (AQPP) writes state implementation plans and regulations to reduce emissions and achieve the

National Ambient Air Quality Standards (NAAQS) for six "criteria" air pollutants: ground-level ozone, particulate matter, lead, carbon

monoxide, nitrogen dioxide, and sulfur dioxide. The AQPP also implements federal, regional, local, and state greenhouse gas emissions

reduction programs, including implementing the requirements of the Maryland Greenhouse Gas Emissions Reduction Act of 2009 and

managing Maryland's involvement in the Regional Greenhouse Gas Initiative (RGGI).

The AQPP consists of three divisions covering its different program areas:

(1) Planning and Policy

(2) Regulation Development

(3) Climate Change

Planning and Policy: State Implementation Plans

The Planning and Policy Division develops air quality plans, also called state implementation plans, which are designed to attain and

maintain the National Ambient Air Quality Standards, and to prevent significant deterioration of air quality in areas cleaner than the

standards.

The state implementation plans are listed below in chronological order with the latest documents first. Some SIPs have many

appendices, but each distinct SIP on the list is identified with the word “Document” followed by the individual SIP’s name below that

and any appendices subsequently.

Note: Maryland's State Implementation Plans are viewable in Adobe Acrobat Reader (pdf) format. To view the documents, you will have

to download the Adobe Acrobat Reader.

New! Public Hearing concerning the Baltimore Nonattainment Area PM2.5 Redesignation Request and

Maintenance Plan

Redesignation Request

Maintenance Plan

Appendices

A public hearinig will be held on Monday, October 7, 2013 at the Maryland Department of the Environment, 1800

Washington Boulevard, Baltimore, Maryland 21230 -- First Floor Conference Room -- 1:00 P.M.

The State of Maryland requests that the United States Environmental Protection Agency (USEPA) redesignate the Baltimore, MD 1997

fine particulate (PM2.5) nonattainment area to attainment for this standard pursuant to the provisions under § 107 of the federal Clean

Air Act (CAA). Since the designations for the National Ambient Air Quality Standards (NAAQS) for this pollutant were published (Federal

Register, Vol. 70, No. 3, 1/5/2005), the area’s PM2.5 air quality has improved due to permanent and enforceable emission reductions.

Air quality in the area is significantly better than required by this standard. Due to the improvement in PM2.5 air quality, the USEPA

finalized a clean data determination for the Baltimore area on May 22, 2012 (Federal Register, Vol. 77, No. 99, 5/22/2012). The State

of Maryland is also requesting that USEPA concurrently approve, as a revision to the state implementation plan (SIP) for each state, the

related § 175A maintenance plan. This plan ensures that good PM2.5 air quality will be maintained through 2025.

The public hearing will be held as required by federal law (Clean Air Act at 42 U.S.C. 7410 (a) and 40 CFR 51.102). After consideration

of comments received, the plan will be finalized and submitted to the United States Environmental Protection Agency (EPA) for

approval. Note: the public library systems in the region can be used for Internet access to view the document.

Copies of the document can be viewed at the offices of the Maryland Department of the Environment, Air and Radiation Management

Administration, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland. For more information, contact Mary Jane Rutkowski at

(410) 537-3240.

Comments may be sent to Mary Jane Rutkowski, Maryland Department of the Environment, Air and Radiation Management

Administration, 1800 Washington Boulevard, Suite 730, Baltimore, MD, 21230; emailed to MaryJane.Rutkowski@Maryland.gov; or faxed

to (410) 537-3203, attn: Mary Jane Rutkowski. Comments must be received by 5:00 P.M. on October 7, 2013, or be submitted at the

hearing.

Persons in need of special accommodations should contact the Department's Office of Fair Practices at (410) 537-3964 at least five (5)

business days in advance of the hearing. TTY users should contact the Department through the Maryland Relay Service at 1-(800) 735-

2258.

For more information, contact Mary Jane Rutkowski at (410) 537-3240 (Toll free in Maryland call 1-(800) 633-6101 ext. 3240), or via

email at MaryJane.Rutkowski@Maryland.gov

New! Public hearing concerning the Washington County, MD Nonattainment Area PM2.5 Redesignation Request

and Maintenance Plan

Redesignation Request

Maintenance Plan

Appendices

A public hearing will be held on Tuesday, October 8, 2013, at the Washington County Planning Department, Washington

County Administrative Annex, 80 West Baltimore Street, Hagerstown, Maryland 21740 – 1:30 P.M

The State of Maryland requests that the United States Environmental Protection Agency (USEPA) redesignate the Washington County,

MD 1997 fine particulate (PM2.5) nonattainment area to attainment for this standard pursuant to the provisions under § 107 of the

Maryland.gov | Phone Directory | State Agencies | Online Services

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federal Clean Air Act (CAA). Since the designations for the National Ambient Air Quality Standards (NAAQS) for this pollutant were

published (Federal Register, Vol. 70, No. 3, 1/5/2005), the area’s PM2.5 air quality has improved due to permanent and enforceable

emission reductions. Air quality in the area is significantly better than required by this standard. Due to the improvement in PM2.5 air

quality, the Washington County, MD nonattainment area is currently operating under a clean data determination (Federal Register, Vol.

77, No. 6, January 10, 2012). The State of Maryland is also requesting that USEPA concurrently approve, as a revision to the state

implementation plan (SIP) for each state, the related § 175A maintenance plan. This plan ensures that good PM2.5 air quality will be

maintained through 2025. 

The public hearing will be held as required by federal law (Clean Air Act at 42 U.S.C. 7410 (a) and 40 CFR 51.102). After consideration

of comments received, the plan will be finalized and submitted to the United States Environmental Protection Agency (EPA) for

approval. Note: the public library systems in the region can be used for Internet access to view the document.

Copies of the document can be viewed at the offices of the Maryland Department of the Environment, Air and Radiation Management

Administration, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland. For more information, contact Mary Jane Rutkowski at

(410) 537-3240.

Comments may be sent to Mary Jane Rutkowski, Maryland Department of the Environment, Air and Radiation Management

Administration, 1800 Washington Boulevard, Suite 730, Baltimore, MD, 21230; emailed to MaryJane.Rutkowski@Maryland.gov; or faxed

to (410) 537-3203, attn: Mary Jane Rutkowski. Comments must be received by 5:00 P.M. on October 8, 2013, or be submitted at the

hearing.

Persons in need of special accommodations should contact the Department's Office of Fair Practices at (410) 537-3964 at least five (5)

business days in advance of the hearing. TTY users should contact the Department through the Maryland Relay Service at 1-(800) 735-

2258.

For more information, contact Mary Jane Rutkowski at (410) 537-3240 (Toll free in Maryland call 1-(800) 633-6101 ext. 3240), or via

email at MaryJane.Rutkowski@Maryland.gov

Public hearing concerning the Baltimore Serious Nonattainment Area 0.08 ppm 8-Hour Ozone State

Implementation Plan Demonstrating Rate of Progress for 2008, 2011 and 2012 Revision to 2002 Base Year

Emissions; and Serious Area Attainment Demonstration

Draft for Public Comment

Appendices A-E

 Appendices A Projection Year Emissions Inventories

 Appendix C Regulatory Support Information

 Appendix D RACM Measures List

 Appendix E Mobile Budget Documentation

Appendix F Attainment Demonstration

 F1-F11

 F13-14

Appendix B - Reasonable Further Progress Calculations - Not available for download -- Please contact Mary Jane Rutkowski at (410)

537-3240.

Appendix F12 - CMAQ Model Performance Performance Data and Documentation Not available for download -- Please contact Mary Jane

Rutkowski at (410) 537-3240.

Date: June 18, 2013

A public hearing was held on Friday, July 19, 2013, at the Maryland Department of the Environment, 1800 Washington

Boulevard, Baltimore, Maryland 21230 – First Floor Conference Room – 2:00 P.M.

On February 1, 2012 (effective March 2, 2012) EPA reclassified the Baltimore, Maryland Nonattainment Area as a "serious"

nonattainment area. As a serious nonattainment area for 8-hour ozone National Ambient Air Quality Standard (NAAQS), the Baltimore

region is required to meet the requirements defined in the Clean Air Act, Section 182 (d) and to submit a revised serious area SIP by

September 30, 2012.

The Serious Area Attainment Plan describes the progress being made to improve air quality in the Baltimore Nonattainment Area and

the efforts underway to assure that all necessary steps are taken to reach the federal health standard for ground-level ozone by 2012.

The plan has been prepared by the Maryland Department of the Environment Air and Radiation Management Administration to comply

with the Clean Air Act Amendments of 1990 (CAAA) and with EPA requirements for the Baltimore region as stated in EPA’s

reclassification of the Baltimore region (77 Fed. Reg. 4901, February 1, 2012).

The public hearing will be held as required by federal law (Clean Air Act at 42 U.S.C. 7410 (a) and 40 CFR 51.102). After consideration

of comments received, the plan will be finalized and submitted to the United States Environmental Protection Agency (EPA) for

approval. Note: the public library systems in the region can be used for Internet access to view the document.

Copies of the document can be viewed at the offices of the Maryland Department of the Environment, Air and Radiation Management

Administration, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland. For more information, contact Mary Jane Rutkowski at

(410) 537-3240.

Comments may be sent to Mary Jane Rutkowski, Maryland Department of the Environment, Air and Radiation Management

Administration, 1800 Washington Boulevard, Suite 730, Baltimore, MD, 21230; emailed to MaryJane.Rutkowski@Maryland.gov; or faxed

to (410) 537-3203, 

attn: Mary Jane Rutkowski. Comments must be received by 5:00 P.M. on July 19, 2013, or be submitted at the hearing.

Persons in need of special accommodations should contact the Department's Office of Fair Practices at (410) 537-3964 at least five (5)

business days in advance of the hearing. TTY users should contact the Department through the Maryland Relay Service at 1-(800) 735-

2258.

For more information, contact Mary Jane Rutkowski at (410) 537-3240 (Toll free in Maryland call

1-(800) 633-6101 ext. 3240), or via email at MaryJane.Rutkowski@Maryland.gov.

New! Public Hearing on Maryland State Implementation Plan for Clean Air Act Section 110(a)(2) for Nitrogen

Dioxide (NO2) and Section 128 for all National Ambient Air Quality Standards

Draft for Public Comment

Date: May 6, 2013

The Maryland Department of the Environment (MDE) will hold a public hearing on a State Implementation Plan (SIP) addressing

implementation, maintenance, and enforcement measures for the 2010, 100 ppb 1-hour nitrogen dioxide (NO2) National Ambient Air

Quality Standard (NAAQS). This SIP also addresses the requirements for all criteria pollutants’ NAAQS in relation to state boards and

agency heads, and disclosure of potential conflicts of interest.

The public hearing will be held on Wednesday, June 12, 2013, at 2:00 P.M. at the Maryland Department of the Environment

headquarters located at 1800 Washington Boulevard, First Floor Conference Room, Baltimore, Maryland, 21230.
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The public hearing will be held as required by federal law (Clean Air Act at 42 U.S.C. 7410 (a) and 40 CFR 51.102). After consideration

of comments received, the plan will be finalized and submitted to the United States Environmental Protection Agency for approval.

Note: the public library systems in the region can be used for Internet access to view the document.

Copies of the document can be viewed at the offices of the Maryland Department of the Environment, Air and Radiation Management

Administration, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland. For more information, contact Molla Sarros at (410) 537-

3240.

Comments may be sent to Molla Sarros, Maryland Department of the Environment, Air and Radiation Management Administration,

1800 Washington Boulevard, Suite 730, Baltimore, MD, 21230; emailed to Molla Sarros; or faxed to (410) 537-3203, attn: Molla

Sarros. 

Comments must be received by 5:00 P.M. on June 12, 2013, or be submitted at the hearing.

Persons in need of special accommodations should contact the Department's Office of Fair Practices at (410) 537-3964 at least five (5)

business days in advance of the hearing. TTY users should contact the Department through the Maryland Relay Service at 1-(800) 735-

2258.

For more information, contact Molla Sarros at (410) 537-3240 (Toll free in Maryland call 1-(800) 633-6101 ext. 3240) or via email to

Molla Sarros;

New! Public Hearing on Maryland State Implementation Plan for Clean Air Act Section 110(a)(2) for Lead (Pb)

Draft for Public Comment

Date: May 6, 2013

The Maryland Department of the Environment (MDE) will hold a public hearing on a State Implementation Plan (SIP) addressing

implementation, maintenance, and enforcement measures for the 2008, 0.15 μg/m3, lead (Pb) National Ambient Air Quality Standard

(NAAQS). This SIP is an addendum to SIP 12-09, dated December 12, 2012, which MDE submitted to EPA on January 3, 2013.

The public hearing will be held on Wednesday, June 12, 2013, at 2:00 P.M. at the Maryland Department of the Environment

headquarters located at 1800 Washington Boulevard, First Floor Conference Room, Baltimore, Maryland, 21230.

The public hearing will be held as required by federal law (Clean Air Act at 42 U.S.C. 7410 (a) and 40 CFR 51.102). After consideration

of comments received, the plan will be finalized and submitted to the United States Environmental Protection Agency for approval.

Note: the public library systems in the region can be used for Internet access to view the document.

Copies of the document can be viewed at the offices of the Maryland Department of the Environment, Air and Radiation Management

Administration, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland. For more information, contact Molla Sarros at (410) 537-

3240.

Comments may be sent to Molla Sarros, Maryland Department of the Environment, Air and Radiation Management Administration, 1800

Washington Boulevard, Suite 730, Baltimore, MD, 21230; emailed to Molla Sarros; or faxed to (410) 537-3203, attn: Molla Sarros.

Comments must be received by 5:00 P.M. on June 12, 2013, or be submitted at the hearing.

Persons in need of special accommodations should contact the Department's Office of Fair Practices at (410) 537-3964 at least five (5)

business days in advance of the hearing. TTY users should contact the Department through the Maryland Relay Service at 1-(800) 735-

2258.

For more information, contact Molla Sarros at (410) 537-3240 (Toll free in Maryland call

1-(800) 633-6101 ext. 3240) or via email at Molla.Sarros@maryland.gov.

Document:

Maryland's Redesignation Request & Maintenance Plan for Fine Particulate (PM2.5) Matter

SIP Document

Document:

Maryland's Implementation, Maintenance, and Enforcement Measures for the 8-Hour Ozone National Ambient Air Quality Standard State

Implementation Plan

Date: December 21, 2012

SIP Document

Document:

Maryland's Lead (Pb) Infrastructure State Implementation Plan

Date: December 12, 2012

SIP Document

Document:

Maryland's Regional Haze State Implementation Plan

Date: February 9, 2012

SIP Document (4,137 KB)

Appendix A- MANE-VU Class I Area Contribution Assessment 

 Appendix A-1 Trajectory Analysis 

 Appendix A-1a: Trajectory Analysis Results at Acadia National Park 

 Appendix A-1b: Trajectory Analysis Results at Brigantine National Park 

 Appendix A-1c: Trajectory Analysis Results at Dolly Sods Wilderness Area 
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 Appendix A-1d: Trajectory Analysis Results at Great Gulf Wilderness Area 

 Appendix A-1e: Trajectory Analysis Results at Great Smokey Mountains National Park 

 Appendix A-1f: Trajectory Analysis Results at James River Face Wilderness Area

 Appendix A-1g: Trajectory Analysis Results at Lye Brook Wilderness Area

 Appendix A-1h: Trajectory Analysis Results at Mohawk Mountain

 Appendix A-1i: Trajectory Analysis Results at Moosehorn National Wildlife Area

 Appendix A-1j: Trajectory Analysis Results at Multiple Sites

 Appendix A-1k: Trajectory Analysis Results at Queens College, New York City

 Appendix A-1l: Trajectory Analysis Results at Pittsburgh, PA

 Appendix A-1m: Trajectory Analysis Results at Shenandoah National Park

 Appendix A-1n: Trajectory Analysis Results at Washington, D.C. 

 Appendix A-2: Source Attribution by Receptor-Based Methods 

 Appendix A-3: Chemical Transport Model Results

 Appendix A-4: CALPUFF Dispersion Modeling Platforms 

 Appendix A-5: Summary of Stakeholder Comments 

 Appendix A-6: MANE-VU Responses to Comments 

 Appendix A-7: Lake Michigan Air Directors Consortium (LADCO) Contribution Assessment

Appendix B- Final Interim Principals for Regional Planning

Appendix C- Federal Land Managers (FLM) Comments (Placeholder)

Appendix D- Base Year Emissions Inventory (EI)

 Appendix D-1- Technical Support Documentation for the MANE-VU 2002 Inventory 

 Appendix D-2: Technical Support Documentation for the MDE 2002 Base Year Inventory

 Appendix D-2.1: Base Year Haze SIP Inventory Methodologies

 Appendix D-2.2: Point Source Base Year Inventory Database 

 Appendix D-2.3: Area/NonRoad/Quasi-Point Source Base Year Inventory Database 

 Appendix D-2.4: Mobile Source Base Year Inventory Database

Appendix E- Future Year Emissions Inventory

 Appendix E-1: MANE-VU Future Year Modeling Inventories

 Appendix E-1-1: 2009 Data 

 Appendix E-1-2: 2012 Data 

 Appendix E-1-3: 2018 Data 

Appendix E-2- Development of Emissions Projections for 2009, 2012, and 2018

Appendix F- SMOKE Modeling Configuration

Appendix G-Best Available Retrofit Technology (BART)

 Appendix G-1- BART Source List- MANE-VU 

 Appendix G-2- Maryland BART Analysis:

 Appendix G-2a- Constellation Power Source Generation BART Assessment

 Crane Generating Station, Wagner Generating Station 

 Appendix G-2b- Eastalco Aluminum BART Assessment

 Appendix G-2c- Independent/ St. Lawrence Cement Assessment:

 Holcim 2010, St. Lawrence Cement 2007 

 Appendix G-2d- Mettiki Coal, LLC BART Assessment:

 Applicability Qualifiers Letter

 Appendix G-2e- New Page/ Westvaco/ Luke Paper BART Assessment: 

 New Page 2007, New Page 2010 

 Appendix G-2f- Mirant Mid Atlantic, LLC BART Assessment Documentation:

 Mirant 

 Appendix G-3: BART CAIR (Clean Air Interstate Rule) Exemption

 Appendix G-4: Five Factor Analysis of BART Eligible Sources 

 Appendix G-5: Assessment of Control Technology Options for BART Eligible Sources

Appendix H- Baseline and Natural Background Visibility Conditions
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Appendix I- The Nature of Fine Particle and Regional Haze Air Quality Problems in the MANE-VU Region

Appendix J- Comparison of CAIR and CAIRPlus Proposal Using the Integrated Planning Model Future Year Emissions Inventory

Appendix K- Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas

Appendix L- MANE-VU Modeling for Reasonable Progress Goals

Appendix M- 2018 Visibility Projections

Appendix N- Table of Top EGU Emission Points

Appendix O- Technical Support Document on Measures to Mitigate Visibility Impacts on Construction Activities in the MANE-VU Region

Appendix P- Technical Support Document on Agricultural and Forestry Smoke Management in the MANE-VU Region

Appendix Q- Inter-RPO State Tribal & FLM Consultation Framework

Appendix R- Documentation of 2018 Emissions from EGU's

Document:

Maryland’s 8-hour Ozone Reasonably Available Control Technology (RACT) State Implementation Plan, DRAFT 2011 Revision to SIP

Number 06-07

Date: August 24, 2011

SIP Document (1,007 KB)

Document:

Letter to U.S. EPA certifying that MDE has the authority to implement, maintain and enforce the federal PM2.5 National Ambient Air

Quality Standards NAAQS

Document:

Baltimore Nonattainment Area PM2.5 State Implementation Plan and Base Year Inventory

March 24, 2008

SIP Document (2377 KB)

Appendix A – Base Year Emission Inventory

Appendix A-1: Base Year Emission Inventory Methodologies (2679 KB)

Appendix A-2: Point Source Base Year Inventory (884 KB)

Appendix A-3: Quasi-Point Source Base Year Inventory (30 KB)

Appendix A-4: Area Source Base Year Inventory (148 KB)

Appendix A-5: Mobile Source Base Year Inventory (362 KB)

Appendix A-6: Nonroad Source Base Year Inventory (235 KB)

Appendix B – Projection Year Methodologies (194 KB)

Appendix C – Reasonably Available Control Measures (RACM) Analysis

Appendix C-1: List of Potential RACM Control Measures & Analysis (998 KB)

Appendix C-2: BMC Reduction Measures List & Analysis (85 KB)

Appendix D – Mobile Budget Documentation

Appendix D-1: PM2.5 Precursor Significance Determination for the Baltimore, MD Nonattainment Area (123 KB)

Appendix D-2: Baltimore Area Mobile Source Emissions Technical Support Document for the PM2.5 Attainment Plan (271 KB)

Appendix D-3: MOBILE6.2 Input Parameter Summary (96 KB)

Appendix D-4: MOBILE6.2 Sample Input Files (128 KB)

Appendix D-5-1: Baltimore Area VMT and Emission Summary By Vehicle Type (22 KB)

Appendix D-5-2: Baltimore Area VMT and Emission Summary By Functional Class (18 KB)

Appendix D-5-3: Baltimore Area 2009 Annual PM2.5 Summary (21 KB)

Appendix E – Ozone Transport Commission MOU (113 KB)

Appendix F – Contingency Synopsis of the ASIP Sensitivity Study

Appendix F-1: Synopsis of the ASIP PM2.5 Sensitivity Study and SO2/NOX Equivalency Ratios (83 KB)

Appendix F-2: Data from the BOTW/VA CAIR Modeling Run for PM2.5 (34 KB)

Appendix G – Attainment Modeling and Weight of Evidence

Appendix G-1: Conceptual Model (5094 KB)

Appendix G-2: Modeling Domain Boundary (42 KB)

Appendix G-3: Horizontal Grid Definitions for MM5 and CMAQ Modeling Domain (36 KB)

Appendix G-4: Vertical Layer Definitions for MM5 and CMAQ Modeling Domain (179 KB)

Appendix G-5: MM5 Model Configuration (61 KB)

Appendix G-6: MM5 Model Performance Evaluation (7615 KB)

Appendix G-7: SMOKE Processing Description and Configuration (1124 KB)

Appendix G-8: CMAQ Configuration (78 KB)

Appendix G-9: CMAQ Model Performance (20 KB)

Appendix G-10: Additional Information on Design value Calculations (53 KB)

Appendix G-11: Weight of Evidence Report
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Appendix G-11-1: Report (7956 KB)

Appendix G-11-2: Report Appendices (67827 KB)

Document:

State Implementation Plan (SIP) for Annual Fine Particle (PM2.5) Standard and 2002 Base Year Inventory for the Washington DC-MDVA Nonattainment Area

Date: March 7, 2008

Click here to download

Document:

Washington County, MD PM2.5 State Implementation Plan and Base Year Inventory

February 29, 2008

SIP Document (2067 KB)

Appendix A – Base Year Emission Inventory

Appendix A-1: Base Year Emission Inventory Methodologies (2679 KB)

Appendix A-2: Point Source Base Year Inventory (73 KB)

Appendix A-3: Quasi-Point Source Base Year Inventory (11 KB)

Appendix A-4: Area Source Base Year Inventory (32 KB)

Appendix A-5: Mobile Source Base Year Inventory (75 KB)

Appendix A-6: Nonroad Source Base Year Inventory

Appendix A-6-1 (33 KB)

Appendix A-6-2 (15 KB)

Appendix B – Projection Year Methodologies (194 KB)

Appendix C – Reasonably Available Control Measures (RACM) Analysis (894 KB)

Appendix D – Mobile Budget Documentation

Appendix D-1: 2008 RFP and 2009 Attainment Year Mobile Budget Methodology and Documentation (64 KB)

Appendix D-2: Washington County Area: Mobile Source Emissions Technical Support Document February 2007 (256 KB)

Appendix D-3: MOBILE6.2 Input Parameter Summary (94 KB)

Appendix D-4: MOBILE6.2 Sample Input Files (127 KB)

Appendix D-5-1: Washington County VMT and Emission Summary By Vehicle Type (39 KB)

Appendix D-5-2: Washington County VMT and Emission Summary By Functional Class (26 KB)

Appendix D-5-3: Washington County 2009 Annual PM2.5 Summary (15 KB)

Appendix E – Ozone Transport Commission MOU (113 KB)

Appendix F – Contingency Synopsis of the ASIP Sensitivity Study

Appendix F-1: Synopsis of the ASIP PM2.5 Sensitivity Study and SO2/NOX Equivalency Ratios (83 KB)

Appendix F-2: Data from the BOTW/VA CAIR Modeling Run for PM2.5 (34 KB)

Appendix G – Attainment Modeling and Weight of Evidence

Appendix G-1: Conceptual Model (4056 KB)

Appendix G-2: Modeling Domain Boundary (42 KB)

Appendix G-3: Horizontal Grid Definitions for MM5 and CMAQ Modeling Domain (36 KB)

Appendix G-4: Vertical Layer Definitions for MM5 and CMAQ Modeling Domain (179 KB)

Appendix G-5: MM5 Model Configuration (61 KB)

Appendix G-6: MM5 Model Performance Evaluation (7615 KB)

Appendix G-7: SMOKE Processing Description and Configuration (1124 KB)

Appendix G-8: CMAQ Configuration (74 KB)

Appendix G-9: CMAQ Model Performance (20 KB)

Appendix G-10: Additional Information on Design value Calculations (41 KB)

Appendix G-11: Weight of Evidence Report

Appendix G-11-1: Report ( KB)

Appendix G-11-2: Report Appendices (67827 KB)

Document:

Proposed Implementation, Maintenance, and Enforcement of the PM2.5 National Ambient Air Quality Standard State Implementation

Plan

Date: February 15, 2008

Click here to download.

Document:

Implementation, Maintenance, and Enforcement Measures for the 8-Hour Ozone National Ambient Air Quality Standard State

Implementation Plan (SIP)

Date: June 15, 2007

Click here to download.

Document:

Baltimore Nonattainment Area 8-hour Ozone State Implementation Plan and Base Year Inventory

June 15, 2007

SIP Document (6.7 MB)

Appendix A

 Appendix A2 (1.2 MB)
Air Quality Planning

http://www.mde.state.md.us/programs/Air/AirQualityPlanning/Pages/programs/airprograms/air_planning/index.aspx[9/6/2013 2:21:20 PM]

 Appendix A3 (429 KB)

 Appendix A4 (280 KB)

 Appendix A5 (710 KB)

 Appendix A6 (878 KB)

Appendix B (194 KB)

Appendix C (823 KB)

Appendix D (92 KB)

Appendix E

 Appendix E1 (330 KB)

 Appendix E2 (59 KB)

Appendix F

 Appendix F - Mobile Source Emission Technical Support Document (232 KB)

 Appendix F - Input Parameter Summary (57 KB)

 Appendix F - Input Files Sample (27 KB)

 Appendix F - Summary Table (40 KB)

 Appendix F - Emissions Summary (28 KB)

Appendix G

 Appendix G1 (514 KB)

 Appendix G2 (15 KB)

 Appendix G3 (15 KB)

 Appendix G4 (2.4 MB)

 Appendix G5 (1.1 MB)

 Appendix G6 (827 KB)

 Appendix G7 (1.0 MB)

 Appendix G8 (1.7 MB)

 Appendix G9 (378 KB)

 Appendix G10 (802 KB)

 Appendix G11 (342 KB)

 Appendix G12 (367 KB)

 Appendix G13 (188 KB)

 Appendix G14 (67 KB)

 Appendix G15 (49 KB)

Appendix H

Appendix I (69 KB)

Document:

Cecil County, Maryland 8-hour Ozone State Implementation Plan and Base Year Inventory

June 15, 2007

SIP Document (5.4 MB)

Appendix A

 Appendix A2 (118 KB)

 Appendix A3 (35 KB)

 Appendix A4 (112 KB)

 Appendix A5 (129 KB)

 Appendix A6 (382 KB)

Appendix B (194 KB)

Appendix C (220 KB)

Appendix D (83 KB)

Appendix E

 Appendix E1 (328 KB)

 Appendix E2 (59 KB)

Appendix F

 Appendix F - Mobile Source Emission Technical Support Document (232 KB)

 Appendix F - Input Parameter Summary (57 KB)

 Appendix F - Input Files Sample (27 KB)

 Appendix F - Summary Table (40 KB)

 Appendix F - Emissions Summary (15 KB)

Appendix G

 Appendix G1 (514 KB)

 Appendix G2 (15 KB)

 Appendix G3 (15 KB)

 Appendix G4 (2.4 MB)

 Appendix G5 (1.1 MB)

 Appendix G6 (827 KB)

 Appendix G7 (1.0 MB)

 Appendix G8 (1.7 MB)

 Appendix G9 (378 KB)

 Appendix G10 (802 KB)

 Appendix G11 (342 KB)

 Appendix G12 (367 KB)

 Appendix G13 (188 KB)

 Appendix G14 (67 KB)

 Appendix G15 (86 KB)

Appendix H

Appendix I (79 KB)

Document:

State Implementation Plan (SIP) for 8-Hour Ozone Standard and 2002 Base Year Inventory for the Washington DC-MD-VA

Nonattainment Area

May 23, 2007

Click here

Document:

Revision to Maryland’s Transportation Conformity State Implementation Plan

November 9, 2006

SIP Document (71 KB)

Regulation (1,087 KB)

Regulation - Full Text (110 KB)

Document:

Maryland’s 8-hour Ozone Reasonably Available Control Technology (RACT) State Implementation Plan

July 31, 2006

SIP Document (510 KB)
Air Quality Planning

http://www.mde.state.md.us/programs/Air/AirQualityPlanning/Pages/programs/airprograms/air_planning/index.aspx[9/6/2013 2:21:20 PM]

Appendix A (102 KB)

Appendix B (15 KB) RACT SIP Survey

Appendix C (333 KB) RACT and Major Sources

Document:

Redesignation Request for Kent and Queen Anne’s Counties 8-hour Ozone Nonattainment Area

Date: March 15, 2006

Click here to download.

Document:

Maintenance Plan and 2002 Base Year Emission Inventory for the Kent and Queen Anne's Counties 8-hour Ozone Nonattainment Area

Date: March 15, 2006

Click here to download.

Document:

Revisions to Kent and Queen Anne’s Counties 1-hour Ozone Maintenance Plan

Date: March 15, 2006

Click here to download.

Document:

Washington County 8-Hour Ozone Early Action Compact (EAC) State Implementation Plan: Air Quality Modeling Addendum

SIP Revision 04-10 - Addendum

Date: February 16, 2005

Click here to download.

Document:

Washington County 8-Hour Ozone Early Action Compact (EAC) State Implementation Plan

SIP Document: Executive Summary/Table of Contents/Chapters 1-8 (2.1 MB PDF file)

Appendix A (574 KB) Early Action Compact Agreement With Washington County

Appendix B (622 KB) EAC Guidance and Protocol Documents

Appendix C (526 KB) EAC Memorandums

Appendix D (36 KB) Control Measures Selected for Action Plan

Appendix E (7,135 KB) Comprehensive Analysis of Transportation Emission Reduction Measures

Appendix F (547 KB) Health and Ozone

Appendix G (249 KB) History of the Early Action Plan

Appendix H (1,866 KB) Regional Transport and 8-Hour Ozone

Appendix I (3,471 KB) Documentation of Public Process

Document:

SIP Revision 04-06 (Proposed) - Revision to the Washington Severe SIP: Implementation of Section 185 Fee Structure

Date: March 26, 2004

Click here to download.

Document:

SIP Revision 04-04 (Proposed) - Memorandum of Agreement (MOA) to Allow EPA to Grant the Separation of the Kent and Queen Anne’s

Counties 8-Hour Ozone Nonattainment Area from the Baltimore Region 8-Hour Ozone Nonattainment Area between U.S. EPA Region III

and MDE

Date: February 25, 2004

Click here to download.

Document:

Modification to the Rate of Progress Plan for Cecil County: Revising Mobile Emission Estimates with Mobile6

Date: January 8, 2004

Click here to download.

Document:

Redesignation Request for Kent and Queen Anne’s Counties Ozone Nonattainment Area

Date: December 18, 2003

Click here to download.

Document:

Maintenance Plan for the Baltimore Carbon Monoxide Attainment Area

Date: December 15, 2003

Click here to download.

Document:

Demonstrating Rate of Progress for 2002 and 2005; Revision to 1990 Base Year Emissions; and Severe Area Attainment Demonstration

for the WASHINGTON DC-MD-VA Nonattainment Area

Date: December 17, 2003

Click here to download.

Document:

Revised Carbon Monoxide Maintenance Plan and Revised 1990 Carbon Monoxide Base Year Emissions Inventory for the Washington DCMD-VA Nonattainment Area

Date: December 17, 2003

Click here to download.

Document:

2002 Maryland Air Quality Report - Status Report and Long-Term Trends

Date: December 3, 2003

Click here to download the report.

Click here for historical air quality data.

Document:

Modification to the Rate of Progress Plan for the Baltimore Region: Revising Mobile Emission Estimates with Mobile6

Date: October 27, 2003

Click here to download.

Appendix A - Mobile6 Documentation

Document:

Proposed State Implementation Plan (SIP) - “Severe Area SIP” - Demonstrating Rate of Progress for 2002 and 2005, Revision to 1990

Base Year Emissions, and Severe Area Attainment Demonstration for the WASHINGTON DC-MD-VA NONATTAINMENT

Date: June 2, 2003

SIP Document: Executive Summary/Table of Contents/Chapters 1-12 (1.2 MB PDF file)
Air Quality Planning

http://www.mde.state.md.us/programs/Air/AirQualityPlanning/Pages/programs/airprograms/air_planning/index.aspx[9/6/2013 2:21:20 PM]

Appendix A (72 KB PDF file) - Membership Rosters for the Metropolitan Washington Air Quality Committee (MWAQC) and

its Technical Advisory Committee and Air Quality Public Advisory Committee

Appendix B (3.7 MB PDF file) - MOBILE6 Inventories and Documentation

Appendices C-F (1.2 MB PDF file)

Appendix C - Round 6.2 Cooperative Forecast Projections: Area and Nonroad Inventories and Projections

Appendix D - Draft Round 6.3 Cooperative Forecast Projections: Area and Nonroad Inventories and Projections

Appendix E - Point Source Inventories and Projections

Appendix F - Use of NOx Substitution in Rate of Progress; RACT Fix-Up Documentation

Appendices G-K (3.1 MB PDF file)

Appendix G - Emission Reduction from Transportation Control Measures

Appendix H - Severe Area Plan Commitments

Appendix I - Contingency Plan Commitments; Emissions Reductions from Phase II RFG Controls; Emissions Reductions from Selected

Contingency Measures

Appendix J - EPA Voluntary Measures Guidance; Allowable Tonnage from Voluntary Measures; Voluntary Measure Documentation

Appendix K - Information Related to Public Hearings, Hearing Notices, Comments Received and Response to Comments

Appendix L (11 KB PDF file) - Analysis of Potential Stationary Source RACM Measures for the Metropolitan Washington Region's Severe

Area SIP

Appendix M (40 KB PDF file) - Analysis of Potential Area Source RACM Measures for the Metropolitan Washington Region's Severe Area

SIP

Appendix N (138 KB PDF file) - Analysis of Potential Non-Road Source RACM Measures for the Metropolitan Washington Region's Severe

Area SIP

Appendix O (285 KB PDF file) - Analysis of Potential Mobile Source RACM Measures for the Metropolitan Washington Region's Severe

Area SIP

Document:

Modification to the Phase II Attainment Plan for the Baltimore and Cecil County Nonattainment Areas: Revising the Mobile Source

Emission Budgets using Mobile 6

Date: May 21, 2003

Click here to download.

Document:

Reasonably Available Control Measure (RACM) Analysis for Cecil County

Date: July 18, 2001

Click here to download.

Document:

Reasonably Available Control Measure (RACM) Analysis for the Baltimore Region

Date: July 6, 2001

Click here to download.

Document:

Modification to the Phase II Attainment Plan for the Baltimore Region: Revising the Mobile Source Emission Budgets, Adding Tier 2

Standards

Date: November 6, 2000

Click here to download.

Document:

Modification to the Phase II Attainment Plan for Cecil County: Revising the Mobile Source Emission Budgets, Adding Tier 2 Standards

Date: November 9, 2000

Click here to download.

Document:

Maryland Commitment letter to EPA for Baltimore region

Date: December 17, 1999

Click here to download.

Document:

Maryland Commitment letter to EPA for Cecil County

Date: February 2, 2000

Click here to download.

Document:

Modification to the Phase II Attainment Plan for the Baltimore Nonattainment Area and Cecil County: Revising the Mobile Source

Emission Budgets

Date: November 9, 1999

Click here to download.

Document:

Phase II Attainment Plan for the Baltimore Nonattainment Area and Cecil County

Date: April 24, 1998

Click here to download.

Document:

Technical Support Document for the Phase II Attainment Plan for the Baltimore Region

Date: June 29, 2001

Click here to download.

Document:

Phase I Attainment Plan for the Baltimore Nonattainment Area and Cecil County

Date: April 24, 1998

SIP Document: Executive Summary, Chapters 1-9, and References

Appendix A: EPA Policy Memorandum
Air Quality Planning

http://www.mde.state.md.us/programs/Air/AirQualityPlanning/Pages/programs/airprograms/air_planning/index.aspx[9/6/2013 2:21:20 PM]

Appendix B: Modifications and Projections to the 1990 Base Year

Appendix C: Post-1996 Target Level Calculation Following EPA Guidance

Appendix D: Nonroad Emission Reductions

Appendix E: Emission Reductions from Control Measures Included in the 15% RPP

Appendix F: The OTC NOx Emission Reduction MOU and Calculation of NOx Emission Reductions from Stationary Sources

Appendix G: Nitrogen Oxides Substitution

Appendix H: Revisions to the 15% Rate of Progress Plan

Document:

1990 Greenhouse Gas Inventory

Date:April, 2001

Click here to download.

Additional Links

Proposed Action for Distributed Generation

National Ambient Air Quality Standards

Emission Reduction Credits

WILMAPCO Transportation Plan

MWCOG Transportation Plan

Baltimore Regional Transportation Plan

Transportation Conformity- MDE Presentation

Contact the Office | Accessibility | Privacy Notice

1800 Washington Boulevard, Baltimore, MD 21230 | (410) 537-3000
Maryland Register

Issue Date: September 20, 2013

Volume 40 • Issue 19 • Pages 1529-1604

IN THIS ISSUE

Judiciary

Regulatory Review and Evaluation

Regulations

Errata

General Notices

Pursuant to State Government Article, §7-206, Annotated Code of Maryland, this issue contains all previously unpublished documents

required to be published, and filed on or before August 29, 2013 5 p.m.

Pursuant to State Government Article, §7-206, Annotated Code of Maryland, I hereby certify that this issue contains all documents

required to be codified as of August 29, 2013.

Brian Morris

Acting Administrator, Division of State Documents

Office of the Secretary of State

Information About the Maryland Register and COMAR

MARYLAND REGISTER

The Maryland Register is an official State publication published every other week throughout the year. A cumulative index is published quarterly.

The Maryland Register is the temporary supplement to the Code of Maryland Regulations. Any change to the text of regulations published in

COMAR, whether by adoption, amendment, repeal, or emergency action, must first be published in the Register.

The following information is also published regularly in the Register:

• Governor’s Executive Orders

• Attorney General’s Opinions in full text

• Open Meetings Compliance Board Opinions in full text

• State Ethics Commission Opinions in full text

• Court Rules

• District Court Administrative Memoranda

• Courts of Appeal Hearing Calendars

• Agency Hearing and Meeting Notices

• Synopses of Bills Introduced and Enacted by the General Assembly

• Other documents considered to be in the public interest

CITATION TO THE MARYLAND REGISTER

The Maryland Register is cited by volume, issue, page number, and date. Example:

• 19:8 Md. R. 815—817 (April 17, 1992) refers to Volume 19, Issue 8, pages 815—817 of the Maryland Register issued on April 17, 1992.

CODE OF MARYLAND REGULATIONS (COMAR)

COMAR is the official compilation of all regulations issued by agencies of the State of Maryland. The Maryland Register is COMAR’s temporary

supplement, printing all changes to regulations as soon as they occur. At least once annually, the changes to regulations printed in the Maryland
GENERAL NOTICES

1601

MARYLAND REGISTER, VOLUME 40, ISSUE 19, FRIDAY, SEPTEMBER 20, 2013

STATE BOARD OF STATIONARY 

ENGINEERS

Subject: Public Meeting

Date and Time: November 19, 2013, 10 

a.m. — 12 p.m.

Place: 500 N. Calvert St., Rm. 302, 

Baltimore, MD

Contact: Gae Herzberger (410) 230-6163

[13-19-17]

DEPARTMENT OF THE 

ENVIRONMENT/AIR AND 

RADIATION MANAGEMENT 

ADMINISTRATION

Subject: Notice of Public Hearing on Air 

Quality Plan

Date and Time: October 7, 2013, 1 p.m.

Place: Dept. of the Environment, 1800 

Washington Blvd., Baltimore, MD

Add’l. Info: The Maryland Department of 

the Environment (MDE) gives notice of a 

Public Hearing concerning Baltimore 

Nonattainment Area PM2.5 Redesignation 

Request and Maintenance Plan.

A public hearing will be held on: 

October 7, 2013, at the Department of the 

Environment, 1800 Washington Boulevard, 

Baltimore, Maryland 21230 — First Floor 

Conference Room — 1:00 P.M. The Public 

Hearing will be held as required by federal 

law (Clean Air Act at 42 U.S.C. 7410(a) 

and 40 CFR 51.102). Interested persons are 

invited to attend and express their views. 

After the Department considers the 

comments received, and revises the 

proposal if necessary, all related items will 

be submitted to the U.S. Environmental 

Protection Agency.

An electronic copy of the 

proposed revision will be available 

on the Maryland Department of 

the Environment’s website at 

http://www.mde.state.md.us/programs/Air/

AirQualityPlanning/Pages/programs/airpro

grams/air_planning/index.aspx. Note: the 

public library systems in Maryland can be 

used for Internet access to view the 

document. An electronic copy of the 

document can also be obtained via email by 

writing to Mary Jane Rutkowski at 

MaryJane.Rutkowski@Maryland.gov.

Copies of the document can also be 

viewed at the Maryland Department of the 

Environment Main Office, Air and 

Radiation Management Administration, 

1800 Washington Boulevard, Baltimore, 

Maryland.

Hard Copy Contact: Mary Jane 

Rutkowski.

Written comments may be presented at the 

hearing, faxed to 410-537-3203, emailed to 

MaryJane.Rutkowski@Maryland.gov, or 

mailed to Mary Jane Rutkowski, MDE 

ARMA, 1800 Washington Boulevard, Suite 

730, Baltimore, MD, 21230. Comments must 

be received before 5 p.m. on July 19, 2013.

Anyone needing special accommodations 

at a public hearing should contact the 

Department’s Fair Practices Office at (410) 

537-3964. TTY users may contact the 

Department through the Maryland Relay 

Service at 1-800-735-2258.

For more information, contact Mary 

Jane Rutkowski, Natural Resources 

Planner, at (410) 537-3240. Toll free in 

Maryland call 1-(800) 633-6101, ext. 3240, 

Maryland Department of the Environment, 

Air and Radiation Management 

Administration, 1800 Washington 

Boulevard, Ste. 730, Baltimore, Maryland 

21230.

Contact: Mary Jane Rutkowski (410) 537-

3240

[13-19-52]

DEPARTMENT OF THE 

ENVIRONMENT/AIR AND 

RADIATION MANAGEMENT 

ADMINISTRATION 

Subject: Notice of Public Hearing on Air 

Quality Plan

Date and Time: October 8, 2013, 1:30 

p.m.

Place: Washington Co. Planning Dept., 

Washington Co. Administrative Annex, 80 

W. Baltimore St., Hagerstown, Maryland 

21740

Add’l. Info: The Maryland Department of the 

Environment (MDE) gives notice of a Public 

Hearing concerning Washington County, MD 

Nonattainment Area PM2.5 Redesignation 

Request and Maintenance Plan.

The Public Hearing will be held as 

required by federal law (Clean Air Act at 

42 U.S.C. 7410(a) and 40 CFR 51.102). 

Interested persons are invited to attend and 

express their views. After the Department 

considers the comments received, and 

revises the proposal if necessary, all related 

items will be submitted to the U.S. 

Environmental Protection Agency.

An electronic copy of the 

proposed revision will be available 

on the Maryland Department 

of the Environment’s website at 

http://www.mde.state.md.us/programs/Air/

AirQualityPlanning/Pages/programs/airpro

grams/air_planning/index.aspx. 

Note: the public library systems in 

Maryland can be used for Internet access to 

view the document. An electronic copy of 

the document can also be obtained via 

email by writing to Mary Jane Rutkowski 

at MaryJane.Rutkowski@Maryland.gov.

Copies of the document can also be 

viewed at the

1. The Maryland Department of the 

Environment, Air and Radiation 

Management Administration, 1800 

Washington Boulevard, Suite 730, 

Baltimore, Maryland. 

2. Washington County Planning 

Department, Washington County 

Administrative Annex, 80 West 

Baltimore Street, Hagerstown, 

Maryland

Hard Copy Contact: Mary Jane 

Rutkowski.

Written comments may be presented at the 

hearing, faxed to 410-537-3203, emailed to 

MaryJane.Rutkowski@Maryland.gov, or 

mailed to Mary Jane Rutkowski, MDE 

ARMA, 1800 Washington Boulevard, Suite 

730, Baltimore, MD, 21230. Comments must 

be received before 5 p.m. on July 19, 2013.

Anyone needing special accommodations 

at a public hearing should contact the 

Department’s Fair Practices Office at (410) 

537-3964. TTY users may contact the 

Department through the Maryland Relay 

Service at 1-800-735-2258.

For more information, contact Mary 

Jane Rutkowski, Natural Resources 

Planner, at (410) 537-3240. Toll free in 

Maryland call 1-(800) 633-6101, ext. 3240, 

Maryland Department of the Environment, 

Air and Radiation Management 

Administration, 1800 Washington 

Boulevard, Ste. 730, Baltimore, Maryland 

21230

Contact: Mary Jane Rutkowski (410) 537-

3240

[13-19-53]

BOARD OF ENVIRONMENTAL 

HEALTH SPECIALISTS

Subject: Public Meeting

Date and Time: October 2, 2013, 10 a.m. 

— 3 p.m.

Place: Howard Co. Bureau of Utilities, 

8720 Old Montgomery Rd., Baltimore, MD

Add’l. Info: The Board may discuss/vote 

on proposed regulations. A portion of the 

meeting may be held in closed session.

Contact: James T. Merrow (410) 764-4722

[13-19-24]

FIRE PREVENTION COMMISSION

Subject: Public Meeting

Date and Time: October 17, 2013, 9:30 

a.m.

Place: Laurel Municipal Bldg., 8103 Sandy 

Spring Rd., Council Chambers, Laurel, MD

Add’l. Info: If public schools in Prince 

George’s County are CLOSED due to 

inclement weather, the meeting and any 

appeals will be rescheduled.

Contact: Heidi Ritchie (877) 890-0199

[13-19-46]
1

Opening Remarks

Public Hearing on 

Baltimore Nonattainment Area PM2.5 Redesignation Request 

and Maintenance Plan

Date: October 7, 2013

Mary Jane Rutkowski, Hearing Officer

Maryland Department of the Environment

If the court reporter would turn on the equipment, we will begin. Good Afternoon. 

On behalf of the Maryland Department of the Environment, Air and Radiation 

Management Administration, I would like to welcome everyone present to this 

public hearing. This public hearing is being held pursuant to federal law found at 

42 U. S. C. § 7410(a) and 40 CFR Parts 51.102 and 251. It is also being held in 

conformance with the State Administrative Procedure Act, under the State 

Government Article, beginning at Section 10-101.

Notice was also posted on the Maryland Department of the Environment web site 

starting on September 6, 2013.
2

My name is Mary Jane Rutkowski. I am a Natural Resources Planner with

the Air and Radiation Management Administration’s Air Quality Planning 

Program. I will serve as hearing officer this morning.

First, I would like to ask all in attendance to please sign-in at the back, if you 

haven't already done so. This will help us to keep an accurate record of the people 

who participate in our proceedings here today. Also, a full copy of the proposed 

SIP is available on the back table for your information. 

The hearing will proceed in the following order. First, ______, a _____with 

the _____Program of the Air and Radiation Management Administration will read 

the Department’s statement into the record.

After ______ is finished reading the Department’s statement, I will first call 

on any elected official or government official who wants to make a statement. 

Then, I will call upon anyone else who indicated on the sign-in sheet that he or she 

would like to make a statement.
3

When giving your statement, please come up to the table, identify yourself 

and your affiliation, and give your statement loudly and clearly so the court 

reporter is sure to catch your words. Hearing procedure does not call for question 

and answer sessions. Statements recorded at this hearing event will be answered in 

writing and published with the final State Implementation Plan document. Are 

there any procedural questions?

Once all questions have been taken -- if there are any -- you are ready to 

begin.

If the court reporter would begin we will go on record to receive comment. -

_______ will proceed with the Department’s statement. Again, there are copies on 

the back table you may use to read along.

(While _____ reads her statement you get up and walk to the back and pick 

up the sign in sheets. You are looking to see who said they would like to make 

a comment. When he is finished his presentation, you thank him and look to 

call on any elected officials who wanted to make a statement first. If there are 

no elected officials, you call on the first person that wanted to comment.)
4

I will now call on .

After calling on all those who wanted to make a statement say the following:

Now is there anyone who would like to make a statement, but did not 

indicate so on the sign-in sheet?

(If no one wants to make statement, say:)

No one has indicated that they wish to make a statement, is there anyone 

who would now like to make a statement, even if they did not indicate so on the 

sign-in sheets.

(After all statements have been presented, say)

Let the record reflect that a statement has been taken from all who wish to 

make one. This will conclude this public hearing. Let the record reflect that it is 

now (The correct time) o'clock and this hearing on the State Implementation Plan 

stands closed at the end of these proceedings on October 7, 2013. Also, at 5:00 pm 

today, the official comment period for the document of record will completely

close.
5

PUBLIC HEARING

WHAT TO SAY IF NOBODY SHOWS FOR THE HEARING

§ WAIT AT LEAST 30 MINUTES BEFORE YOU DO ANYTHING !!!

IF THE COURT REPORTER WOULD PLEASE TURN ON THE 

NECESSARY EQUIPMENT: LET THE RECORD SHOW THAT the time is 

now XXX o’clock on October 7, 2013. This hearing was scheduled for a 1:00

pm start time. There are currently no persons in the audience wishing to make 

any statements on the record so we request that the court reporter please enter 

the hearing statement into the record at this time. This public hearing is now 

closed. Also, at 5:00 pm today, the official comment period for the document of 

record will close.
1

Statement of the Air and Radiation Management Administration

Maryland Department of the Environment

For the Public Hearing concerning the 

Baltimore Nonattainment Area

PM2.5 Redesignation Request and Maintenance Plan 

October 7, 2013

Good Afternoon. My name is Molly Berger. I am a Natural Resources Planner in the SIP Development & 

Emissions Inventory Division, Air Quality Planning Program of the Air & Radiation Management 

Administration, Maryland Department of the Environment. 

This public hearing is related to the air quality plan entitled the Baltimore Nonattainment Area

PM2.5 Redesignation Request and Maintenance Plan

This public hearing is being held pursuant to federal law found at 42 U. S. C. § 7410(a) and 40 CFR Parts 

51.102 and 251. It is also being held in conformance with the State Administrative Procedure Act, under 

the State Government Article, beginning at Section 10-101.

Notice of this public hearing appeared on the Maryland Department of the Environment's website on 

September 6, 2013, and remained on the website to the date of today's hearing.

Copies of each of the public hearing notices and the proposed SIP revision will be part of the formal hearing 

record. Access to the proposed document was made available via the website of the Maryland Department of 

the Environment. Hard copies were also available at the Maryland Department of the Environment.

The purpose of this hearing is to provide the public with an opportunity to formally comment on the 

proposed document.

-----------------

The Clean Air Act was passed in 1970 to protect public health and welfare. Congress amended the Act in 

1990 to establish requirements for areas not meeting the National Ambient Air Quality Standards 

(NAAQS). The Clean Air Act Amendments established a process for evaluating air quality in each region 

and identifying nonattainment areas according to the severity of its air pollution problem. The Clean Air 

Act sets health standards for six ambient pollutants: carbon monoxide, sulfur dioxide, nitrogen oxides, 

ozone, lead and particulate matter. The Environmental Protection Agency establishes rules and regulations 

to implement the Clean Air Act.

The State of Maryland requests that the United States Environmental Protection Agency (USEPA) 

redesignate the Baltimore, MD 1997 fine particulate (PM2.5) nonattainment area to attainment for this 

standard pursuant to the provisions under § 107 of the federal Clean Air Act (CAA). Since the 

designations for the National Ambient Air Quality Standards (NAAQS) for this pollutant were published 

(Federal Register, Vol. 70, No. 3, 1/5/2005), the area’s PM2.5 air quality has improved due to permanent 
2

and enforceable emission reductions. Air quality in the area is significantly better than required by this 

standard. Due to the improvement in PM2.5 air quality, the USEPA finalized a clean data determination 

for the Baltimore area on May 22, 2012 (Federal Register, Vol. 77, No. 99, 5/22/2012). The State of 

Maryland is also requesting that USEPA concurrently approve, as a revision to the state implementation 

plan (SIP) for each state, the related § 175A maintenance plan. This plan ensures that good PM2.5 air 

quality will be maintained through 2025.

CONSIDERATION OF COMMENTS 

The Department will consider all pertinent comments, and revise the proposed plan if necessary, before 

making a final decision to adopt the plan and submit it to the U.S. Environmental Protection Agency for 

approval as a Maryland State Implementation Plan. Oral and written comments may be presented at this 

hearing. The 30-day public comment period that began on September 6, 2013, for receipt of all comments 

to the plan will close at 5:00 PM today.
In the Matter of:

Maryland Department of the Environment

October 7, 2013

Public Hearing

Condensed Transcript with Word Index

For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555
Public Hearing

Maryland Department of the Environment 10/7/2013

(301) 870-8025 - www.ftrinc.net - (800) 921-5555

For The Record, Inc.

1 (Pages 1 to 4)

1

1 MARYLAND DEPARTMENT OF THE ENVIRONMENT

2 AIR AND RADIATION MANAGEMENT ADMINISTRATION

3

4

5 PUBLIC HEARING

6 BALTIMORE NONATTAINMENT AREA PM2.5

7 REDESIGNATION REQUEST AND MAINTENANCE PLAN

8 BALTIMORE, MARYLAND

9

10

11

12 OCTOBER 7, 2013

13 1:00 p.m.

14

15

16 MARYLAND DEPARTMENT OF THE ENVIRONMENT

17 1800 WASHINGTON BOULEVARD

18 BALTIMORE, MARYLAND 21230

19

20

21 Reported by: Kathleen Vetters

22

2

1 A T T E N D E E S

2

3 Ms. Mary Jane Rutkowski, MDE

4 Ms. Molly Berger, MDE

5 Ms. Sara Tomlinson, Baltimore Metropolitan Council

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

3

1 P R O C E E D I N G S

2 - - - - -

3 MS. RUTKOWSKI: If the court reporter would

4 turn on the equipment we will begin. Good afternoon. On

5 behalf of the Maryland Department of the Environment, Air

6 and Radiation Management Administration, I would like to

7 welcome everyone present to this public hearing.

8 This public hearing is being held pursuant to

9 federal law found at 42 U.S.C. Section 7410(a) and

10 40 CFR Parts 51.102 and 251. It is also being held in

11 conformance with the State Administrative Procedure Act

12 under the State Government Article, beginning at Section

13 10-101. Notice was also posted on the Maryland Department

14 of the Environment's website starting on September 6,

15 2013.

16 My name is Mary Jane Rutkowski. I am a Natural

17 Resources Planner with the Air and Radiation Management

18 Administration's Air Quality Planning Program. I will

19 serve as hearing officer this afternoon. A full copy of

20 the proposed SIP is available on the back table.

21 This hearing will proceed in the following

22 order. First, Molly Berger, a Natural Resources Planner

4

1 with the Air Quality Planning Program of the Air and

2 Radiation Management Administration, will read the

3 Department's statement into the record.

4 After Molly is finished reading the

5 Department's statement I will call on any elected

6 officials. Then, I will call upon anyone else who

7 indicated on the sign-in sheet that he or she would like

8 to make a statement. The hearing procedure does not call

9 for question and answer sessions. Statements recorded at

10 this hearing event will be answered in writing and

11 published with the final State Implementation Plan

12 document. Are there any procedural questions?

13 MS. TOMLINSON: No.

14 MS. RUTKOWSKI: Okay. If the court reporter

15 would begin, we will go on record to receive comments.

16 Molly will proceed with the Department's statement.

17 MS. BERGER: Good afternoon. My name is Molly

18 Berger. I am a Natural Resources Planner in the SIP

19 Development and Emissions Inventory Division, Air Quality

20 Planning Program of the Air and Radiation Management

21 Administration, Maryland Department of the Environment.

22 This public hearing is related to the air
Public Hearing

Maryland Department of the Environment 10/7/2013

(301) 870-8025 - www.ftrinc.net - (800) 921-5555

For The Record, Inc.

2 (Pages 5 to 8)

5

1 quality plan entitled the Baltimore Nonattainment Area

2 PM2.5 Redesignation Request and Maintenance Plan.

3 This public hearing is being held pursuant to

4 federal law found at 42 U.S.C. Section 7410(a) and

5 40 CFR Parts 51.102 and 251. It is also being held in

6 conformance with the State Administrative Procedure Act

7 under the State Government Article, beginning at Section

8 10-101.

9 Notice of this public hearing appeared on the

10 Maryland Department of the Environment's website on

11 September 6, 2013, and remained on the website to the

12 date of today's hearing.

13 Copies of each of the public hearing notices

14 and the proposed SIP revision will be part of the formal

15 hearing record. Access to the proposed document was made

16 available via the website of the Maryland Department of

17 the Environment. Hard copies were also available at the

18 Maryland Department of the Environment.

19 The purpose of this hearing is to provide the

20 public with an opportunity to formally comment on the

21 proposed document.

22 The Clean Air Act was passed in 1970 to protect

6

1 public health and welfare. Congress amended the Act in

2 1990 to establish requirements for areas not meeting the

3 National Ambient Air Quality Standards. The Clean Air Act

4 Amendments established a process for evaluating air

5 quality in each region and identifying nonattainment

6 areas according to the severity of its air pollution

7 problem.

8 The Clean Air Act sets health standards for six

9 ambient pollutants: carbon monoxide, sulfur dioxide,

10 nitrogen oxides, ozone, lead, and particulate matter. The

11 Environmental Protection Agency establishes rules and

12 regulations to implement the Clean Air Act.

13 The State of Maryland requests that the United

14 States Environmental Protection Agency redesignate the

15 Baltimore, Maryland 1997 fine particulate nonattainment

16 area to attainment for this standard pursuant to the

17 provisions under Section 107 of the federal Clean Air

18 Act.

19 Since the designations for the National Ambient

20 Air Quality Standards for this pollutant were published,

21 the area's PM2.5 air quality has improved due to permanent

22 and enforceable emission reductions. Air quality in the

7

1 area is significantly better than required by this

2 standard.

3 Due to the improvement in PM2.5 air quality, the

4 United States Environmental Protection Agency finalized a

5 clean data determination for the Baltimore area on May 22,

6 2012. The State of Maryland is also requesting that

7 United States EPA concurrently approve, as a revision to

8 the state implementation plan for each state, the related

9 Section 175A maintenance plan. This plan ensures that good

10 PM2.5 air quality will be maintained through 2025.

11 The Department will consider all pertinent

12 comments and revise the proposed plan, if necessary,

13 before making a final decision to adopt the plan and

14 submit it to the U.S. Environmental Protection Agency for

15 approval as a Maryland State Implementation Plan. Oral

16 and written comments may be presented at this hearing.

17 The 30-day public comment period that began on September

18 6, 2013 for receipt of all comments to the plan will

19 close at 5:00 p.m. today.

20 MS. RUTKOWSKI: Maybe we want to go off the

21 record now for a little while.

22 (Off the record.)

8

1 MS. RUTKOWSKI: Okay. Back on the record.

2 No one has indicated that they wish to make a statement.

3 Is there anyone who would now like to make a statement,

4 even if they did not indicate so on the sign-in sheets?

5 Let the record reflect that a statement has

6 been taken from all who wish to make one. This will

7 conclude this public hearing. Let the record reflect

8 that it is now 1:31 p.m. and this hearing on the State

9 Implementation Plan stands closed at the end of these

10 proceedings on October 7, 2013. Also, at 5:00 p.m. today

11 the official comment period for the document of record

12 will completely close.

13 (Whereupon, the public

14 hearing was concluded.)

15

16

17

18

19

20

21

22
Public Hearing

Maryland Department of the Environment 10/7/2013

(301) 870-8025 - www.ftrinc.net - (800) 921-5555

For The Record, Inc.

3 (Page 9)

9

1 CERTIFICATE OF COURT REPORTER

2

3 I, Kathleen Vetters, a Notary Public of the

4 State of Maryland, County of Baltimore, do hereby certify

5 the foregoing proceeding was recorded verbatim by me and

6 this transcript is a true record of the proceedings.

7 I further certify that I am not of counsel to

8 any of the parties, nor in any way interested in the

9 outcome of this action.

10 As witness my hand and notarial seal this

11 21st day of October, 2013.

12

13 ___________________________________

14 KATHLEEN VETTERS, Court Reporter

15 NOTARY PUBLIC

16

17 My Commission Expires: November 19, 2015

18

19

20

21

22
Public Hearing

Maryland Department of the Environment 10/7/2013

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For The Record, Inc.

[10]

A

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approval 7:15

approve 7:7

area 1:6 5:1 6:16 7:1

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attainment 6:16

available 3:20 5:16

5:17

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back 3:20 8:1

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close 7:19 8:12

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conclude 8:7

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concurrently 7:7

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copies 5:13,17

copy 3:19

Council 2:5

counsel 9:7

County 9:4

court 3:3 4:14 9:1

9:14

D

D 2:1 3:1

data 7:5

date 5:12

day 9:11

decision 7:13

Department 1:1,16

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5:16,18 7:11

Department's 4:3,5

4:16

designations 6:19

determination 7:5

Development 4:19

dioxide 6:9

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document 4:12 5:15

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due 6:21 7:3

E

E 2:1,1,1 3:1,1

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enforceable 6:22

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entitled 5:1

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Environment's 3:14

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Environmental 6:11

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equipment 3:4

establish 6:2

established 6:4

establishes 6:11

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event 4:10

Expires 9:17

F

federal 3:9 5:4 6:17

final 4:11 7:13

finalized 7:4

fine 6:15

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following 3:21

foregoing 9:5

formal 5:14

formally 5:20

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full 3:19

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G 3:1

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hand 9:10

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3:21 4:8,10,22 5:3

5:9,12,13,15,19

7:16 8:7,8,14

held 3:8,10 5:3,5

I

identifying 6:5

implement 6:12

implementation

4:11 7:8,15 8:9

improved 6:21

improvement 7:3

indicate 8:4

indicated 4:7 8:2

interested 9:8

Inventory 4:19

J

Jane 2:3 3:16

K

Kathleen 1:21 9:3

9:14

L

law 3:9 5:4

lead 6:10

little 7:21

M

maintained 7:10

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7:9

making 7:13

Management 1:2

3:6,17 4:2,20

Mary 2:3 3:16

Maryland 1:1,8,16

1:18 3:5,13 4:21

5:10,16,18 6:13,15

7:6,15 9:4

matter 6:10

MDE 2:3,4

meeting 6:2

Metropolitan 2:5

Molly 2:4 3:22 4:4

4:16,17

monoxide 6:9

N

N 2:1 3:1

name 3:16 4:17

National 6:3,19

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4:18

necessary 7:12

nitrogen 6:10

nonattainment 1:6

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Notary 9:3,15

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order 3:22

outcome 9:9

oxides 6:10

ozone 6:10

P

P 3:1

p.m 1:13 7:19 8:8,10

part 5:14
Public Hearing

Maryland Department of the Environment 10/7/2013

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For The Record, Inc.

[11]

particulate 6:10,15

parties 9:8

Parts 3:10 5:5

passed 5:22

period 7:17 8:11

permanent 6:21

pertinent 7:11

plan 1:7 4:11 5:1,2

7:8,9,9,12,13,15

7:18 8:9

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4:18

Planning 3:18 4:1

4:20

PM2.5 1:6 5:2 6:21

7:3,10

pollutant 6:20

pollutants 6:9

pollution 6:6

posted 3:13

present 3:7

presented 7:16

problem 6:7

procedural 4:12

procedure 3:11 4:8

5:6

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proceeding 9:5

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questions 4:12

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R 3:1

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receipt 7:18

receive 4:15

record 4:3,15 5:15

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region 6:5

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required 7:1

requirements 6:2

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4:18

revise 7:12

revision 5:14 7:7

rules 6:11

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3:16 4:14 7:20 8:1

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S 2:1 3:1

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September 3:14

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serve 3:19

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severity 6:6

sheet 4:7

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significantly 7:1

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six 6:8

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8:2,3,5

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States 6:14 7:4,7

submit 7:14

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T

T 2:1,1

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taken 8:6

today 7:19 8:10

today's 5:12

Tomlinson 2:5 4:13

transcript 9:6

true 9:6

turn 3:4

U

U.S 7:14

U.S.C 3:9 5:4

United 6:13 7:4,7

V

verbatim 9:5

Vetters 1:21 9:3,14

W

want 7:20

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website 3:14 5:10,11

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welfare 6:1

wish 8:2,6

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Y

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1997 6:15

2

2012 7:6

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22 7:5

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3

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4

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5

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6

6 3:14 5:11 7:18

7

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MARYLAND DEPARTMENT OF THE ENVIRONMENT

AIR AND RADIATION MANAGEMENT ADMINISTRATION

PUBLIC HEARING CONCERNING:

Baltimore Nonattainment Area 

PM2.5 Redesignation Request and Maintenance Plan

October 7, 2013

Name

(please print)

Signature Organization or 

Affiliation

Address Do You 

Wish To 

Testify?

How did you 

find out about 

this hearing?

No persons attended this hearing.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

Mr. George S. A bum, Director 

Air & Radiation Management Administration 

Maryland Department of the Environment 

1800 Washington Boulevard 

Baltimore, Maryland 21230~ 1720 

Dear Mr. Abum: 

SEP 3 0 2013 

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

to review the proposed "Baltimore Nonattainment Area PM2.s Redesignation Request," dated 

May 28, 2013, and "Baltimore Nonattainment Area PM2.5 Maintenance Plan," dated May 27, 

2013. EPA has reviewed the proposed re~esignation request and maintenance plan. Our 

comments are enclosed. 

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

you to resolve these comments. Should you have any questions pertaining to EPA's review of 

Maryland's proposed redesignation request and maintenance plan for the Baltimore 1997 PM2.5 

nonattainment area, please do not hesitate to contact me. If members of your staff have 

questions, they may direct them to Ms. Maria A. Pino at (215) 814~2181. 

Sincerely, ~ 

12;~ Director 

Air Protection Division 

Enclosure 

!j Printed on 100% recycled/recyclable paper with I 00% post-consumer fiber and process chlorine free. 

Customer Service Hotline: 1-800-438-2474 
EPA comments on Maryland's proposed "Baltimore Nonattainment Area PM2.s 

Redesignation Request," dated May 27, 2013 and "Baltimore Nonattainment Area PM2.s 

Maintenance Plan," dated May 28, 2013 

Redesignation Request 

Introduction 

This section contains an ambiguous statement. 

"The State of Maryland is also requesting that USEP A concurrently approve, as a 

revision to the state implementation plan (SIP) (or each state, the related § 175A 

maintenance plan." 

Section 2.2 Baltimore, MD N onattainment Designation 

There is an erroneous statement regarding the course particulate matter (PM10) standard. 

"U.S. EPA replaced the existing PM1 0 standard with a health-based PM2.5 standard and 

retained the PM 1 0 standard as a particulate standard protecting welfare." 

While EPA did issue new primary (health-based) fine particulate (PM2_5) standards in 1997, it 

did not eliminate the primary standard for PM10. 

Section 3.1 Attainment of the Standard 

This section references determining attainment based on the average annual number of expected 

exceedances being less than or equal to one. The 1997 annual PM2.5 NAAQS is met when the 

annual design value is less than or equal to 15.0 micrograms per cubic meter {!.tg!m\ and is not 

based on expected exceedances. 

Sections 3.1.3 

2012 monitoring data has been quality assured and is available in EPA's Air Quality System 

(AQS). 2012 data and 2010-2012 design values should be included in the redesignation request. 

3.5.1 Demonstration of Compliance 

While a requirement for redesignation is that the area has a fully approved SIP under 11 0 and 

Part D, EPA has done numerous rulemakings where we state that for redesignations, only 

elements linked to the area's nonattainment status are relevant for redesignation. In other words, 

if the requirement is still applicable regardless of an areas nonattainment or attainment 

designation, approval of that element should not be a prerequisite for redesignation. The 

requirements of section 11 0( a )(2) are statewide requirements that are not linked to the PM2.s 

nonattainment status. Therefore, these SIP elements are not applicable requirements for 

purposes of review of the state's PM2.5 redesignation request. Please see EPA's proposed 

approval ofthe Ohio1997 PM2_5 redesignation request for the Huntington-Ashland Area (76 FR 

79593) http:/ /www.gpo.gov/fdsys/pkg/FR-20 11-12-22/pdf/20 11-32819 .pdf (3rd page, #79595). 
Maintenance Plan 

General Comment: 

EPA's Final Clean Air Fine Particle Implementation Rule (72 FR 20586, April25, 2007) 

contained rebuttable presumptions concerning certain PM2.5 precursors applicable to attainment 

plans and control measures related to those plans. The proposed redesignation request and 

maintenance plan reference this rebuttable presumption regarding volatile organic compounds 

(VOCs) and ammonia (NH3) and state that these precursors were determined to be insignificant 

for the PM2.5 NAAQS in the nonattainment area. However, on January 4, 2013, in Natural 

Resources Defense Council v. EPA, the D.C. Circuit Court remanded to EPA the PM2.s 

implementation rule. In light of this remand, the maintenance plan should assess the potential 

role ofVOC and ammonia in demonstrating continued maintenance in this area. Therefore, at a 

minimum, the maintenance plan should include the 2007,2017, and 2025 VOC and NH3 I 

inventories contained in Appendix G: Information Addressing NRDC v. EPA, Case No. 08-1250. 

Emissions Inventories: 

• Page 10: There is a missing link for the detailed accounting ofthe emissions inventory. 

• Page 11: There is a missing link for the detailed accounting of their projection year 

inventory. 

• Appendix D is labeled as Emission Inventory documentation however; it only contains 

documentation for the 2025 projection inventory. Documentation for the 2007 attainment 

year inventory and the 2017 interim year inventory must be included. 

• When submitting the final documentation, please submit the emission inventories in Excel 

format. 

4.6.1 Budget Level for On-Road Mobile Source Emissions 

Please include a table that enumerates the safety margins so that the reader can follow the 

difference between the modeled motor vehicle emissions and the added safety margins. 

4.7.2 Near Term Contingency Measures for Air Quality Exceedances 

Have the emission reductions discussed in this section, which were supposed to occur in January 

2013, taken place? If so, this section should be updated to reflect that. 

2 
MARYLAND DEPARTMENT OF THE ENVIRONMENT

RESPONSE TO COMMENTS

for the

PUBLIC HEARING and SUBMISSION

Hearing held on October 7, 2013 in Baltimore, Maryland in relation to:

Baltimore, MD Nonattainment Area 

PM2.5 Redesignation Request and Maintenance Plan

NO COMMENTS WERE RECEIVED AT THE HEARING.

The following comments were received from the Unites States Environmental 

Protection Agency, Region III in a letter dated September 30, 2013. The 

Department of the Environment’s responses follow each comment.

Redesignation	Request

Introduction

Comment: This section contains an ambiguous statement.

"The State of Maryland is also requesting that US EPA concurrently 

approve, as a revision to the state implementation plan (SIP) for 

each state, the related§175A maintenance plan."

Response: The Department agrees with the comment. The phrase, “for each 

state”, has been deleted from the text.

Section 2.2 Baltimore, MD Nonattainment Designation

Comment: There is an erroneous statement regarding the course particulate 

matter (PM10) standard. "U.S. EPA replaced the existing PM10 

standard with, a health-based PM2.5 standard and retained the 

PM10 standard as a particulate standard protecting welfare."

While EPA did issue new primary (health-based) fine particulate 

(PM2.5) standards in 1997, it did not eliminate the primary standard 

for PM10.

Response: The Department agrees with the comment. The text has been 

corrected to read, “U.S. EPA issued a new primary (health-based) 

PM2.5 standard and retained the primary PM10 standard.”

Section 3.1 Attainment of the Standard

Comment: This section references determining attainment based on the 

average annual number of expected exceedances being less than 

or equal to one. The 1997 annual PM2.5 NAAQS is met when the 

annual design value is less than or equal to 15.0 micrograms per 

cubic meter (μg/m3) and is not based on expected exceedances.
Response: The Department agrees with the comment. The text has been 

replaced with the statement, “The 1997 annual PM2.5 NAAQS is met 

when the annual design value is less than or equal to 15.0 

micrograms per cubic meter (μg/m3).”

Sections 3.1 Attainment of the Standard

Comment: This section references determining attainment based on the 

average annual number of expected exceedances being less than 

or equal to one. The 1997 annual PM2.5 NAAQS is met when the 

annual design value is less than or equal to 15.0 micrograms per 

cubic meter (μg/m3), and is not based on expected exceedances.

Response: The Department agrees with this comment. The text has been 

revised to read. “The 1997 annual PM2.5 NAAQS is met when the 

annual design value is less than or equal to the 15.0 micrograms 

per cubic meter (μg/m3).”

Sections 3.1.3

Comment: 2012 monitoring data has been quality assured and is available in 

EPA’s Air Quality System (AQS). 2012 data and 2010-2012 design 

values should be included in the redesignation request.

Response: The Department agrees with this comment. 2012 data and 2010-

2012 design values are included in the redesignation request.

3.5.1 Demonstration of Compliance

Comment: While a requirement for redesignation is that the area has a fully 

approved SIP under 110 and Part D, EPA has done numerous 

rulemakings where we state that for redesignations, only elements 

linked to the area's nonattainment status are relevant for 

redesignation. In other words, if the requirement is still applicable 

regardless of an areas nonattainment or attainment designation, 

approval of that element should not be a prerequisite for 

redesignation. The requirements of section 110(a)(2) are statewide 

requirements that are not linked to the PM2.5 nonattainment status. 

Therefore, these SIP elements are not applicable requirements for

purposes of review of the state's PM2.5 redesignation request. 

Please see EPA's proposed approval of the Ohio 1997 PM2.5 

redesignation request for the Huntington-Ashland Area (76 

FR79593) http://www.gpo.gov/fdsys/pkg/FR-20 11-12-22/pdf/2011-

32819.pdf (3rd page, #79595).

Response: The Department agrees with the comment. The table that 

references section 110(a)(2) has been deleted from the text.
Maintenance	Plan

General

Comment: EPA's Final Clean Air Fine Particle Implementation Rule (72 FR 

20586, April25, 2007) contained rebuttable presumptions 

concerning certain PM2.5 precursors applicable to attainment plans 

and control measures related to those plans. The proposed 

redesignation request and maintenance plan reference this 

rebuttable presumption regarding volatile organic compounds 

(VOCs) and ammonia (NH3) and state that these precursors were 

determined to be insignificant for the PM2.s NAAQS in the 

nonattainment area. However, on January 4, 2013, in Natural 

Resources Defense Council v. EPA, the D.C. Circuit Court 

remanded to EPA the PM2.5 implementation rule. In light of this 

remand, the maintenance plan should assess the potential role of 

VOC and ammonia in demonstrating continued maintenance in this 

area. Therefore, at a minimum, the maintenance plan should 

include the 2007, 2017, and 2025 VOC and NH3 inventories 

contained in Appendix G: Information Addressing NRDC v. EPA, 

Case No. 08-1250.

Response: The Department agrees with this comment. The document has 

been modified on page 8 to incorporate this comment and a 

footnote has been added to page 9.

Emissions Inventories

Comment: Page 10: There is a missing link for the detailed accounting of the 

emissions inventory. Page 11: There is a missing link for the 

detailed accounting of their projection year inventory.

Response: The Department agrees with this comment. The links have been 

corrected.

Comment: Appendix D is labeled as Emission Inventory documentation 

however; it only contains documentation for the 2025 projection 

inventory. Documentation for the 2007 attainment year inventory 

and the 2017 interim year inventory must be included.

Response: Documentation for the 2007 and 2017 inventories may be found in 

Appendix D beginning on page 81.

Comment: When submitting the final documentation, please submit the 

emission inventories in Excel format.

Reply: The Department will submit the emissions inventories in 

Excel format.
4.6.1 Budget Level for On-Road Mobile Source Emissions

Comment: Please include a table that enumerates the safety margins so that 

the reader can follow the difference between the modeled motor 

vehicle emissions and the added safety margins.

Response: The reader may enumerate the safety margins by calculating the 

percent difference between the mobile source emissions budgets 

presented in Tables 4-3 (without Mobile budget) and 4-6 (with 

Mobile budget).

4.7.2 Near Term Contingency Measures for Air Quality Exceedances

Comment: Have the emission reductions discussed in this section, which were 

supposed to occur in January 2013, taken place? If so, this section 

should be updated to reflect that.

Response: The Department agrees with this comment. The text has been 

revised to account for emissions reductions that took place in 

January, 2013.