### Appendix F

Technical Support Document fo r the Developm ent of the 2025

Emission Inventory for PM Nonatta inment Counties in the MANEVU Region; ver. 3.3, rev. 2; January 23, 2012

# Technical Support Document

for the

Development of the 2025

Emission Inventor y

for PM Nonattainment Counties

in the MANE

- VU Region

Version 3.3

Prepared for:

Mid

- Atlantic Regional Air Management Association (MARAMA)

8600 LaSalle Road, Suite 636

Towson , MD 21286

(443) 901

- 1882

January 23 , 201 2

MARAMA Contract Agreement FY20 11

- 004

Submitted by

AMEC Environment & Infrastructure SRA International, Inc.

4021 Stirrup Creek Drive 652 Peter Jefferson Parkway

Suite 100 Suite 300

Durham, NC 27703 Charlottesville, VA 22911

919 381

- 9900 571 499

- 0833

### Acknowledgements

Funds for this CONTRACT are provided by MARAMA’s Memorandum of Agreement with the

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

–

Regional Haze Planning in the Northeast and Mid

- Atlantic States (CFDA 66.034). The purpose

of that Memorandum of Agreement is to support the Mid

- Atlantic / Northeast Visibility Union

(MANE

- VU) in developing programs to control regional haze or visibility impairment in the

Northeast and Mid

- Atlantic states

.

About MARAMA

The Mid

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

- profit

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

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

prevent and reduce air pollution in the Mid

- Atlantic Region. MARAMA provides cost

- effective

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

ideas, and train staff to implement common requirements.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page i



## Table of Contents

1.0 INTRODUCTION

................................ ................................ ................................ .................. 1

1.1 INVENTORY PURPOSE

................................ ................................ ................................ 1

1.2 SOURCE CATEGORIES

................................ ................................ ................................ 1

1.3 GEOG RAPHIC AND TEMPORAL RESOLUTION

................................ ........................... 2

1.4 POLLUTANTS

................................ ................................ ................................ ................ 3

1.5 DATA FORMATS

................................ ................................ ................................ ........... 3

1.6 INVENTORY VERSIONS

................................ ................................ ............................... 3

1.6.1 Version 2 Modeling Inventories with Existing Controls

................................ ............ 3

1.6.2 Version 3 Modeling Inventories with Existing Controls

................................ ............ 3

1.6.3 Version 3 Modeling Inventories with Potential New Controls

................................ ... 4

1.6.4 Version 3 2025 Inventory for PM Nonattainment Counties

................................ ...... 4

1.7 REPORT ORGANIZATION

................................ ................................ ............................. 5

2.0 AREA SOURCES

................................ ................................ ................................ ................ 8

2.1 AREA SOU RCE CATEGORIES

................................ ................................ ...................... 8

2.2 2007 INVENTORY DEVELOPMENT

................................ ................................ .............. 8

2.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections

.......................... 8

2.3 2025 INVENTORY DEVELOPMENT

................................ ................................ ............. 13

2.3.1 Area Source Growth Factors

................................ ................................ .................. 13

2.3.1.1 AEO Fuel Use Projection

................................ ................................ ................... 13

2.3.1.2 Population Projections

................................ ................................ ....................... 14

2.3.1.3 Employment Projections

................................ ................................ .................... 15

2.3.1.4 VMT Projections

................................ ................................ ................................ . 15

2.3.1.5 No Growth Assignment for Certain Area Source Categories

.............................. 25

2.3.1.6 USEPA 2020 Projections for Residential Wood

................................ ................. 26

2.3.1.7 SCC, SIC, NAICS and Growth Parameter Crosswalk

................................ ........ 27

2.3.1.8 Final Version 2 Growth Factors for Area Sources

................................ .............. 27

2.3.1.9 Version 3 Update to New Jersey G rowth Factors for Area Sources

................... 28

2.3.1.10 Version 3 Update to Growth Factors for the District of Columbia

.................... 28

2.3.2 Area Source Control Factors

................................ ................................ .................. 30

2.3.2.1 Federal Rules Affecting Area Sources

................................ ............................... 30

2.3.2.2 Federal MACT Rules

................................ ................................ ......................... 30

2.3.2.3 OTC Model Rules for VOC Sources

................................ ................................ ... 31

2.3.2.4 OTC Model Rule for ICI Boilers

................................ ................................ .......... 32

2.3.2.5 MANE

- VU Fuel Oil Sulfur Strategy

................................ ................................ ..... 33

3.0 POINT SOURCES

................................ ................................ ................................ .............. 45

3.1 POINT SOURCE CATEGORIES

................................ ................................ ................... 45

3.2 2007 INVENTORY DEVELOPMENT

................................ ................................ ............. 45Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page ii



### 3.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections

......................... 46

3.3 2025 NONEGU INVENTORY DEVELOPMENT

................................ ............................. 47

3.3.1 NonEGU Growth Factors

................................ ................................ ....................... 47

3.3.2 Emission Reduction Credits

................................ ................................ ................... 49

3.3.3 NonEGU Control Factors

................................ ................................ ....................... 50

3.3.3.1 Federal Actions Affecting NonEGU Point Sources

................................ ............. 50

3.3.3.2 OTC 2001 Model Rules for NonEGUs

................................ ................................ 52

3.3.3.3 OTC 2006 Model Rules for NonEGUs

................................ ................................ 52

3.3.3.4 MANE

- VU Fuel Oil Sulfur Strategy

................................ ................................ ..... 55

3.3.3.5 State

- specific NonEGU Control Factors

................................ ............................. 55

3.4 2025 EGU INVENTORY DEVELOPMENT

................................ ................................ ..... 57

3.4.1 EGU Growth Factors

................................ ................................ ............................. 58

3.4.2 EGU Control Factors

................................ ................................ ............................. 62

3. 4.3 Consideration of CSAPR Emission Allowances

................................ ..................... 63

4.0 NONROAD MOBILE S OURCES INCLUDED IN N MIM

................................ ...................... 64

4.1 NONROAD MODEL CATEGORIES

................................ ................................ ............... 64

4.2 2007 INVENTORY DEVELOPMENT

................................ ................................ ............. 64

4.3 2025 INVENTORY DEVELOPMENT

................................ ................................ ............. 65

4.4 REMOVAL OF AIRPORT GROUND SUPPORT EQUIPMENT

................................ ...... 65

4.5 NMIM/NONROAD GROWTH AND CONTROL INFORMATION

................................ ..... 65

5.0 MARINE VESSELS, AIRPORTS, AND RAILRO ADS

................................ ......................... 69

5.1 MAR INVENTORY CATEGORIES

................................ ................................ ................. 69

5.2 2007 INVENTORY DEVELOPMENT

................................ ................................ ............. 69

5.3 2025 INVENTORY DEVELOPMENT

................................ ................................ ............. 69

5.3.1 Commercial Marine Vessels

................................ ................................ .................. 69

5.3.1.1 CMV Diesel Growth Factors

................................ ................................ ............... 70

5.3.1.2 CMV Diesel Control Factors

................................ ................................ ............... 70

5.3.1.3 CMV Residual Oil Growth Factors

................................ ................................ ..... 71

5.3.1.4 CMV Residual Oil Control Factors

................................ ................................ ..... 72

5.3.1.5 Military Vessels Growth and Control Factors

................................ ...................... 73

5.3.1.6 State

- specific CMV Updates for 2025

................................ ................................ 73

5.3.2 Airports

................................ ................................ ................................ .................. 73

5.3.2.1 Airport Growth Factors

................................ ................................ ....................... 74

5.3.2.2 Aircraft Control Factors

................................ ................................ ...................... 75

5.3.2.3 State

- specific Airport Updates for 2025

................................ .............................. 76

5.3.3 Railroad Locomotives

................................ ................................ ............................ 76

5.3.3.1 Railroad Growth Factors

................................ ................................ .................... 76

5.3.3.2 Railroad Control Factors

................................ ................................ .................... 77

5.3.3.3 State

- specific Railroad Updates for 2025

................................ ........................... 78Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page iii



### 6.0 ONROAD MOBILE SO URCES INCLUDED IN MO VES

................................ ..................... 79

6.1 MOVES MODEL CATEGORIES

................................ ................................ .................... 79

6.2 2007 MOVES MODEL INVENTORY

................................ ................................ .............. 79

6.3 2025 MOVES MODEL INVENTORY

................................ ................................ .............. 79

7.0 EMISSION SUMMARI ES

................................ ................................ ................................ .... 80

8.0 DELIVERABLES

................................ ................................ ................................ ................ 93

9.0 REFERENCES

................................ ................................ ................................ ................... 95



## List of Appendices

Appendix A1 AEO2010 New England.xls

Appendix A2 AEO2010 Mid Atlantic.xls

Appendix A3 AEO2010 South Atlantic.xls

Appendix A4 AEO2011 New England.xls

Appendix A5 AEO2011 Mid Atlantic.xls

Appendix A6 AEO2011 South Atlantic.xls

Appendix A7 AEO2010 vs AEO2011 Comparison.docx

Appendix B Population_Factors.xls

Appendix C Employment_Factors.xls

Appendix D VMT GF Nonattainment Counties.xls

Appendix E EPA2020 Res Wood.xls

Appendix F AEO2011

- Electricity Generation by EMM.xlsx

Appendix G UAF NEEDS Control FileMASTER92211.xls

Appendix H MAR Growth and Control.xlsDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page iv



## List of Exhibits

Exhibit 1

- 1 Comparison of Data Used for the 2025 PM Nonattainment Inventory and

Version 3 of the Modeling Inventory

Exhibit 1

- 2 List of PM Nonattainment Areas and Counties

Exhibit 2

- 1 Area Source SCCs Affected by PM Transport Fraction

Exhibit 2

- 2 PM Transport Fractions for PM Nonattainment Counties

Exhibit 2

- 3 Comparison of 2007 Paved Road Dust PM10 Emission Estimates

Exhibit 2

- 4 Comparison of 2007 Paved Road Dust PM 2.5 Emission Estimates

Exhibit 2

- 5 Growth Factors for Coal Fuel Use by AEO Region 2007

- 2025

Exhibit 2

- 6 Growth Factors for Residual Oil Fuel Use by AEO Region 2007

- 2025

Exhibit 2

- 7 Growth Factors for Distillate Oil Fuel Use by AEO Region 2007

- 2025

Exhibit 2

- 8 Growth Factors for Natural Gas Fuel Use by AEO Region 2007

- 2025

Exhibit 2

- 9 Growth Factors for Gasoline Fuel Use by AEO Region 2007

– 2025

Exhibit 2

- 10 Population Growth Factors by AEO Region 2007

– 2025

Exhibit 2

- 11 Employment Growth Factors by AEO Region 2007

– 2025

Exhibit 2

- 1 2 2007 and 2025 VMT and the 2007

- 2025 Growth Factor

Exhibit 2

- 1 3 Area Source Categories with No Growth Assignment

Exhibit 2

- 1 4 State Recommendations to Address Negative Growth

and Other Growth Factors for the Area Source Sector

Exhibit 2

- 15 Exhibit 2

- 15 USEPA Estimated Percent Reductions for RICE MACT Standard

Exhibit 2

- 16 Area Source Emission Reductions from New Jersey ICI Boiler NO

x 

### Rules

Exhibit 2

- 17 MANE

- VU Low Sulfur Fuel Oil Strategy

Exhibit 2

- 18 Sulfur Content and Control Factors for Residential Fuel Oil Combustion

Exhibit 2

- 19 Sulfur Content and Control Factors for Distillate Fuel Oil Combustion

Exhibit 2

- 20 Sulfur Content and Control Factors for Residual Fuel Oil Combustion

Exhibit 3

- 1 NonEGU Point Source S CCs Affected by PM Transport Fraction

Exhibit 3

- 2 State Recommendations to Address Negative Growth for the NonEGU

Point Source Sector

Exhibit 3

- 3 USEPA Estimated Percent Reductions for RICE MACT Standard

Exhibit 3

- 4 NonEGU Point Source Emission Redu ctions from New Jersey

ICI Boiler NO

x 

### Rules

Exhibit 3.5 Electricity Market Module Regions

Exhibit 3.6 Electricity Generation Growth Factors for Coal

Exhibit 3.7 Electricity Generation Growth Factors for Petroleum

Exhibit 3.8 Electricity Generation Growth Factors for Natural GasDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page v



### Exhibit 3.9 Electricity Generation Growth Factors for Renewables

Exhibit 4

- 1 Control Programs Included in the NMIM/NONROAD Model

Exhibit 5

- 1 CMV Diesel Control Factors by Year and Pollutant

Exhibit 5

- 2 CMV Residual Oil Control Factors by Year and Pollutant

Exhibit 5

- 3 Crosswalk between SCC and FAA Operations Type

Exhibit 5

- 4 Region

- wide Growth Factors from 2007 by FAA Operations Type

Exhibit 5

- 5 Rail Control Factors by Year, Pollutant, and SCC

Exhibit 7 .1 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Allentown, PA

Exhibit 7

. 2 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Baltimore, MD

Exhibit 7

. 3 Comparison of 2007 and 2025 PM2. 5 and PM Precursor Emissions

Nonattainment Area: Hagerstown

- Martinsburg, MD

- WV

Exhibit 7

. 4 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Harrisburg

- Lebanon

- Carlisle

- York, PA

Exhibit 7 .5 Comparison of 2007 and 2025 PM2 .5 and PM Precursor Emissions

Nonattainment Area: Johnstown, PA

Exhibit 7 .6 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Lancaster, PA

Exhibit 7 .7 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattai nment Area: Metro New York/Northern New Jersey/Long Island

NY/NJ/CT

Exhibit 7 .8 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Philadelphia

- Wilmington, PA/DE/NJ

Exhibit 7 .9 Comparison of 2007 and 2025 PM2.5 and PM Prec ursor Emissions

Nonattainment Area: Pittsburgh

- Beaver Valley, PA

Exhibit 7 .10 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Reading, PA

Exhibit 7 .11 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonatta inment Area: Washington DC/MD/VA

Exhibit 7 .12 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: York, PA

Exhibit 8 .1 Final DeliverablesDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page vi



## A cronyms and Abbreviations

Acronym Description

CAA Clean Air Act

CAMD Clean Air Markets Division ( US EPA)

CEM Continuous e mission m onitoring

CMV Commercial marine vessel

CO Carbon monoxide

EGU Electric g enerating u nit

ERTAC Eastern Regional Technical Advisory Co mmittee

FIPS Federal Information Processing Standard

GSE Ground support equipment

MACT Maximum achievable control technology

MANE

- VU Mid

- Atlantic/Northeast Visibility Union

MANE

- VU+VA MANE

- VU states plus Virginia

MAR Marine, airport, rail

MARAMA Mid

- Atlantic Regional Air Management Association

MOBILE6 USEPA model

MOVES Motor Vehicle Emissions Simulator model

NAAQS National Ambient Air Quality Standards

NAICS North American Industry Classification System code

NCD National county database

NEI National Emission Inventory

NESCAUM Northeast States for Coordinated Air Use Management

NIF3.0 N EI Input Format Version 3.0

NMIM National Mobile Input Model

N O F3.0 NEI Output Format Version 3.0

NONROAD USEPA model



### NO

x Oxides of nitrogen

ORL One

- record

- per

- line (SMOKE format)

OTAQ Office of Transportation and Air Quality ( US EPA)

PFC Portable fuel container

PM

- CON Primary PM, c ondensable portion only ( < 1 micron)

PM

- FIL Primary PM, Filterable portion only

PM

- PRI Primary PM, includes filterable and condensable

PM

- PRI= PM

- FIL + PM

- CON

PM10

- FIL Primary PM10, f ilterable portion only

PM10

- PRI Primary PM10, includes filterable and condensable

,

PM10

- PRI = PM0

- FIL + PM

- CON

PM25

- FIL Primary PM2.5, f ilterable portion onlyDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page vii

Acronym Description

PM25

- PRI Primary PM2.5, includes filterable and condens a ble

PM25

- PRI= PM25

- FI L + PM

- CON

RWC Residential wood combustion

SEMAP Southeast Modeling, Analysis and Planning

SIC Standard Industrial Classification code

SIP State Implementation Plan

SCC Source c lassification c ode

S/L State/local

SMOKE Sparse Matrix Operator Kernel Emissions

SO 2 Sulfur d ioxide

TSD Technical Support Document

USEPA U.S. Environmental Protection Agency

VISTAS Visibility Improvement State and Tribal Association of the Southeast

VMT Vehicle miles traveled

VOC Volatile o rganic c ompoundsDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 1



## 1.0 INTRODUCTION

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

preparing emission projections for 2025 for particulate matter (PM) nonattainment areas in

the Mid

- Atlantic / Northeast Visibility Union (MANE

- VU) region. The MANE

- V U

region includes Connecticut, Delaware, the District of Columbia, Maine, Maryland,

Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and

Vermont

. Virginia is not included in the MANE

- VU region; however, several cities and

co unties in northern Virginia were included in this inventory as they are part of a

nonattainment area that includes MANE

- VU jurisdictions

.

1.1 INVENTORY PURPOSE

The Clean Air Act (CAA), as amended, requires each state with areas failing to meet the

National Ambient Air Quality Standards (NAAQS) to develop State Implementation Plans

(SIPs) to expeditiously attain and maintain the standards. The CAA allows states to

request nonattainment areas to be re

- design ated to attainment provided certain criteria are

met. For particulate matter, the U.S. Environmental Protections Agency’s ( USEPA ’s ) re

design ation guidance requires the submittal of a comprehensive inventory of direct PM2.5

emissions and emissions of PM p recursors representative of the year when the area

achieves attainment of the PM2.5 air quality standards. Another emission inventory

related requirement includes a projection of the emission inventory to a year at least 10

years following re

- design ation.

To support state’s efforts in developing PM2.5 maintenance plans and re

- design ation

requests, MARAMA issued a contract to AMEC E&I to assemble a comprehensive

emission inventor y for 2025. A workgroup was formed to guide the 2025 inventory

development pr ocess. Participants include d a member from each state with a PM2.5

nonattainment area, as follows: Paul Bodner (CT), Dave Fees and Jack Sipple (DE), Roger

Thunell (MD), Judy Rand and Danny Wong (NJ), Ron Stannard (NY), Arleen Shulman

(PA), and Doris McLe od (VA). The committee has met via teleconference on multiple

occasions to discuss plans for the 2025 inventory. The 2025 inventory was developed

using a combination of MARAMA’s in

- house resources, support from state agencies and

contractor support from AMEC E&I, Inc. and SRA International, Inc.

1.2 SOURCE CATEGORIES

This report documents the development of annual emission projections for 2025 for each

of these sectors, as follows:Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 2



### EGU Point Source s are units that generate electric power and sell most of the

power generated to the electrical grid.

NonEGU Point Source s are individual industrial, commercial, and institutional

facilities and are further subdivided by stack, emission unit, and emission process.

Stationary Area Source s include sources that in and of themselves are quite small

, but in aggregate may contribute significant emissions. Examples include small

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

house painting or consumer products , gasoline service stations, and agricultural

fertilizer/pesticide application

.

Non

- road Mobile Sources include i nternal combustion engines used to prop e l

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

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

than marine vessels, airplanes, and railroad locomotives (MAR), the inventory was

developed using the most current version of USEPA’s NONROAD model as

embedded in the National Mobile Inventory Model (NMIM)

. Because the

NONROAD model does not include emissions from MAR sources, these emissions

were estimated based on data and methodologies used in recent USEPA regulatory

impact analyses.

On

- r oad Mobile Source s are sources of air pollution from internal combu stion

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

Emission projections for on

- road mobile sources were developed by MARAMA or

state staff using USEPA ’s Motor Vehicle Emission Simulator (MOVES) model.

Biogenic/geogen ic emissions are not included in this inventory.

1.3 GEOGRAPHIC AND TEMPORAL RESOLUTION

The geographic area for the 2025 inventory includes only those counties that are classified

as nonattainment for the annual (1997) or daily (2006) particulate matter NAAQS

. The

inventory was developed at the county

- level for non

- point sources and at the process level

for point sources

.

Annual inventories are required for re

- designation of areas designated as nonattainment for

the 1997 and 2006 NAAQS. Other inventory ele ments required by USEPA (such as

interim inventory years) are being addressed by individual states in their SIP submittals.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 3



### 1.4 POLLUTANTS

The inventory includes emissions for directly emitted PM and PM

- precursors (oxides of

nitrogen {NO

x 

### }, and sulfur dioxide {SO 2 

### }). The PM species in the inventory are

categorized as particles with an aerodynamic diameter less than or equal to a nominal 2.5

micrometers (PM25

- PRI ) , which includes both condensable particles (PM

- CON) and

filterable particles (PM25

- FIL)

.

1.5 DATA FO RMATS

For each sector, we prepare d eas y

- to

- review spreadsheets that provide 2007 emissions and

2025 growth factors

, control factors

, and emissions. We also prepared county level and

nonattainment area summaries for all PM nonattainment counties and areas. The

summaries show the 2007 and 2025 emissions, along with the percent change in emissions

from 2007 to 2025 for each source secto r.

1.6 INVENTORY VERSIONS

The development of base and future year inventories is a n iterative process that continually

attempts to use the best data available to meet air quality planning needs, given time and

resource constraints. The following subsections summarize the work completed to date.

1.6.1 Version 2 Modeling Inventories with Existing Controls

MARAMA developed comprehensive emission inventor ies to support air quality modeling

in the region . MARAMA developed a calendar year 2007 (MARAMA 2011a) inventory

for all sectors except the onroad sector. These inventories, completed in February of 2011,

are referred to as Version 2 of the MANE

- VU+VA 2007 base year inventory. The

inventories were provided in formats required for air quality modeling. Under a sepa rate

effort, the Northeast States for Coordinated Air Use Management (NESCAUM) developed

a 2007 onroad inventory using the MOVES model to support air quality modeling.

MARAMA also prepared emission projections for 2013/2017/2020 (MARAMA 2011b)

for all sect ors except the electric generation and onroad sectors. These projections reflect a

scenario representing the best estimate s for the future year

, accounting for all in

- place

controls that are fully adopted into federal or individual state regulations or SI Ps . In the

past, this inventory is also referred to as the "on

- the

- books" inventory. Modelers often

refer to this scenario as the "future base case".

1.6.2 Version 3 Modeling Inventories with Existing Controls

Beginning in the fall of 2011, MARAMA sponsored development of Version 3 _3 of the

2007 base year modeling inventory to incorporate new paved road emission estimates,Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 4



### revised modeling of nonroad and onroad sources , and other state

- specific changes

(MARAMA201 2a )

. MARAMA develop ed Version 3 _3 of the futu re year inventory to

account for changes to the 2007 base year inventory and selected changes in growth and

control factors identified by states (MARAMA201 2b )

. T he future year modeling

inventories for electric generating units (EGUs) are currently being d eveloped under a

separate effort lead by the Eastern Regional Technical Advisory Committee (ERTAC).

The future year modeling inventories for onroad sources are currently being developed by

NESCAUM, MARAMA or individual states.

1.6.3 Version 3 Modeling Inventori es with Potential New Controls

MARAMA also developed annual emission scenario intended to include all 2017/2020

existing controls plus any new state measures that are under consideration. This is a "what

if" scenario that assumes that all states adopt certain new control measures by 2017.

Modelers sometimes call this the "future control case”.

1.6.4 Version 3 2025 Inventory for PM Nonattainment Counties

The 2025 inventory for PM nonattainment counties was developed using Version 3 _3 of

the modeling invent ory, with the following exceptions:

Growth and control factors for 2025 were developed for the area, nonEGU point,

and nonroad MAR sectors, using the same methodologies and data sources that

were used to develop the 2017/2020 inventories with existing cont rols.

For nonroad sources included in NMIM, Version 2 results were available for 2007,

2017, and 2020. MARAMA and New York made additional NMIM runs for 2025

based on Version 2 inputs. MARAMA made revisions to some of the inputs to

NMIM for Version 3 _3 of the modeling inventory; however, these revised NMIM

runs were not used in the 2025 PM nonattainment county inventory due to time

constraints.

For onroad sources included in the MOVES model, MARAMA and states executed

the model in the inventory mode f or 2007 and 2025. Version 3 _3 of the modeling

inventory used results of the MOVES model executed in a manner to support air

quality modeling.

For EGU point sources, the results of the ERTAC EGU projection methodology are

not currently available. An alternative methodology for projecting EGU emissions

based on growth and control factors was used, as described in Section 4.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 5



### Only counties classif

ied as nonattainment for the PM2.5 annual or 24

- hour

NAAQS were included.

Exhibit 1

- 1 shows the data sources used for the 2025 PM nonattainment area inventory.

Exhibit 1

- 2 lists the counties included in the 2025 PM nonattainment area inventory.

1.7 REPORT ORG ANIZATION

Section s 2 to 6 describe the emission projection process for the following source sectors:

area sources; p oint sources; nonroad mobile sources included in the NMIM model; other

nonroad mobile sources (marine vessels, aircraft, and railroad locomo tives ) ; and onroad

mobile sources included in the MOVES model. Section 7 provides nonattainment area

emission pollutant summaries. Section 8 provides a description of the final deliverables,

including the file names for all final deliverable products. References for the TSD are

provided in Section 9

.

Exhibit 1

. 1

– Comparison of Data Used for Version 3 of the Modeling Inventory

and the 2025 PM Nonattainment Inventory

Sector Modeling Inventory 2025 PM Nonattainment Invento ry

2007 2017/2020 2007 2025

Area Version 3 _3 Version 3 _3 Version 3 _3 Version 3 _3

Nonroad

- NMIM Version 3 _3 Version 3 _3 Version 2 2025 NMIM run

based on

Version 2 inputs

Nonroad

- MAR Version 3 _3 Version 3 _3 Version 3 _3 Version 3 _3

Onroad MOVES runs by

NESCAUM to

support AQ

modeling MOVES runs by

NESCAUM to

support AQ

modeling MOVES runs by

MARAMA or

states in

inventory mode MOVES runs by

MARAMA or

states in

inventory mode

Point

- EGU Version 3 _3 To be developed

by ERTAC Version 3 _3 See section 4 for

proj ection

methodology

Point

- nonEGU Version 3 _3 Version 3 _3 Version 3 _3 Version 3 _3Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 6



### Exhibit 1 .2

– List of PM Nonattainment Areas and Counties

Nonattainment Area State FIPS

Code County PM Nonattainment?

2006

Daily

NAAQS 1997

Annual

NAAQS

Allentown, PA PA 42077 Lehigh Yes Yes

PA 42095 Northampton Yes Yes

Baltimore, MD MD 24003 Anne Arundel No Yes

MD 24005 Baltimore No Yes

MD 24013 Carroll No Yes

MD 24025 Harford No Yes

MD 24027 Howard No Yes

MD 24510 Baltimore City No Yes

Hagerstown

- Martinsburg, MD

- WV MD 24043 Washington No Yes

Harrisburg

- Lebanon

- Carlisle

- York, PA PA 42041 Cumberland Yes Yes

PA 42043 Dauphin Yes Yes

PA 42075 Lebanon Yes Yes

PA 42133 York * Yes No

Johnstown, PA PA 42021 Cambria Yes Yes

PA 42063 Indiana (P) Yes Yes

Lancaster, PA PA 42071 Lancaster Yes Yes

New York

- N. New Jersey

- Long Island, CT 09001 Fairfield Yes Yes

NY

- NJ

- CT CT 09009 New Haven Yes Yes

NJ 34003 Bergen Yes Yes

NJ 34013 Essex Yes Yes

NJ 34017 Hudson Yes Yes

NJ 34021 Mercer Yes Yes

NJ 34023 Middlesex Yes Yes

NJ 34025 Monmouth Yes Yes

NJ 34027 Morris Yes Yes

NJ 34031 Passaic Yes Yes

NJ 34035 Somerset Yes Yes

NJ 34039 Union Yes Yes

NY 36005 Bronx Yes Yes

NY 36047 Kings Yes Yes

NY 36059 Nassau Yes Yes

NY 36061 New York Yes Yes

NY 36071 Orange Yes Yes

NY 36081 Queens Yes Yes

NY 36085 Richmond Yes Yes

NY 36087 Rockland Yes Yes

NY 36103 Suffolk Yes Yes

NY 36119 Westchester Yes Yes

Philadelphia

- Wilmington, PA

- NJ

- DE DE 10003 New Castle Yes Yes

NJ 34005 Burlington Yes Yes

NJ 34007 Camden Yes Yes

NJ 34015 Gloucester Yes Yes

PA 42017 Bucks Yes YesDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 7

Nonattainment Area State FIPS

Code County PM Nonattainment?

2006

Daily

NAAQS 1997

Annual

NAAQS

PA 42029 Chester Yes Yes

PA 42045 Delaware Yes Yes

PA 42091 Montgomery Yes Yes

PA 42101 Philadelphia Yes Yes

Pittsburgh

- Beaver Valley, PA PA 42003 Allegheny (P) Yes Yes

PA 42005 Armstrong (P) Yes Yes

PA 42007 Beaver Yes Yes

PA 42019 Butler Yes Yes

PA 42059 Greene (P) Yes Yes

PA 42073 Lawrence (P)* Yes Yes

PA 42125 Washington Yes Yes

PA 42129 Westmoreland Yes Yes

Reading, PA PA 42011 Berks No Yes

Washington, DC

- MD

- VA DC 11001 Washington No Yes

MD 24017 Charles No Yes

MD 24021 Frederick No Yes

MD 24031 Montgomery No Yes

MD 24033 Prince George No Yes

VA 51013 Arlington No Yes

VA 51059 Fairfax No Yes

VA 51107 Loudoun No Yes

VA 51153 Prince William No Yes

VA 51510 Alexandria No Yes

VA 51600 Fairfax City No Yes

VA 51610 Falls Church No Yes

VA 51683 Manassas City No Yes

VA 51685 Manassas

Park No Yes

York, PA PA 42133 York * No Yes

* York County, PA, is in one nonattainment area for the 2006 24

- hour standard (Harrisburg

Lebanon

- Carlisle

- York, PA) and another for the 1997 annual standard (York, PA)

.

(P) indicates that only part of the county is in the nonattainment area; for this inventory, emissions

for the ent ire county are included.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 8



## 2.0 AREA SOURCES

2.1 AREA SOURCE CATEGORIES

The area source sector contains emissions estimates for sources which individually are too

small in magnitude or too numerous to inventory as individual point sources, and which

can often be estimated more accurately as a single aggregate source for a coun ty.

Examples are emissions from home heating systems , house painting

, consumer products

usage, and small industrial/commercial operations that are not permitted as point sources.

There are 356 individual area source categories in the MANE

- VU+VA inventory,

categorized by a 10

- digit SCC.

2.2 2007 INVENTORY DEVELOPMENT

The emission projections f or the 2025 area source inventory were based on Version 3_3 of

the 2007 MANE

- VU+VA inventory and are fully documented in the TSD for that effort

(MARAMA 2012a). The only adjustment to the 2007 Version 3_3 area source inventory

was to apply “transport fact ors” to fugitive dust sources, as described in the following

subsection.

2.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections

Grid air quality models consistently overestimate fugitive dust impacts as compared to

ambient samples. USEPA develope d a methodology to reduce fugitive dust emissions for

use in grid modeling analyses. It is considered a logical step to improve the ability to

account for the removal of particles near their emission source by vegetation and surface

features and can be us eful in grid

- based modeling analyses.

In February 2011, MARAMA developed 2007 emission modeling files for area sources

which applied the USEPA “transport factor” to reduce fugitive dust emissions to account

for the removal of particles near their emission source by vegetation and surface features.

The standard transport fractions and SCC assignments from USEPA ’s CHIEF website

(USEPA 2007 a ) were used to reduce the PM25

- PRI emissions in th is inventory . Two files

were used. Exhibit 2 .1 shows the list of non EGU SCCs for which the transport factor was

applied. The major source categories included paved and unpaved roads, construction

activity, agricultural crop land tilling, and agricultural livestock operations. Exhibit 2 .2

lists the transport fractions for PM nonattainment counties which vary by county. For

example, the transport factors ranges from 0.1 375 in Camden, New Jersey to 0.80 in

Suffolk County, New York. For Virginia, no transport fraction was provided for the City

of Fairfax; Fairfax County’s t ransport fraction was used for this jurisdiction.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 9



### Exhibit 2

. 1 Area Source SCCs Affected by PM Transport Fraction

SCC SCC Description

2294000000 Paved Roads: All Paved Roads: Total: Fugitives

2296000000 Unpaved Roads: All Unpaved Roads: Total: Fugitives

2311000000 Construction: All Processes: Total

2311010000 Construction: General Building Construction: Total

2311020000 Construction: Heavy Construction: Total

2311030000 Construction: Road Construction: Total

2801000000 Miscellaneous Area Sources;Agriculture Production

- Crops;Agriculture

- Crops;Total

2801000001 Ag crops: Agriculture

- Crops: Land Breaking

2801000002 Ag crops: Agriculture

- Crops: Planting

2801000003 Ag crops: Agriculture

- Crops: Tilling

2801000004 Ag crops: Agriculture

- Crops: Defoliation

2801000005 Ag crops: Agriculture

- Crops: Harvesting

2801000006 Ag crops: Agriculture

- Crops: Drying

2801000007 Ag crops: Agriculture

- Crops: Loading

2801000008 Ag crops: Agriculture

- Crops: Transport

2805000000 Ag livestock: Agriculture

- Livestock: Total

2805001000 Ag livestock: Beef Cattle Feedlots: Total (also see 2805020000)

2805001001 Ag livestock: Beef Cattle Feedlots: Feed Preparation

2805005000 Ag livestock: Poultry Operations: Total

2805010000 Ag livestock: Dairy Operations: Total

2805015000 Ag livestock: Hog Operations: Total

2805020000 Ag livestock: Cattle and Calves Composite: Total

2805025000 Ag livestock: Hogs and Pigs Composite: Total

2805030000 Ag livestock: Poultry and Chickens Composite: Total

2805035000 Ag livestock: Horses and Ponies Composite: Total

2805040000 Ag livestock: Sheep and Lambs Composite: Total

2805045001 Ag livestock: Goats: TotalDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 10



### Exhibit 2

. 2 PM Transport Fractions for PM Nonattainment Counties

State FIPS County PM Transport

Fraction

CT 09001 FAIRFIELD 0.4347

CT 09009 NEW HAVEN 0.4442

DE 10003 NEW CASTLE 0.5087

DC 11001 WASHINGTON 0.3953

MD 24003 ANNE ARUNDEL 0.4874

MD 24005 BALTIMORE 0.4047

MD 24013 CARROLL 0.5641

MD 24017 CHARLES 0.4879

MD 24021 FREDERICK 0.4904

MD 24025 HARFORD 0.5147

MD 24027 HOWARD 0.2798

MD 24031 MONTGOMERY 0.3089

MD 24033 PRINCE GEORGES 0.2950

MD 24043 WASHINGTON 0.4003

MD 24510 BALTIMORE (CITY) 0.4874

NJ 34003 BERGEN 0.2657

NJ 34005 BURLINGTON 0.3008

NJ 34007 CAMDEN 0.1375

NJ 34013 ESSEX 0.3461

NJ 34015 GLOUCESTER 0.4361

NJ 34017 HUDSON 0.5286

NJ 34021 MERCER 0.3472

NJ 34023 MIDDLESEX 0.3273

NJ 34025 MONMOUTH 0.5468

NJ 34027 MORRIS 0.2297

NJ 34031 PASSAIC 0.1971

NJ 34035 SOMERSET 0.3635

NJ 34039 UNION 0.3117

NY 36005 BRONX 0.6145

NY 36059 NASSAU 0.6595

NY 36061 NEW YORK 0.6483

NY 36071 ORANGE 0.3803

NY 36081 QUEENS 0.6505

NY 36085 RICHMOND 0.7159

NY 36087 ROCKLAND 0.3556

NY 36103 SUFFOLK 0.7997

NY 36119 WESTCHESTER 0.3531

PA 42003 ALLEGHENY 0.2308

PA 42005 ARMSTRONG 0.3289

PA 42007 BEAVER 0.3141Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 11

State FIPS County PM Transport

Fraction

PA 42011 BERKS 0.4682

PA 42017 BUCKS 0.3980

PA 42019 BUTLER 0.3621

PA 42021 CAMBRIA 0.2253

PA 42029 CHESTER 0.4757

PA 42041 CUMBERLAND 0.4649

PA 42043 DAUPHIN 0.3438

PA 42045 DELAWARE 0.3515

PA 42059 GREENE 0.3224

PA 42063 INDIANA 0.2884

PA 42071 LANCASTER 0.6183

PA 42073 LAWRENCE 0.4422

PA 42075 LEBANON 0.4521

PA 42077 LEHIGH 0.4487

PA 42091 MONTGOMERY 0.3729

PA 42095 NORTHAMPTON 0.4306

PA 42101 PHILADELPHIA 0.3471

PA 42125 WASHINGTON 0.3436

PA 42129 WESTMORELAND 0.2875

PA 42133 YORK 0.5134

VA 51013 ARLINGTON 0.3534

VA 51059 FAIRFAX 0.2457

VA 51107 LOUDOUN 0.3345

VA 51153 PRINCE WILLIAM 0.1814

VA 51510 ALEXANDRIA 0.3745

VA 51610 FALLS CHURCH 0.3400

VA 51683 MANASSAS 0.3474

VA 51685 MANASSAS PARK 0.3551Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 12



### Exhibit 2.3

– Comparison of 2007 Paved Road Dust PM10 Emission Estimates

Nonattainment Area Without

Transport Factor With

Transport Factor

Version2 Version 3

New

Method Version2 Version 3

New

Method

Allentown 4,228 1,733 1,859 764

Baltimore 15,175 5,412 6,658 2,400

Hagerstown 1,490 263 596 105

Harrisburg

- Lebanon

- Carlisle

- York 9,133 4,124 4,149 1,855

Johnstown 2,663 1,133 673 289

Lancaster 4,339 1,808 2,683 1,118

New York

- N orthern NJ

- Long Island

- CT 58,512 28, 747 29,128 14,2 60

Philadelphia

- Wilmington 29,379 12,644 11,070 4,801

Pittsburgh

- Beaver Valley 14,470 6,173 4,491 1,920

Reading 3,346 1,423 1,567 666

Washington, DC

- MD

- VA 21,067 9,909 6,846 3,194

York 3,684 1,458 1,891 749



### Exhibit 2.4

– Comparison of 2007 Paved Road Dust PM2.5 Emission Estimates

Nonattainment Area Without

Transport Factor With

Transport Factor

Version2 Version 3

New

Method Version2 Version 3

New

Method

Allentown 264 433 116 191

Baltimore 1,770 1,328 782 589

Hagerstown 196 64 78 26

Harrisburg

- Lebanon

- Carlisle

- York 605 1,031 277 464

Johnstown 198 283 50 72

Lancaster 295 452 182 280

New York

- Northern NJ

- Long Island

- CT 2,400 7, 173 1,252 3,5 47

Philadelphia

- Wilmington 1,396 3,165 547 1,202

Pittsburgh

- Beaver Valley 942 1,543 299 480

Reading 209 356 98 167

Washington, DC

- MD

- VA 1,713 2,432 594 784

York 257 365 132 187Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 13



### 2.3 2025 INVENTORY DEVELOPMENT

The general procedures and data used for projecting emissions for the area source sector

are summarized in this section. G rowth factors were applied to the MANE

- VU+VA 2007

inventory to account for changes in fuel use, population

, economic activity. Next, control

factors were applied to account for future emission reductions from control regulati ons.

The 2025 inventory accounts for post

- 2007 emission reductions from promulgated federal,

State, local, and site

- specific control programs and proposed control programs that are

reasonably anticipated to result in post

- 2007 emission reductions.

2.3.1 Area Source Growth Factors

The area and nonEGU point source growth factors were developed using six sets of data:

The Annual Energy Outlook (AEO ) fuel consumption forecasts;

County

- level population projections;

State

- level employment projections by NAICS code;

County

- level vehicle miles travelled ( VMT ) projections;

USEPA projections for livestock and residential wood combustion; and

Other state

- specific emission projection data.

The priority for applying these growth factors was to first use the state

- supplie d projection

data (if available). If state

- supplied data were not provided , then the AEO projection

factors were used for fuel consumption sources

, and the population/employment/VMT data

were used for other source categories

.

2.3.1.1 

### AEO F uel Use Projection

Th e AEO is published annually by the U.S. Energy Information Administration (EIA). It

presents long

- term projections of energy supply, demand, and prices through 2035, based

on results from EIA’s National Energy Modeling System (NEMS). NEMS projects the

pr oduction, imports, conversion, consumption, and prices of energy, subject to

assumptions on macroeconomic and financial factors, world energy markets, resource

availability and costs, behavioral and technological choice criteria, energy technology cost

and performance characteristics, and demographics.

AEO provides regional fuel

- use forecast s for various fuel types (e.g., coal, residual oil,

distillate oil, natural gas) by end use sector (e.g., residential, commercial, industrial,

transportation, and electr ic power)

. Energy use projections are reported at the Census

division level. The c ensus divisions grouped s tates as follows:

South Atlantic

- D E, DC, MD, VA

Middle Atlantic

– N J, NY, PA

New England

– C T, ME, MA, NH, RI, VTDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 14



### Appendices A1, A2, and A3 contain the AEO2010 fuel use projections for each of these

three regions. Appendices A4, A5, and A6 contain the AEO2011 fuel use projections

Version 2 of the MANE

- VU+VA future year inventories was developed using AEO2010

(EIA2010) . After the release of V ersion 2, AEO2011 was published ( EIA2011a).

MARAMA reviewed the updated fuel forecasts and compared the AEO2010 and

AEO2011 projections. Appendix A 7 documents MARAMA’s analysis. MARAMA

calculated the difference in projected fuel usage between AEO2010 and AEO2011 for the

residential, commercial, industrial, transportation, and electric power sector for the

distillate fuel oil, residual fuel oil, coal, natural gas, and renewable fuel types. MARAMA

identified thresholds for what constitutes a major change as follows:

An increase or decrease of 1% or less is considered to be no change and did not

warrant a change in the growth factors between Versions 2 and 3 of the inventory;

An increase or decrease of between 1% and 5% is considered to be a minor change,

and states agreed that these differences between AEO2010 and AEO2011 did not

warrant a change in the growth factors between Versions 2 and 3 of the inv entory;

An increase or decrease above 5% is considered a major change, and warrants a

change in the growth factors used in Version 3.

MARAMA recommended that the AEO2010 projections be retained for all residential,

commercial, and industrial sector fuel u se, except for industrial natural gas usage, where

the AEO2011 projections will be used for Version 3 of the future year modeling inventory.

New Jersey elected to use the more recent growth factors from AEO2011 instead of the

AEO2010 growth factors for al l area source fossil fuel use categories.

Exhibits 2. 5 to 2. 9 summarize the projected fuel use rates by source sector (residential,

commercial, industrial, transportation) and AEO geographic area for the years 2007 to

2025. The unusual growth in commerc ial residual oil use in the South Atlantic region

could not be explained; Maryland elected to use employment instead of the AEO2010

growth factor for commercial residual oil combustion

, while V irginia and the District

chose to assume flat growth in this se ctor

.

2.3.1.2 

### Population Projections

States provided county

- level historic population data and projections for future years. The

historical and projection years varied from state to state, so values were interpolated, when

necessary, to create population estima tes for each year from 2007 to 2025. The population

data were then normalized to create growth factors from 2007 for each year future year.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 15



### For example, Delaware had a population of 861,087 in 2007, and the projected population

in 2017 is 953,204. Thus, the growth factor for 2017 is 953,204 / 861,087 = 1.107.

Exhibit 2.10 summarizes the population growth factors by state and AEO2010 region.

Population is projected to grow in every state between 2007 and 2025. The population

growth in the New England s tates varies significantly by state. Population growth in the

South Atlantic states is projected to be much higher than in the New England and Mid

Atlantic states. Appendix B contains the data use to develop the population projections.

2.3.1.3 

### Employment Projec tions

Every two years, the federal Bureau of Labor Statistics produces long

- term industry and

occupation forecasts for ten future years

, and states are asked to do the same for their

respective economies. The most recent projections are from state Depart ments of Labor

for the period 2006 to 2016 , most of which were published in 2008

. These 10

- year

forecasts are updated every other year. The next set of state

- specific projections will be for

the period 2008 to 2018. Only the District of Columbia and Del aware were able to provide

employment projections for 2008 to 2017; the 2008 to 2018 projections were not available

for other states in time for use on this project. The employment projections are state

- wide

by 3

- digit NAICS code. Exhibit 2.11 summarizes the manufacturing employment (NAICS

sector 310) growth factors by state and AEO2010 region. States in the Northeast / Mid

Atlantic region show a marked decrease in manufacturing employment from 2007 forward.

Appendix C contains the data that were used t o develop the employment projections.

2.3.1.4 

### VMT Projections

States developed projections of vehicle miles traveled (VMT) for 2007 and 2025 which

were used as the growth factor for projecting emissions from re

- entrained road dust from

travel on paved roads (SCC 22

- 94

- 000

- 000). The 2007 and 2025 VMT are identical to

those used in the MOVES modeling discussed in Section 8. Exhibit 2.12 shows the county

level VMT for 2007 and 2025, and the growth factor for projecting 2007 emissions to

2025. Growth factors for 2 013, 2017, and 2020 were based on a linear interpolation of the

2007 and 2025 VMT. Appendix D contains additional information on the data used to

develop the VMT growth factors.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 16



### Exhibit 2. 5 AEO2010 Growth Factors for Coal by AEO Region 2007

– 2025Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 17



### Exhibit 2. 6 Growth Factors for Residual Oil by AEO Region 2007

– 2025Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 18



### Exhibit 2. 7 AEO2010 Growth Factors for Distillate Oil by AEO Region 2007

– 2025Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 19



### Exhibit 2. 8 Growth Factors for Natural Gas by AEO Region 2007

– 2025

AEO2010 for Residential/Commercial, AEO2011 for IndustrialDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 20



### Exhibit 2. 9 AEO2010 Growth Factors for Gasoline by AEO Region 2007

– 2025Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 21



### Exhibit 2. 10 Population Growth Factors by AEO Region 2007

– 2025Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 22



### Exhibit 2. 11 Manufacturing Employment Growth Factors by Region 2007

- 2025Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 23



### Exhibit 2.1 2 2007 and 2025 VMT and the 2007

- 2025 Growth Factor

Million VMT Growth

Nonattainment Area County FIPS 2007 2025 2007

- 2005

Allentown Lehigh 42077 2,947 3,700 1.256

Allentown Northampton 42095 2,020 2,629 1.301

Baltimore Anne Arundel 24003 5,786 7,907 1.367

Baltimore Baltimore 24005 8,261 10,330 1.251

Baltimore Carroll 24013 1,296 1,766 1.363

Baltimore Harford 24025 2,362 3,060 1.296

Baltimore Howard 24027 3,815 6,059 1.588

Baltimore Baltimore City 24510 3,626 4,150 1.145

Hagerstown Washington 24043 2,090 2,940 1.407

Harrisburg

- Lebanon

- Carlisle

- York Cumberland 42041 2,861 3,704 1.295

Harrisburg

- Lebanon

- Carlisle

- York Dauphin 42043 3,072 3,689 1.201

Harrisburg

- Lebanon

- Carlisle

- York Lebanon 42075 1,209 1,507 1.247

Harrisburg

- Lebanon

- Carlisle

- York York 42133 3,304 4,209 1.274

Johnstown Cambria 42021 1,157 1,110 0.959

Johnstown Indiana 42063 844 928 1.100

Lancaster Lancaster 42071 4,255 5,395 1.268

New York Metro NY/NJ/CT Fairfield 9001 7,560 8,568 1.133

New York Metro NY/NJ/CT New Haven 9009 6,856 8,085 1.179

New York Metro NY/NJ/CT Bergen 34003 7,879 10,464 1.328

New York Metro NY/NJ/CT Essex 34013 4,895 6,131 1.253

New York Metro NY/NJ/CT Hudson 34017 2,313 2,801 1.211

New York Metro NY/NJ/CT Mercer 34021 3,566 3,996 1.121

New York Metro NY/NJ/CT Middlesex 34023 7,810 9,748 1.248

New York Metro NY/NJ/CT Monmouth 34025 6,319 8,595 1.360

New York Metro NY/NJ/CT Morris 34027 5,530 6,523 1.180

New York Metro NY/NJ/CT Passaic 34031 2,918 3,490 1.196

New York Metro NY/NJ/CT Somerset 34035 3,230 3,667 1.135

New York Metro NY/NJ/CT Union 34039 4,623 5,730 1.239

New York Metro NY/NJ/CT Bronx 36005 3,677 4,830 1.314

New York Metro NY/NJ/CT Kings 36047 5,461 6,272 1.148

New York Metro NY/NJ/CT Nassau 36059 11,780 14,705 1.248

New York Metro NY/NJ/CT New York 36061 3,938 5,203 1.321

New York Metro NY/NJ/CT Orange 36071 4,431 5,906 1.333

New York Metro NY/NJ/CT Queens 36081 8,859 10,949 1.236

New York Metro NY/NJ/CT Richmond 36085 2,152 3,354 1.558

New York Metro NY/NJ/CT Rockland 36087 2,675 4,060 1.517

New York Metro NY/NJ/CT Suffolk 36103 13,767 20,514 1.485

New York Metro NY/NJ/CT Westchester 36119 8,201 11,811 1.490

Philadelphia PA/DE/NJ New Castle 10003 5,544 6,959 1.255

Philadelphia PA/DE/NJ Burlington 34005 4,704 5,062 1.076Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 24

Million VMT Growth

Nonattainment Area County FIPS 2007 2025 2007

- 2005

Philadelphia PA/DE/NJ Camden 34007 4,090 4,267 1.043

Philadelphia PA/DE/NJ Gloucester 34015 2,723 3,284 1.206

Philadelphia PA/DE/NJ Bucks 42017 5,047 6,516 1.291

Philadelphia PA/DE/NJ Chester 42029 4,423 6,201 1.402

Philadelphia PA/DE/NJ Delaware 42045 3,766 4,371 1.161

Philadelphia PA/DE/NJ Montgomery 42091 7,075 8,220 1.162

Philadelphia PA/DE/NJ Philadelphia 42101 5,973 6,337 1.061

Pittsburgh

- Beaver Valley Allegheny 42003 9,345 10,134 1.084

Pittsburgh

- Beaver Valley Armstrong 42005 628 672 1.071

Pittsburgh

- Beaver Valley Beaver 42007 1,487 1,585 1.066

Pittsburgh

- Beaver Valley Butler 42019 1,762 2,173 1.233

Pittsburgh

- Beaver Valley Greene 42059 464 504 1.086

Pittsburgh

- Beaver Valley Lawrence 42073 812 880 1.084

Pittsburgh

- Beaver Valley Washington 42125 2,245 2,531 1.127

Pittsburgh

- Beaver Valley Westmoreland 42129 3,512 3,898 1.110

Reading Berks 42011 3,341 4,079 1.221

Washington DC/MD/VA DC 11001 3,666 3,861 1.053

Washington DC/MD/VA Charles 24017 1,284 1,825 1.421

Washington DC/MD/VA Frederick 24021 3,009 4,442 1.476

Washington DC/MD/VA Montgomery 24031 7,471 9,711 1.300

Washington DC/MD/VA Prince George's 24033 8,754 11,616 1.327

Washington DC/MD/VA Arlington 51013 1,663 1,917 1.153

Washington DC/MD/VA Fairfax 51059 10,123 13,880 1.371

Washington DC/MD/VA Loudoun 51107 2,403 3,741 1.557

Washington DC/MD/VA Prince William 51153 3,202 4,643 1.450

Washington DC/MD/VA Alexandria 51510 736 866 1.177

Washington DC/MD/VA Fairfax 51600 193 220 1.143

Washington DC/MD/VA Falls Church 51610 64 76 1.186

Washington DC/MD/VA Manassas 51683 273 360 1.317

Washington DC/MD/VA Manassas Park 51685 26 30 1.166Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 25



### 2.3.1.5 

### N o Growth Assignment for Certain Area Source Categories

For several area source categories, it seems reasonable that emissions would not change

from the 2007 values. No growth was applied to the 2007 emissions for the area source

categories shown in Exhibit 2.1 3

.

Exhibit 2.1 3 Area Source Categories with No Growth Assignment

SCC SCC Description

2296000000 Unpaved Roads /All Unpaved Roads /Total: Fugitives

2401008000 Surface Coating /Traffic Markings /Total: All Solvent Types

2461020000 Misc Non

- industrial: Commercial /Asphalt Application: All Processes /Total: All

2461021000 Misc Non

- industrial: Commercial /Cutback Asphalt /Total: All Solvent Types

2461022000 Misc Non

- industrial: Commercial /Emulsified Asphalt /Total: All Solvent Types

2461023000 Misc Non

- industrial: Commercial /Asphalt Roofing /Total : All Solvent Types

2601000000 On

- site Incineration /All Categories /Total

2601010000 On

- site Incineration /Industrial /Total

2601010000 On

- site Incineration /Industrial /Total

2601020000 On

- site Incineration /Commercial/Institutional /Total

2601020000 On

- site Incineration /Commercial/Institutional /Total

2601030000 On

- site Incineration /Residential /Total

2610000100 Open Burning /All Categories /Yard Waste

- Leaf Species Unspecified

2610000400 Open Burning /All Categories /Yard Waste

- Brush Species Unspecified

2610000500 Open Burning /All Categories /Land Clearing Debris (use 28

- 10

- 005

- 000 for Logging

2610030000 Open Burning /Residential /Household Waste (use 26

- 10

- 000

- xxx for Yard Wastes)

2610040400 Open Burning /Municipal (from residences, parks, other for central burn)

2660000000 Leaking Underground Storage Tanks /Leaking Underground Storage Tanks /Total: All

2680001000 Composting /100% Biosolids (e.g., sewage sludge, manure, mixtures of these matls

2680002000 Composting /Mixed Waste (e.g., a 50:50 mixture of biosolids and green wastes)

2806010000 Domestic Animals Waste Emissions /Cats /Total

2806015000 Domestic Animals Waste Emissions /Dogs /Total

2807020001 Wild Animals Waste Emissions /Bears /Black Bears

2807020002 Wild Animals Waste Emissions /Bears /Grizzly Bears

2807025000 Wild Animals Waste Emissions /Elk /Total

2807030000 Wild Animals Waste Emissions /Deer /Total

2807040000 Wild Animals Waste Emissions /Birds /Total

2810001000 Forest Wildfires

- Wildfires

– Unspecified

2810003000 Cigarette Smoke /Total

2810005000 Managed Burning, Slash (Logging Debris) /Unspecified Burn Method

2810010000 Human Perspiration and Respiration /Total

2810014000 Prescribed Burning /Generic

- Unspecified land cover, ownership, class/purposeDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 26

SCC SCC Description

2810015000 Prescribed Forest Burning /Unspecified

2810020000 Prescribed Rangeland Burning /Unspecified

2810030000 Structure Fires /Unspecified

2810035000 Firefighting Training /Total

2810050000 Motor Vehicle Fires /Unspecified

2810060200 Cremation /Animals

2810090000 Open Fire /Not categorized

2820010000 Cooling Towers /Process Cooling Towers /Total

2830000000 Catastrophic/Accidental Releases /All Catastrophic/Accidental Releases /Total

2830010000 Catastrophic/Accidental Releases /Transportation Accidents /Total



### 2.3.1.6 

### USEPA 2020 P rojections for Residential Wood

US EPA made available its 2020 emissions projections associated with its 2005

- based v4

modeling platform . MARAMA decided to use USEPA emission projection parameters for

residential wood combustion. USEPA ’s methodology and data sources are summarized

below (USEPA 20 10 a).

USEPA projected residential wood combustion emissions are based on the expected

increase in the number of low

- emitting wood stoves and the corresponding decrease in

other types of wood stoves. As newer, cleaner woodstoves replace older, more polluting

stoves, there will be an overall reduction of emissions from this category. The approach

used by USEPA was developed as part of a modeling exercise to estimate the expected

benefits of the woodstove change

- out program. This methodology uses a combination

growth and control factor s and is based on activity not pollutant. The growth and control

are accounted for in a single factor for each residential wood SCC (certain SCCs represent

controlled equipment, while other SCCs represent uncontrolled equipment)

. C ontro l

factors are indirectly incorporated based on which stove is used. The specific assumptions

USEPA made were:

Fireplaces, SCC=2104008001: increase 1%/y ear;

Old woodstoves, SCC=2104008002, 2104008010, 2104008051: decrease 2%/y ea r ;

New woodstoves, SCC=2104008003, 2104008004, 2104008030, 2104008050,

2104008052 or 2104008053: increase 2%/y ear.

For the general woodstoves and fireplaces category (SCC 2104008000) USEPA computed

a weighted average distribution based on 19.4% fireplaces, 71.6% old woodstov es, 9.1%

new woodstoves using 2002 Platform emissions for PM2.5. These fractions are based on

the fraction of emissions from these processes in the states that did not have the “generalDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 27



### woodstoves and fireplaces” SCC in the 2002 NEI. This approach result s in an overall

decrease of 1.056% per year for this source category. Appendix E contains the residential

wood projection data from USEPA

.

2.3.1.7 

### SCC, SIC, NAICS and Growth Parameter Crosswalk

Since the employment projections were based on 3

- digit NAICS code, it was necessary to

map NAICS codes to SCCs and SIC codes that were used by states. Employment

projections at the more specific 4

- digit or 6

- digit NAICS codes were not available.

The first step for developing a comprehensive crosswalk between the differ ent source

classification codes (SCC, SIC, and NAICS codes) and emission activity growth indicators

was to compile a complete list of the NAICS codes in the 2007 point source inventory

.

Some states use the SIC code while other use the NAICS code. Still o ther states use both

the SIC and NAICS codes. When the NAICS code was not available SIC codes were

converted to NAICS codes. The 6

- digit NAICS code was truncated to a 3

- digit code,

which represents major industry subsectors of the economy. A U.S. Census Bureau

document was used to perform this conversion (CENSUS 2000).

The next step w as to review parameters that could be used as the emission activity growth

indicator for each SCC or NAICS. We initially relied on two USEPA crosswalks (USEPA

2004a, USEPA 2004b) to match area and nonEGU point source SCCs to AEO2010

categories, employment NAICS codes, and population.

2.3.1.8 

### Final Version 2 Growth Factors for Area Sources

The previous section s described the initial growth factors recommended to develop

projected future year emissions inventories for area and non

- EGU sources. Draft growth

and c ontrol factors, and a draft technical support document, were circulated for review by

MARAMA and state agencies. During the review, it was noted that several emissions

categories show negative growth into the future, particularly categories related to fos sil

fuel combustion and manufacturing employment.

Many of the growth factors used to project emissions for area and non

- EGU sources were

based on the AEO2010 fuel consumption forecasts and state

- level employment projections.

The AEO2010 forecasts show d eclining trends for many fuel consumption sectors,

especially industrial, residential, and commercial distillate fuel oil use. Similarly, the

employment projections show declines in the predicted number of employees for many

sectors of the economy. This is particularly true for the manufacturing sector, which is of

interest because this sector is often associated with higher emissions than those for other

sectors. By contrast, the employment projections show increasing trends in retail andDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 28



### service

- relate d sectors. However, these sectors are not typically associated with significant

emissions.

Predicted declines in fuel use and employment resulted in growth factors less than unity

(i.e., represent negative growth) for many area and non

- EGU point source ca tegories.

Consequently, for some categories, emissions were initially projected to be lower for the

projected future years than for the base year, even before the application of control

assumptions (i.e.

, the future "growth only" emissions are lower than the base year

emissions). A c onference call was held to discuss the negative growth issue, and states

were polled as to whether or not they felt that the current set of proposed growth factors

-

including the negative growth factors

- were realistic for t heir state. In reply, some

representatives mentioned that they have observed historic state

- specific data that supports

the trends displayed by the proposed growth factors. Other representatives mentioned that

they feel comfortable with the growth factor s and don't have a technical basis to change

them or suggest others. Some states will supply their own factors or make their own

assumptions.

As a result of these discussions, each state provided guidance on how to handle projections

when negative growt h is indicated. Exhibit 2

. 1 4 shows the state recommendations for area

sources.

2.3.1.9 

### Version 3 Update to New Jersey Growth Factors for Area Sources

New Jersey provided updated growth factors for area source for use in developing the 2025

inventory for PM non attainment counties. One of the key revisions was to use the more

recent data from AEO2011 for energy consumption instead of the AEO2010 projections.

New Jersey also provided updated employment, paved road, pesticide and agricultural

livestock growth fac tors.

2.3.1.10 

### Version 3 Update to Growth Factors for the District of Columbia

The District of Columbia provided updated employment growth factors based on DC

Department of Labor forecasts for the period 200 8 to 201 8.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 29



### Exhibit 2

- 1 4 State Recommendations to Addr ess Negative Growth

and Other Growth Factors for the Area Source Sector

State AEO2010

Growth Factors Employment

Growth Factors Population

Growth Factors

CT Use AEO2010 growth rates Use state DOL employment

projections by 3

- digit NAICS Use county

- level

population projections

DE Use AEO2010 growth rates ; no growth for suspect AEO2010

projection for commercial /

institutional residual oil For 2013, use state DOL

employment projections by 3

- digit

NAICS; For 2017 and 2020, use

no growth (growth factor=1) when

employment growth is negative;

otherwise use employment if

positive growth Use county

- level

population projections

DC Use AEO2010 growth rates ; no growth for suspect AEO2010

projection for commercial /

institutional residual oil Use DOL employment growth for

NAICS 722 for food and kindred

product SCC; otherwise use

2008

- 2018 data For dry cleaning, use

employment growth for

NAICS 812 instead of

population

MD Not using AEO2010 ; used

employment for commercial &

institutional fuel; used housing

units for residential fuel Provided updated employment

projections; changed cross

- walk

between NAICS code and SCC

for selected source categories Provided updated

population projections

by county

NJ NJ submitted state specific

growth f actors. For fuel

combustion categories only,

used AEO2011 growth rates

except for residual oil (use no

growth) NJ submitted state specific

growth factors. NJ submitted state

specific growth factors

and provided

population projections

by county

NY Use AEO2010 growth rates Use state DOL employment

projections by 3

- digit NAICS Use county

- level

population projections

PA Use AEO2010 growth rates Use state DOL employment

projections by 3

- digit NAICS Use county

- level

population projections

VA Use AEO2010 growth rates ; no growth for suspect AEO2010

projection for commercial /

institutional residual oil Use state DOL employment

projections by 3

- digit NAICS Use county

- level

population projectionsDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 30



### 2.3.2 Area Source Control Factors

Control factors were developed to estimate post

- 2007 emission reductions resulting from

on

- the

- books regulations and other emission reduction measures . Control factors were

developed for the following national

, regional and state measures:

Federal Rules A ffecting Area Sources

Federal MACT Rules

OTC 2001 Model Rules

OTC 2006 Model Rules

MANE

- VU Sulfur in Fuel Oil Limitations

These control programs

, including their impact on PM2.5 and PM precursor emissions, are

discussed in the following subsections.

2.3.2.1 

### Federal Rules Affecting Area Sources

USEPA made available its 2020 emissions projections associated with its 2005

- based v4

modeling platform (USEPA 2010a). USEPA accounted for control strategies for four area

source categories, only one of which reduced emissions of PM2.5 or PM2.5 precursors.

USEPA developed projection factors to account for the replacement of retired woodstoves

that were installed before promulgation of the new source performance standard (NSPS).

We used USEPA ’s latest methodology which uses a combination growth and control factor

and is based on activity and not pollutant. The growth and control are accounted for in a

single factor for specific SCCs that account for the turnover from pre

- NSPS to post

- NSPS

woodstove.

2.3.2.2 

### Federal MACT R ules

USEPA developed guidance for e stimating VOC and NO

x 

### e mission c hanges from MACT

Rules (USEPA 2007b). We reviewed the guidance to identify area source controls

associated with the federal maximum achievable control technology (MACT) standards for

cont rolling hazardous air pollutants (HAPs). Although designed to reduce HAPs, many of

the MACT standards also provide a reduction in criteria air pollutants. USEPA ’s guidance

document provides an estimate of the percent reduction in VOC and NO

x 

### from each

st andard, and the compliance date for the standard. The information concerning MACT

compliance periods provided was used to determine whether the MACT standard provided

post

- 2007 emission reductions. For example, if a compliance period of a MACT standard

w as 2007 or earlier, then we assumed that the emission reductions from the MACT

standard should be reflected in the baseline year and not as an additional post

- 2007 credit.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 31



### Only one area source category was listed in USEPA ’s guidance document

- m unicipal

solid w aste l andfills

. As the compliance date for this standard was January 2004, no post

2007 reductions were applied because the emission reductions from the MACT standard

should be reflected in the 2007 inventory and not as an additional post

- 2007 cred it.

USEPA has or will soon develop MACT standards for about 70 area source categories.

We reviewed USEPA’s 2020 emissions projections described in the previous section and

found that USEPA did not include emission reductions from recent area source MACT

standards. We conducted a review of USEPA’s air toxic website and found that USEPA

determined that many area source MACT standards would result in nationwide reductions

in criteria air pollutants in addition to the reductions in HAP emissions. However, many

States in the MANE

- VU+VA region already have emission standards for many categories

that are as stringent as the Federal area source MACT standards. For example, many states

in the MANE

- VU+VA region already have requirements as stringent as the Gasol ine

Distribution MACT and GACT (generally achievable control technology) standards, and

little additional VOC reductions would be realized in the region. Given the resources

allocated to this project, it was beyond the scope to conduct an analysis of the area source

MACT requirements and state

- by

- state emission regulations to determine whether there

would be emission reductions resulting from the area source MACT standards.

The only exception to the above discussion of area source MACT standards pertains to the

recently promulgated rules for reciprocating internal combustion engines (RICE). USEPA

made available an estimate of the percent reduction in emissions attributable to the RICE

MACT rule in 2012 and 2014 (USEPA 2010 b ). These reductions by SCC are shown in

Exhibit 2

- 15. The USEPA 2014 estimates were used for the MANE

- VU+VA 2017 , 2020

and 202 5 inventories.

2.3.2.3 

### OTC Model Rules for VOC Sources

The Ozone Transport Commission (OTC) developed model rules for its member states in

2002 for several area sour ce VOC categories: consumer products, architectural and

industrial maintenance (AIM) coatings, portable fuel containers (PFCs), mobile equipment

repair and refinishing, and solvent cleaning (OTC 2001). In 2006 the OTC introduced

model rules for two additional area source categories (adhesives/sealants and asphalt

paving) and more stringent requirements for consumer products and portable fuel

containers (OTC 2007). These rules resulted in reductions of VOC emissions. Because

VOC emissions are generally not considered to be significant PM precursors, and these

rules did not result in reductions in PM2.5 or precursor emissions, no further discussion of

the OTC model rules for VOC sources is warranted.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 32



### E xhibit 2

- 15 USEPA Estimate d Percent Reductions for RICE MACT Standard

SCC NOx PM2.5 SCC Description

2101004000 7.57 Electric Utility;Distillate Oil;Total: Boilers and IC Engines

2101004002 11.81 Electric Utility;Distillate Oil;All IC Engine Types

2101006000 7.97 Electric Utility;Natural Gas;Total: Boilers and IC Engines

2101006002 9.87 Electric Utility;Natural Gas;All IC Engine Types

2102004000 7.57 Industrial;Distillate Oil;Total: Boilers and IC Engines

2102006000 7.97 Industrial;Natural Gas;Total: Boilers and IC Engines

2102006002 9.87 Industrial;Natural Gas;All IC Engine Types

2103004000 7.57 Commercial/Institutional;Distillate Oil;Total: Boilers and IC

Engines

2103006000 7.97 Commercial/Institutional;Natural Gas;Total: Boilers and IC

Engines

2199004000 7.57 Area Source Fuel Combustion;Distillate Oil;Total: Boilers and IC

Engines

2199004002 11.81 Area Source Fuel Combustion;Distillate Oil;All IC Engine Types

2199006000 7.97 Area Source Fuel Combustion;Natural Gas;Total: Boilers and IC

Engines

2310000000 12.53 Oil and Gas Production: All Processes;Total: All Processes

2310000220 12.53 Oil and Gas Exploration/Production; Drill Rigs

2310000440 12.53 Oil and Gas Exploration/Production; Saltwater Disposal Engines

2310001000 12.53 Oil and Gas Production: SIC 13; On

- shore;Total: All Processes

2310002000 12.53 Oil and Gas Production: SIC 13; Off

- shore;Total: All Processes

2310020000 12.53 Oil and Gas Production: SIC 13;Natural Gas;Total: All Processes

2310020600 12.53 Oil and Gas Exploration and Production;Natural Gas;Compressor

Engines

2310023000 12.53 Oil and Gas Exploration and Production;Natural Gas;Cbm Gas

Well

- Dewatering Pump Engines



### 2.3.2.4 

### OTC Model Rule for ICI Boilers

T he OTC recommended that member states pursue state

- specific rulemakings or other

implementation methods to achieve NO

x 

### emission reduction for industrial, commercial,

and institutional (ICI) boilers based on guidelines that varied by boiler size and fuel ty pe.

States were polled to determine whether they have adopted a rule that would achieve

reductions equivalent to the 2006 OTC recommendations and whether the estimated

reduction in NO

x 

### emissions should be applied in 2013, 2017, and 2020.

All but one sta te , New Jersey, indicate d that they have not adopted rules for area sources

equivalent to the 2006 OTC recommendations. New Jersey specified that the state has

post

- 2007 ICI boiler rules that reduce NO

x 

### emissions and provided the estimates of theDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 33



### reductio ns in NO

x 

### emissions by SCC resulting from boiler tune

- up requirements, as shown

in Exhibit 2.16:

Exhibit 2. 16 Area Source Emission Reductions from

New Jersey ICI Boiler NO

x 

### Rules

SCC SOURCE

CATEGORY Percent

Reduction

from Tune

ups 2007

-

2013 Rule

Effectivenes

s Rule

Penetratio

n Overall

Percent

Reduction

2007

- 2013

2102004000 Industrial : Distillate 25% 80% 30% 6%

2102005000 I ndustrial : Residual 25% 80% 30% 6%

2102006000 I ndustrial : Nat Gas 25% 80% 30% 6%

2102007000 Industrial : LPG 25% 80% 30% 6%

2103004000 C omm/Inst : Distillate 25% 80% 30% 6%

2103005000 Comm/Inst : Residual 25% 80% 30% 6%

2103006000 Comm/Inst : Nat Gas 25% 80% 30% 6%

2103007000 C omm/Inst

- LPG 25% 80% 30% 6%



### 2.3.2.5 

### MANE

- VU Fuel Oil Sulfur Strategy

MANE

- VU developed a low sulfur fuel oil strategy to help states develop Regional Haze

SIP s ( MANE_VU 2007)

. The sulfur in fuel oil recommendations are shown in Exhibit

2. 17 and vary by state , type of fuel oil, and year of implementation.

Exhibit 2. 17 MAN E

- VU Low Sulfur Fuel Oil Strategy

Inner Zone States (DE, NJ, NY, PA)

Fuel Oil Type Sulfur Content

2012 Sulfur Content

2016

Distillate 500 ppm 15 ppm

#4 Residual 0.25 % 0.25 %

#6 Residual 0.3 to 0.5 % 0.3 to 0.5 %

Outer Zone States (CT, DC, MD)

Fuel Oil Type Sulfur Content

2014 Sulfur Content

2018

Distillate 500 ppm 15 ppm

#4 Residual n/a 0.25 to 0.5 %

#6 Residual n/a 0.5 %Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 34



### Each state was polled and asked to provide guidance as to when, if at all , the MANE

- VU

strategy would be incorporated into their state rules. States were also asked to provide the

2007 sulfur contents for each fuel type by county in order to calculate the percent reduction

in emissions for the future years. Three states ( MD, NJ, NY) have adopted or are

committed to adopt ing the strategy into their rules. Four jurisdictions (CT, DC, DE, PA)

indicated that not enough regulatory development progress has been made to include the

reductions in future years with absolute certainty. One state (VA) has no plans to adopt the

low sulfur fuel oil strategy. The response from each jurisdiction is summarized below:

Connecticut will not include the reductions from MANE

- VU low sulfur fuel oil

strategy at this time for official SIP invento ries used for the PM2.5 redesignation

effort. Section 16a

- 21a of the Connecticut General Statutes (as amended by PA 10

-

74) conditions implementation of number two heating oil sulfur limitation ( 50 ppm

beginning 7/1/2011 and 15 ppm beginning 7/1/2014 ) on s imilar implementation in

NY, MA and RI. NY has taken action, but the other states have not done so yet.

CTDEP expects that 15ppm residential heating oil will be in place in CT by the

"MANE

- VU Ask" 2018 target date. However, until the other states act, S IP

emission inventories will not be approvable with the 15 ppm value. Therefore, at

this time CT elects to retain the 2007 sulfur value through 2025. For residual oil,

Section 22a

- 174

- 19a of the Regulations of CT State Agencies (RCSA) limits

sources >=15 MW and boilers >=250 mm Btu/hr to 0.5% and further limits any of

those sources that are also Title IV acid rain sources to 0.3%. For affected sources,

these limits are consistent with the "MANE

- VU Ask", and should be reflected in

the actual emissions incor porated into the 2007 point source inventory. Other

sources (including most area sources) not otherwise restricted by permit/order are

limited to 1.0% by RCSA 22a

- 174

- 19. As both of these regulations have not

changed after 2007, there are no new controls ( i.e., post 2007 control factors are

1.0) for residual oil

.

The District of Columbia does n ot have a low sulfur rule in place yet. They do

have a draft, and anticipate adopting a rule by 2014, but are inclined not to take

credit for reductions at this point in time

.

Delaware’s low

- sulfur fuel regulation development is running behind schedule and

will not be promulgated done in time to include in the re

- design ation

requests/maintenance plans. Emission reductions from MANE

- VU low sulfur fuel

oil strate gy are not included in the 2025 inventory at this time.

Maryland expects to revise COMAR 26.11.09.07 ( Sulfur Content Limitations for

Fuel 

### ) by 2014 to adopt the limits in the MANE

- VU low sulfur fuel oil strategy.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 35



### New Jersey has revised N.J.A.C. 7:27

- 9.2 ( Sulfur content standards ) to adopt the

2016 sulfur content limits and schedule shown in Exhibit 2.19. All of the PM

nonattainment counties in New Jersey already meet the MANE

- VU limits for

residual oil.

New York adopted a law that limits the sulfur cont ent of No. 2 heating oil to no

more than 15 parts per million starting in July 2012, down from the current range

of 2,000 to 15,000 parts per million. New York expects to revise 6 NYCRR

Subpart 225

- 1 ( Fuel Composition and Use

- Sulfur Limitations ) to lowe r the sulfur

content of distillate fuel oil for all stationary sources (including home heating) and

stationary internal combustion engines. Nearly all of the PM nonattainment

counties in New York already meet the MANE

- VU limits for residual oil. For the

two counties (Orange and Suffolk), compliance with the MANE

- VU limits is

expected by 2017.

Pennsylvania low

- sulfur fuel regulation development is running behind schedule

and will not be promulgated done in time to include in the re

- design ation

requests/maintenance plans. Emission reductions from MANE

- VU low sulfur fuel

oil strategy are not included in the 2025 inventory at this time.

Virginia will not include the emission reductions from low sulfur fuel oil

, as it is

not part of MANE

- VU and has no plans to ad opt the low sulfur fuel oil strategy.

The state responses regarding the currently adopted sulfur contents for home heating oil,

distillate oil, and residual oil are summarized in Exhibits 2. 18 , 2. 19 and 2.2 0 , res pectively

.

F or the purposes of developing the 2025 inventory that will be used for re

- design ations and

maintenance plans

, the sulfur contents and control factors shown in the Exhibits were used

on a county

- by

- county basis to account for the emission reduc tions from the MANE

- VU

low sulfur fuel oil strategy. There are separate columns in the detailed area source

inventory spreadsheet that specify SO 2 

### control factors and emissions for each projection

year for a “currently adopted” scenario that includes redu ctions for states (MD, NJ, NY)

that have or are committed to having rules in place. No emission reductions are applied for

the other states (CT, DC, DE, PA, VA) in the “currently adopted” scenario.

For other air quality planning purposes, we accounted s eparately for emission reductions

that would occur assuming all states fully adopt the MANE

- VU low sulfur fuel limits by

2025. T here are separate columns for SO 2 

### control factors and emissions for a “fully

adopted” scenario where all states (except Virgini a) have the MANE

- VU low sulfur fuel

oil limits in place.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 36



### Exhibit 2. 18 Currently Adopted Sulfur Content and Control Factors for Residential Fuel Oil Combustion

Sulfur Content (ppm) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

CT 09001 Fairfield 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

CT 09009 New Haven 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DE 10003 New Castle 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DC 11001 Washington 1 000 1 000 1000 1000 1000 1.000 1.000 1.000 1.000

MD 24003 Anne Arundel 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24005 Baltimore 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24013 Carroll 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24017 Charles 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24021 Frederick 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24025 Harford 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24027 Howard 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24031 Montgomery 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24033 Prince Georges 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24043 Washington 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24510 Baltimore City 3000 3000 15 15 15 1.000 0.005 0.005 0.005

NJ 34003 Bergen 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34005 Burlington 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34007 Camden 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34013 Essex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34015 Gloucester 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34017 Hudson 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34021 Mercer 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34023 Middlesex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34025 Monmouth 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34027 Morris 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34031 Passaic 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 37

Sulfur Content (ppm) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

NJ 34035 Somerset 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34039 Union 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NY 36005 Bronx 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36047 Kings 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36059 Nassau 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36061 New York 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36071 Orange 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36081 Queens 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36085 Richmond 2000 15 15 15 15 0.007 0.007 0.007 0.007

NY 36087 Rockland 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36103 Suffolk 3700 15 15 15 15 0.004 0.004 0.004 0.004

NY 36119 Westchester 3700 15 15 15 15 0.004 0.004 0.004 0.004

PA 42003 Allegheny 3 000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42005 Armstrong 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42007 Beaver 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42011 Berks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42017 Bucks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42019 Butler 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42021 Cambria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42029 Chester 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42041 Cumberland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42043 Dauphin 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42045 Delaware 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42059 Greene 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42063 Indiana 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42071 Lancaster 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42073 Lawrence 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42075 Lebanon 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

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Page 38

Sulfur Content (ppm) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

PA 42077 Lehigh 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42091 Montgomery 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42095 Northampton 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42101 Philadelphia 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42125 Washington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42129 Westmoreland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42133 York 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51013 Arlington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51059 Fairfax 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51107 Loudoun 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51153 Prince William 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51510 Alexandria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51600 Fairfax City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51610 Falls Church 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51683 Manassas City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 516 85 Manassas Park City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 39



### Exhibit 2. 19 Currently Adopted Sulfur Content and Control Factors for Distillate Fuel Oil Combustion

Sulfur Content ( % S ) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

CT 09001 Fairfield 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

CT 09009 New Haven 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DE 10003 New Castle 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

DC 11001 Washington 1000 1000 1000 1000 1000 1.000 1.000 1.000 1.000

MD 24003 Anne Arundel 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24005 Baltimore 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24013 Carroll 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24017 Charles 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24021 Frederick 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24025 Harford 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24027 Howard 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24031 Montgomery 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24033 Prince Georges 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24043 Washington 3000 3000 15 15 15 1.000 0.005 0.005 0.005

MD 24510 Baltimore City 3000 3000 15 15 15 1.000 0.005 0.005 0.005

NJ 34003 Bergen 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34005 Burlington 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34007 Camden 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34013 Essex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34015 Gloucester 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34017 Hudson 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34021 Mercer 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34023 Middlesex 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34025 Monmouth 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34027 Morris 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34031 Passaic 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 40

Sulfur Content ( % S ) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

NJ 34035 Somerset 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NJ 34039 Union 2000 2000 15 15 15 1.000 0.0075 0.0075 0.0075

NY 36005 Bronx 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36047 Kings 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36059 Nassau 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36061 New York 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36071 Orange 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36081 Queens 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36085 Richmond 2000 2000 15 15 15 1.000 0.007 0.007 0.007

NY 36087 Rockland 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36103 Suffolk 3700 3700 15 15 15 1.000 0.004 0.004 0.004

NY 36119 Westchester 3700 3700 15 15 15 1.000 0.004 0.004 0.004

PA 42003 Allegheny 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42005 Armstrong 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42007 Beaver 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42011 Berks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42017 Bucks 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42019 Butler 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42021 Cambria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42029 Chester 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42041 Cumberland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42043 Dauphin 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42045 Delaware 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42059 Greene 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42063 Indiana 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42071 Lancaster 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42073 Lawrence 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42075 Lebanon 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 41

Sulfur Content ( % S ) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

PA 42077 Lehigh 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42091 Montgomery 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42095 Northampton 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42101 Philadelphia 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42125 Washington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42129 Westmoreland 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

PA 42133 York 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51013 Arlington 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51059 Fairfax 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51107 Loudoun 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51153 Prince William 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51510 Alexandria 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51600 Fairfax City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51610 Falls Church 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 51683 Manassas City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000

VA 516 85 Manassas Park City 3000 3000 3000 3000 3000 1.000 1.000 1.000 1.000Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 42



### Exhibit 2. 2 0 Currently Adopted Sulfur Content and Control Factors for Residual Fuel Oil Combustion

Sulfur Content ( % S ) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

CT 09001 Fairfield 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

CT 09009 New Haven 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

DE 10003 New Castle 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

DC 11001 Washington 1 .0 1 .0 1 .0 1.0 1.0 1.000 1.000 1.00 0 1.0 0 0

MD 24003 Anne Arundel 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24005 Baltimore 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24013 Carroll 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24017 Charles 2.0 2.0 0.5 0.5 0.5 1.000 0.250 0.250 0.250

MD 24021 Frederick 2.0 2.0 0.5 0.5 0.5 1.000 0.250 0.250 0.250

MD 24025 Harford 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24027 Howard 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24031 Montgomery 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24033 Prince Georges 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

MD 24043 Washington 2.0 2.0 0.5 0.5 0.5 1.000 0.250 0.250 0.250

MD 24510 Baltimore City 1.0 1.0 0.5 0.5 0.5 1.000 0.500 0.500 0.500

NJ 34003 Bergen 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34005 Burlington 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34007 Camden 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34013 Essex 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34015 Gloucester 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34017 Hudson 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34021 Mercer 0.5 0.5 0.5 0.5 0.5 1.000 1.000 1.000 1.000

NJ 34023 Middlesex 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34025 Monmouth 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34027 Morris 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34031 Passaic 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 43

Sulfur Content ( % S ) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

NJ 34035 Somerset 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NJ 34039 Union 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36005 Bronx 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36047 Kings 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36059 Nassau 0.37 0.37 0.37 0.37 0.37 1.000 1.000 1.000 1.000

NY 36061 New York 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36071 Orange 1.5 1.5 0.5 0.5 0.5 1.000 0.333 0.333 0.333

NY 36081 Queens 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36085 Richmond 0.3 0.3 0.3 0.3 0.3 1.000 1.000 1.000 1.000

NY 36087 Rockland 0.37 0.37 0.37 0.37 0.37 1.000 1.000 1.000 1.000

NY 36103 Suffolk 1 1 0.5 0.5 0.5 1.000 0.500 0.500 0.500

NY 36119 Westchester 0.37 0.37 0.37 0.37 0.37 1.000 1.000 1.000 1.000

PA 42003 Allegheny 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42005 Armstrong 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42007 Beaver 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42011 Berks 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42017 Bucks 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42019 Butler 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42021 Cambria 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42029 Chester 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42041 Cumberland 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42043 Dauphin 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42045 Delaware 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42059 Greene 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42063 Indiana 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42071 Lancaster 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42073 Lawrence 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42075 Lebanon 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 44

Sulfur Content ( % S ) Control Factor

STATE FIPS CNTY_NAME 2007 2013 2017 2020 2025 CF_07_13 CF_07_17 CF_07_20 CF_07_25

PA 42077 Lehigh 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42091 Montgomery 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42095 Northampton 2.0 2.0 2.0 2.0 2.0 1.000 1.000 1.000 1.000

PA 42101 Philadelphia 1.0 1.0 1.0 1.0 1.0 1.000 1.000 1.000 1.000

PA 42125 Washington 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42129 Westmoreland 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

PA 42133 York 2.8 2.8 2.8 2.8 2.8 1.000 1.000 1.000 1.000

VA 51013 Arlington 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51059 Fairfax 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51107 Loudoun 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51153 Prince William 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51510 Alexandria 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51600 Fairfax City 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51610 Falls Church 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51683 Manassas City 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000

VA 51685 Manassas Park City 2.25 2.25 2.25 2.25 2.25 1.000 1.000 1.000 1.000Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 45



## 3.0 POINT SOURCES

3.1 POINT SOURCE CATEGORIES

States were asked to classify units in the 2007 MANE

- VU+VA point source emissions

inventory as either EGU or nonEGU. Most, but not all, units that report hourly emissions

to USEPA’s C lean Air Markets Division (CAMD) are classified as EGUs.

CAMD implements USEPA ’s rule found in Volume 40 Part 75 of the Code of Federal

Regulations (CFR), which requires an hourly accounting of emissions from each affected

unit

- i.e., sources participa ting in an emissions cap and trade program under the Acid

Rain Control Program, the NO

x 

### Budget Trading Program, or the Clean Air Interstate Rule.

Most of the CAMD sources are traditional power plants that sell electricity to the electrical

grid. However, there are other types of sources that report to CAMD that are not

considered to be EGUs, such as petroleum refineries and cement kilns.

The following criteria was provided to states to classify a unit as an EGU:

An EGU sells most of the power generated to the electrical grid;

An EGU burns mostly commercial fuel. Commercial fuel in this case means

natural gas, oil, and coal. Wood is not considered a commercial fuel because some

states identify wood as renewable . T herefore, to avoid double counting, uni ts that

burn wood and other renewable sources (depending on each state's own definition)

should not be considered as an EGU (unless it is already in the CAMD database)

.

The following units were not considered EGUs for emission projections: (1) a unit that

generates power for a facility but occasionally sells to the grid; (2) emergency generators;

or (3) distributed generation units.

The emission projection methodology for units classified as nonEGUs is discussed in

Section 3.3 . The emission projection methodology for EGUs is discussed in Section 3. 4.

3.2 2007 INVENTORY DEVELOPMENT

The emission projections for the 2025 point source were based on Version 3_3 of the 2007

MANE

- VU+VA inventory and are fully documented in the TSD for that effort

(MARAMA 2012a). The only adjustment to the 2007 Version 3_3 point source source

inventory was to apply “transport factors” to fugitive dust sources, as described in the

following subsection.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 46



### 3.2.1 Adjustments to the 2007 Inventory Used for the 2025 Projections

As described previously in Section 2.2.1.1, PM2.5 emissions for point sources were

adjusted using the USEPA PM transport fractions for fugitive dust s ources. Exhibit 3.1

shows the list of nonEGU SCCs for which the transport factor was applied. The major

source categories included various operations in the mineral products and construction

industries. Exhibit 2.2 in the previou s Section 2 shows the tr ansport fractions for each PM

nonattainment count y

.

E xhibit 3. 1 NonEGU Point Source SCCs Affected by PM Transport Fraction

SCC SCC Description

30300519 Prim Metal Prod: Primary Copper Smelting: Unpaved Road Traffic: Fug Emiss

30300831 Prim Metal Prod: Iron Production: Unpaved Roads: Light Duty Vehicles

30300832 Prim Metal Prod: Iron Production: Unpaved Roads: Med Duty Vehicles

30300833 Prim Metal Prod: Iron Production: Unpaved Roads: Heavy Duty Vehicles

30300834 Prim Metal Prod: Iron Production: Paved Roads: All Vehicle Types

30302321 Prim Metal Prod: Taconite Iron Ore Processing: Haul Road: Rock

30302322 Prim Metal Prod: Taconite Iron Ore Processing: Haul Road: Taconite

30500290 Industrial Processes;Mineral Products;Asphalt Concrete;Haul Roads : General

30501024 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Hauling

30501030 Industrial Processes;Mineral Products;Coal Mining, Cleaning, and Material

Handling (See 305310);Tops

30501031 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Scrapers: Travel Mode

30501039 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Hauling: Haul Trucks

30501045 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Bulldozing: Overburden

30501046 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Bulldozing: Coal

30501047 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Grading

30501048 Industrial Processes;Mineral Products;Coal Mining, Cleaning, and Material

Handling (See 305310);Over

30501049 Industrial Processes;Mineral Products;Coal Mining, Cleaning, and Material

Handling (See 305310);Wind

30501050 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Vehicle Traffic:

Light/Medium Vehicles

30501090 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Haul Roads: General

30501640 Mineral Products: Lime Manufacture: Vehicle Traffic

30502011 Mineral Products: Stone Quarrying

- Processing: Hauling

30502504 Mineral Products: Construction Sand and Gravel: Hauling

30531090 Mineral Products: Coal Mining, Cleaning, & Mat'l Handling: Haul Roads: General

31100101 Building Const: Construction: Building Contractors: Site Preparation: Topsoil

Removal

31100102 Building Const: Construction: Building Contractors: Site Prep: Earth Moving (Cut

and Fill )Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 47

SCC SCC Description

31100103 Building Const: Construction: Building Contractors: Site Prep: Aggregate Hauling

(On Dirt)

31100205 Building Const: Demolitions/Special Trade Contracts: On

- site Truck Traffic

31100206 Building Const: Demolitions/Special Trade Contracts: On

- si te Truck Traffic

50100401 Waste Disposal;Solid Waste Disposal

- Government;Landfill Dump;Unpaved Road

Traffic



### 3.3 2025 NONEGU INVENTORY DEVELOPMENT

3.3.1 NonEGU Growth Factors

NonEGU point source growth factors were developed using three sets of data:

Annual Energy Outlook fuel consumption forecasts;

State

- level employment projections by NAICS code; and

Other state

- specific emission projection data.

The priority for applying these growth factors was to first use the state

- supplied projection

data (if av ailable). If no state

- supplied data are available, then we use d AEO projection

factors for fuel consumption sources and employment data for other source categories

. The AEO fuel consumption forecasts and employment projections by NAICS code used

for area sources were also used for nonEGU point sources. See Section 2.3.1 of this report

for a description of these data sets.

Section 2 described the growth factors used to develop projected future year emissions

inventories for both area and non

- EGU sources . Draft growth and control factors, and a

draft technical support document, were circulated for review by MARAMA and state

agencies. During the review, it was noted that several emissions categories show negative

growth into the future, particularly cate gories related to fossil fuel combustion and

manufacturing employment. The AEO forecasts show declining trends for many fuel

consumption sectors, especially industrial, residential, and commercial distillate fuel oil

use. Similarly, the employment projec tions show declines in the predicted number of

employees for many sectors of the economy. This is particularly true for the

manufacturing sector, which is of interest because this sector is often associated with

higher emissions than those for other secto rs. By contrast, the employment projections

show increasing trends in retail and service

- related sectors.

Predicted declines in fuel use and employment resulted in growth factors less than unity

(i.e., represent negative growth) for many area and non

- EG U point source categories.

Consequently, for some categories, emissions are lower for the projected future years thanDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 48



### for the base year, even before the application of control assumptions ( i.e., the future

"growth only" emissions are lower than the base y ear emissions). The MARAMA

emissions inventory workgroup met on several occasions via conference calls and email

exchanges to discuss whether the negative growth projections were realistic, and what

additional assumptions should be made. A topic of parti cular concern is negative growth

for non

- EGU point sources versus the treatment of Emissions Reduction Credits (ERCs) in

the future year inventories.

A few states cited the importance of the negative growth issue for non

- EGUs and how it

relates to their ER C programs which are critical to new businesses being able to locate in

those states. Because businesses could apply for and sell ERCs at the level of the base

year inventory, it would not be realistic to show negative growth for non

- EGU point

sources. D uring an economic downturn, a facility could shut down and sell its ERCs,

making the effective level of future year emissions equal to ( i.e., no lower than) the base

year. Therefore, a recommended conservative approach for addressing negative growth for

n on

- EGU point sources is to set a minimum growth rate of 1 (no growth).

During the conference call held on July 23, 2010 to discuss the negative growth issue, state

agency representatives were polled as to whether or not they felt that the current set of

pr oposed growth factors

- including the negative growth factors

- were realistic for their

state or district. In reply, some representatives mentioned that they have observed historic

state

- specific data that supports the trends displayed by the proposed gr owth factors. Other

representatives mentioned that they feel comfortable with the growth factors and don't

have a technical basis to change them or suggest others. Some states will supply their own

factors or make their own assumptions.

As a result of these discussions, each state provided guidance on how to handle projections

when negative growth is indicated. Exhibit 3.2 shows the state recommendations for

nonEGU point sources.

Exhibit 3.2 State Recommendations to Address Negative Growth

for the NonEGU Point Source Sector

State AEO2010 Growth Factors Employment Growth Factors

CT Use no growth (growth factor=1) when AEO

growth is negative; otherwise use AEO2010 if

positive growth Use state DOL employment projections by 3

- digit NAICS

DE Use AEO2010 growth rates For 2013, use state DOL employment

projections by 3

- digit NAICS;

For 2017 and 2020, use no growth (growth

factor=1) when employment growth isDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 49

State AEO2010 Growth Factors Employment Growth Factors

negative; otherwise use employment if

positive growth

DC Use AEO2010 growth rates Use state 2008

- 2018 DOL employment

projections by 3

- digit NAICS ; no growth when

employment is projected to decrease

MD Not using AEO2010 growth factors (except for

the electric power generation SCCs);

Use MD DOL employment projections for

industrial and commercial fuel use SCCs,

unless employment growth rate is negative, in

which case use no growth (growth factor=1) Use updated state DOL employment

projections by 3

- digit NAICS;

For DoD facilities, account for impacts of Base

Realignment and Closure;

For source that have closed, account for

emission reduction credits

NJ New Jersey submitted state specific growth

factors. Used either state specific growth

factors, no growth (growth factor=1) when

state AEO growth is negative or AEO if

positive growth NJ submitted state specific growth factors.

Use d either state specific factors, no growth

(growth factor=1) when state DOL

employment growth is negative or employment if positive growth

NY Use no growth (growth factor=1) when AEO

growth is negative; otherwise use AEO2010 if

positive growth Use no growth (growth factor=1) when

employment growth is negative; otherwise use

employment if positive growth

PA Use no growth (growth factor=1) when AEO

growth is negative; otherwise use AEO2010 if

positive grow th Use no growth (growth factor=1) when

employment growth is negative; otherwise use

employment if positive growth

VA Use no growth (growth factor=1) when AEO

growth is negative; otherwise use AEO2010 if

positive growth Use no growth (growth factor=1) whe n

employment growth is negative; otherwise use

employment if positive growth



### 3.3.2 Emission Reduction Credits

Mulitple states ( Connecticut, Maryland, and New Jersey ) added county level records

account for account emission reduction credits (ERCs) issued to stat ionary sources

pursuant to state regulation s

. States provided ERCs on a county

- by

- county basis.

Fictitious facilities with an identifier of “OFFSET99999” were created for each county

using SCC 23

- 99

- 000

- 000 (miscellaneous industrial processes: not elsewhere classified)

. Stack data were developed that assumed that emissions were released at the county

centroid with an assumed release height of 10 feet. For the 20 17 and 2020 inventories

,

ERC emissions were set to the amount of banked emissions avail able in 2007.

Delaware included the banked credits at the specific locations that they were generated

. New York and Pennsylvania did not explicitly provide any information on ERCs.

The District of Columbia and V irginia do not have a formal banking and trading program

. They used growth rates of 1 for those SCCs in the point source emissions inventory that

showed a negative growth

. In addition, for units that have or are projected to have shutDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 50



### down

, they preserve d the 2007 emissions in the inventory to account for potential use as

offsets or credits.

3.3.3 NonEGU Control Factors

Control factors were developed for both on

- the

- books regulations and proposed regulations

and other actions to estimate emission reductions in future ye ars . Control factors were

considered for the following national or regional control measures:

Federal Rules Affecting NonEGU Point Sources

OTC 2001 Model Rules

OTC 2006 Model Rules

MANE

- VU Sulfur in Fuel Oil Strategy

These control programs are discus sed in the following subsections.

3.3.3.1 

### Federal Actions Affectin g NonEGU Point Sources

USEPA made available its 2020 emissions projections associated with its 2005

- based v4

modeling platform (USEPA 2010 a ). These categories, and how they were accounted for in

the MANE

- VU+VA emission projection inventories, are described below:

MACT Standards

- USEPA developed guidance for e stimating VOC and NO

x



### e mission c hanges from MACT Rules (USEPA 2007b). We reviewed the guidance

to identify nonEGU source controls associated with MACT standards for

controlling HAPs. The information concerning MACT compliance periods was

used to determine whether the MACT standard resulted in post

- 2007 emission

reductions. Because major source categories had a comp liance period of 2007 or

earlier, we assumed that the emission reductions from the MACT standard should

be reflected in the baseline year and not as an additional post

- 2007 credit. The

only exception to the above discussion of area source MACT standards pertains to

the recently promulgated rules for reciprocating internal combustion engines

. USEPA made available an estimate of the percent reduction in emissions

attributable to the RICE MACT rule in 2012 and 2014 (USEPA 2010 b ). These

reductions by SCC ar e shown in Exhibit 3.3. The USEPA 2014 estimates were

used for the MANE

- VU+VA 2017, 2020 and 2025 inventories.

Industrial, Commercial, and Institutional Boilers and Process Heaters MACT

Standard

- USEPA’ s 2020 control factor file identified a number of solid fuel

burning SCCs for which they estimated an 87% reduction in both PM10 and

PM2.5. These were used for 2025 also for the affected SCCs.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 51



### Petroleum refinery enforcement settlements

- For the facilities identified by

USEPA located in New Jersey and Pe nnsylvania we applied post

- 2007 estimated

reductions for NO

x 

### , PM10, PM2.5, and SO 2 

### to affected units.

Exhibit 3.3 USEPA Estimated Percent Reductions for RICE MACT Standard

SCC NOx PM2.5 SCC Description

20100102 15.14 Electric Generation;Distillate Oil (Diesel);Reciprocating

20100105 15.14 Electric Generation;Distillate Oil (Diesel);Reciprocating:

Crankcase Blowby

20100107 15.14 Electric Generation;Distillate Oil (Diesel);Reciprocating:

Exhaust

20100202 12.53 Electric Generation;Natural Gas;Reciprocating

20100207 12.53 Electric Generation;Natural Gas;Reciprocating: Exhaust

20200102 15.14 Industrial;Distillate Oil (Diesel);Reciprocating

20200104 15.14 Industrial;Distillate Oil (Diesel);Reciprocating: Cogeneration

20200107 15.14 Industrial;Distillate Oil (Diesel);Reciprocating: Exhaust

20200202 12.53 Industrial;Natural Gas;Reciprocating

20200204 12.53 Industrial;Natural Gas;Reciprocating: Cogeneration

20200207 12.53 Industrial;Natural Gas;Reciprocating: Exhaust

20200253 37.96 Industrial;Natural Gas;4

- cycle Rich Burn

20200301 37.96 Industrial;Gasoline;Reciprocating

20200307 37.96 Industrial;Gasoline;Reciprocating: Exhaust

20201001 12.53 Industrial;Liquified Petroleum Gas (LPG);Propane

20201002 12.53 Industrial;Liquified Petroleum Gas (LPG);Butane

20201702 37.96 Industrial;Gasoline;Reciprocating Engine

20201707 37.96 Industrial;Gasoline;Reciprocating: Exhaust

20300101 15.14 Commercial/Institutional;Distillate Oil (Diesel);Reciprocating

20300105 15.14 Commercial/Institutional;Distillate Oil

(Diesel);Reciprocating: Crankcase Blowby

20300106 15.14 Commercial/Institutional;Distillate Oil

(Diesel);Reciprocating: Evaporative Losses

20300107 15.14 Commercial/Institutional;Distillate Oil

(Diesel);Reciprocating: Exhaust

20300201 12.53 Commercial/Institutional;Natural Gas;Reciprocating

20300204 12.53 Commercial/Institutional;Natural Gas;Cogeneration

20300207 12.53 Commercial/Institutional;Natural Gas;Reciprocating:

Exhaust

20300301 37.96 Commercial/Institutional;Gasoline;Reciprocating

20300307 37.96 Commercial/Institutional;Gasoline;Reciprocating: Exhaust

20301001 12.53 Commercial/Institutional;Liquified Petroleum Gas

(LPG);Propane

20301002 12.53 Commercial/Institutional;Liquified Petroleum Gas

(LPG);Butane

20400401 37.96 Engine Testing;Reciprocating Engine;GasolineDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 52

SCC NOx PM2.5 SCC Description

20400402 15.14 Engine Testing;Reciprocating Engine;Diesel/Kerosene

20400403 15.14 Engine Testing;Reciprocating Engine;Distillate Oil: CI: CI:

VOC 2005cr = 0

31000203 12.53 Oil and Gas Production;Natural Gas

Production;Compressors

50100421 12.53 Solid Waste Disposal;Landfill Dump;Waste Gas Recovery:

Internal Combustion Device



### 3.3.3.2 

### OTC 2001 Model Rules for NonEGUs

The OTC developed NO

x 

### control measures for industrial, commercial, and institutional

(ICI) boilers and distributed generation units in 2001 (OTC 2001). We reviewed the

OTC’s status reports to identify states status in adopting the OTC 2001 model rules (OTC

2009a). Most state s have adopted the OTC model rules with compliance dates in 2007 or

earlier. As a result, we assumed that the emission reductions from the 2001 OTC model

rules for nonEGUs are already reflected in the 2007 inventory and no post

- 2007

reductions were appli ed.

3.3.3.3 

### OTC 2006 Model Rules for NonEGUs

In 2006

, the OTC introduced model rules (OTC 2007) for one nonEGU VOC source

category (adhesives/sealants) and new/more stringent requirements for several NO

x 

### source

categories (asphalt production plants, cement kil ns, glass/fiberglass furnaces, and

industrial, commercial, and institutional {ICI} boilers). We reviewed the OTC’s status

reports to identify where state status in adopting the OTC 2006 model rules (OTC 2009b).

To obtain further clarification of each sta te ’s status, states were polled to determine

whether they have adopted a rule that would achieve reductions equivalent to the OTC

model rule, whether credit for each rule was already accounted for in the 2007 inventory

,

and whether the estimated reduction in emissions should be applied in 2013, 2017, 2020

and 2025 . The following paragraphs describe the control factors applied for each rule by

state and future year.

3.3.3.3.1 OTC 2006 Model Rule for Asphalt Production Plants



### T he OTC recommended that member states p ursue state

- specific rulemakings or other

implementation methods that would achieve a 35 percent reduction in NO

x 

### emissions.

States were polled to determine whether they have adopted a rule that would achieve

reductions equivalent to the 2006 OTC model ru le and whether the estimated reduction in

NO

x 

### emissions should be applied in 2013, 2017, 2020 and 2025 . Only New Jersey

indicated that the reductions should be applied. New York did not provide guidance, and itDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 53



### was assumed that the NO

x 

### reductions should be applied in New York for three future

years. All other states indicated that the NO

x 

### reductions should not be applied in the future

years. For those states that indicated they wanted to include the reductions, a 35 percent

reduction in NO

x 

### emissions wa s applied for SCC 3

- 05

- 002

- xx.

3.3.3.3.2 OTC 2006 Model Rule for Cement Manufacturing Plants



### Cement kilns are located in Maryland, New York, and Pennsylvania

. Virginia has one

cement kiln, which is not located in a PM nonattainment county. T he OTC recommended

state

- specific rulemakings or other implementation methods that would result in about a 60

percent reduction in uncontrolled levels NO

x 

### emissions. This e mission reduction for

cement kilns was calculated using the methodology previously developed and documented

in the OTC report (OTC 2007). Cement kilns are already subject to NO

x 

### controls as part

of Phase I of the NO

x 

### SIP call. Emission reductions resulting from the NO

x 

### SIP call are

already accounted for in the 2007 inventory.

The foll owing methods were used to calculate the additional reductions from the OTC

2006 Control Measure in each state :

Maryland indicated controls will become effective in 2011 for the two facilities in

the state . Maryland specified a 25 percent reduction for th e Holcim facility and a

40 percent reduction for the Lehigh facility. No reductions were specified for the

two kilns at the Essroc facility.

New York did not provide guidance regarding cement kilns. We used the percent

reductions previously developed a nd documented in the previous round of emission

projections developed for MARAMA (MARAMA 2007). An incremental control

efficiency of 40 percent was used for New York cement kilns in that inventory.

Pennsylvania provided kiln

- specific projected future year NO

x 

### emissions for 2013,

2017, and 2020. The 2020 controlled emissions were also used for 2025. A kiln

specific control factor was calculated based on the ratio of the future year emissions

to the 2007 emissions.

3.3.3.3.3 OTC 2006 Model Rule for Glass and Fiberg lass Furnaces



### T he OTC recommended state

- specific rulemakings or other implementation methods to

achieve an approximately 85 percent reduction in NO

x 

### emissions from uncontrolled levels.

Emission reductions for glass and fiberglass furnaces were calculated using the

methodology previously developed and documented in the OTC report (OTC 2007). Glass

and fiberglass furnaces are located in Maryland, New Jersey, New York, and Pennsylvania.

There are no other States with facilities in a PM nonattainment county.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 54



### The following methods were used to calculate the additional reductions from the OTC

2006 Control Measure in each state :

Maryland indicated that a 48 percent reduction should be applied to the single glass

manufacturing facility in Maryland.

New Jersey indicated that a 50 percent reduction in NO

x 

### emissions should be

applied to glass and fiberglass furnaces in 2013, 2017, 2020 and 2025

.

New York did not provide guidance regarding glass or fiberglass furnaces . We

used the percent reductions developed and documented in the previous round of

emission projections developed for MARAMA (MARAMA 2007). An

incremental control efficiency of 70 percent was used for New York glass and

fiberglass furnaces in that inventory.

Pennsylvania provided furnace

- specific proj ected future year NO

x 

### emissions for

2017 and 2020 for all facilities , including those in Allegheny County. The 2020

controlled emissions were also used for 2025. A furnace

- specific control factor

was calculated based on the ratio of the future year emiss ions to the 2007

emissions.

For the three glass manufacturing facilities in Allegheny County, we used the

percent reductions previously developed and documented in the previous round of

emission projections developed for MARAMA (MARAMA 2007). An

increme ntal control efficiency of 86 percent was used for Allegheny County glass

and fiberglass furnaces in that inventory.

3.3.3.3.4 OTC 2006 Model Rule for ICI Boilers



### T he OTC recommended that m ember states pursue state

- specific rulemakings or other

implementation methods to achieve NO

x 

### emission reduction for industrial, commercial,

and institutional (ICI) boilers based on guidelines that varied by boiler size and fuel type.

States were polled to determine whether they have adopted a rule that would achieve

reductions equivalent to the 2006 OTC recommendations and whether the estimated

reduction in NO

x 

### emissions should be applied in 2013, 2017, 2020

, and 2025

.

Most states have not adopted rules equivalent to the 2006 OTC recommendations. These

states indicated that they will likely depend on a USEPA national rule for possible

inclusion in the BOTW inventory. Specifically, the OTC Resolution 10

- 01 (June, 2010)

called on USEPA for national regulations for I CI boilers

.

New Jersey provided NO

x 

### percent reductions that varied by heat input rate and fuel/boiler

type and included an 80 percent rule effectiveness adjustment, as shown in Exhibit 3. 4

.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 55



### Exhibit 3. 4 NonEGU Point Source Emission Reductions from

New Je rsey ICI Boiler NO

x 

### Rules

Heat Input Rate

(mmBtu/hr) Fuel/Boiler Type Overall %

Reduction

2007

- 20 25

at least 5 but < 10 All 20%

at least 10 but < 20 All 20%

at least 25 but < 50 Natural gas only 40%

No. 2 Fuel oil only 40%

Refinery fuel gas and

other gaseous fuels 40%

Other liquid fuels 40%

Duel Fuel using fuel oil

and/or natural gas 40%

at least 50 but < 100 Natural gas only 40%

No. 2 Fuel oil only 27%

Other liquid fuels 27%

Duel Fuel using fuel oil

and/or natural gas 40%

at least 100 or greater No. 2 Fuel oil only 40%



### The NIF file submitted by New Jersey for this project did not include the boiler design

capacity. This data gap was filled using the boiler design capacities previously developed

for the OTC study in 2006, if available; otherwise the SCC description was used to assign

a default boiler design capacity.

New York specified that a 50 percent reduction should be applied in the existing controls

inventory for all boilers with greater than 25 mmBtu/hour design capacit y. The NIF file

submitted by New York for this project did not include the boiler design capacity. This

data gap was filled using the boiler design capacities previously developed for the OTC

study in 2006, if available; otherwise the SCC description was used to assign a default

boiler design capacity.

3.3.3.4 

### MANE

- VU Fuel Oil Sulfur Strategy

MANE

- VU developed a low sulfur fuel oil strategy to help states develop Regional Haze

SIP s ( MANE

- VU 2007). The sulfur in fuel oil recommendations were previously shown

in S ection 2.3.2.5 and vary by state, fuel oil type, and implementation year.

3.3.3.5 

### S tate

- specific NonEGU Control Factors

The following state

- specific nonEGU control factors were provided:Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 56



### Bellefield Boiler Plant, Allegheny County

. Allegheny County indicated that this

facility changed their fuel source from coal to natural gas in July 2009 and future

year emissions were changed to reflect the fuel switch.

USS Clairton Works

, Allegheny County

. The facility will remove Batteries 7

- 9

and have Battery C operational by 2013, resulting in a change in PM emissions in

2013. Also, USS Clairton Works will remove Batteries 1

- 3 and have Battery D

operational in 2015, resulting in a change in PM emissions in 2017

, 2020 and 2025

.

Chrysler, D elaware

. The Chrysler facility (ID 1000300128) shut down in 2009.

Delaware specified that only a 25 percent reduction should be taken for all

pollutants as some emissions will be banked for future use by other sources.

OSG Ship Management (ID 1000500093 ), Delaware

. Delaware provided source

specific growth factors and percent reductions in VOC emissions for 2013, 2017,

and 2020 from the lightering operations at OSG Ship Management (ID

1000500093). The 2025 emissions were expected to be the same as the 2 020

emissions.

Control Technology Guidance (CTG) Documents, Delaware. Delaware

determined that VOC e mission reductions from new CTG recommendations would

be very small. Although the new CTGs set up new recommendations for higher

control efficiencies, th e actual VOC reductions would be minimum, if not none

,

because most DE’s existing facilities are not affected by the new requirements and

emissions from those facilities are relatively small (based on 2002 inventory ).

Unit Shutdowns, Delaware. Delaware i dentified several emission units that have

shut down at the following facilities: Dow Reichhold Specialty latex (ID

1000100016), SPI Poly

- Ols (ID 1000300426), and Invistas (ID 1000500002).

Emissions for all pollutants were set to zero for these units.

P remcor Refinery NO

x 

### Plantwide Cap, Delaware. The refinery was sold to the

Delaware City Refining Company and an agreement was reached with DNREC's

Secretary that allows plant

- wide applicability limit (cap) for NO

x 

### . Delaware

decided to devide the NO

x 

### - cap to each stack equally. Delaware estimated a

plantwide reduction of 10.05 percent in 2013 and 41.22 percent in 2017, 2020 and

2025.

PEPCO Benning Road , District of Columbia. This facility is scheduled for

deactivation in 2012. All emissions were set t o zero in the projection inventories.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 57



### 2009 New Jersey Rule for NO

x 

### for Municipal Solid Waste Incinerators. This

rule will achieve a 27 percent reduction from one facility

- Camden County Energy

Recovery Associates, L.P. (ID 3400751614).

New Jersey R ule for VOC Storage Tanks. New Jersey provided expected VOC

emission reductions resulting from post

- 2007 rules for VOC storage tanks. For

refinery floating roof storage tanks (SCC 4

- 03

- 011

- xx), the reductions are 75

percent for 2013, 82 percent for 2017, and 85 percent for 2020. For bulk terminal

tanks (SCC 4

- 04

- 001

- xx), the reductions are 20 percent for 2013, 40 percent for

2017, and 50 percent for 2020. For pipeline breakout stations (SCCs 4

- 04

- 002

- xx

and 4

- 06

- 005

- xx), the reductions are 26 percent for 20 13, 52 percent for 2017, and

65 percent for 2020 and 2025.

3.4 2025 EGU INVENTORY DEVELOPMENT

An emission projection methodology for EGUs is being developed as part of an inter

- RPO

coordination effort under the direction of ERTAC. The computer code to impl ement the

ERTAC methodology will not be available in time for use in state’s re

- designation requests

or maintenance plans. An interim approach for projecting EGU emissions is discussed in

the following paragraph.

Annual 2007 EGU point emissions were gro wn to 2025 based on electricity generation

projections that are delineated by region and fuel. Growth factors are based on AEO2011

Table 96

- Electricity Generation by Electricity Market Module Region and Fuel Source

(see Appendix F). The 2007 emissions were extracted for those units flagged as EGUs in

the MANE

- VU+VA 2007 inventory. The appropriate AEO2011 growth factor was

applied to the 2007 emissions to calculate a “growth only” emission value for 2025. The

following key assumptions were made:

Growth beyond unit capacity or permit limits w as not considered (e.g., fuel

consumption was allowed to grow beyond a unit’s physical capacity or permit

limit) ;

Generation from specific new units that are anticipated to operate in 2025 but did

not in 2007 is no t explicitly accounted for, but instead is assumed to be accounted

for in the AEO2011 growth forecasts ;

Similarly, generation from specific units that have or are anticipated to shut down

after 2007 is not explicitly accounted for, but instead are assum ed to be accounted

for in the AEO2011 growth forecasts.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 58



### States indicate d where post

- 2007 controls or shut downs were to be applied on a

unit by unit basis. T he control factor s were applied to the grown emissions to

calculate a “growth and control” emission value for 2025.

Details on the growth and control factors are provided in the following sections.

3.4.1 EGU Growth Factors

Table 96 of the AEO2011 provides electricity generation projections by e lectricity m arket

m odule r egion and fuel s ource for the years 2007 to 2035 (EIA 2011 b ). AEO2011

disaggregat es generation to 22 sub

- regions for electricity planning and dispatch This is a

new approach started in AEO2011. Disaggregation of the Electrici ty Market Module

(EMM) is intended to reduce errors that result from aggregation and averaging, to better

represent environmental and regional issues, and thus to improve the projections of

capacity additions and fuels consumed for generation. Exhibit 4.1 identifies the 22 sub

regions.

Exhibit 3.5 Electricity Market Module RegionsDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 59



### The EIA provided a file that assigns each EGU to an EMM region. Units in the PM

nonattainment counties included in this analysis reside in one of the following seven EMM

reg ions:

Northeast Power Coordinating Council / Northeast (NEWE)

Northeast Power Coordinating Council / NYC Westchester (NYCW)

Northeast Power Coordinating Council / Long Island (NYLI)

Northeast Power Coordinating Council / Upstate New York (NYUP)

Reliability First Corporation / East (RFCE)

Reliability First Corporation / West (RFCW)

SERC Reliability Corporation / Virginia Carolina (SRVC)

Exhibit 3.6 shows the growth factors for electricity generation for coal. The AEO2011

shows zero generation fr om coal in the NYC Westchester and Long Island regions.

Generation from coal is project ed to decline significantly in the Northeast and Upstate

New York regions. Generation from coal is expected to decline slightly in the RFC East,

RFC West, and SERC Vir ginia

- Carolina regions.

Exhibit 3.7 shows the growth factors for electricity generation for petroleum. The

AEO2011 shows that the growth factors vary widely by EMM region. A positive growth

rate (e.g., growth factor > 1) from 2007 to 2025 is projected for the RFC East and SERC

Virginia

- Carolina regions. In all other EMM regions in the study area, generation from

petroleum is projected to decline (e.g., growth factor < 1).

Exhibit 3.8 shows the growth factors for electricity generation for natural gas

. The

AEO2011 shows that the growth factors vary widely by EMM region. A negative growth

rate (e.g., growth factor < 1) from 2007 to 2025 is projected for the NYC Westchester and

SERC Virginia

- Carolina regions. In all other EMM regions in the study area, generation

from natural gas is projected to increase (e.g., growth factor > 1).

Exhibit 3.9 shows the growth factors for electricity generation for renewables. The

AEO2011 shows that the growth factors vary widely by EMM region. A large increase in

gene ration from renewables from 2007 to 2025 is projected for the RFC East, RFC West

and SERC Virginia

- Carolina regions. A more modest increase in renewable is projected

for the Northeast and Upstate New York regions. A slight decline is projected for the

NY C Westchester and Long Island regions.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 60



### Exhibit 3.6 Electricity Generation Growth Factors for Coal

Exhibit 3.7 Electricity Generation Growth Factors for PetroleumDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 61



### Exhibit 3.8 Electricity Generation Growth Factors for Natural Gas

Exhibit 3.9 Electricity Generation Growth Factors for RenewablesDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 62



### After reviewing the AEO growth factors, New York had doubts about the AEO

projections. To be conservative, New York specified that a growth factor of 1.0 should be

used for any unit where AEO growth was projected to be negative.

3.4.2 EGU Control Factors

Stat es provided information on post

- 2007 controls or shut downs to be applied on a unit by

unit basis for the 2025 inventory. This control information was provided in a format that is

being used by the ERTAC EGU Projection Methodology ( Appendix G UAF NEEDS

Co ntrol FileMASTER92211.xls ).

In addition to the ERTAC control file, the following comments were received:

Delaware

– The Edge Moor facility (ORIS=593) plans to switch from coal to

natural gas/# 6 oil. However, the Title V permit is not yet approved. Del aware

made the decision to assume the facility still is burning coal in 2025 for the

purposes of this PM re

- design ation inventory. Delaware may change the EGU

estimates at a future date when the SIP submittal is written.

District of Columbia

– The PEPCO B enning Road facility (ORIS=603) is

scheduled to shut down permanently in 2012 and all future year emissions have

been set to zero.

Maryland

– The Healthy Air Act sets unit

- specific emission caps (tons/year) for

SO 2 

### and NO

x 

### . Maryland provided unit specific control factors to ensure that the

future year emissions were equal to the Healthy Air Act emission caps. Affected

facilities include CP Crane, Herbert A Wagner, R. Paul Smith, Chalk Point,

Dickerson, Morgantown, and Brandon Shores.

New Jersey

– Contro l factors for SO 2 

### and NO

x 

### for each unit were calculated based

on the ratio of the future controlled emission rate (lbs/mmBtu) to the 2007 actual

emission rate (lbs/mmBtu). Large reductions in SO 2 

### emissions are expected from

the installation of control equ ipment at the Hudson and Mercer generating stations.

NO

x 

### controls were also installed at the Hudson generating station in 2010.

Pennsylvania

– RRI’s Portland Generating Station is under a USEPA Order to

reduce SO 2 

### emissions. SO 2 

### emissions beyond 013 wer e reduced by 95 percent to

address the ordered emission reductions. SO 2 

### controls were installed at RRI

Keystone, PPL Brunner Island, and Allegheny Energy Hatfields Ferry in 2010.

SO 2 

### controls at the Cheswick Station were installed in 2011. Units 1 and 2 at PPL

Martins Creek, Units 1 and 2 at Exelon Cromby, and Units 1 and 2 at ExelonDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 63



### Eddystone are or will be permanently shut down by 2013 and the emissions for all

pollutants were set to zero for 2017/2020/2025. The future operation of Unit 1 at

Exelon Schuy l kill are projected to be about 250 hours, compared to 1,037 hours in

2007. Future emissions for this unit were reduced by 75 percent to reflect this

lowered operating capacity.

Virginia

– Dry scrubbers at the Potomac River Generating Station were in stalled in

2008. In 2008, the facility received a federally enforceable facility

- wide permit

that placed limits on the facility’s annual potential to emit of both NO X 

### and SO 2



### .

3.4.3 Consideration of CSAPR Emission Allowances

On July 6, 2011, the USEPS finalized the Cross

- State Air Pollution Rule (CSAPR) that

requires 27 states to reduce power plant emissions that contribute to ozone and/or fine

particle pollution in other states. This final rule replaces the 2005 Clean Air Interstate

Rule (CAIR). Under the fin al rule, USEPA distributes a annual SO2 and NOx emission

allowances to covered units in each state, the sum of which equals the annual SO2 and

NOx budgets for those states (allowing for a two percent set

- aside for new units).

USEPA provided allocations f or each affected unit. States initially considered w hether

these unit

- level allocations for SO2 and NOx provided a more realistic estimate of future

year emissions than the growth and control methodology described in Sections 4.3.1 and

4.3.2 of this repor t. However, the United States Court of Appeals for the District of

Columbia issued an order staying CSAPR on December 31, 2011, pending the resolution

of an appeal of the rule. Because of the uncertainty regarding implementation of CSAPR,

states decided to use the growth and control methodology described in Sections 4.3.1 and

4.3.2 rather than the proposed CSAPR caps for SO2 and NOx.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

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## 4.0 NONROAD MOBILE SOURCES INCLUDED IN NMIM

4.1 NONROAD MODEL CATEGORIES

USEPA’s NONROAD model estimates emissions from equipmen t such as recreational

marine vessels, recreational land

- based vehicles, farm and construction machinery, lawn

and garden equipment , a ircraft ground support equipment (GSE) and rail maintenance

equipment. This equipment is powered by diesel, gasoline, com pressed natural gas (CNG)

or liquefied petroleum gas (LPG) engines.

NMIM was developed by USEPA to develop county

- level emission estimates for certain

types of nonroad equipment. NMIM uses the current version the NONROAD model to

develop emission estimates and was used to develop the projection inventories discussed

here. The NMIM national county database contains monthly input data to reflect county

specific fuel parameters and temperatures. Most of the work associated with executing

NMIM involved updating the NMIM county database with state

- specific information.

4.2 2007 INVENTORY DEVELOPMENT

MARAMA used the NMIM model to develop county level emission estimates by SCC for

2007 (see {MARAMA 2011a} for complete documentatio n )

. For this analysis, the

NMIM2008 software (version NMIM20090504), the NMIM County Database (version

NCD20090531), and N ONROAD2008a (July 2009 version) were used as starting point s

(USEPA 2009 a ). Changes were made to the NCD20090531 based on state revi ew and

comment

.

A summary of t he major adjustments to the default NMIM County Database for the 2007

NMIM model runs include s :

State review and adjustments to fuel characteristics (Reid Vapor Pressure, sulfur

and oxygenate fractions ) to better represent county

- specific fuel characteristics in

2007; and

States identified discrepancies in the housing and population data contained in the

NONROAD model and these data were updated using 2007 housing information

and updated 2007 population estimates.

Two states

– New York and Virginia

– provided their independent NONROAD modeling

results which were used instead of the MARAMA modeling results.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

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Page 65



### 4.3 2025 INVENTORY DEVELOPMENT

MARAMA ran the NMIM model for 2025 for six jurisdictions (CT, DE, D C, MD, PA).

Two states, New York and Virginia, did their own NONROAD modeling and provided

2025 NMIM results for the affected counties

.

4.4 REMOVAL OF AIRPORT GROUND SUPPORT EQUIPMENT

The NMIM/NONROAD model includes emissions from a irport ground s upport

e quipm ent . Emissions from airport ground support equipment is also included in

USEPA’s aircraft inventory that was prepared using the Federal Aviation Administration’s

Emissions and Dispersion Modeling System (EDMS). Correspondence with USEPA

indicated that US EPA considers the emissions calculated by EDMS to be better than those

calculated by NONROAD. For this reason, all emissions calculated by NMIM/

NONROAD for airport ground support equipment were removed from both the 2007 and

2025 inventories to avoid dou ble counting emissions.

4.5 NMIM/NONROAD GROWTH AND CONTROL INFORMATION

In estimating future year emissions, t he NMIM/ NONROAD model includes growth and

scrappage rates for equipment in addition to a variety of control programs. It is not

possible to separate out the future year emissions due to “growth only” or “control only” in

a single run. That is, the model run provides a single future year estimate that is a “growth

and control” scenario.

The growth data used in the NMIM/NONROAD model is documented in a USEPA report

(USEPA 2004c). The GROWTH packet of the NONROAD model cross

- references each

SCC to a growth indicator code. The indicator code is an arbitrary code that identifies an

actual predicted value such as human population or employment that is use d to estimate

the future year equipment population. The GROWTH packet also defines the scrappage

curves used to estimate the future year model year distribution.

The NMIM/NONROAD model also accounts for all USEPA emission standards for

nonroad equipment. There are multiple standards that vary by equipment type, rated

power, model year, and pollutant . Exhibit 4 .1 is a summary of the emission control

programs accounted for in the NMIM/NONROAD model. A complete summary of the

nonroad equipment emission sta ndards can be found on USEPA ’s nonroad emission

standards reference guide website (USEPA 2011).Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

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Page 66



### Exhibit 4 .1 Control Programs Included in the NMIM/NONROAD Model

Regulation Description

Control of Air Pollution;

Determination of Significance for

Nonroad Sources and Emission

Standards for New Nonroad

Compression Ignition Engines At or

Above 37 Kilowatts

59 FR 31036

June 17, 1994 This rule establishes Tier 1 exhaust emission standards for

HC, NO

x , CO, and PM for nonroad compression

- ignition

(CI) engines ≥3 7kW (≥50hp). Marine engines are not

included in this rule. The start dates and pollutants

aff ected vary by hp category as follows:

50

- 100 hp: Tier 1,1998; NO

x only

100

- 175 hp: Tier 1, 1997; NO

x only

175

- 750 hp: Tier 1, 1996; HC, CO, NO

x , PM

>750 hp: Tier 1, 2000; HC, CO, NO

x , PM

Emissions for New Nonroad Spark

Ignition Engines At or Below 19

Kilowatts; Final Rule

60 FR 34581

July 3, 1995 This rule establishes Phase 1 exhaust emission standards

for HC, N NO

x Ox, and CO for nonroad spark

- ignition

engines ≤19kW (≤25hp). This rule includes both handheld

(HH) and non

- hand

- held (NHH) engines. The Phase 1

standards become effective in 1997 for :

Class I NHH engines (<225cc),

Class II NHH engines (≥225cc),

Class III HH engines (<20cc), and

Class IV HH engines (≥20cc and <50cc).

The Phase 1 standards become effective in 1998 for:

Class V HH engines (≥50cc)

Final Rule for New Gasoline Spark

Ignition Marine Engines; Exemptions

for New Nonroad Compression

Ignition Engines at or Above 37

Kilowatts and New Nonroad Spark

Ignition Engines at or Below 19

Kilowatts

61 FR 52088

October 4, 1996 This rule establishes exhaust emission standards for HC+

NO

x for personal watercraft and outboard (PWC/OB)

marine S I engines. The standards are phased in from

1998

- 2006.

Control of Emissions of Air Pollution

From Nonroad Diesel Engines

63 FR 56967

October 23, 1998 This final rule sets Tier 1 standards for engines under 50

hp, phasing in from 1999 to 2000. It also pha ses in more

stringent Tier 2 standards for all en gine sizes from 2001 to

2006, and yet more stringent Tier 3 standards for engines

rated over 50 hp from 2006 to 2008. The Tier 2 standards

apply to NMHC+ NO

x , CO, and PM, whereas the Tier 3

standards apply to NMHC+ NO

x and CO. The start dates

by hp categ ory and tier are as follows:

hp<25: Tier 1,2000; Tier 2, 2005; no Tier 3

25

- 50 hp: Tier 1, 1999; Tier 2, 2004; no Tier 3

50

- 100 hp: Tier 2, 2004; Tier 3, 2008

100

- 175 hp: Tier 2, 2003; Tier 3, 2007

175

- 300 hp: Tier 2, 2003; Tier 3, 2006

300

- 600 hp: Tier 2, 2001, Tier 3, 2006

600

- 750 hp: Tier 2, 2002; Tier 3, 2006

>750 hp: Tier 2, 2006, no Tier 3

This rule does not apply to marine diesel engines above 50

hp.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 67

Regulation Description

Phase 2: Emission Standards for

New Nonroad Nonhandheld Spark

Ignition Engi

nes At or Below 19

Kilowatts

64 FR 15207

March 30, 1999 This rule establishes Phase 2 exhaust emission standards

for HC+ NO

x for nonroad nonhandheld (NHH) spark

ignition engines ≤19kW (≤25hp). The Phase 2 standards

for Class I NHH engines (<225cc) become effective on

August 1, 2007 (or August 1, 2003 for any engine initially

produced on or after that date). The Phase 2 standards for

Class II NHH engines (≥2 25cc) are phased in from 2001

-

2005.

Phase 2: Emission Standards for

New Nonroad Spark

- Ignition

Hand held Engines At or Below 19

Kilowatts and Minor Amendments to

Emission Requirements Applicable

to Small Spark

- Ignition Engines and

Marine Spark

- Ignition Engines; Final

Rule

65 FR 24268

April 25, 2000 This rule establishes Phase 2 exhaust emission standards

for HC+ NO

x for nonroad handheld (HH) spark

- ignition

engines ≤19kW (≤25hp). The Phase 2 standards are

phased in from 2002

- 2005 for Class III and Class IV

engines and are phased in from 2004

- 2007 for Class V

engines.

Control of Emissions From Nonroad

Lar ge Spark

- Ignition Engines and

Recreational Engines (Marine and

Land

- Based); Final Rule

67 FR 68241

November 8, 2002 This rule establishes exhaust and evaporative standards

for several nonroad categorie s:

1) Two tiers of emission standards are established for large

s park

- ignition engines over 19 kW. Tier 1 includes exhaust

standards for HC+ NO

x and CO and is phased in from

2004

- 2006. Tier 2 becomes effective in 2007 and includes

exhaust standards for HC+ NO

x and CO

, as along with

evaporative controls aff ecting fuel line permeation, diurnal

emissions and running loss emissions.

2) Exhaust and evaporative emission standards are

established for recreational vehicles, which include

snowmobiles, off

- highway motorcycles, and all

- terrain

vehicles (ATVs). For s nowmobiles , HC and CO exhaust

standards are phased

- in from 2006

- 2012. For off

- highway

motorcycles, HC+ NO

x and CO exhaust emission

standards are phased in from 2006

- 2007. For ATVs,

HC+ NO

x and CO exhaust emission standards are phased

in from 2006

- 2007. Evaporative emission standards for

fuel tank and hose permeation apply to all recreational

vehicles beginning in 2008.

3) Exhaust emission standards for HC+ NO

x , CO, and PM

for recreational marine diesel engine s over 50 hp begin in

2006

- 2009, depending on t he engine displacement. These

are “Tier 2” equivalent standards.

Control of Emissions of Air Pollution

From Nonroad Diesel Engines and

Fuel; Final Rule (Clean Air Nonroad

Diesel Rule

– Ti er 4)

69 FR 38958

June 29, 2004 This final rule sets Tier 4 exhaust standards for CI engines

covering all hp categories (except marine and

locomotives), and also regulates nonroad diesel fuel sulfur

content.

1) The Tier 4 start dates and pollutants affect ed vary by hp

and tier as follows:

hp<25: 2008, PM only

25

- 50 h p: Tier 4 transitional, 2008, PM only;

Tier 4 final, 2013, NMHC+ NO

x and PMDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 68

Regulation Description

50

- 75 hp: Tier 4 transitional, 2008; PM only;

Tier 4 final, 2013, NMHC + NO

x and PM

75

- 175 hp: Tier 4 transitional, 2012, HC, NO

x , and PM;

Tier 4 final, 2014, HC, NO

x ,PM

175

- 750 hp:Tier 4 transitional, 2011, HC, NO

x , and PM;

Tier 4 final, 2014, HC, NO

x ,PM

>750 hp: Tier 4 trans itional, 2011, HC, NO

x , and PM;

Tier 4 final, 2015, HC, NO

x ,PM

2) This rule will reduce nonroad diesel fuel sulfur levels in

two steps. First, starting in 2007, fuel sulfur levels in

nonroad diesel fuel will be limited to a maximum of 500

ppm, the same as for curren t highway diesel fuel. Second,

starting in 2010, fuel sulfur levels in most nonroad diesel

fuel will be reduced to 15 ppm.

Control of Emissions From Nonroad

Spark

- Ignition Engines and

Equipment; Final Rule (Bond Rule)

73 FR 59034

October 8, 2008 This rule establishes exhaust and evaporative standards

for small SI engines and marine SI engines:

1) Phase 3 HC+ NO

x exhaust emission standards are

established for Class I NHH engines starting in 2012 and

for Class II NHH engines starting in 2011. There are no

new exhaus t emission standards for handheld engines.

New evaporative standards are adopted for both handheld

and nonhandheld equipment. The new evaporative

standards control fuel tank permeation, fuel hose

permeation, and diffusion losses. The evaporative

standar ds begin in 2012 for Class I NHH engines and 2011

for Class II NHH engines. For handheld engines, the

evaporative standards are phased

- in from 2012

- 2016.

2) More stringent HC+ NO

x and CO standards are

established for marine SI PWC/OB engines beginning in

2010. In addition, new exhaust HC+ NO

x and CO

standards are established for sterndrive and inboard (SD/I)

marine SI engines also beginning in 2010. High

performance SD/I engines are subject to separate HC+

NO

x a nd CO exhaust standards that are phased

- in from

2010

- 2011. New evaporative standards were also adopted

for all marine SI engines that control fuel hose permeation,

diurnal emissions, and fuel tank permeation emissions.

The hose permeation, diurnal, and t ank permeation

standards take eff ect in 2009, 2010, and 2011,

respectively.

Source: USEPA 2010 cDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

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Page 69



## 5.0 MARINE VESSELS, AIRPORTS, AND RAILROADS

5.1 MAR INVENTORY CATEGORIES

This category of sources is collectively referred to as the MAR (marine, airports, railroads)

sector. It include s nonroad engines associated with the following activities:

Marine Vessels

- The Commercial Marine Vehicle (CMV) sector includes all boats

and ships used either directly or indirectly in the conduct of commerce or military

act ivity. The majority of these vessels are powered by diesel engines that are either

fueled with distillate or residual fuel oil blends. For the purpose of this inventory it

is assumed that Category 3 vessels primarily use residual blends

, while Category 1

and 2 vessels typically used distillate fuels.

Airports

- The aircraft sector includes all aircraft types used for public, private,

and military purposes. This includes four types of aircraft 1) Commercial; 2) Air

Taxis; 3) General Aviation; and 4) Milit ary. Ground support equipment (GSE) and

auxiliary power units (APU) are also included.

Railroads

- The railroad sector includes railroad locomotives powered by diesel

electric engines. Locomotives are divided into Class I line haul, Class II/III line

h aul, commuter/passenger and Class I yard.

5.2 2007 INVENTORY DEVELOPMENT

The emission projections for the 2025 point source were based on Version 3_3 of the 2007

MANE

- VU+VA inventory and are fully documented in the TSD for that effort

(MARAMA 2012a). The re w ere no adjustment to the 2007 Version 3_3 MAR inventory

for this analysis.

5.3 2025 INVENTORY DEVELOPMENT

Appendix H contains the data that were used to develop growth and control factors for the

commercial marine vessel, airport, and railroad sectors.

5.3.1 C omm ercial Marine Vessels

For the purpose of emission calculations , marine vessel engines are divided into three

categories based on displacement (swept volume) per cylinder. Category 1 and Category 2

marine diesel engines typically range in size from about 500 to 8,000 kW (700 to 11,000

hp). These engines are used to provide propulsi on power on many kinds of vessels

including tugboats, pushboats, supply vessels, fishing vessels, and other commercialDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 70



### vessels in and around ports. They are also used as stand

- alone generators for auxiliary

electrical power on vessels. Category 3 marine diesel engines typically range in size from

2,500 to 70,000 kW (3,000 to 100,000 hp). These are very large marine diesel engines used

for propulsion power on ocean

- going vessels such as container ships, oil tankers, bulk

carriers, and cruise ships.

The maj ority of marine vessels are powered by diesel engines that are either fueled with

distillate or residual fuel oil blends. For the purpose of emission inventories, USEPA has

assumed that Category 3 vessels primarily use residual blends

, while Category 1 and 2

vessels typically use distillate fuels.

USEPA developed national emission inventories for Category 1 and 2 vessels and

Category 3 vessels for calendar years 2002 through 2040 as part of its effort to develop

emission standards for these vessels. The methodologies used to develop the emission

projections (for both a baseline and controlled scenario) are documented in three regulatory

impact assessments (USEPA 2008 b , USEPA 2009c, USEPA 2009d). T he USEPA data

and methodologies from these RIAs were used to develop separate growth and control

factors for Category 1 and 2 vessels (diesel) and Category 3 vessels (residual).

5.3.1.1 

### CMV Diesel Growth Factors

For Category 1 and 2 diesel vessels, USEPA used projection data for domestic shipping

from the AEO2006 (EIA 2006). The annual growth rate reported in the RIA is 0.9%.

More recent growth data for domestic shipping is available in the AEO2010 (EIA 2010).

Because Category 1 and 2 vessels primarily account for activity data for ships that carry

domestic cargo, we decided to use the recent growth data for domestic shipping available

in the AEO2010. We used Table A

- 7 of the AEO2010 for domestic shipping to calculate

the growth factor for 2007

- 20 25 to be 1.064 . Th is growth factor w as used for CMV diesel

port emissi ons (SCC 22

- 80

- 002

- 100) and CMV diesel underway emissions (SCC 22

- 80

-

002

- 200).

5.3.1.2 

### CMV Diesel Control Factors

In developing their emission projections, USEPA developed two scenarios that accounted

for both the 2004 nonroad diesel rule and the 2008 diesel mar ine vessel rule:

USEPA’s baseline (pre

- control) inventory accounted for:

1. the 0.9 percent annual growth in fuel use based on AEO2006

,

2. the impact of existing engine regulations that took effect in 2008,

3. the 2004 Clean Air Nonroad Diesel Rule that will decrease the allowable

levels of sulfur in fuel beginning in 2012, and

4. fleet turnover.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 71



### USEPA’s controlled inventory accounted for:

1. the 0.9 percent annual growth in fuel use based on AEO2006 ;

2. the reductions included in the baseline inventory, and the red uctions from

USEPA’s 2008 rule Final Locomotive

- Marine rule for Tier 3 and 4 engines;

3. The 2008 final rule that includes the first

- ever national emission standards

for existing marine diesel engines, applying to engines larger than 600kW

when they are rem anufactured. The rule also sets Tier 3 emissions

standards for newly

- built engines that are phasing in from 2009. Finally,

the rule establishes Tier 4 standards for newly

- built commercial marine

diesel engines above 600kW, phasing in beginning in 2014.

To calculate a control factor that accounts for reductions included in the USEPA controlled

inventory, it was necessary to first calculate a “growth only” scenario applying USEPA’s

0.9 percent annual growth rate to the 200 7 base emissions. Once the growt h rate was

applied, then a control factor for each pollutant was calculated by dividing the future year

controlled emissions by the future year “growth only” emissions. Exhibit 5 .1 shows the

control factors for 2013, 2017, 2020

, and 2025 for diesel commer cial marine vessels.

Exhibit 5 .1 CMV Diesel Control Factors by Year and Pollutant

Year NOx PM2.5 SO2

2013 0.787 0.747 0.464

2017 0.642 0.550 0.076

2020 0.537 0.460 0.032

2025 0.401 0.353 0.031



### 5.3.1.3 

### CMV Residual Oil Growth Factors

For Category 3 residual oil vessels, data from a USEPA

- sponsored study was used to

develop an annualized growth factor of 4.5 percent for the region. A few states considered

the growth rate to be extremely high and not reflective of recent economic condit ions.

Because USEPA’s Category 3 vessel inventory is primarily based on activity data for ships

that carry foreign cargo, we decided to use the recent growth data for international

shipping available in the AEO2010. We used data from Table A

- 7 of the AEO 2010 for

international shipping to calculate the growth factor for 2007

- 2025 to be 0.956 . These

growth factors were used for CMV residual oil port emissions (SCC 22

- 80

- 003

- 100) and

CMV residual oil underway emissions (SCC 22

- 80

- 003

- 200).Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 72



### 5.3.1.4 

### CMV Residual Oil Control Factors

On December 22, 2009, USEPA announced final emission standards under the Clean Air

Act for new marine diesel engines with per

- cylinder displacement at or above 30 liters

(called Category 3 marine diesel engines) installed on U.S.

- flagged ve ssels. The final

engine standards are equivalent to those adopted in the amendments to Annex VI to the

International Convention for the Prevention of Pollution from Ships (a treaty called

"MARPOL"). The emission standards apply in two stages: near

- term standards for newly

built engines will apply beginning in 2011, and long

- term standards requiring an 80

percent reduction in NO

x 

### will begin in 2016. USEPA also adopted changes to the diesel

fuel program to allow for the production and sale of diesel fuel with no more than 1,000

ppm sulfur for use in Category 3 marine vessels. The regulations generally forbid

production and sale of fuels with more than 1,000 ppm sulfur for use in most U.S. waters,

unless operators achieve equivalent emission reductions in other ways.

On March 26, 2010, the International Maritime Organization (IMO) officially designated

waters off North American coasts as an emissions control area (ECA) in which stringent

international emission standards will apply to ships. In practice, i mplementation of the

ECA means that ships entering the designated area would need to use compliant fuel for

the duration of their voyage that is within that area, including time in port and voyages

whose routes pass through the area without calling on a po rt. The North American ECA

includes waters adjacent the Atlantic extending up to 200 nautical miles from east coast of

the US

. The quality of fuel that complies with the ECA standard will change over time.

From the effective date in 2012 until 2015, fuel used by vessels operating in designated

areas cannot exceed 1.0 percent sulfur (10,000 ppm). Beginning in 2015, fuel used by

v essels operating in these areas cannot exceed 0.1 percent sulfur (1000 ppm). Beginning

in 2016, NO

x 

### after treatment requirements become applicable.

To calculate a control factor that accounted for reductions included in the USEPA

controlled inventory, it was necessary to first calculate a “growth only” scenario applying

USEPA’s 4.5 percent annual growth rate to the 200 7 base emissions. Once the growth rate

was applied, then a control factor for each pollutant was calculated by dividing the future

year con trolled emissions by the future year “growth only” emissions.

Exhibit 5 .2 shows the control factors for 2013, 2017, and 2020 for residual oil commercial

marine vessels.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

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Page 73



### Exhibit 5 .2 CMV Residual Oil Control Factors by Year and Pollutant

Year NOx PM2.5 SO2

2013 0.736 0.353 0.270

2017 0.654 0.216 0.120

2020 0.597 0.137 0.036

2025 0.480 0.137 0.036



### 5.3.1.5 

### Military Vessels Growth and C ontrol Factors

Virginia reported emissions for military vessels, but did not distinguish between diesel or

residual fuels. An assumption of “no growth” for military vessel activity and emissions in

Virginia was made so that emissions remain at 2007 levels in 2025 . Virg inia was the only

state to report emission from military vessels.

5.3.1.6 

### State

- specific CMV Updates for 2025

New Jersey provided updated CMV emission estimates for 2007, 2013, 2017, 2020, and

2025 , and growth and control factors for 2013, 2017, 2020, and 2025 . These data were

used to replace the emission estimates previously used for the 2007 MANE

- VU+VA base

year inventory and the MANE

- VU+VA future year inventories.

5.3.2 A irports

Aircraft emissions in the 2007 MANE

- VU+VA inventory are available on either a county

by

- county or airport

- by

- airport basis for six types of aircraft operations:

Air carrier operations represent landings and take

- offs (LTOs) of commercial

aircraft with seating capacity of more than 60 seats;

Commuter/air taxi operations are one category. C ommuter operations include

LTOs by aircraft with 60 or fewer seats that transport regional passengers on

scheduled commercial flights. Air taxi operations include LTOs by aircraft with 60

or fewer seats conducted on non

- scheduled or for

- hire flights;

Gene ral aviation represents all civil aviation LTOs not classified as commercial;

Military operations represent LTOs by military aircraft;

Ground Support Equipment (GSE) typically includes aircraft refueling and baggage

handling vehicles and equipment, aircra ft towing vehicles, and passenger buses ;

Auxiliary power units (APUs) provide power to start the main engines and run the

heating, cooling, and ventilation systems prior to starting the main engines.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 74



### 5.3.2.1 

### Air port Growth Factors

Aircraft operations were projec ted to future years by applying activity growth using data

on itinerant (ITN) operations at airports as reported in the Federal Aviation

Administration’s (FAA) Terminal Area Forecast (TAF) System for 2009

- 2030 (FAA

2010). The ITN operations are defined as aircraft take

- offs or landings. This information is

available for approximately 3300 individual airports. Actual LTOs are reported for 2007

and projected LTOs are provided for all years up to 2030.

The data was aggregated and applied at the county level for the four operation types:

commercial, general, air taxi, military. A growth factor was computed for each operation

type by dividing future

- year ITN by 2007

- year ITN. Inventory SCCs were assigned

factors based on the operation type, as shown in Exhi bit 5 .3.

Exhibit 5 .3 Crosswalk between SCC and FAA Operations Type

SCC SCC Description FAA Operation Type Used for

Growth Factor

2265008005 Airport Ground Support Equipment, 4

- Stroke Gas Total Itinerant Operations

2267008005 Airport Ground Support Equipment, LPG Total Itinerant Operations

2268008005 Airport Ground Support Equipment, CNG Total Itinerant Operations

2270008000 Airport Ground Support Equipment, Diesel Total Itinerant Operations

2270008005 Airport Ground Support Equipment, Diesel Tota l Itinerant Operations

2275001000 Aircraft /Military Aircraft /Total Itinerant Military Operations

2275020000 Aircraft /Commercial Aircraft /Total: All Types Itinerant Air Carrier Operations

2275050000 Aircraft /General Aviation /Total Itinerant General Aviation Operations

2275050011 Aircraft /General Aviation /Piston Itinerant General Aviation Operations

2275050012 Aircraft /General Aviation /Turbine Itinerant General Aviation Operations

2275060000 Aircraft /Air Taxi /Total Itinerant Air Taxi Operations

2275060011 Aircraft /Air Taxi /Piston Itinerant Air Taxi Operations

2275060012 Aircraft /Air Taxi /Turbine Itinerant Air Taxi Operations

2275070000 Aircraft /Aircraft Auxiliary Power Units /Total Total Itinerant Operations



### Exhibit 5 .4 summarizes the region

- wide growth factors by FAA operation type. The

growth factor for individual airports/counties may deviate substantially from these region

wide growth factors.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 75



### Exhibit 5 .4 Region

- wide Growth Factors from 2007 by FAA Operations Type

5.3.2.2 

### Aircraft Control Factors

The NO

x 

### aircraft engine emissions standards adopted by USEPA in November 2005

(USEPA 2005) were reviewed. The standards are equivalent to the NO

x 

### emission

standards (adopted in 1999 for implementation beginning in 2004) of the United Nations

International Civil Aviation Organization (ICAO), and will bring the US aircraft standards

into alignment with the international standards. The standards appl y to new aircraft

engines used on commercial aircraft including small regional jets, single

- aisle and twin

aisle aircraft, and 747s and larger aircraft. The standards also apply to general aviation and

military aircraft, which sometimes use commercial engi nes. For example, small regional jet

engines are used in executive general aviation aircraft, and larger commercial aircraft

engines may be used in military transport aircraft.

N early all previously certified or in

- production engine models currently meet or perform

better than the standards USEPA adopt ed in th e November 2005 rule. In addition,

manufacturers have already been developing improved technology in response to the

ICAO standards. According to USEPA’s recent analysis for the proposed transport rule

(USEPA 2010 b ), this rule is expected to reduce NO

x 

### emissions by approximately 2 percent

in 2015 and 3 percent in 2020. Because of the relatively small amount of NO

x 

### reductions,

our aircraft emission projections do not account for this control program

.

USEPA has also issued an Advance Notice of Proposed Rulemaking (ANPR) on lead

emissions from piston

- engine aircraft using leaded aviation gasoline (U S EPA 2010 c )

. However, this rule has not yet been adopted and co

- benefits for criteria air pollutants are

likely to be small. Therefore, the effects of this rule were not included in the future

- year

emissions projections.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 76



### 5.3.2.3 

### State

- specific Airport Updates for 2025

After reviewing the growth factors described in the previous section, Connecticut provided

state

- s pecific growth factors for 2025 by SCC and county. These state

- specific factors

were used instead of the factors described in the previous section.

New Jersey provided updated aircraft growth factors and emission estimates for 2007,

2013, 2017, 2020, and 2025. These data were used to replace the emission estimates

previously used for the 2007 MANE

- VU+VA base year inventory and the MANE

VU+VA future year inventories.

5.3.3 R ailroad Locomotives

Railroad locomotive engine emissions in the 2007 MARAMA inventory are classified into

the following categories:

Class I line haul locomotives are operated by large freight railroad companies and

are used to power freight train operations over long distances (SCC 22

- 85

- 002

-

006);

Class II/III line haul locomotives are operated by smaller freight railroad

companies and are used to power freight train operations over long distances (SCC

22

- 85

- 002

- 007);

Inter

- city passenger train locomotives are operated primarily by Amtrak to provide

inter

- city p assenger transport (SCC 22

- 85

- 002

- 008) ;

Independent commuter rail systems operate locomotives that provide passenger

transport within a metropolitan area (SCC 22

- 85

- 002

- 009) ; and

Yard/switch locomotives are used in freight yards to assemble and disassemble

trains, or for short hauls of trains that are made up of only a few cars ( SCC 22

- 85

-

002

- 010 ).

5.3.3.1 

### Railroad Growth Factors

In March 2008, USEPA finalized a three part program that will dramatically reduce

emissions from diesel locomotives of all typ es

-- line

- haul, switch, and passenger rail. As

part of this work USEPA developed a national emission inventory for calendar years 2002

through 2040. Emission projections methodologies for a baseline and controlled scenario

were developed and documented (USEPA 200 8b ). USEPA used projection data from the

AEO2006 (EIA 2 006). Table A

- 7 of AEO2006 showed that freight rail energy use will

grow 1.6 percent annually.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 77



### More recent growth data is available in the AEO2010 which was published in May 2010.

There a re separate projections for passenger rail and freight rail energy use. For the

MANE VU+VA inventory the more recent AEO2010 growth projections were used

.

Passenger rail data from AEO2010 Table A

- 7 was used to calculate the growth factor for

2007

- 202 5 to be 1.241 . These growth factors were applied to inter

- city passenger train

locomotives (SCC 22

- 85

- 002

- 008) and independent commuter rail systems (SCC 22

- 85

-

002

- 009).

For freight rail, the data from AEO2010 Table A

- 7 was used to calculate the growth facto r

for 2007

- 2025 to be 1.0 98

. T he freight rail annual growth factors for Class I line haul

(SCC 22

- 85

- 002

- 006), Class II/III line haul (SCC 22

- 85

- 002

- 007), and yard switch (SCC

22

- 85

- 002

- 010) locomotives were used.

5.3.3.2 

### Railroad Control Factors

USEPA developed two scenarios that accounted for both the 2004 nonroad diesel rule and

the 2008 diesel locomotive rule:

USEPA ’s baseline (pre

- control) inventory accounted for

1. AEO2006 annual growth in fuel use,

2. The impact of existing regulations for Tier 0, 1, and 2 l ocomotive engines

that take effect in 2008,

3. The 2004 Clean Air Nonroad Diesel Rule that will decrease allowable

levels of sulfur in locomotives fuel beginning in 2012, and

4. Fleet turnover.

USEPA ’s controlled inventory accounted for

1. AEO2006 annual growth in fuel use,

2. Reductions included in the baseline inventory, and

3. Reductions from USEPA’s 2008 rule Final Locomotive

- Marine rule for

Tier 3 and 4 engines. This rule lowered diesel sulfur content and tightened

emission standards for ex isting and new locomotives.

4. V oluntary retrofits under the National Clean Diesel Campaign are not

included in our projections.

To calculate a factor that accounted for reductions included in the USEPA controlled

inventory, it was necessary to first calc ulate a “growth only” scenario applying USEPA’s

1.6% annual growth rate to the 2006 base emissions. Once the growth rate was applied,

then a control factor for each pollutant was calculated by dividing the future year

controlled emissions by the future ye ar “growth only” emissions.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 78



### Exhibit 5 .5 shows the control factors for 2013, 2017, 2020 , and 2025 for the five

locomotive classifications and pollutants.

5.3.3.3 

### State

- specific Railroad Updates for 2025

New Jersey provided updated railroad growth factors, contr ol factors, and emission

estimates for 2007, 2013, 2017, 2020, and 2025. These data were used to replace the

emission estimates previously used for the 2007 MANE

- VU+VA base year inventory and

the MANE

- VU+VA future year inventories.

Exhibit 5 .5 Rail Control Factors by Year, Pollutant, and SCC

Year NOx PM2.5 SO2

SCC 22

- 85

- 002

- 006 Line Haul Class I Operations

2013 0.771 0.595 0.003

2017 0.633 0.449 0.003

2020 0.547 0.364 0.003

2025 0.412 0.252 0.003

SCC 22

- 85

- 002

- 00 7 Line Haul Class I I / III Operations

2013 1.000 0.829 0.003

2017 0.960 0.791 0.003

2020 0.920 0.752 0.003

2025 0.852 0.688 0.003

SCC 22

- 85

- 002

- 00 8 Inter

- City Passenger

2013 0.571 0.566 0.003

2017 0.421 0.402 0.003

2020 0.340 0.294 0.003

2025 0.241 0.180 0.003

SCC 22

- 85

- 002

- 00 9 Commuter Rail

2013 0.571 0.566 0.003

2017 0.421 0.402 0.003

2020 0.340 0.294 0.003

2025 0.241 0.180 0.003

SCC 22

- 85

- 002

- 0 10 Yard / Switch

2013 0.912 0.777 0.003

2017 0.843 0.712 0.003

2020 0.771 0.650 0.003

2025 0.634 0.534 0.003Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 79



## 6.0 ONROAD MOBILE SOURCES INCLUDED IN MOVES

6.1 MOVES MODEL CATEGORIES

USEPA’s MOVES model estimates emissions from vehicles travel such as cars, trucks,

buses and motorcycles. These vehicles are powered by diesel, gasoline, and alternative

fuel formulations. MO VES2010 includes the capability to estimate both vehicle exhaust

and evaporative emissions (including vehicle refueling emissions) and brake wear and tire

wear emissions for criteria pollutants and precursors. However, MOVES2010 does not

include the capability to estimate emissions of re

- entrained road dust. E stimate s of

emissions from re

- entrained road dust are included in the area sou rce inventory.

6.2 2007 MOVES MODEL INVENTORY

MARAMA provided county

- level MOVES results for 2007 for CT, DE, DC, and MD.

Other states (NJ, NY, PA, VA) provided results for affected counties in their states.

6.3 2025 MOVES MODEL INVENTORY

MARAMA provided county

- level MOVES results for 2025 for CT, DE, DC, and MD.

Other states (NJ, NY, PA, VA) provided results for affected counties in their states.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 80



## 7.0 EMISSION SUMMARIES

Exhibits 7 .1 to 7 .12 summarize PM2.5 and PM precursor emissions by PM nonattainment

area and source sector for 2007 and 2025. Some general observations by pollutant include:

PM2.5 emissions are projection to decrease between 2007and 2025 in all PM

nonattainment areas. The reductions are due to the turnover to cleaner onroad

vehicles, nonroa d engines , and residential wood combustion equipment. The

PM2.5 emissions shown account for the application of the PM transport factor (see

discussion in Section 2.2.1.1 of this TSD).

NO

x 

### emissions decline in all PM nonattainment areas between 2007 and 20 25 and

by more than 50 percent in a few areas . Most of the decline results from the

turnover of the onroad vehicle fleet to vehicles with improved emission controls

and fuel efficiency. Reductions in nonroad sources are also substantial. Three

areas (Ba ltimore, NY/NJ/CT, and Washington DC/MD/VA) also show substantial

reductions due to controls on EGUs.

SO 2 

### emissions decrease in all PM nonattainment areas. All areas are showing

reductions due to the lower sulfur contents of fuels used by onroad vehicle s and

nonroad equipment. Additional reductions in areas located in Maryland, New

Jersey, and New York are due to the lower sulfur content regulations in those state

for home heating

, distillate oil , and residual oil. Connecticut, Delaware, the

District o f Columbia, Pennsylvania, and Virginia did not take credit for any

reductions for low sulfur fuel oils since they have not adopted the MANE

- VU

recommendations into their regulations (see discussion in Section 2.3.2.5 of the

TSD) . Especially large reductio ns are found in areas where controls are projected

to be in place on EGUs ( Allentown, Baltimore, Harrisburg, Metro New York

, Philadelphia, Pittsburgh, Washington DC/MD/VA, and York, PA).

County

- by

- county emissions for 2007 and 2025 are available on the MARAMA ftp site

.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 81



### Exhibit 7 .1 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Allentown, PA

Annual Annual Change (t py ) Change (%)

(tons) (tons) from from

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (N Ox )

A rea 1,987 1,936

- 51

- 2.6%

N onroad MAR 516 277

- 239

- 46.3%

N onroad NM IM 2,661 1,007

- 1,654

- 62.1%

O nroad MOVES 15,652 4,190

- 11,462

- 73.2%

P oint EGU 7,763 5,837

- 1,927

- 24.8%

Point non EGU 5,900 2,114

- 3,786

- 64.2%

34,480 15,362

- 19,117

- 55.4%

Direct PM2.5

A rea 2,150 1,958

- 192

- 8.9%

N onroad MAR 26 15

- 11

- 42.3%

N onroad NM IM 229 113

- 117

- 51.0%

O nroad MOVES 528 190

- 338

- 64.0%

P oint EGU 2,264 2,138

- 125

- 5.5%

Point non EGU 1,301 1,227

- 75

- 5.7%

6,498 5,640

- 858

- 13.2%

Sulfur Dioxide (SO2)

A rea 2,552 1,118

- 1,434

- 56.2%

N onroad MAR 12 4

- 8

- 70.4%

N onroad NM IM 147 4

- 143

- 97.3%

O nroad MOVES 118 43

- 75

- 63.2%

P oint EGU 48,203 3,962

- 44,241

- 91.8%

Point non EGU 5,868 5,875 7 0.1%

56,900 11,005

- 45,895

- 80.7%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES modelDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 82



### Exhibit 7 .2 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Baltimore, MD

Annual Annual Change (t py ) Change (%)

(tons) (tons) from F rom

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (N Ox )

A rea 4,732 5,167 435 9.2%

N onroad MAR 16,703 8,521

- 8,182

- 49.0%

N onroad NM IM 10,466 4,265

- 6,201

- 59.2%

O nroad MOVES 43,939 15,900

- 28,038

- 63.8%

P oint EGU 23,572 8,939

- 14,634

- 62.1%

Point non EGU 11,981 13,362 1,380 11.5%

111,394 56,154

- 55,240

- 49.6%

Direct PM2.5

A rea 5,004 5,197 193 3.9%

N onroad MAR 572 201

- 371

- 64.8%

N onroad NM IM 969 519

- 450

- 46.4%

O nroad MOVES 1,503 749

- 755

- 50.2%

P oint EGU 6,677 7,134 456 6.8%

Point non EGU 2,296 2,366 71 3.1%

17,022 16,166

- 855

- 5.0%

Sulfur Dioxide (SO2)

A rea 2,316 315

- 2,001

- 86.4%

N onroad MAR 1,803 268

- 1,535

- 85.1%

N onroad NM IM 581 15

- 566

- 97.4%

O nroad MOVES 375 380 5 1.3%

P oint EGU 93,665 18,922

- 74,744

- 79.8%

Point non EGU 4,759 4,867 108 2.3%

103,499 24,766

- 78,733

- 76.1%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES modelDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 83



### Exhibit 7 .3 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

N onattainment Area: Hagerstown Martinsburg, MD

- WV

Annual Annual Change (t py ) Change (%)

(tons) (tons) from from

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (N Ox )

A rea 296 339 43 14.5%

N onroad MAR 289 144

- 145

- 50.2%

N onroad NM IM 793 301

- 492

- 62.0%

O nroad MOVES 5,124 1,966

- 3,158

- 61.6%

P oint EGU 1,398 1,390

- 8

- 0.6%

Point non EGU 1,982 1,518

- 465

- 23.4%

9,883 5,657

- 4,225

- 42.8%

Direct PM2.5

A rea 501 538 37 7.3%

N onroad MAR 10 3

- 7

- 68.6%

N onroad NM IM 74 33

- 41

- 55.6%

O nroad MOVES 185 69

- 117

- 62.8%

P oint EGU 310 299

- 11

- 3.5%

Point non EGU 188 188 0 0.1%

1,269 1,131

- 138

- 10.9%

Sulfur Dioxide (SO2)

A rea 274 83

- 191

- 69.7%

N onroad MAR 5 2

- 4

- 69.4%

N onroad NM IM 45 1

- 44

- 97.6%

O nroad MOVES 44 47 3 6.4%

P oint EGU 5,536 4,590

- 946

- 17.1%

Point non EGU 1,277 1,271

- 6

- 0.5%

7,182 5,993

- 1,189

- 16.5%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES model

Note: only includes emissions for Washington County, MD; emissions for West Virginia portion of

the nonattainment area will be provided by Maryland in their SIP submittal.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 84



### Exhibit 7 .4 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Harrisburg

- Lebanon

- Carlisle

- York, PA

Annual Annual Change (t py ) Change (%)

(tons) (tons) from F rom

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 3,874 3,705

- 169

- 4.4%

Nonroad MAR 1,775 981

- 793

- 44.7%

Nonroad NMIM 5,329 2,055

- 3,274

- 61.4%

Onroad MOVES 36,440 9,338

- 27,102

- 74.4%

Point EGU 15,985 15,531

- 454

- 2.8%

Point nonEGU 10,965 9,646

- 1,319

- 12.0%

74,368 41,255

- 33,113

- 44.5%

Direct PM2.5

Area 5,452 5,201

- 251

- 4.6%

Nonroad MAR 74 35

- 39

- 52.3%

Nonroad NMIM 474 211

- 263

- 55.4%

Onroad MOVES 1,225 346

- 879

- 71.8%

Point EGU 2,123 2,060

- 63

- 3.0%

Point nonEGU 923 915

- 8

- 0.9%

10,272 8,769

- 1,503

- 14.6%

Sulfur Dioxide (SO2)

Area 4,900 2,763

- 2,136

- 43.6%

Nonroad MAR 30 15

- 15

- 50.2%

Nonroad NMIM 293 8

- 285

- 97.3%

Onroad MOVES 255 89

- 165

- 64.9%

Point EGU 106,189 5,179

- 101,010

- 95.1%

Point nonEGU 11,520 11,539 19 0.2%

123,186 19,593

- 103,593

- 84.1%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES modelDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 85



### Exhibit 7 .5 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Johnstown, PA

Annual Annual Change (t py ) Change (%)

(tons) (tons) from F rom

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 861 822

- 39

- 4.5%

Nonroad MAR 1,132 568

- 564

- 49.8%

Nonroad NMIM 909 366

- 543

- 59.7%

Onroad MOVES 6,017 1,217

- 4,800

- 79.8%

Point EGU 41,440 40,004

- 1,435

- 3.5%

Point nonEGU 932 1,097 165 17.7%

51,291 44,074

- 7,216

- 14.1%

Direct PM2.5

Area 1,198 1,114

- 84

- 7.0%

Nonroad MAR 45 18

- 27

- 60.6%

Nonroad NMIM 84 36

- 48

- 56.9%

Onroad MOVES 195 43

- 152

- 78.2%

Point EGU 2,867 2,768

- 99

- 3.4%

Point nonEGU 231 234 3 1.4%

4,619 4,212

- 407

- 8.8%

Sulfur Dioxide (SO2)

Area 1,179 593

- 586

- 49.7%

Nonroad MAR 13 1

- 12

- 95.9%

Nonroad NMIM 51 1

- 50

- 97.4%

Onroad MOVES 45 12

- 32

- 72.3%

Point EGU 143,303 141,481

- 1,821

- 1.3%

Point nonEGU 30 35 4 14.7%

144,621 142,123

- 2,498

- 1.7%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES model

Note: summary includes emissions for all of Indiana County; however, only part of the county is in

the nonattainmen t area.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 86



### Exhibit 7 .6 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Lancaster, PA

Annual Annual Change (t py ) Change (%)

(tons) (tons) from F rom

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,827 1,704

- 122

- 6.7%

Nonroad MAR 293 140

- 153

- 52.1%

Nonroad NMIM 2,880 1,170

- 1,710

- 59.4%

Onroad MOVES 14,163 3,779

- 10,384

- 73.3%

Point EGU 0 0 0 0.0%

Point nonEGU 1,147 1,383 236 20.5%

20,310 8,177

- 12,133

- 59.7%

Direct PM2.5

Area 1,827 1,704

- 122

- 6.7%

Nonroad MAR 293 140

- 153

- 52.1%

Nonroad NMIM 2,880 1,170

- 1,710

- 59.4%

Onroad MOVES 14,163 3,779

- 10,384

- 73.3%

Point EGU 0 0 0 0.0%

Point nonEGU 1,147 1,383 236 20.5%

20,310 8,177

- 12,133

- 59.7%

Sulfur Dioxide (SO2)

Area 3,030 1,766

- 1,264

- 41.7%

Nonroad MAR 4 0

- 3

- 87.6%

Nonroad NMIM 144 5

- 139

- 96.8%

Onroad MOVES 104 38

- 66

- 63.4%

Point EGU 0 0 0 0.0%

Point nonEGU 102 120 18 17.5%

3,384 1,929

- 1,454

- 43.0%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES modelDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 87



### Exhibit 7 .7 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Metro New York/Northern New Jersey/Long Island NY/NJ/CT

Annual Annual Change (t py ) Change (%)

(tons) (tons) from from

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 64,044 56,873

- 7,170

- 11.2%

Nonroad MAR 46,842 31,820

- 15,023

- 32.1%

Nonroad NMIM 71,021 13,771

- 57,250

- 80.6%

Onroad MOVES 252,723 74,474

- 178,249

- 70.5%

Point EGU 36,928 34,378

- 2,550

- 6.9%

Point nonEGU 20,117 20,881 765 3.8%

491,675 232,198

- 259,477

- 52.8%

Direct PM2.5

Area 18,512 19,318 805 4.4%

Nonroad MAR 1,705 755

- 950

- 55.7%

Nonroad NMIM 5,926 1,528

- 4,398

- 74.2%

Onroad MOVES 10,189 4,878

- 5,311

- 52.1%

Point EGU 6,267 4,660

- 1,607

- 25.6%

Point nonEGU 1,530 1,704 174 11.4%

44,131 32,844

- 11,287

- 25.6%

Sulfur Dioxide (SO2)

Area 42,122 10,353

- 31,768

- 75.4%

Nonroad MAR 11,823 1,957

- 9,865

- 83.4%

Nonroad NMIM 2,204 56

- 2,148

- 97.5%

Onroad MOVES 1,750 1,564

- 186

- 10.6%

Point EGU 63,236 44,867

- 18,370

- 29.0%

Point nonEGU 5,293 5,351 59 1.1%

126,427 64,149

- 62,279

- 49.3%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES model

Note: 2025 NMIM emiss ions for New York counties are missing from the above summaries.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 88



### Exhibit 7

. 8 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Philadelphia

- Wilmington , PA /DE/NJ

Annual Annual Change (t py ) Change (%)

(tons) (tons) from F rom

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 18,043 17,741

- 302

- 1.7%

Nonroad MAR 12,271 9,357

- 2,913

- 23.7%

Nonroad NMIM 19,579 8,305

- 11,274

- 57.6%

Onroad MOVES 106,315 26,648

- 79,668

- 74.9%

Point EGU 12,616 4,873

- 7,743

- 61.4%

Point nonEGU 19,143 14,944

- 4,199

- 21.9%

187,967 81,869

- 106,099

- 56.4%

Direct PM2.5

Area 13,811 12,983

- 829

- 6.0%

Nonroad MAR 658 299

- 360

- 54.7%

Nonroad NMIM 1,808 1,059

- 749

- 41.4%

Onroad MOVES 3,795 1,443

- 2,352

- 62.0%

Point EGU 1,048 813

- 236

- 22.5%

Point nonEGU 3,524 3,062

- 462

- 13.1%

24,644 19,657

- 4,987

- 20.2%

Sulfur Dioxide (SO2)

Area 16,763 9,756

- 7,007

- 41.8%

Nonroad MAR 5,136 677

- 4,459

- 86.8%

Nonroad NMIM 998 32

- 966

- 96.7%

Onroad MOVES 773 422

- 351

- 45.4%

Point EGU 20,665 4,563

- 16,102

- 77.9%

Point nonEGU 14,370 8,990

- 5,380

- 37.4%

58,705 24,440

- 34,265

- 58.4%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES modelDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 89



### Exhibit 7 .9 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Pittsburgh

- Beaver Valley, PA

Annual Annual Change (t py ) Change (%)

(tons) (tons) from F rom

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (N Ox )

A rea 8,608 8,613 5 0.1%

N onroad MAR 14,258 7,116

- 7,142

- 50.1%

N onroad NM IM 9,827 4,223

- 5,605

- 57.0%

O nroad MOVES 56,652 12,725

- 43,927

- 77.5%

P oint EGU 82,657 84,453 1,795 2.2%

Point non EGU 20,217 18,760

- 1,456

- 7.2%

192,219 135,890

- 56,330

- 29.3%

Direct PM2.5

A rea 7,562 6,835

- 728

- 9.6%

N onroad MAR 467 196

- 271

- 58.1%

N onroad NM IM 880 432

- 448

- 50.9%

O nroad MOVES 1,905 531

- 1,374

- 72.1%

P oint EGU 6,293 6,348 55 0.9%

Point non EGU 5,108 5,109 1 0.0%

22,216 19,450

- 2,766

- 12.4%

Sulfur Dioxide (SO2)

A rea 13,589 10,791

- 2,798

- 20.6%

N onroad MAR 260 95

- 165

- 63.4%

N onroad NM IM 529 15

- 514

- 97.2%

O nroad MOVES 419 141

- 278

- 66.4%

P oint EGU 429,186 93,130

- 336,056

- 78.3%

Point non EGU 13,247 13,699 451 3.4%

457,230 117,871

- 339,359

- 74.2%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES model

Note: summary includes emissions for all of Allegheny, Armstrong, Greene and Lawrence counties ;

however, only part s of th ose count ies are in the nonattainment area.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 90



### Exhibit 7 .10 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Reading, PA

Annual Annual Change (t py ) Change (%)

(tons) (tons) from F rom

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 1,289 1,114

- 175

- 13.6%

Nonroad MAR 621 307

- 314

- 50.5%

Nonroad NMIM 1,911 696

- 1,215

- 63.6%

Onroad MOVES 11,370 2,831

- 8,538

- 75.1%

Point EGU 2,506 2,432

- 74

- 2.9%

Point nonEGU 3,288 1,919

- 1,369

- 41.6%

20,983 9,298

- 11,685

- 55.7%

Direct PM2.5

Area 1,859 1,727

- 132

- 7.1%

Nonroad MAR 30 15

- 15

- 51.5%

Nonroad NMIM 161 72

- 88

- 54.9%

Onroad MOVES 379 96

- 284

- 74.7%

Point EGU 947 921

- 26

- 2.7%

Point nonEGU 325 331 6 1.8%

3,701 3,161

- 540

- 14.6%

Sulfur Dioxide (SO2)

Area 2,389 1,223

- 1,166

- 48.8%

Nonroad MAR 7 1

- 7

- 92.6%

Nonroad NMIM 99 3

- 96

- 97.1%

Onroad MOVES 81 27

- 53

- 66.3%

Point EGU 14,491 13,990

- 501

- 3.5%

Point nonEGU 649 660 11 1.7%

17,716 15,903

- 1,812

- 10.2%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES modelDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 91



### Exhibit 7 .11 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: Washi ngton DC/MD/VA

Annual Annual Change (t py ) Change (%)

(tons) (tons) from F rom

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (NOx)

Area 8,936 9,342 406 4.5%

Nonroad MAR 6,700 6,711 11 0.2%

Nonroad NMIM 20,181 8,003

- 12,179

- 60.3%

Onroad MOVES 42,971 14,067

- 28,904

- 67.3%

Point EGU 29,029 13,919

- 15,109

- 52.0%

Point nonEGU 8,826 11,253 2,427 27.5%

116,643 63,295

- 53,348

- 45.7%

Direct PM2.5

Area 9,528 9,725 198 2.1%

Nonroad MAR 201 160

- 40

- 20.2%

Nonroad NMIM 2,003 1,112

- 891

- 44.5%

Onroad MOVES 1,467 728

- 739

- 50.4%

Point EGU 4,984 4,996 12 0.2%

Point nonEGU 563 594 32 5.6%

18,746 17,316

- 1,430

- 7.6%

Sulfur Dioxide (SO2)

Area 5,733 3,862

- 1,871

- 32.6%

Nonroad MAR 416 488 72 17.3%

Nonroad NMIM 1,230 30

- 1,201

- 97.6%

Onroad MOVES 387 347

- 40

- 10.4%

Point EGU 179,243 24,694

- 154,549

- 86.2%

Point nonEGU 4,206 3,570

- 636

- 15.1%

191,215 32,990

- 158,225

- 82.7%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES model

Note: 2007 and 2025 MOVES onroad emissions for Virginia counties are missing from the above

summaries.Documentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 92



### Exhibit 7 .12 Comparison of 2007 and 2025 PM2.5 and PM Precursor Emissions

Nonattainment Area: York, PA

Annual Annual Change (t py ) Change (%)

(tons) (tons) from F rom

SECTOR 2007 2025 2007 to 2025 2007 to 2025

Oxides of Nitrogen (N Ox )

A rea 1,680 1,678

- 2

- 0.1%

N onroad MAR 198 104

- 93

- 47.2%

N onroad NM IM 2,463 836

- 1,627

- 66.1%

O nroad MOVES 10,519 2,740

- 7,779

- 74.0%

P oint EGU 15,760 15,226

- 534

- 3.4%

Point non EGU 6,404 6,431 28 0.4%

37,024 27,015

- 10,008

- 27.0%

Direct PM2.5

A rea 2,394 2,325

- 69

- 2.9%

N onroad MAR 13 7

- 6

- 48.7%

N onroad NM IM 189 77

- 112

- 59.4%

O nroad MOVES 348 121

- 227

- 65.2%

P oint EGU 2,098 2,026

- 72

- 3.4%

Point non EGU 364 365 1 0.3%

5,407 4,921

- 486

- 9.0%

Sulfur Dioxide (SO2)

A rea 1,684 1,059

- 625

- 37.1%

N onroad MAR 2 0

- 2

- 88.4%

N onroad NM IM 132 3

- 129

- 97.5%

O nroad MOVES 79 28

- 50

- 63.8%

P oint EGU 106,158 5,136

- 101,021

- 95.2%

Point non EGU 9,743 9,749 6 0.1%

117,798 15,977

- 101,821

- 86.4%

Nonroad MAR

– includes commercial marine vessel s, airports, and railroad locomotives

Nonroad NMIM

– includes equipment included in USEPA ’s NMIM/NONROAD model

Onroad MOVES

– includes emissions calculated by USEPA ’s MOVES modelDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 93



## 8.0 DELIVERABLES

Files are stored on MARAMA ftp site:

Address: ftp.marama.org

Login ID: regionalei

Password: marama2007

Folder: /2025 / Final 2025 (Version 3_3)

Exhibit 8 .1 lists the file names for all final deliverables.

Exhibit 8 .1 Final Deliverables

File Name Description

TSD V 3

_ 3 MANE

- VU 2025 Inventory PM

Nonattainment Counties.docx Technical Support Document for 2025 emission

inventory for PM nonattainment counties

Appendix A1 AEO2010 New England.xls AEO2010 Energy Consumption by Sector and

Source for New England Region (CT, MA, ME,

NH, RI, VT) and calculated growth factors

Appendix A2 AEO2010 Mid Atlantic

. xls AEO2010 Energy Consumption by Sector and

Source for Mid

- Atlantic Region (NJ, NY, PA)

and calculated growth factors

Appendix A3 AEO2010 South Atlantic.xls AEO201 0 Energy Consumption by Sector and

Source for South Atlantic Region (DC, DE, MD,

VA) and calculated growth factors

Appendix A 4 AEO2011 New England.xls AEO2011 Energy Consumption by Sector and

Source for New England Region (CT, MA, ME,

NH, RI, VT) and calcul ated growth factors

Appendix A 5 AEO2011 Mid Atlantic

. xls AEO2011 Energy Consumption by Sector and

Source for Mid

- Atlantic Region (NJ, NY, PA)

and calculated growth factors

Appendix A 6 AEO2011 South Atlantic.xls AEO2011 Energy Consumption by Sector and

Source for South Atlantic Region (DC, DE, MD,

VA) and calculated growth factors

Appendix A7 AEO2010 vs AEO2011

Comparison.docx Technical Memorandum comparing AEO2010

and AEO2011 energy consumption projections

Appendix B Population_Factors.xls County

- level population growth factors as

provided by statesDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 94

File Name Description

Appendix C Employment_Factors.xls State

- level employment growth factors provided

by states

Appendix D VMT GF Nonattainment

Counties.xls County

- level VMT for 2007 and 2025

Appendix E EPA2020 Res Wood.xls USEPA growth factor formulas by SCC for

residential wood combustion

Appendix F AEO2011

- Electricity Generation by

EMM.xlsx AEO 2011 Electricity Generation by Electricity

Market Module Region and Source, Reference

case , and associated growth fa ctors

Appendix G UAF NEEDS Control

FileMASTER92211.xls State information on future EGU controls and

emission rates

Appendix H MAR Growth and Control.xls USEPA and FAA data used to develop growth

and control factors for commercial marine

vessels, airports, and railroads

V3_3 Area_07_25 PM Nonattainment.xlsx County and SCC

- level emissions and

growth/control factors for area sources

V3_3 EGU _07_25 PM Nonattainment.xlsx Unit level emissions and growth/control factors

for EGUs

V3_3 MAR _07_25 PM Nona ttainment.xlsx County and SCC

- level emissions and

growth/control factors for commercial marine

vessels, airports, and railroad locomotives

V3_3 MOVES _07_25 PM Nonattainment.xlsx County level emissions for onroad vehicles

included in USEPA’s MOVES model

V3_3 NMIM _07_25 PM Nonattainment.xlsx County and SCC

- level emissions for nonroad

equipment included in USEPA’s

NMIM/NONROAD model

V3_3 NonEGU _07_25 PM Nonattainment.xlsx Unit level emissions and growth/control factors

for nonEGUs

V3_3 Summaries_ 07_25 PM

Nonattainment.xlsx Emission summaries by county and

nonattainment areaDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 95



## 9.0 R EFER ENCES

EIA 2006 . U.S. Department of Energy, Energy Information Administration. Annual

Energy Outlook with Projections to 2030 (AEO2006). DOE/EIA

- 0383(2006). February

2006. http://www.eia.doe.gov/oiaf/archive/aeo06/pdf/0383(2006).pdf

EIA 2010 . U.S. Department of Energy, Energy Information Administration. Annual

Energy Outlook with Projections to 203 5 (AEO2010) ; DOE/EIA

- 0383(2010). April 2010.

http://www.eia.doe.gov/oiaf/aeo/assumption/pdf/0554(2010).pdf

EIA 2011 a . U.S. Department of Energy, Energy Information Administrat ion. Annual

Energy Outlook with Projections to 2035 (AEO2011) ; DOE/EIA

- 0383(2011). April 2011.

http://www.eia.gov/forecasts/aeo/pdf/0383(2011).pdf

EIA 2011 b . U.S. Department of Energy, Energy Information Administration. Annual

Energy Outlook with Projections to 2035 (AEO2011)

– Table 96 Electricity Generation by

Electricity Market Module Region and Source, Reference case ; DOE/EIA

- 0383(2011).

April 2011. http://www.eia.gov/forecasts/aeo/pdf/0383(2011).pdf

FAA 2010. Federal Aviation Administration. Terminal Area Forecast 2009

- 2030

. Database file (APO100_TAF_Final_2010.zip) downloaded July 2010.

http://aspm.faa.gov/main/taf.asp

MANE

- VU 2007. Mid

- Atlantic / Northeast Visibility. Statement of the Mid

Atlantic/Northeast Visibility Union Concerning a Course of Action within MANE

- VU

Toward Assuring Reasonable Progress . June 20, 2007.

http://www.otcair.org/manevu/document.asp?fview=Formal%20Actions

MARAMA 2007. Prepared by MACTEC Federal Programs, Inc. for the Mid

- Atlantic

Regional Air M anagement Association. Development of Emissions Projections for 2009,

2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE

- VU Region.

February 2007. http://www.marama.org/technical

- center/emissions

- inventory/2002

-

inventory

- and

- projections/mane

- vu

- future

- year

- emissions

- inventory

MARAMA 2011a. Prepared by MACTEC Engineering and Consulting, Inc . for the Mid

Atlantic Regional Air Management Association. Technical Support Document for the

Development of the 2007 Emission Inventory for Regional Air Quality Modeling in the

Northeast / Mid

-

Atlantic Region . February 27, 2011.

MARAMA 2011b. Prepare d by MACTEC Engineering and Consulting, Inc. for the Mid

Atlantic Regional Air Management Association. Technical Support Document for theDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 96



### Development of the 2013/2017/2020 Emission Inventories for Regional Air Quality

Modeling in the Northeast / Mid

- Atlan tic Region . February 27, 2011.

MARAMA 201 2a

. Prepared by AMEC Environment and Infrastructure and SRA

International for the Mid

- Atlantic Regional Air Management Association. Technical

Support Document for the Development of the 2007 Emission Inventory f or Regional Air

Quality Modeling in the Northeast / Mid

- Atlantic Region Version 3_3

. January 23, 2012

.

MARAMA 201 2b

. Prepared by AMEC Environment and Infrastructure and SRA

International for the Mid

- Atlantic Regional Air Management Association. Technical

Support Document for the Development of the 2013/2017/2020 Emission Inventories for

Regional Air Quality Modeling in the Northeast / Mid

- Atlantic Region Version 3_3

. January 23, 2012

OTC 200 1

. Prepared by E.H. Pechan & Associates, Inc. for the Ozone Transport

Commission. Control Measure Development Support Analysis of Ozone Transport

Commission Model Rules . March 31, 2001.

http://www.otcair.org/Document.asp?fview=Report#

OTC 20 0 7

. Prepared by MACTEC Federal Programs, Inc. for the Ozone Transport

Commission. Identification and Evaluation of Candidate Control Measures

– Final

Technical Support Document. February 28, 2007.

http://www.otcair.org/Document.asp?fview=Report#

OTC 2009a. Ozone Transport Commission. Status Report on OTC States’ Efforts to

Promulgate Regulations Based on OTC 2001 Model Rules . October 19, 2009.

http://www.otcair.org/interest.asp?Fview=stationary

OTC 2009b. Ozone Transport Commission. Status Report on OTC States’ Efforts to

Promulgate Regulations Based on OTC 2006 Model Rules . October 19, 2009.

http://www.otcair.org/interest.asp?Fview=stationary

USEPA 2004a. E.H. Pechan & Associates, Inc. for the U.S. Environmental Protection

Agency Crosswalk Between Source Classification Code (SCC)and Emission Activity

Growth Factors

– Final Technical Memorandum. September 9, 2004.

http://www.epa.gov/ttn/ecas/SCCcrosswalk.pdf

USEPA 2004 b. E.H. Pechan & Associates, Inc. for the U.S. Environmental Protection

Agency Crosswalk Between Standard Industrial Classification (SIC) Codes and Emission

Activity Growth Factors

– Final Technical Memorandum. September 9, 2004.

http://www.epa.gov/ttn/ecas/SICcrosswalk.pdfDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 97



### USEPA 2004c. U.S. Environmental Protection Agency. Nonroad Engine Gr o wth

Estimates . EPA

- 420/P

- 04

- 08. April 2004.

http://www.epa.gov/otaq/models/nonrdmdl/nonrdmdl2004/420p04008.pdf

USEPA 2005 a

. U.S. Environmental Protection Agency. Control of Air Pollution From

Aircraft and Aircraft Engines; Emission Standards and Test Procedures: Fina l Rule.

November 17, 2005. http://www.epa.gov/fedrgstr/EPA

- AIR/2005/November/Day

17/a22704.pdf

USEPA 2007 a

. U.S. Environmental Protections Agency. Emissions Modeling

Clearinghouse

- Fugitive Dust Fractions . February 2007.

http://www.epa.gov/ttn/chief/emch/dustfractions )

USEPA 2007b. U.S. Environmental Protection Agency. Guidance for Estimating VOC

and NOx Emission Changes from MACT Rules . EPA

- 457/B

- 07

- 001. May 2007.

http://www.epa.gov/ttn/naaqs/ozone/o3imp8hr/docume nts/guidance/200705_epa457_b

- 07

-

001_emission_changes_mact_rules.pdf

USEPA 2008 a

. U.S. Environmental Protection Agency. Control Techniques Guidelines

. http://www.epa.gov/ttncaaa1/t1ctg.html

USEPA 2 008 b

. U.S. Environmental Protection Agency. Regulatory Impact Analysis:

Control or Emissions of Air Pollution from Locomotive Engines and Marine Compression

Engines Less than 30 Liters Per Cylinder. EPA420

- R

- 08

- 001a. May 2008.

http://www.epa.gov/otaq/regs/nonroad/420r08001a.pdf

US EP A 200 9a

. U.S. Environmental P rotection Agency

. National Mobile Inventory

Model. http://www.epa.gov/otaq/nmim.htm

USEPA 2009c. U.S. Environmental Protection Agency. Regulatory Impact Analysis:

Control of Emissions of Air Pollution from Category 3 Marine Diesel Engines. EPA420

- R

09

- 019. December 2009. http://www.epa.gov/otaq/regs/nonroad/marine/ci/420r09019.pdf

USEPA 2009d. U.S. Environmental Protection Agency. Proposal to Designate an

Emissions Control Area for Nitrogen Oxides, Sulfur Oxides, and Parti culate Matter. EPA

420

- R

- 09

- 007. April 2009. http://www.epa.gov/otaq/regs/nonroad/marine/ci/420r09007

-

chap2.pdf

USEPA 2010 a

. U.S. Environmental Protection Agency. 2020 Emissions Data from

EPA’s 2005

- based V4 Modeling Platform; Projection and Control Factors . Provided by

Rich Mason on April 15, 2010.

ftp://ftp.epa.gov/EmisInventory/2005v4 /projection_control_packetsDocumentation for the 2025 Emission Inventory for PM Nonattainment Counties in the MANE

- VU Region January 23, 2012

Page 98



### USEPA 2010 b

. U.S. Environmental Protection Agency. Transport Rule Emission

Inventories Notice of Data Availability (NODA). Docket ID No. EPA

- HQ

- OAR

- 2009

-

0491 . October 27, 2010. TR_EI_NODA_relevant_CoSTpackets_and_inventories.xls

ftp://ftp.epa.gov/EmisInventory/2005v4/tr_ei_noda

USEPA 2010 c

. U.S. Environmental Protection Agency. Advance Notice of Proposed

Rulemak ing on Lead Emissions from Piston

- Engine Aircraft Using Leaded Aviation

Gasoline . April 2010. http://www.epa.gov/oms/regs/nonroad/aviation/420f10013.pdf

USEPA 2011. U.S. Environ mental Protection Agency. Emission Standards Reference

Guide. http://www.epa.gov/otaq/standards/index.htm