GeorgeS. Aburn, Director 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

Maryland Department of the 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 of the 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 Register publication 

date. 

Pursuant to 40 CFR 93.118(e)(4) of the Transportation Conformity Rule (40 CFR part 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). EPA has determined that these 

MVEBs are adequate for transportation conformity purposes. However, this adequacy finding does not 

relate to the merits of the SIP submittal nor does it indicate whether the 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 of EPA's finding, the State of Maryland must use the 2012 RFP MVEBs for future 

conformity determinations. 

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Customer Service Hotline: 1-800-438-2474 
Table 1. 2012 RFP Mobile 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 in tons per 

day day 

2012 93.5 40.2 

EPA opened the public comment period on the adequacy of the submitted SIP by posting to the EPA 

Office of Transportation 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 of 40 CFR 93.118(e)(4)(iv), and are therefore adequate 

for transportation conformity purposes. EPA will soon publish a notice in the 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 on the effective date. 

If members of your staff have 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 of Air Program Planning 

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Customer Service Hotline: 1-800-438-2474 
DATE: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION III 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Technical Support Document (TSD) - Adequacy Finding for the Baltimore 1997 8-

SUBJECT: Hour Ozone Rate of Progress 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 of Progress Budgets for Volatile Organic Compounds (VOCs) and 

Nitrogen Oxjdes (NO~r 2012. 

{A,-,;:::;~ I -1'1~1(, . Cristina Fernandez, Associate Director 

Office of Air Program Planning (3AP30) 

I. Background 

On July 22, 2013, Maryland Department of the 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 in the 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 NOx Emission (tons/day) Baltimore Nonattainment Area" 

and Section 7.0 of the SIP submittal, which gives the 2012 projected controlled emissions for attainment, by sector. 

The total2012 emissions to meet RFP on pages 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 of the SIP submittal are the 

same as the mobile source controlled emissions in Table 4.7 of the 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, transit projects, and other activities are consistent with 

(conform to) the purpose of the SIP. The CAA requires federal actions in nonattainment and 

maintenance areas to "conform to" the goals of SIP. This means that such actions will not cause 

or contribute to violations of a NAAQS; worsen the severity of an existing violation; or delay 

timely attainment of any NAAQS or any interim milestone. Actions involving Federal Highway 

Administration (FHW A) or Federal Transit Administration (FTA) funding or approval are 

subject to the Transportation Conformity Rule (40 CFR part 93, subpart A). Under this rule, 

metropolitan planning organizations (MPOs) in nonattainment and maintenance areas coordinate 

with state air quality and transportation agencies, EPA, FHW A, and FT A to demonstrate that 

their metropolitan transportation plans and transportation improvement plans (TIPs) conform to 

applicable SIPs. This is typically determined by showing that estimated emissions from existing 

and planned highway and transit systems are less than or equal to the MVEBs contained in a SIP. 

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

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

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

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

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

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

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

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

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

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

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

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

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

factors or estimates of vehicle miles traveled). 

III. Review of Motor Vehicle Emissions Modeling 

To evaluate the submitted motor vehicle emissions inventory, it was necessary to review the 

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 on the use of the MOVES model to develop inventories for SIPs as well as analysis of 

emissions for transportation conformity determinations. 

2 
EPA 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 of the modeling 

domain and analysis year. Table 1 presents a summary of the review of the RunSpecs and the 

selections made for each parameter. Table 2 presents a summary of the review of each MOVES 

input parameter from MDE's submittal. Table 3 presents a summary of the 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 Inventories for 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 of RunS pees for 2012 for the Baltimore 1997 8-Hour Ozone Rate of 

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 of MOVES input databases for 2012 for the Baltimore 1997 8-Hour 

Ozone Rate of Progress 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 of road 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 A VFT 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 of the day for each month. 

Ramp Fraction Local fractions of ramp driving times were provided for restricted 

access roadways. 

Road Type Distribution The vehicle miles traveled (VMT) fraction for each road type was 

provided for each source type and road !Y!Je. 

Source Type Population The number of vehicles of each 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 of the output database and post-processing steps for 2012 for the 

Baltimore 1997 8-Hour Ozone Rate of Progress Budgets for VOCs and NOx 

MOVES run table Appropriate version of MOVES was used. All calculation bundles 

were processed. 

MOVES error table No errors were produced in any of the 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 
I inventory. The methodology was documented. 

IV. Administrative Requirements for Making Adequacy 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 of the submitted 

SIP MVEBs in accordance with the procedures listed in the January 1997 Conformity 

Regulations contained in 40 CFR part 93, 118(f) "Adequacy review process for implementation 

plan submissions." 

On November 23,2015, a notice was posted on EPA's website entitled, "Baltimore, Maryland, 

1997 8-hour ozone rate of progress (budgets for VOC and NOx for 2012)," located at: 

http://www3 .epa.gov/otag/stateresources/transconf/adequacy.htm, for the purpose of opening 

EPA's 30-day public comment period on the proposed 2012 RFP MVEBs in the Baltimore SIP 

rev1s10n. 

EPA's public comment period closed on December 23,2015. EPA received no comments on the 

proposed MVEBs. This TSD will be an enclosure to the letter from EPA to MDE informing the 

State of EPA's findings on the 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 

of the adequacy findings will be 15 days after the publication date of that 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 Motor Vehicle Emissions 

Budgets for NOx in tons per Budgets for VOCs in tons per 

day day 

2012 93.5 40.2 

V. Evaluation of the Adequacy of the 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 with the Baltimore 1997 8-

5 
Hour Ozone Nonattainment Area for conformity purposes. EPA is using the evaluation criteria 

detailed in the Transportation Conformity Rule, 40 CFR part 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 of the 2012 RFP MVEBs contained in the Baltimore 1997 8-Hour Ozone 

SIP Revision 

Transportation Conformity Rule Review Criteria Was the Criterion Satisfied? 

40 CFR Part 93 If Yes, How was this Criteria 

Satisfied? 

Sec. 93.118(e)(4)(i) Was the submitted revised Yes. The SIP was endorsed 

plan endorsed by the and submitted by the 

Governor (or his or her Governor's designee, Robert 

designee) and subject to a M. Summers, the Secretary of 

State public hearing? the Maryland· Department of 

the Environment. A public 

hearing on the SIP proposal 

was held on July 19,2013. 

Sec. 93.118(e)(4)(ii) Before the implementation Yes. Consultation has 

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 FHW A, FT A, Maryland 

documentation provided to Department of Transportation 

EPA, and was EPA's stated (MOOT), and the Baltimore 

concerns, if any, addressed? Regional Transportation 

Board (BRTB). 

Sec. 93 .118( e)( 4 )(iii) Were the MVEBs clearly Yes, the budgets are clearly 

identified and precisely identified on pages 93-94 of 

quantified? the Baltimore 1997 8-Hour 

Ozone Nonattainment Area 

SIP revision prepared by the 

Maryland Department of the 

Environment and Appendix E 

prepared by Michael Baker, 

Jr., Inc. Additional 

clarification of the budgets can 

be found in the supplemental 

letter sent to EPA from MOE 

at: 

.http://www .mde.state.md.us/p 

rograms/ Air/ AirQualityPlanni 

6 
ng/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 

emission reductions, emission reductions, the 

consistent with applicable mobile emissions budgets for 

requirements for 2012 for VOCs and NOx 

maintenance strategies? reflect a continuation of a 

downward trend in mobile 

emissions over time. 

Sec. 93.118(e)(4)(v) Are the motor vehicle EPA believes that the 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 plan because 

explain and document any MDE has yet to submit a 

changes to previously redesignation request 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 of vehicle miles 

·. traveled). 

Sec. 93.118(e)(5) Did they provide and we There were no comments on 

review public comments and the proposed motor emission 

the State's responses to those budgets in the SIP. 

comments with the submitted 

control strategy SIP? 

VI. Findings 

7 
Based upon EPA's review and evaluation of the 2012 RFP MVEBs contained in the Baltimore 

1997 8-Hour Ozone SIP revision, EPA finds the MVEBs adequate for transportation conformity 

purposes. The applicable MVEBs for purposes of determining conformity are 93.5 tons per day 

ofNOx and 40.2 tons per day ofVOCs for 2012. 

8