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1000 FRIENDS OF MARYLAND ● AMERICAN LUNG ASSOCIATION OF MARYLAND ● BALTIMORE BICYCLING CLUB ● BALTIMORE REGIONAL PARTNERSHIP ● CHESAPEAKE BAY FOUNDATION CITIZENS PLANNING AND HOUSING ASSOCIATION ENVIRONMENTAL DEFENSE ● GREATER BALTIMORE URBAN LEAGUE ● MARYPIRG ● GREATER BALTIMORE GROUP OF THE SIERRA CLUB

  July 1, 2003

Mr. Brian Hug
Maryland Department of the Environment
1800 Washington Boulevard
Suite 730
Baltimore , MD   21230-1720

RE: Revisions to the State Implementation Plan (SIP) for the Baltimore region

Dear Mr. Hug:

We the undersigned organizations are concerned that the revisions to the mobile source emission budgets in the Baltimore region’s State Implementation Plan (SIP Revision 03-04) mean that we risk unnecessarily endangering the health of the citizens of the Baltimore region, hampering our economic competitiveness, and violating the federal Clean Air Act.

For public health, economic competitiveness, and social equity reasons, we believe that it is imperative that the Baltimore metropolitan area meet the public health standards in the federal Clean Air Act by that law’s 2005 deadline.  A 1999 study calculated nearly 2000 respiratory-related emergency room visits and 86,000 asthma attacks in a typical Baltimore summer due to ozone smog pollution.[1]  Just this past summer the Baltimore region suffered 17 “Code Red” ozone days where pollution levels exceeded the federal “1-hour” ozone standard.  Such pollution carries social equity implications, as well.  Asthma is almost twice as common among African Americans as among whites, and African Americans suffer 24 percent of asthma deaths nationwide while comprising only 12 percent of the population.[2]

Meeting the 1-hour ozone standard in the Clean Air Act by 2005 means the Baltimore region should have only three Code Red days from this year through 2005, yet we have already experienced two Code Red days this year alone.  Common sense would indicate that attaining this health standard would be a tremendous challenge, although one the Baltimore area must work hard to meet as an important step towards making this a healthy and attractive place to live.

That is why we are so concerned about the expansion of the “mobile source” emissions budgets for cars, trucks, and buses that the Maryland Department of the Environment (MDE) has proposed in its revisions to the State Implementation Plan (SIP) for the Baltimore area.  The updated MOBILE6 air pollution model released early last year by the U.S. Environmental Protection Agency (EPA) shows much more ozone-forming pollution for the Baltimore area in 2005 than EPA’s MOBILE5 model: 52 percent more nitrogen oxide (NOx) pollution and 22 percent more volatile organic compounds (VOCs).  If MDE is to propose that these far greater pollution levels will still result in attaining the federal health standard in 2005, particularly in light of the daunting empirical evidence from last summer, one would think rigorous testing and scientific modeling would be in order, as is required by EPA rules for such attainment under the Clean Air Act.

Yet, MDE has chosen not to undertake such analysis.  Instead, it has used what we believe to be unreliable data calculations to continue to claim that the Baltimore area will meet the 2005 Clean Air Act deadline:

 
“Relative Reduction” Method

 
Rather than conduct the rigorous analysis that would show that the pollution levels found by EPA’s MOBILE6 model will still enable the Baltimore area to meet the federal 1-hour ozone standard by 2005, MDE has used a “relative reduction” method to assert our region’s compliance.  MDE has run 13 year-old data through the EPA’s new model to try to reconstruct actual pollutant emission levels in 1990 and then indirectly reconstruct 2005 ozone pollution levels by comparing newly-calculated 2005 emissions from the MOBILE6 model to the reconstructed 1990 emissions.

 
We believe this method relies on the scientifically discredited assumption that a reduction in ozone precursors leads to a proportional reduction in ozone levels, despite studies by the National Academy of Sciences in the early 1990s and by others showing that this linear proportional rollback analysis method is invalid.  These studies show that ozone concentrations are typically reduced by a lower percentage than the reduction in emissions of ozone precursors.

 
Taking these studies into account, we believe it is unlikely Baltimore ’s pollution control plan will produce attainment of the 1-hour ozone standard by the meet 2005 Clean Air Act deadline.  An assertion that these SIP control strategies will produce attainment will be credible only if demonstrated using a photochemical grid modeling envisioned as required by long-standing EPA rules. The public health of the citizens of the Baltimore region should not be put at risk by approving this SIP as adequate to demonstrate attainment.

 
In the case of NOx pollution, which plagues the Chesapeake Bay in addition to threatening public health, even MDE’s “relative reduction” method does not work.  While the MOBILE6 model shows a greater reduction in VOC emissions than does the EPA’s old MOBILE5 model, the reverse is true for NOx emissions.  The old MOBILE5 model showed a greater reduction of NOx pollution from 1990 to 2005 than does the new MOBILE6 model.  Thus, MDE has turned to the second practice that we believe to be unreliable and questionable:

 
Pollution Substitution

 
Needing further NOx reductions, even under the “relative reduction” method of calculating emissions of key pollutants, MDE has asserted that every ton of VOCs reduced is actually equivalent to nearly 1.5 tons of NOx reduced.  We believe this is problematic in our area for three reasons:

First, it removes the assertion that Baltimore will meet federal health standards for ozone smog even further from the rigorous modeling envisioned for such demonstrations by EPA rules.  Second, as a related point, removing some of the VOC “relative reduction” and applying it to the shortfall in NOx shaves the margin of error for both pollutants dangerously thin, even assuming MDE’s methodology.  Such a thin margin of error when public health is on the line makes the need to conduct rigorous modeling even more apparent.  In fact, the studies by the National Academy of Sciences and others cited above also show that in regions like Baltimore it may be much more important to reduce NOx than to reduce VOCs in order to bring down peak ozone concentrations.

Finally, as also mentioned above, substituting VOC emission reductions for NOx reductions in the Baltimore area is also problematic in a larger environmental picture.  Airborne nitrogen oxides account for one-quarter of the nitrogen pollution that plagues the Chesapeake Bay .  Not only is substituting VOC emissions for NOx emissions questionable from an air quality standpoint, it removes an important secondary water quality benefit of the Clean Air Act here in Maryland .

Given the concerns we express above, we believe MDE has two choices under the Clean Air Act:

 
Conduct Photochemical Grid Modeling

 
If MDE wishes to assert that the vastly increased pollution levels in the Baltimore region indicated by EPA’s new MOBILE6 pollution model will still lead to attainment of the federal 1-hour ozone standard by 2005 – now just two years away, we believe MDE must show that result through rigorous photochemical grid modeling, as stipulated in EPA rules.

 
Cut Pollution with Additional Transportation Control Measures (TCMs)

 
Should MDE wish to avoid additional photochemical grid modeling, under the Clean Air Act it must reduce the pollution in its mobile source budget by adding Transportation Control Measures (TCMs) to the SIP or adopt other SIP control strategies to offset the increase in pollution forecast by MOBILE6 compared to MOBILE5.  We are attaching a list of initiatives that we recommend be considered – and many adopted – in that process.

The document on which we are commenting is technical and complex, but its implications are asthma attacks and emergency room visits among children and others in the Baltimore area.  We urge the Maryland Department of the Environment to abide by both the letter and the spirit of the Clean Air Act, especially now that we have nearly had our 15 years under the law to meet a basic ozone smog health standard.  Not doing so endangers the health of our region’s citizens and ultimately endangers the attractiveness and economic health of our region as well.

 Sincerely,

  TRANSPORTATION CONTROL MEASURES
RECOMMENDED FOR CONSIDERATION IN THE BALTIMORE REGION

July 1, 2003

Short-Term Measures

Expansion of Employer Participation in State Commuter Choice Program

Bicycle Transportation Infrastructure and Safety Improvements

Pedestrian Transportation Infrastructure and Safety Improvements

Transit Improvements

Cleaner Fuels

Campus Transportation Management

Off-Road Diesel Contracting Requirements

Mid-Term to Long-Term Measures

Bicycle/Pedestrian Improvements

Transit Improvements

  Land Use/Housing

Transportation Pricing Strategies

Baltimore Regional Partnership · 512 Orchard Street  · Baltimore, MD 21201-1947
 phone: (410) 523-8150  x249 · fax: (410) 523-4022