GeorgeS. Aburn, Director UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill 1650 Arch Street Philadelphia, Pennsylvania 19103-2029

Maryland Department ofthe Environment 1800 Washington Boulevard Baltimore, Maryland 21230
Dear Mr. Aburn:
The purpose ofthis letter is to notify you the U.S. Environmental Protection Agency (EPA) will soon announce in the Federal Register EPA's determination that the motor vehicle emission budgets (MVEBs) for the Baltimore 1997 8-Hour Ozone Rate ofProgress Budgets for volatile organic compounds (VOCs) and nitrogen oxides (NOx) for the year 2012, contained in the latest Baltimore 1997 8-Hour Ozone Nonattainment Area State Implementation Plan (SIP), submitted by Maryland Department ofthe Environment (MOE), are adequate for transportation conformity purposes. The SIP revision incorporates the latest available demographic projections into the MVEBs, and establishes the modeled budget year. The budgets will become effective 15 days after the Federal Registerpublication date.
Pursuantto 40 CFR 93.118(e)(4) ofthe Transportation Conformity Rule (40 CFRpart 93, subpart A), EPA has reviewed the MVEBs contained in the Baltimore SIP revision, which were developed with the use ofEPA's Motor Vehicle Emission Simulator (MOVES2014). EPAhas determined that these MVEBs are adequate for transportation conformity purposes. However, this adequacy finding does not relate to the merits ofthe SIP submittal nor does it indicate whetherthe submittal meets the requirements for approval. Maryland's Baltimore SIP revision has 2012 reasonable further progress (RFP) MVEBs for NOx and VOCs for 2012 shown in Table 1. The MVEBs are 93.5 tons per day ofNOx and 40.2 tons per day of VOCs. These MVEBs meet the standard requirement that any MVEB must meet before it can be used to determine conformity for a transportation improvement program or long range transportation plan. As a result ofEPA's finding, the State ofMaryland must use the 2012 RFP MVEBs for future conformity determinations.



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### Table 1. 

### 2012 RFPMobile Budgets for the Baltimore 1997 8-Hour Ozone Nonattainment Area Year Motor Vehicle Emissions Motor Vehicle Emissions Budgets for NOx in tons per Budgets for VOCs intons per day day 2012 93.5 40.2

EPA openedthe public commentperiod onthe adequacy ofthe submitted SIP by posting to the EPA Office ofTransportation and Air Quality's**adequ~cy** review website (http://www.epa

.gov/otag/stateresources/transconf/adeguacy

.htm) on November 23, 2015. The comment period closed on December 23,2015, and no comments were received. EPA has concluded that 2012 RFP MVEBs satisfy the requirements of40 CFR93.118(e)(4)(iv), and are therefore adequate for transportation conformitypurposes. EPA will soonpublish a notice inthe Federal Register announcing this adequacy finding. The Federal Register will also announce the date that the adequacy finding becomes effective

. The MVEBs will be available for use onthe effective date.
Ifmembers ofyour staffhave any questions regarding this finding, they may direct them to Mr. Gregory Becoat, at (215) 814-2036.

Enclosure

cc: Brian Hug (MDE) Colleen Turner (MDOT) Regina Aris (BMC) Sincerely,

Cristina Fernandez, Associate Director Office ofAir Program Planning



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Technical Support Document (TSD)

- Adequacy Finding for the Baltimore 1997 8- SUBJECT: Hour Ozone Rate ofProgress Budgets for Volatile Organic Compounds (VOCs) and Nitrogen Oxides (NOx) for 2012.

FROM:

TO:

THRU: Administrative Record for the Adequacy Finding for the Baltimore 1997 8-Hour Ozone Rate ofProgress Budgets for Volatile Organic Compounds (VOCs) and Nitrogen Oxjdes**(NO~r** 2012.

### {A,-,;:::;~ I

### -1'1~1(,**.** CristinaFernandez, Associate Director Office ofAir Program Planning (3AP30)
I. Background
OnJuly 22, 2013, Maryland Department ofthe Environment (MDE) submitted a formal revision to its State Implementation Plan (SIP). The SIP revision included a plan demonstrating rate of progress for 1997, 2011, and 2012, a revision to the 2002 base year emissions, revised 2012 reasonable further progress (RFP) motor vehicle budgets (MVEBs), and a serious area attainment demonstration. On October 9, 2015, MDE submitted a supplemental letter to EPA clarifying that the 2012 attainment MVEBs mentioned inthe July 22, 2013 submittal was an administrative issue and truly represent the 2012 RFP MVEBs based on additional evidence provided. 1 EPA believes that the evidence provided within MDE's supplemental letter specifically corresponds to the 2012 RFP budgets, incorporates the latest available demographic projections into the MVEBs, and establishes the modeled budget years.

1 See Table 4.7, "2012 Projected Controlled VOC and NOxEmission (tons/day) Baltimore Nonattainment Area" and Section 7.0 ofthe SIP submittal, which gives the 2012 projected controlled emissions for attainment, by sector

. The total2012 emissions to meet RFP onpages 39 and 53 are the same (i.e. RFP and attainment inventories are equal)

. The mobile budgets in Section 10, "Mobile Source Conformity," on page 91 ofthe SIP submittal are the
same as the mobile source controlled emissions in Table 4.7 ofthe SIP submittal.II. Transportation Conformity Requirements Transportation conformity is required under section 176(c) ofthe Clean Air Act (CAA) to ensure that federally supported highway, transitprojects, and other activities are consistent with (conform to) the purpose ofthe SIP. The CAA requires federal actions in nonattainment and maintenance areas to "conformto" the goals ofSIP. This means that such actions will not cause or contribute to violations ofa NAAQS; worsen the severity ofan existing violation; or delay timely attainment ofany NAAQS or any interim milestone. Actions involving Federal Highway Administration (FHWA) or Federal TransitAdministration (FTA) funding or approval are subjectto the Transportation Conformity Rule (40 CFRpart 93, subpart A). Underthis rule, metropolitanplanning organizations (MPOs) in nonattainment and maintenance areas coordinate with state air quality and transportation agencies, EPA, FHW A, and FTA to demonstrate that their metropolitan transportationplans and transportation improvement plans (TIPs) conform to applicable SIPs. This is typically determined by showingthat estimated emissions from existing and planned highway and transit systems are less than or equal to the MVEBs contained in a SIP.

For MVEBs to be approvable, they must meet, at a minimum, EPA's adequacy criteria found at 40 CFR 93.118(e)(4). EPA's adequacy criteria are: (1) the submitted control strategy implementation planwas endorsed by the Governor or designee and was subject to a State public hearing; (2) consultation among Federal, State, and local agencies occurred; full implementation plan documentation was provided to EPA; and EPA's stated concerns, ifany, were addressed before the control strategy implementation planwas submitted; (3) the MVEBs are clearly identified and precisely quantified; (4) the MVEBs, when considered together with all other emissions sources, are consistent with applicable requirements for maintenance; (5) the MVEBs are consistent with and clearly related to the emissions inventory and the control measures in the submitted control strategy implementation plan; and (6) revisions to previously submitted maintenance plans explain and document any changes to previously submitted budgets and control measures; impacts onpoint and area source emissions; any changes to established safety margins; and reasons for the changes (including the basis for any changes related to emission factors orestimates ofvehicle miles traveled).


### III. Review ofMotor Vehicle Emissions Modeling
To evaluate the submitted motor vehicle emissions inventory, it was necessary to reviewthe supporting modeling completed using EPA's Motor Vehicle Emission Simulator (MOVES2014). MDE's submitted files include run specifications (RunSpecs) describing the scenario parameters, input databases containing local fleet data, and output databases containing the modeling results. The submitted RunSpecs, input databases, and output database(s) were reviewed against the EPA document: MOVES2014 Technical Guidance: Using MOVES to Prepare Rmissions Inventories for State Implementation Plans and Transportation Conformity. This document provides guidance onthe use ofthe MOVES model to develop inventories for SIPs as well as analysis of emissions for transportation conformity determinations.

2EPA carefully reviewed the RunSpecs, input databases, and output databases used in the analysis to ensure that all was completed consistently with the recommendations outlined in the above mentioned MOVES Technical Guidance and are appropriately representative ofthe modeling domain and analysis year. Table 1presents a summary ofthe review ofthe RunSpecs and the selections made for each parameter. Table 2 presents a summary ofthe review ofeach MOVES input parameter from MDE's submittal. Table 3 presents a summary ofthe review ofthe output and post-processing methodology.
The RunSpecs, input databases, and output database were reviewed and found to have followed the applicable EPA guidance provided in the MOVES2014 Technical Guidance: Using MOVES to Prepare Emissions Inventoriesfor State Implementation Plans and Transportation Conformity. Additionally, sufficient documentation was provided by MDE to support the data, decisions, and assumptions made for each parameter

.



### Table 1. 

### Review ofRunSpees for 2012 for the Baltimore 1997 8-Hour Ozone Rateof Progress Budgets for Volatile Organic Compounds (VOCs) and Nitrogen Oxides (NOx) Domain/Scale County scale was selected

- allowing for appropriate detail necessary
_

for regulatory analysis. Time Spans Panel Hourly time aggregation was selected. All appropriate months, days, and hours were selected. The appropriate year was selected for the scenario being modeled. Geographic Bounds Baltimore City, Anne Arundel County, Baltimore County, Carroll County, Harford County, and Howard County was selected. Vehicles/Equipment Gasoline, ethanol, diesel, and compressed natural gas (CNG) fuels were selected. All source types were selected. Road Type All road types were selected

. Pollutants and Processes NOx and VOCs were selected

. All processes were included in the analysis
.

3

### Table 2. Review ofMOVES input databases for 2012 for the Baltimore 1997 8-Hour Ozone Rate ofProgress Budgets for VOCs and NOx Parameter Submittal Age Distribution All source types were included with fractions for ages (0-30 years). Average Speed Average speed distributions were provided for all source types, for Distribution each combination ofroad type and hour ofthe day. Fuel (fuel formulation, 

## • A complete fuel supply table was provided with all fuel types fuel supply, fuel usage, present in the region. and alternative vehicle 

## • Appropriate fuel properties were included in the fuel fuels and technologies formulation table, including Reid Vapor Pressure (RVP), (AVFT)) ethanol content, and sulfur levels. 

## • The fuel usage table was provided and described the ethanol
use by E-85 capable vehicles. 

# • The AVFT table was provided

. Any and all changes to the default fuels have been sufficiently documented. Meteorology Data Local meteorology data (temperature and humidity) was provided for each hour ofthe day for each month. Ramp Fraction Local fractions oframp driving times were provided for restricted
access roadways. Road Type Distribution The vehicle miles traveled (VMT) fraction for eachroad type was provided for each source type and road !Y!Je. Source Type Population The number ofvehicles ofeach source type was provided. 

# • Annual VMT was provided for the five MOVES highway performance management system (HPMS) vehicle categories. Vehicle Type VMT 

## • Monthly VMT fractions were provided for all source types (includes inputs for and month. annual VMT, daily 

# • Daily VMT fractions were provided for all days and source VMT fraction, hourly types. VMT fraction, and 

## • Hourly VMT fractions were provided for each day type and monthly VMT fraction) source type. Inspection/Maintenance (1/M) Programs The existing liM program was accurately described.



### Table 3. Review ofthe outputdatabase and post-processing steps for 2012 for the Baltimore 1997 8-HourOzone Rate ofProgress Budgets forVOCs and NOx MOVES run table Appropriate version ofMOVES was used. All calculationbundles were processed. MOVES error table No errors were produced in any ofthe runs. MOVES output The output contains emission results for all necessary source types, processes, and pollutants. Output processing The output was appropriately summed to generate the emissions

4

# Iinventory
. The methodology was documented.


### IV. Administrative Requirements for MakingAdequacy Finding
This TSD is only addressing the 2012 RFP MVEBs contained in the Baltimore 1997 8-Hour Ozone SIP revision. EPA followed the process for determining the adequacy ofthe submitted SIP MVEBs in accordance with the procedures listed in the January 1997 Conformity Regulations contained in 40 CFRpart 93, 118(f) "Adequacyreviewprocess for implementation plan submissions."
OnNovember 23,2015, a notice was posted on EPA's website entitled, "Baltimore, Maryland, 1997 8-hour ozone rate ofprogress (budgets for VOC and NOx for 2012)," located at: http://www3

.epa
.gov/otag/stateresources/transconf/adequacy

.htm, for the purpose ofopening EPA's 30-daypublic commentperiod onthe proposed 2012 RFP MVEBs inthe Baltimore SIP rev1s10n.
EPA's public comment period closed onDecember 23,2015. EPAreceived no comments onthe proposed MVEBs. This TSD will be an enclosure to the letter from EPA to MDE informing the State ofEPA's findings onthe 2012 RFP MVEBs for the Baltimore 1997 8-Hour Ozone SIP revision submitted on July 22, 2013.
EPA will publish a Federal Register notice announcing our adequacy findings. The effective date ofthe adequacy findings will be 15 days after the publication date ofthat notice. Once EPA has published the Federal Register notice, the letter EPA sent to MDE and this TSD will be posted at http:/ /www3.epa
.gov/otag/stateresources/transconf/adeguacy
.htm

. Shown in Table 4 are the 2012 RFP MVEBs from the Baltimore 1997 8-Hour Ozone SIP revision. The MVEBs in Table 4 for year 2012 for NOx and VOCs will be applied to all future transportation conformity determinations and analyses for the ozone national ambient air quality standard (NAAQS).


### Table 4. 2012 RFP Mobile Budgets for the Baltimore 1997 8-Hour Ozone Nonattainment Area Year Motor Vehicle Emissions MotorVehicle Emissions Budgets for NOx intons per Budgets for VOCs intons per day day 2012 93.5 40.2



### V. Evaluation ofthe Adequacy ofthe MVEBs in the Baltimore 1997 8-Hour Ozone Rate of Progress Budgets for VOCs and NOx for 2012 Submitted by the Maryland Department of the Environment

In this TSD, EPA is evaluating the 2012 RFP MVEBs associated withthe Baltimore 1997 8-

5Hour Ozone Nonattainment Area for conformity purposes. EPA is using the evaluation criteria detailed in the Transportation Conformity Rule, 40 CFRpart 93.118(e)(4)(i) through 93.118(e)(4)(vi) and 93.118(e)5. The evaluation is presented in Table 5, below.

Table 5. Adequacy ofthe 2012 RFP MVEBs contained in the Baltimore 1997 8-Hour Ozone SIP Revision Transportation Conformity Rule Review Criteria Was the Criterion Satisfied? 40 CFRPart 93 IfYes, Howwas this Criteria Satisfied? Sec. 93.118(e)(4)(i) Was the submitted revised Yes. The SIP was endorsed plan endorsed by the and submitted bythe Governor (or his orher Governor's designee, Robert designee) and subject to a M. Summers, the Secretary of State public hearing? the Maryland·Departmentof the Environment. A public hearing onthe SIP proposal
was held on July 19,2013. Sec. 93.118(e)(4)(ii) Before the implementation Yes. Consultationhas plan was submitted to EPA, occurred among all required did consultation between Federal, State, and local federal, State and local agencies. This included the agencies occur; was full following: MOE, EPA, implementation plan FHWA, FT A, Maryland documentation provided to Department ofTransportation EPA, and was EPA's stated (MOOT), and the Baltimore concerns, ifany, addressed? Regional Transportation Board (BRTB). Sec. 93.118(e)(4)(iii) Were the MVEBs clearly Yes, the budgets are clearly identified and precisely identified onpages 93-94 of quantified? the Baltimore 1997 8-Hour Ozone Nonattainment Area SIP revision prepared by the Maryland Department ofthe Environment and Appendix E prepared by Michael Baker, Jr., Inc. Additional clarification ofthe budgets can be found in the supplemental letter sent to EPA from MOE at:

.http://www.mde.state.md.us/p rograms/Air/AirQualityPlanni

6ng/Pages/programs/airprogram s/air planning/index.aspx. Sec. 93.118(e)(4)(iv) Are the motor vehicle EPA believes the budgets can emissions, when considered be declared adequate because together with all other in conjunction with the other emissionreductions, emissionreductions, the consistent with applicable mobile emissions budgets for requirements for 2012 for VOCs and NOx maintenance strategies? reflect a continuation ofa downward trend in mobile emissions over time. Sec. 93.118(e)(4)(v) Are the motor vehicle EPA believes thatthe motor emissions consistent with vehicle emissions have clearly and clearly related to the related to the emissions emissions inventory and the inventory and control control measures in the Plan? measures in the SIP submittal.

Sec. 93.118(e)(4)(vi) Revisions to previously There are no revisions to the submitted maintenance plan: maintenance planbecause explain and document any MDE has yet to submit a changes to previously redesignationrequest and the submitted budgets and associated maintenance plan control measures; impacts on for the Baltimore 1997 8-Hour point and area source Ozone Nonattainment Area. emissions; any changes to established safety margins (see Sec. 93.101 for definition); and reasons for the changes (including the basis for any changes related to emission factors or estimates ofvehicle miles



### ·. traveled). Sec. 93.118(e)(5) Didtheyprovide and we There were no comments on reviewpublic comments and the proposed motor emission the State'sresponses to those budgets inthe SIP. comments withthe submitted control strategy SIP?



### VI. Findings

7BaseduponEPA'sreview and evaluation ofthe 2012 RFP MVEBs contained inthe Baltimore 1997 8-Hour Ozone SIP revision, EPAfinds the MVEBs adequate for transportation conformity purposes. The applicable MVEBs for purposes ofdetermining conformity are 93.5 tons perday ofNOx and 40.2 tons per day ofVOCsfor 2012.

8