IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue

Governor Indianapolis, Indiana 46204

(317) 232-8603

Thomas W. Easterly Toll Free (800) 451-6027

Commissioner www.idem.lN.gov

June 16, 2011

Ms. Susan Hedman

Regional Administrator

U.S. Environmental Protection Agency

Region 5

77 West Jackson Boulevard

Chicago, IL 60604-3950

Re: Request for Redesignation Petition and

Maintenance Plan for the Indiana Portion

(Madison Township, Jefferson County and

Clark and Floyd counties) of the Louisville

KY-IN Nonattainment Area for Fine

Particles

Dear Ms. Hedman:

The Indiana Department of Environmental Management (IDEM) submits a

Redesignation Petition and Maintenance Plan for the Indiana Portion (Madison Township,

Jefferson County and Clark and Floyd counties) of the Louisville KY-IN Nonattainment

Area, which was designated as nonattainment of the annual standard for fine particles on

April 5, 2005. IDEM conducted a public hearing concerning the Redesignation Petition

and Maintenance Plan on May 26, 2011, and the public comment period concluded on

May 29,2011.

During the public comment period, the Louisville Metro Air Pollution Control District

and Kentucky Department of Environmental Management provided an updated emission

inventory for Kentucky's portion of the nonattainment area (Bullitt and Jefferson

counties). The new emission inventory numbers have been incorporated into the final

Redesignation Petition and Maintenance Plan and Appendices S, C, and E.

The attached document consists of the following:

Redesignation Petition and Maintenance Plan

• A formal request that the Indiana Portion (Madison Township, Jefferson County

and Clark and Floyd counties) of the Louisville KY-IN Nonattainment Area for Fine

Particles be redesignated to attainment and reclassified as maintenance. It

contains and meets the requirements set forth in Section 107 of the Clean Air Act

and in United States Environmental Protection Agency (U.S. EPA) Redesignation

Guidance.

• The appendices of the document contain historical air quality trend data, projected

emission inventory data, and thorough documentation of the mobile emissions

analysis.

•

Recycled Paper (i) An Equal O!>!>orlunity Employer Please Recycle 0
Ms. Hedman

Page 2

• A maintenance year of 2025 is established and 2015 and 2020 are analyzed as

interim years.

• A summary of, and response to, all comments.

Motor Vehicle Emissions Budgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget

for 2015 and 2025. The Kentuckiana Regional Planning and Development

Agency's (KIPDA's) travel demand forecasting model and U.S. EPA's software

program referred to as Motor Vehicle Emission Simulator (MOVES) were used to

determine emissions for the annual fine particle nonattainment area.

• A conservative margin of safety was applied to the 2015 and 2025 projected

emissions.

• The travel demand model was updated with the best available assumptions.

• Vehicle registration data gathered from the Indiana Bureau of Motor Vehicles were

used to replace the MOVES default vehicle age distribution.

IDEM requests that U.S. EPA proceed with review and approval of this submittal.

If you have any questions or need additional information, please contact Scott Deloney,

Chief, Air Programs Branch, at (317) 233-5694.

Sincerely,

/~ 8'--'-8" p oj

Keith Baugues

Assistant Commissioner

Office of Air Quality

KB/sad/ghf

Enclosure:

Request for Redesignation Petition and Maintenance Plan Under the Annual

National Ambient Air Quality Standard for Fine Particles for the Indiana Portion of

the Louisville KY-IN Nonattainment Area

Cc: John Summerhays, U.S. EPA Region 5 (wI enclosures)

Matt Rau, U.S. EPA Region 5 (wI enclosures)

John Mooney, U.S. EPA Region 5 (no enclosures)

. Cheryl Newton, U.S. EPA Region 5 (no enclosures)

. Pat Morris, U.S. EPA Region 5 (no enclosures)

Cynthia Lee, LMAPCD (wI enclosures)

John Gowins, KDEP (wI enclosures)

Randy Simon, KIPDA (no enclosures)

Larry D. Chaney, KIPDA (wI enclosure)

Jesse Mayes, KYTC (no enclosures)

Scott Deloney, IDEM (no enclosures)

Christine Pedersen, IDEM (no enclosures)

Gale Ferris, IDEM (wI enclosures)
REQUEST FOR REDESIGNATION AND

MAINTENANCE PLAN

UNDER THE ANNUAL NATIONAL

AMBIENT AIR QUALITY.

STANDARD FOR FINE PARTICLES

For the Indiana Portion

ofthe

Louisville KY-IN

Nonattainment Area for Fine Particles

Jefferson County (Madison Township), Clark and

Floyd Counties, Indiana

Prepared By:

The Indiana Department ofEnvironmental Management

June 2011
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11
iii 

TABLE OF CONTENTS 

1.0 INTRODUCTION....................................................................................................................1

1.1 Background ................................................................................................................................1 

1.2 Geographical Description ..........................................................................................................3 

1.3 Status of Air Quality ..................................................................................................................3 

2.0 REQUIREMENTS FOR REDESIGNATION ......................................................................3

2.1 General .......................................................................................................................................3 

2.2 Fine Particle Monitoring ............................................................................................................4 

2.3 Emission Inventory ....................................................................................................................4 

2.4 Modeling Demonstration ...........................................................................................................5 

2.5 Controls and Regulations ...........................................................................................................5 

2.6 Corrective Actions for Potential Future Violations of the Fine Particle Standard ....................5 

3.0 FINE PARTICLE MONITORING ........................................................................................5

3.1 Fine Particle Monitoring Network .............................................................................................5 

3.2 Ambient Fine Particle Monitoring Data ....................................................................................6

3.3 Quality Assurance ....................................................................................................................11 

3.4 Continued Monitoring ..............................................................................................................11 

4.0 EMISSION INVENTORY ....................................................................................................11

4.1 Emission Trends .......................................................................................................................12 

4.2 Base Year Inventory ................................................................................................................22 

4.3 Emission Projections ................................................................................................................23 

4.4 Demonstration of Maintenance ................................................................................................29 

4.5 Permanent and Enforceable Emission Reductions ..................................................................30 

4.6 Provisions for Future Updates .................................................................................................30 

5.0 TRANSPORTATION CONFORMITY BUDGETS ..........................................................30

5.1 Onroad Emission Estimates .....................................................................................................30 

5.2 Overview ..................................................................................................................................31 

5.3 Emission Estimations ...............................................................................................................31 

6.0 CONTROL MEASURES AND REGULATIONS ..............................................................33 

6.1 Reasonably Available Control Technology (RACT) ...............................................................33 

6.2 Implementation of Past State Implementation Plan (SIP) Revisions.......................................34 

6.3 Nitrogen Oxides (NOx) Rule ....................................................................................................34 
iv 

6.4 Measures Beyond Clean Air Act SIP Requirements ...............................................................35 

6.5 Controls to Remain in Effect ...................................................................................................39 

6.6 New Source Review Provisions ...............................................................................................39 

7.0 MODELING AND METEOROLOGY................................................................................39 

7.1 Summary of Modeling Results to Support Rulemakings ........................................................40 

7.2 Lake Michigan Air Directors Consortium’s (LADCO) Round 5 Speciated 

 Modeled Attainment Test Results ............................................................................................43

7.3 LADCO Round 5 Particulate Source Apportionment Results .................................................44 

7.4 Summary of Existing Modeling Results ..................................................................................50 

7.5 Meteorological Analysis for the Louisville Area .....................................................................50 

7.6 Surface Air Conditions Present during High Fine Particle Concentration Days .....................50 

7.7 Upper Air Conditions Present during High Fine Particle Concentration Days .......................50 

7.8 Analyses of Atmospheric Conditions during High Fine Particle Concentration Days ............51 

7.9 Summary of Air Quality Index (AQI) Days in the Louisville Area ........................................51 

7.10 Summary of Meteorological Analysis for the Louisville Area ..............................................52 

8.0 CORRECTIVE ACTIONS ...................................................................................................53 

8.1 Commitment to Revise Plan ....................................................................................................53 

8.2 Commitment for Contingency Measures .................................................................................53 

8.3 Contingency Measures .............................................................................................................53 

9.0 PUBLIC PARTICIPATION ................................................................................................54 

10.0 CONCLUSIONS ..................................................................................................................55 

FIGURES

Figure 3.1 Louisville Basic Nonattainment Area ............................................................................6 

TABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles (PM2.5) ..............................2 

Table 3.1 Monitoring Data for Indiana’s Portion of the Louisville Area ........................................7 

Table 3.2 Monitoring Data for Kentucky’s Portion of the Louisville Area .....................................8 

Table 4.1 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, 

 Clark, Floyd, and Jefferson Counties, Indiana ..............................................................29 

Table 4.2 Comparison of 2008 Estimated and 2025 Projected Emission Estimates, 

 Louisville Area ..............................................................................................................29 

Table 5.1 Emission Estimations for Onroad Mobile Sources ........................................................32 

Table 5.2 Motor Vehicle Emission Budgets for the Louisville Area ............................................32 

Table 6.1 Trends in Electric Generating Unit (EGU) NOx Emissions Statewide in Indiana .........35 
v 

Table 7.1 Clean Air Transport Rule Modeling Results from U.S. EPA (Using 2003- 2007 

 Design Values) ...........................................................................................................40 

Table 7.2 Clean Air Transport Rule Modeling Results from U.S. EPA (Using 2006 – 2010 

 Design Values) ...........................................................................................................41 

Table 7.3 LADCO Round 6 Modeling Results for Annual PM2.5 – Without Clean Air 

 Interstate Rule Emission Reductions (Using 2003 – 2007 Design Values) ...............42 

Table 7.4 LADCO Round 6 Modeling Results for Annual PM2.5 – Without Clean Air ............43 

 Interstate Rule Emission Reductions (Using 2006 – 2010 Design Values) 

Table 7.5 LADCO Round 5 Speciated Modeled Attainment Test Modeling Results for 

 Southern Indiana .........................................................................................................44 

Table 7.6 Ranking and Percentage of Highest Number of Days at AQI Levels 

 of Health Concern ......................................................................................................52 

GRAPHS

Graph 3.1 Fine Particle Design Values for Indiana’s Portion of the Louisville Area ...................9 

Graph 3.2 Fine Particle Design Values for Kentucky’s Portion of the Louisville Area ...............9 

Graph 3.3 Annual Fine Particle Trends for Indiana’s Portion of the Louisville Area ................10 

Graph 3.4 Annual Fine Particle Trends for Kentucky’s Portion of the Louisville Area .............10 

Graph 4.1 NOx Point Source Emissions Trend, Clark, Floyd, and Jefferson Counties, 

 Indiana ........................................................................................................................12 

Graph 4.2 Sulfur Dioxide (SO2) Point Source Emissions Trend, Clark, Floyd, and 

 Jefferson Counties, Indiana ........................................................................................13 

Graph 4.3 Direct PM2.5 Point Source Emissions Trend, Clark, Floyd, and Jefferson 

 Counties, Indiana ........................................................................................................13 

Graph 4.4 NOx Point Source Emissions Trend, Louisville Area ................................................14 

Graph 4.5 SO2 Point Source Emissions Trend, Louisville Area .................................................14 

Graph 4.6 Direct PM2.5 Point Source Emissions Trend, Louisville Area ...................................15 

Graph 4.7 NOx Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana 

 ....................................................................................................................................16 

Graph 4.8 SO2 Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana 

 ....................................................................................................................................17 

Graph 4.9 Direct PM2.5 Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, 

 Indiana ........................................................................................................................17 

Graph 4.10 NOx Emissions Trend, All Sources, Louisville Area ..................................................18 

Graph 4.11 SO2 Emissions Trend, All Sources, Louisville Area ..................................................18 

Graph 4.12 Direct PM2.5 Emissions Trend, All Sources, Louisville Area .....................................19 

Graph 4.13 NOx Emissions from EGUs, Floyd, and Jefferson Counties, Indiana ........................20 

Graph 4.14 SO2 Emissions from EGUs, Floyd, and Jefferson Counties, Indiana .........................21 

Graph 4.15 NOx Emissions from EGUs, Louisville Area .............................................................21 

Graph 4.16 SO2 Emissions from EGUs, Louisville Area ..............................................................22 

Graph 4.17 Comparison of 2005, 2008, 2015, and 2025 Projected NOx Emissions, Clark, 

 Floyd, and Jefferson Counties, Indiana ......................................................................25 

Graph 4.18 Comparison of 2005, 2008, 2015, and 2025 Projected SO2 Emissions, Clark, 

 Floyd, and Jefferson Counties, Indiana ......................................................................25 
vi 

Graph 4.19 Comparison of 2005, 2008, 2015, and 2025 Projected Direct PM2.5 Emissions, 

 Clark, Floyd, and Jefferson Counties, Indiana ...........................................................26 

Graph 4.20 Comparison of 2005, 2008, 2015, and 2025 Projected NOx, SO2, and Direct 

 PM2.5 Emissions, Clark, Floyd, and Jefferson Counties, Indiana ...............................26 

Graph 4.21 Comparison of 2005, 2008, 2015, and 2025 Projected NOx Emissions, 

 Louisville Area ...........................................................................................................27 

Graph 4.22 Comparison of 2005, 2008, 2015, and 2025 Projected SO2 Emissions, 

 Louisville Area ...........................................................................................................27 

Graph 4.23 Comparison of 2005, 2008, 2015, and 2025 Projected Direct PM2.5 Emissions, 

 Louisville Area ...........................................................................................................28 

Graph 4.24 Comparison of 2005, 2008, 2015, and 2025 Projected NOx, SO2, and Direct 

 PM2.5 Emissions, Louisville Area ..............................................................................28 

Graph 7.1 PM2.5 Design Value Trends for the Louisville Area ..................................................41 

CHARTS

Chart 7.1 Regional/Emission Sector Particulate Source Apportionment Technology 

 Results, Jeffersonville, Indiana – Walnut Street PM2.5 Monitor ................................45 

Chart 7.2 Modeled Contribution by Species at the Jeffersonville, Indiana 

 Walnut Street PM2.5 Monitor ......................................................................................46 

Chart 7.3 Modeled Contribution by Species at the New Albany, Indiana PM2.5 Monitor .........46 

Chart 7.4 Modeled Contribution by Species at the Carpenter Street – Shepherdsville, 

 Kentucky PM2.5 Monitor .............................................................................................47 

Chart 7.5 Modeled Contribution by Species at the Elizabethtown, Kentucky 

 PM2.5 Monitor .............................................................................................................47 

Chart 7.6 Modeled Contribution by Species at the Southern Avenue – Louisville, 

 Kentucky PM2.5 Monitor ............................................................................................48 

Chart 7.7 Modeled Contribution by Species at the Wyandotte Park – Louisville, Kentucky 

PM2.5 Monitor .............................................................................................................48 

Chart 7.8 Modeled Contribution by Species at the Barret Avenue – Louisville, Kentucky 

 PM2.5 Monitor .............................................................................................................49 

Chart 7.9 Modeled Contribution by Species at the Watson Elementary – Louisville, 

 Kentucky PM2.5 Monitor .............................................................................................49 

Chart 7.10 Distribution of PM2.5 Concentration Days on the AQI Levels of Health Concern 

 for the Louisville Area ...............................................................................................51 
vii 

APPENDICES

A Air Quality System (AQS) and Indiana Department of Environmental 

 Management (IDEM) Fine Particle Monitor Data Values for the Louisville 

 Area (2000 – 2010) 

B NOx, SO2, and Direct PM2.5 Point Source Emissions (2005 and 2008), Louisville 

 Area 

C NOx, SO2, and Direct PM2.5 Emissions, All Sources (2005 and 2008), Louisville 

 Area 

D NOx and SO2 Emission Trends from EGUs, Louisville Area (1999 to 2009) 

E 2005 and 2008 Base Year Emission Inventories and 2015 and 2025 Projected Emission 

 Inventories for NOx, SO2, and Direct PM2.5, Louisville Area 

F Example Mobile Source Input and Output Calculation Files for the Louisville Area 

G IDEM - Area Source Inventory Standard Operating Procedure 

H LADCO Emission Estimates Technical Support Document 

I LADCO Round 5 Modeling Technical Support Document (Round 5 Photochemical 

Modeling Based on “Base M” Emission Inventory, revised version of “Base K”) 

J Modeling Summary 

K Public Participation Process Documents

 
viii 

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1

REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN 

UNDER THE ANNUAL NATIONAL AMBIENT AIR 

QUALITY STANDARD FOR FINE PARTICLES 

LOUISVILLE KY-IN AREA 

1.0 INTRODUCTION

 

This document supports Indiana’s request that Jefferson County (Madison Township) and Clark 

and Floyd counties, Indiana, which are part of the Louisville KY-IN nonattainment area for fine 

particles (herein referred to as the “Louisville Area”), be redesignated from nonattainment to 

attainment of the 1997 annual standard for fine particles. All monitors for fine particles in the 

Louisville Area have recorded three years of quality assured ambient air quality monitoring data 

for the years 2008 through 2010, demonstrating attainment with the annual standard for fine 

particles; therefore, Indiana’s portion of the Louisville Area is eligible for redesignation. 

Section 107 of the Clean Air Act (CAA) establishes specific requirements to be met in order for 

an area to be considered for redesignation, including: 

(a) A determination that the area has attained the annual standard for fine particles. 

(b) A State Implementation Plan (SIP) for the area under Section 110(k) that is fully 

approved. 

(c) A determination that the improvement in air quality is due to permanent and 

enforceable reductions in emissions resulting from implementation of the SIP and 

other federal requirements.

(d) A maintenance plan under Section 175A that is fully approved. 

(e) A determination that all Section 110 and Part D requirements have been met. 

A maintenance plan provides for the continued attainment of the air quality standard by an area 

for a period of ten years after the United States Environmental Protection Agency (U.S. EPA) 

has formally redesignated the area to attainment. The plan also provides assurances that even if 

there is a subsequent exceedance of the air quality standard, then measures in the maintenance 

plan will prevent any future occurrences through contingency measures that would be triggered. 

This document addresses each of these requirements, and provides additional information to 

support continued compliance with the annual standard for fine particles. 

1.1 Background

The CAA requires states with areas designated nonattainment of the applicable National 

Ambient Air Quality Standard (NAAQS) for fine particles to develop SIPs to expeditiously 

attain and maintain the standard. In 1997, U.S. EPA set daily and annual air quality standards 

for fine particles (PM2.5), as shown in Table 1.1. The terms “fine particles” and “PM2.5” are used 

synonymously throughout this document. The PM2.5 standards were legally challenged and 

upheld by the U.S. Supreme Court in February of 2001. In 1999, the Indiana Department of 
2

Environmental Management (IDEM) began monitoring for fine particle concentrations. U.S. 

EPA designated areas in Indiana under the annual standard for fine particles on December 17, 

2004, as attainment, nonattainment or unclassifiable, with an effective date of April 5, 2005. 

Table 1.1 

National Ambient Air Quality Standards for Fine Particles 

 

Annual 24-Hour 

1997 PM2.5 Standards 

15 μg/m3*

Annual arithmetic mean, 

averaged over three years 

65 μg/m3

24-hour average, 98th percentile, 

averaged over three years 

2006 PM2.5 Standards 

15 μg/m3

Annual arithmetic mean, 

averaged over three years 

35 μg/m3

24-hour average, 98th percentile, 

averaged over three years 

* micrograms per cubic meter (μg/m3) 

Note: The Louisville Area meets the 1997 and 2006 24-hour NAAQS for fine particles. Since this area is 

solely designated nonattainment under the 1997 annual standard for fine particles, this document only 

addresses the annual standard. 

On December 17, 2004, based on 2001 through 2003 monitoring data, U.S. EPA designated the 

Louisville Area as nonattainment of the annual standard for fine particles (40 CFR 81.315). The 

Louisville Area is subject to Section 172 of the CAA, including the development of a plan to 

reduce nitrogen oxides (NOx), sulfur dioxide (SO2), and direct PM2.5 emissions and a 

demonstration that the area will meet the annual standard for fine particles by April 5, 2010. In 

order to satisfy these requirements, Indiana submitted an attainment demonstration to U.S. EPA 

on April 3, 2008, demonstrating that with the combination of clean air measures and the 

implementation of local and federally required control measures, air quality in the nonattainment 

area would meet the annual NAAQS for fine particles by April 5, 2010, with an ample margin of 

safety. The Louisville Area monitors have continued to meet the annual NAAQS for fine 

particles since the end of 2008. 

There were no fine particle monitors in the Louisville Area that violated the 1997 24-hour 

standard for fine particles and none that currently violate the 2006 24-hour standard for fine 

particles. As a result, the Louisville Area was designated nonattainment for fine particles solely 

under the 1997 annual standard. Therefore, this document pertains only to the 1997 annual 

standard for fine particles. 

The Louisville nonattainment area for fine particles, as defined in Section 1.2, has not previously 

been subject to nonattainment area rulemakings for fine particles. However, Clark and Floyd 

counties, Indiana and Bullitt, Oldham, and Jefferson counties, Kentucky, have been subject to 

nonattainment area rulemakings under the 1-hour ozone standard. The 1-hour ozone standard 

was revoked on June 15, 2005. These counties have also been subject to nonattainment 

rulemakings under the 8-hour ozone standard. Clark and Floyd counties were redesignated to 

attainment and classified as maintenance under the 8-hour ozone standard on July 19, 2007. 

Bullitt, Oldham, and Jefferson counties were redesignated to attainment and classified as 

maintenance on August 6, 2007. 
3

1.2 Geographical Description

The Louisville nonattainment area for fine particles consists of Jefferson County (Madison 

Township) and Clark and Floyd counties, Indiana, and Bullitt and Jefferson counties, Kentucky. 

The Louisville Area contains such cities as Clarksville, New Albany, and Madison in Indiana 

and Louisville in Kentucky. This area is depicted in Figure 3.1. 

The agencies responsible for assuring the nonattainment area for fine particles complies with the 

CAA requirements are: 

• IDEM, which is responsible for Jefferson County (Madison Township) and Clark and 

Floyd counties, Indiana. 

• The Louisville Metro Air Pollution Control District (LMAPCD), which is responsible 

for Jefferson County, Kentucky. 

• The Kentucky Department for Environmental Protection (KDEP), which is 

responsible for Bullitt County, Kentucky. The KDEP is requesting redesignation of 

Kentucky’s portion of the nonattainment area. 

 

These three agencies have worked cooperatively with U.S. EPA Regions IV and V to address 

attainment planning issues. 

Although the agencies have worked together on a comprehensive plan for the multi-state 

nonattainment area, the State of Kentucky is required to make a separate submittal for its portion 

of the planning components to U.S. EPA. This submittal only covers Jefferson County (Madison 

Township) and Clark and Floyd counties, Indiana. 

1.3 Status of Air Quality

Monitoring data for fine particles for the three years, 2008 through 2010, demonstrates that air 

quality has met the annual NAAQS for fine particles in the Louisville Area. This fact, 

accompanied by the permanent and enforceable reductions in emission levels discussed in 

Section 4.0, justifies a redesignation to attainment for the area based on Section 107(d)(3)(E) of 

the CAA. 

2.0 REQUIREMENTS FOR REDESIGNATION

2.1 General

Section 110 and Part D of the CAA list a number of requirements that must be met by 

nonattainment areas prior to consideration for redesignation to attainment. In addition, U.S. EPA 

has published detailed guidance in a document entitled “Procedures for Processing Requests to 

Redesignate Areas to Attainment”, issued September 4, 1992, to Regional Air Directors. This 

document is hereafter referred to as “Redesignation Guidance”. This Request for Redesignation 

and Maintenance Plan is based on the Redesignation Guidance, supplemented with additional 
4

guidance received from staff of the Attainment Planning and Maintenance Section of U.S. EPA 

Region V. The specific requirements for redesignation are listed below. 

2.2 Fine Particle Monitoring 

1) A demonstration that the annual standard for fine particles, as published in 40 

Code of Federal Regulations (CFR) 50.13, has been attained. Fine particle 

monitoring data must show that violations of the annual ambient standard are no 

longer occurring. 

 

2) Ambient monitoring data quality-assured in accordance with 40 CFR 58.15, 

recorded in the U.S. EPA Air Quality System (AQS) database, and available for 

public view. 

3) A showing that the three-year average of annual values, based on data from all 

monitoring sites in the area or its affected downwind environs, do not exceed 15.0 

μg/m3

. This showing must rely on three complete, consecutive calendar years of 

quality assured data. 

4) A commitment that, once redesignated, the state will continue to operate an 

appropriate monitoring network to verify the area is in compliance (maintenance) 

with the standard. 

2.3 Emission Inventory 

1) A comprehensive emission inventory of the precursors of fine particles (direct 

PM2.5, NOx, and SO2) completed for the base year (2008, in this case). 

2) A projection of the emission inventory to a year at least ten years following 

redesignation. 

3) A demonstration that the projected level of emissions is sufficient to maintain the 

annual standard for fine particles. 

4) A demonstration that improvement in air quality between the year violations 

occurred and the year attainment was achieved is based on permanent and 

enforceable emission reductions and not on temporary adverse economic 

conditions or unusually favorable meteorology. 

5) Provisions for future updates of the inventory to enable tracking of the emission 

levels, including emission inventory statements from emission sources. 
5

2.4 Modeling Demonstration 

While no modeling is required for redesignating nonattainment areas, IDEM has evaluated the 

results of federal control-case modeling to demonstrate that compliance with the standard will be 

maintained. 

2.5 Controls and Regulations 

1) A U.S. EPA-approved SIP control strategy that includes Reasonably Available 

Control Technology (RACT) requirements for existing stationary sources covered 

by Control Technology Guidelines (CTG) and non-CTG RACT for all major 

sources. 

2) Evidence that control measures required in past SIP revisions have been fully 

implemented. 

 

3) Acceptable provisions to provide for new source review. 

4) Assurances that existing controls will remain in effect after redesignation, unless 

the state demonstrates through photochemical modeling that the standard can be 

maintained without one or more controls. 

5) If appropriate, a commitment to adopt a requirement that all transportation plans 

conform with, and are consistent with, the SIP. 

2.6 Corrective Actions for Potential Future Violations of the Fine Particle Standard

1) A commitment to submit a revised plan eight years after redesignation. 

2) A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

(triggers) or in the event that future violations of the ambient standard occur. 

3) A list of potential contingency measures that would be implemented in such an 

event. 

4) A list of NOx, SO2, and direct PM2.5 sources potentially subject to future controls. 

3.0 FINE PARTICLE MONITORING

3.1 Fine Particle Monitoring Network

There are currently eight Federal Reference Method monitors measuring fine particle 

concentrations in this nonattainment area. Three monitors are located in Indiana’s portion of the 

nonattainment area and are operated by IDEM’s Office of Air Quality (OAQ). Five monitors 
6

located in Kentucky’s portion of the nonattainment area are operated by the LMAPCD. The 

monitor readings from 2008 through 2010 are shown in Tables 3.1, 3.2, and Appendix A and 

were retrieved from U.S. EPA’s AQS database. The locations of the monitoring sites for this 

nonattainment area are shown in Figure 3.1. The Barret Avenue monitor (21-111-0048) located 

in Jefferson County, Kentucky was discontinued on December 31, 2008. 

Figure 3.1 

Louisville Basic Nonattainment Area 

3.2 Ambient Fine Particle Monitoring Data

The following information summarizes U.S. EPA's "Guideline on Data Handling Conventions 

for the PM NAAQS," U.S. EPA-454/R-99-008, April 1999. Three complete years of fine 

particle monitoring data are required to demonstrate attainment at a monitoring site. The annual 

ambient air quality standard for fine particles is met at an ambient air quality monitoring site 
7

when the three-year average of the annual average of fine particle concentrations is less than or 

equal to 15.0 μg/m3

. When this occurs, the site is said to be in attainment. While calculating 

design values, three significant digits must be carried in the computations, with final values 

rounded to the nearest 0.1 μg/m3

. Decimals of 0.05 or greater are rounded up, and those less 

than 0.05 are rounded down, so that 15.049 μg/m3

 is the largest concentration that is less than or 

equal to 15.0 μg/m3. Values at or below 15.0 μg/m3 meet the standard. Values equal to or 

greater than 15.1 μg/m3

 exceed the standard. 

 

Data handling procedures are applied on an individual basis at each monitor in the area. An 

individual site’s three-year average of the annual average fine particle concentration is also 

called the site’s design value. An area is in compliance with the annual NAAQS for fine 

particles only if all monitoring sites meet the NAAQS. The air quality design value for the area 

is the highest design value among all sites in the area. Table 3.1 outlines the annual fine particle 

values by site and the 2008 through 2010 design values for the three active fine particle 

monitoring sites in Indiana’s portion of the Louisville Area. Table 3.2 outlines the annual fine 

particle values by site and the 2008 through 2010 design values for the six fine particle 

monitoring sites (five active and one recently discontinued) in Kentucky’s portion of the 

Louisville Area. Appendix A contains the complete monitoring data summary from 2000 to 

2010 for all of the Louisville Area monitors. 

Table 3.1 

Monitoring Data for Indiana’s Portion of the Louisville Area 

(Annual Average and 2008 through 2010 Design Values) 

SITE ID COUNTY SITE NAME YEAR 

Annual 

Average 

(μg/m3) 

2008-2010 

Design 

Value 

(μg/m3) 

18-019-0006 Clark Jeffersonville – 

Walnut Street 

2008 14.48 

2009 13.01 14.1

2010 14.67 

18-019-0008 Clark Charlestown State Park 

2008 13.44 

2009 10.84 12.2

2010 12.45 

18-089-2004 Floyd New Albany 2008 12.70 

2009 11.91 12.8

2010 13.80 

 Red Text Indicates Incomplete Data 

 The Charlestown State Park monitor began operation on July 2, 2008. 
8

Table 3.2 

Monitoring Data for Kentucky’s Portion of the Louisville Area 

(Annual Average and 2008 through 2010 Design Values) 

SITE ID COUNTY SITE NAME YEAR 

Annual 

Average 

(μg/m3) 

2008-2010 

Design Value 

(μg/m3) 

21-029-0006 Bullitt Shepherdsville 2008 12.84 

2009 11.81 12.70

2010 13.45 

21-111-0043 Jefferson Southern Avenue 2008 13.17 

2009 12.21 12.95

2010 13.47 

21-111-0044 Jefferson Wyandotte Park 2008 13.41 

2009 12.45 13.20

2010 13.74 

21-111-0048 Jefferson Barret Avenue 2008 13.44 

2009 N/A 13.44

2010 N/A 

21-111-0051 Jefferson Watson Elementary 2008 12.78 

2009 11.59 13.07

2010 14.83 

21-111-0067 Jefferson Cannons Lane 2008 N/A 

2009 11.67 12.47

2010 13.27 

Blue Text Indicates Design Value Based on One Year of Data 

Green Text Indicates Design Value Based on Two Years of Data 

The Barrett Avenue monitor discontinued operation on December 31, 2008. 

The Cannons Lane monitor began operation on January 1, 2009. 

Graph 3.1 visually demonstrates the 2006 through 2010 design values for Indiana’s portion of 

the Louisville Area. Graph 3.2 visually demonstrates the 2006 through 2010 design values for 

Kentucky’s portion of the Louisville Area. 
9

Graph 3.1

Fine Particle Design Values for Indiana’s Portion of the Louisville Area, 2006 through 2010 

Red line represents the annualstandard for fine particles of 15 μg/m3.

 

The Charlestown State Park monitor began operation on July 2, 2008. 

Graph 3.2 

Fine Particle Design Values for Kentucky’s Portion of the Louisville Area, 

2006 through 2010 

Red line represents the annual standard for fine particles of 15 μg/m3.

 The Barrett Avenue monitor discontinued operation on December 31, 2008. 

The Cannons Lane monitor began operation on January 1, 2009. 

6.0

8.0

10.0

12.0

14.0

16.0

2006‐2008 2007‐2009 2008‐2010

ug/m3

Jeffersonville ‐ Walnut Street Charlestown State Park New Albany

6.0

8.0

10.0

12.0

14.0

16.0

18.0

Shepherdsville Southern

Avenue

Wyandotte Park Barret Avenue Watson

Elementary

Cannons Lane

21‐029‐0006 21‐111‐0043 21‐111‐0044 21‐111‐0048 21‐111‐0051 21‐111‐0067

ug/m3

2006‐2008 2007‐2009 2008‐2010
10

The design values for Clark and Floyd counties, Indiana, along with the nonattainment area in its 

entirety, demonstrate that the annual NAAQS for fine particles has been attained. 

Graph 3.3 

Annual Fine Particle Trends for Indiana’s Portion of the Louisville Area, 

2006 through 2010 

Red line represents the annual standard for fine particles of 15 μg/m3. 

The Charlestown State Park monitor began operation on July 2, 2008.

Graph 3.4 

Annual Fine Particle Trends for Kentucky’s Portion of the Louisville Area, 

2006 through 2010 

Red line represents the annual standard for fine particles of 15 μg/m3

.

The Barrett Avenue monitor discontinued operation on December 31, 2008. 

 The Cannons Lane monitor began operation on January 1, 2009. 

8.0

10.0

12.0

14.0

16.0

18.0

2006 2007 2008 2009 2010

ug/m3

Jeffersonville ‐ Walnut Street Charlestown State Park New Albany

Year

8.0

10.0

12.0

14.0

16.0

18.0

2006 2007 2008 2009 2010

ug/m3

Shepherdsville Southern Avenue Wyandotte Park

Barret Avenue Watson Elementary Cannons Lane

Year
11

Graphs 3.1 and 3.2 show the trends in design values, while Graphs 3.3 and 3.4 show the trends 

for annual fine particles. The area's design values have recently trended downward, as emissions 

have declined both regionally and locally due to programs such as the Acid Rain program and 

cleaner automobiles and fuels. U.S. EPA’s rule to control nitrogen oxides from specific source 

categories (40 CFR Parts 51, 72, 75, and 96, published on October 17, 1998, and referred to as 

the “NOx SIP Call”) has significantly reduced emissions from large electric generating units 

(EGUs), industrial boilers, and cement kilns. Indiana's NOx SIP Call Rule was adopted into the 

Indiana Administrative Code (IAC) on June 6, 2001 at 326 IAC 10-3 and 326 ICA 10-4. The 

elevated fine particle values for 2005 are considered an abnormal occurrence. An analysis of 

meteorological conditions and monitoring values is included in Section 7.0 and supports the 

conclusion that attainment of the standard as of 2010 is not the result of unusually favorable 

meteorological conditions. It is expected that this downward trend will persist as the above 

programs continue and U.S. EPA’s proposed Clean Air Transport Rule (Transport Rule) is 

implemented. 

3.3 Quality Assurance

Indiana and Kentucky have quality assured all data shown in Appendix A in accordance with 40 

CFR 58.10 and recorded the data in the AQS database and, thus, the data is available to the 

public. 

3.4 Continued Monitoring

Indiana and Kentucky commit to continue monitoring fine particle concentrations at the active 

sites indicated in Tables 3.1 and 3.2, and Appendix A. IDEM will consult with U.S. EPA 

Region V staff prior to making changes to the existing Indiana monitoring network through the 

annual network review should changes become necessary in the future. IDEM will continue to 

quality assure the Indiana monitoring data to meet the requirements of 40 CFR 58. IDEM will 

enter all data into AQS on a timely basis in accordance with federal guidelines. 

4.0 EMISSION INVENTORY 

U.S. EPA’s Redesignation Guidance and Implementation Rule requires the submittal of a 

comprehensive inventory of precursor emissions for fine particles (NOx, SO2, and direct PM2.5) 

representative of the year when the area achieved attainment of the annual NAAQS for fine 

particles (base year). IDEM is using 2008 as the base year. Consistent with the federal 

implementation rule for fine particles, IDEM and U.S. EPA do not consider volatile organic 

compounds (VOCs) or ammonia (NH3) to be significant contributors to fine particles. IDEM 

must also demonstrate that the improvement in air quality between the year that violations 

occurred and the year that attainment was achieved is based on permanent and enforceable 

emission reductions. Other requirements related to the emission inventory include: a projection 

of the emission inventory to a year at least ten years following redesignation; a demonstration 

that the projected level of emissions is sufficient to maintain the annual standard for fine 
12

particles; and a commitment to provide future updates of the inventory to enable tracking of 

emission levels during the ten year maintenance period. The following subsections address each 

of these requirements. 

4.1 Emission Trends

Point Sources

The point source data are obtained from Indiana's emissions reporting program and are based on 

county point source totals. Clark, Floyd, and Jefferson counties, Indiana, had a 7.43% reduction 

in NOx point source emissions, a 19.07% reduction in SO2 point source emissions, and a 11.09% 

reduction in direct PM2.5 point source emissions from 2005 to 2008. Graphs 4.1, 4.2, and 4.3 

demonstrate the trends in point source emissions of NOx, SO2, and direct PM2.5 for these 

counties. 

The Louisville Area had a slight increase of 1.62% NOx point source emissions, a 16.50% 

reduction in SO2 point source emissions, and a 9.07% reduction in direct PM2.5 point source 

emissions from 2005 to 2008. Point source data for the Louisville Area is a combination of data 

from Indiana’s and Kentucky’s emissions reporting programs. Graphs 4.4, 4.5, and 4.6 show the 

trends in point source emissions of total NOx, SO2, and direct PM2.5 emissions for the Louisville 

Area. Graphs and data tables of emissions for the point source category can be found in 

Appendix B. 

Graph 4.1 

NOx Point Source Emissions Trend, Clark, Floyd, and Jefferson Counties, Indiana, 

2005 and 2008 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

2005 2008

Tons per Year

Nitrogen Oxides

Year
13

Graph 4.2 

SO2 Point Source Emissions Trend, Clark, Floyd, and Jefferson Counties, 

Indiana, 2005 and 2008 

Graph 4.3 

Direct PM2.5 Point Source Emissions Trend, Clark, Floyd, and Jefferson Counties, Indiana, 

2005 and 2008 

0

200

400

600

800

1,000

1,200

1,400

2005 2008

Tons per Year

Fine Particles Year

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

2005 2008

Tons per Year

Sulfur Dioxide Year
14

Graph 4.4 

NOx Point Source Emissions Trend, Louisville Area, 2005 and 2008 

Graph 4.5 

SO2 Point Source Emissions Trend, Louisville Area, 2005 and 2008 

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

2005 2008

Tons per Year

Nitrogen Oxides Year

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

2005 2008

Tons per Year

Sulfur Dioxide Year
15

Graph 4.6 

Direct PM2.5 Point Source Emissions Trend, Louisville Area, 2005 and 2008 

All Anthropogenic Sources

Periodic inventories, which include emissions from all sectors (mobile, area, nonroad, and point 

source), were prepared for 2005 and 2008. The 2008 data were extrapolated from the 2005 

emission inventory. Regional NOx emission reductions affect fine particle levels in the 

Louisville Area far more so than NOx emission reductions within the nonattainment area itself. 

These emission trends roughly follow the years of monitored trends discussed in Section 3.0. 

There is a downward trend in NOx and SO2 emissions from 2005 to 2008 in Clark, Floyd and 

Jefferson counties, Indiana, as well as the Louisville Area. The decrease in NOx can be largely 

attributed to the impact of the NOx SIP Call. Graphs and data tables of emissions from each 

source category are available in Appendix C. 

Mobile emission inventories and projections for all counties in the Louisville Area were prepared 

by the Kentuckiana Regional Planning and Development Agency (KIPDA), Indiana Department 

of Transportation (INDOT), and IDEM and are explained in further detail in Section 5.0. All 

2005 data for Clark, Floyd, and Jefferson counties, Indiana are from the 2005 periodic inventory 

which has been identified as one of the preferred databases for SIP development. All 2008 

emissions were extrapolated from the 2005 Lake Michigan Air Directors Consortium’s 

(LADCO’s) modeling inventory, using LADCO’s growth factors, for all sectors except point 

sources (electrical generating units and non-electrical generating units). Point source emissions 

for 2008 were compiled from Indiana’s annual emission inventory database. 

0

1,000

2,000

3,000

4,000

5,000

6,000

2005 2008

Tons per Year

Fine Particles Year
16

Graphs 4.7, 4.8, and 4.9 show the trends in anthropogenic emissions for Clark, Floyd, and 

Jefferson counties, Indiana. Graphs 4.10, 4.11, and 4.12 show the trends in anthropogenic 

emissions for the Louisville Area. The emission inventory development and emissions 

projection discussion below, with the exception of the mobile emission inventory and 

projections, identify procedures used by IDEM and LADCO regarding emissions for the 

Louisville Area. 

Graph 4.7 

NOx Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana, 

2005 and 2008 

 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

2005 2008

Tons per Year

Nitrogen Oxides Year
17

Graph 4.8 

SO2 Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana, 

2005 and 2008 

Graph 4.9 

Direct PM2.5 Emissions Trend, All Sources, Clark, Floyd, and Jefferson Counties, Indiana, 

2005 and 2008 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

2005 2008

Tons per Year

Sulfur Dioxide Year

0

500

1,000

1,500

2,000

2005 2008

Tons per Year

Fine Particles Year
18

Graph 4.10 

NOx Emissions Trend, All Sources, Louisville Area, 2005 and 2008 

Graph 4.11 

SO2 Emissions Trend, All Sources, Louisville Area, 2005 and 2008 

0

20,000

40,000

60,000

80,000

100,000

120,000

2005 2008

Tons per Year

Nitrogen Oxides Year

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

2005 2008

Tons per Year

Sulfur Dioxide Year
19

Graph 4.12 

Direct PM2.5 Emissions Trend, All Sources, Louisville Area, 2005 and 2008 

EGU Sources

Both NOx and SO2 emissions have decreased substantially in the Louisville Area in response to 

national programs affecting all EGUs, such as the Acid Rain program and the NOx SIP Call. 

Other sectors of the inventory also impact the formation of fine particles, but large regional 

sources, such as EGUs, have a substantial impact on the formation of fine particles. The data 

was taken from U.S. EPA's Clean Air Markets database.1

As part of the NOx SIP Call, the states were required to adopt into their rules a budget for all 

large EGUs. Indiana’s budget is referenced in 326 IAC 10-4. The budget represents a statewide 

cap on NOx emissions. Although each unit is allocated emissions based upon historic heat input, 

utilities can meet this budget by over-controlling certain units or purchasing credits from the 

market to account for overages at other units. To summarize, NOx emissions have dramatically 

decreased over the years represented on these graphs. 

These emissions, capped by the state rule, are expected to remain near these levels throughout 

the maintenance period covered by this request. The state cap for the NOx SIP Call remained in 

place through 2008, at which time the Clean Air Interstate Rule (CAIR) program superseded it. 

CAIR, issued in March 2005, adopted by the Indiana Air Pollution Control Board on November 

1, 2006, and implemented beginning in 2010, will continue to reduce regional EGU NOx

emissions statewide by approximately another 17% by 2015 and 57% for EGU SO2 emissions by 

 

1

 http://www.epa.gov/airmarkets 

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

10,000

2005 2008

Tons per Year

Fine Particles Year
20

2015. The D.C. Circuit court’s vacatur of CAIR in July of 2008 and subsequent remand without 

vacatur of CAIR in December 2008, directs U.S. EPA to revise the CAIR rule in the future. The 

proposed Clean Air Transport Rule (CAIR’s replacement rule) will result in similar or greater 

emission reductions than assumed within the current emission inventories once it is 

implemented. 

There are two EGUs located in Indiana’s portion of the nonattainment area: The Duke Energy 

Indiana – Gallagher Generating Station in Floyd County, Indiana and the Indiana Kentucky 

Electric Corporation (IKEC) – Clifty Creek Power Plant in Jefferson County, Indiana. As the 

result of a recent settlement with U.S. EPA to resolve violations of the CAA’s new source review 

requirements, the Duke Energy Indiana – Gallagher Generating Station will be shutting down 

two of its four coal-fired EGUs (Units 1 and 3) by no later than February 1, 2012. The 

settlement also establishes overall NOx and SO2 caps. The remaining units (Units 2 and 4) have 

recently installed dry sorbent control technology to reduce SO2. Graphs 4.13 and 4.14 depict the 

trends in NOx and SO2 EGU emissions in Floyd and Jefferson counties, Indiana for the years 

1999 through 2009. Graphs 4.15 and 4.16 depict the trends in NOx and SO2 emissions from 

EGUs in the Louisville Area for the years 1999 through 2009. Graphs and data tables of 

emissions from the EGU source category can be found in Appendix D.

Graph 4.13

NOx Emissions from EGUs, Floyd and Jefferson Counties, Indiana, 1999 to 2009 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Tons per Year

Nitrogen Oxides Year
21

Graph 4.14

SO2 Emissions from EGUs, Floyd, and Jefferson Counties, Indiana, 1999 to 2009 

Graph 4.15 

NOx Emissions from EGUs, Louisville Area, 1999 to 2009 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Tons per Year

Sulfur Dioxide Year

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Tons per Year

Nitrogen Oxides Year
22

Graph 4.16 

SO2 Emissions from EGUs, Louisville Area, 1999 to 2009 

4.2 Base Year Inventory

IDEM prepared a comprehensive inventory for the Louisville Area, including area, mobile, 

nonroad, and point sources for direct PM2.5, NOx, and SO2 for 2005 and 2008 (the years with the 

most complete emission inventory available at this time). The 2008 emission inventory 

represents a base year for maintenance purposes. The 2007 implementation rule for the annual 

standard for fine particles states that NOx, SO2, and direct PM2.5 are the regulated precursors for 

fine particles. Ammonia and VOCs are not required to be addressed unless the state or U.S. EPA 

make a technical demonstration that emissions of these pollutants from sources in the state 

significantly contribute to PM2.5 concentrations in a given nonattainment area. U.S. EPA and 

IDEM have not determined that ammonia or VOCs are significant contributors to fine particles 

formation in Indiana. IDEM’s 2008 base year inventory was developed as follows: 

 Area sources were extrapolated from the Indiana 2005 periodic inventory submitted to 

U.S. EPA. 

 Mobile source emissions were calculated from U.S. EPA’s Motor Vehicle Emission 

Simulator (MOVES) model-produced emission factors and data extracted from the 

region’s travel-demand model. These emissions were then interpolated as needed to 

determine 2008 base year values. 

 Point source information was compiled from IDEM’s emission inventory database and 

U.S. EPA's Clean Air Markets acid rain database. 

 Biogenic emissions are not specifically included in these summaries, but are included in 

the photochemical modeling results presented in Section 7.0. 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Tons per Year

Sulfur Dioxide Year
23

 Nonroad emissions were extrapolated from the 2005 National Emissions Inventory 

(NEI). To address concerns about the accuracy of some of the categories in U.S. EPA’s 

nonroad emissions model, LADCO contracted with two companies to review the base 

data and make recommendations. One of the contractors also estimated emissions for 

two nonroad categories not included in U.S. EPA's nonroad model. Emissions were 

estimated for commercial marine vessels and railroads. The recreational motorboat 

population and spatial surrogates (used to assign emissions to each) were also 

significantly updated. The populations for the construction equipment category were also 

reviewed and updated based upon surveys completed in the Midwest. The temporal 

allocation for agricultural sources was also updated. A new nonroad estimation model 

was provided by U.S. EPA for the 2005 analysis. 

● Area, nonroad, mobile, and point source emissions data referenced for Kentucky’s 

portion of the Louisville Area were provided by LAMPCD, KDEP, and KIPDA. This 

inventory was prepared using similar methodologies. 

Appendix C contains data tables and graphs of these emissions. 

4.3 Emission Projections

In consultation with U.S. EPA and other stakeholders, IDEM selected the year 2025 as the 

maintenance year for this redesignation request. This document contains projected emission 

inventories for 2015 and 2025. These emission projections were prepared by IDEM, with 

assistance from LADCO, LAMPCD, KDEP, and KIPDA. 

The detailed 2015 and 2025 emission inventory for the Louisville Area can be found in 

Appendix E. Emission trends are an important gauge for continued compliance with the annual 

standard for fine particles. Therefore, IDEM performed an initial comparison of the inventories 

for the base year of 2008, interim year of 2015, and maintenance year of 2025 for Clark, Floyd, 

and Jefferson counties, Indiana, as well as the entire Louisville Area. 

The 2005 LADCO modeling inventory was used as the basis for estimated emissions for the 

years 2008, 2015, and 2025, using LADCO’s growth factors, for all sectors except point sources 

(electric generating units and non-electric generating units). Point source emissions for 2005 and 

2008 were compiled from Indiana’s annual emission inventory database. The 2015 interim year 

emissions were interpolated based on the 2009 and 2018 LADCO modeling inventory, using 

LADCO’s growth factors, for all sectors. The 2025 maintenance year emissions were 

extrapolated from the 2018 LADCO modeling inventory. 

The projected emission inventories for 2015 and 2025 for Kentucky’s portion of the Louisville 

Area were provided by LAMPCD, KDEP, and KIPDA. 

Graphs 4.17, 4.18, 4.19, and 4.20 visually compare 2005 and 2008 (base year) NOx, SO2, and 

direct PM2.5 total estimated emissions with the 2015 and 2025 projected emissions for Clark, 

Floyd, and Jefferson counties, Indiana. Graphs 4.21, 4.22, 4.23, and 4.24 visually compare the 

2005 and 2008 (base year) NOx, SO2, and direct PM2.5 total estimated emissions with the 2015 

and 2025 projected emissions for the Louisville Area. Mobile source emission inventories are 
24

further described in Section 5.0. In addition to LADCO’s estimates, point source emissions were 

projected based upon the statewide EGU NOx budgets from Indiana’s NOx rule. NOx and SO2

EGU emission estimates for 2015 and 2025 for the IKEC – Clifty Creek Power Plant were 

projected using the budgets from the proposed Clean Air Transport Rule and Options 1 and 2 

from the recent Notice of Data Availability. Since it is likely that the finalized rule will include a 

budget approximating one of these, IDEM used the option with the highest allotment to develop 

conservative projections. Further, the Duke Energy Indiana/U.S. EPA consent decree provides 

overall NOx and SO2 caps for the Duke Energy – Gallagher Generating Station in Floyd County, 

Indiana. The emissions allowed under these caps are similar to those in the Transport Rule. 

Therefore, IDEM is confident that NOx and SO2 emissions in 2015 and 2025 will be close to or 

below the projections. Additionally, the SO2 and NOx allocations for the Duke Energy Indiana – 

Gallagher Generating Station and IKEC – Clifty Creek Power Plant for 2014 and beyond within 

the proposed Clean Air Transport Rule are less than 2009 actual emissions. Direct PM2.5

emission estimates for 2015 and 2025 for the IKEC – Clifty Creek Power Plant were projected 

using the limits from the new proposed National Emission Standards for Hazardous Air 

Pollutants for coal and oil-fired EGUs. The Duke Energy – Gallagher Generating Station 

replaced the electrostatic precipitators with baghouses on all four of their EGU units in late 2007 

and early 2008. This reduced direct PM2.5 emissions below base year levels. Duke Energy 

Indiana will also be shutting down two of its four coal-fired EGUs (Units 1 and 3) by no later 

than February 1, 2012. The remaining units (Units 2 and 4) have recently installed dry sorbent 

control technology to reduce SO2. This will further reduce direct PM2.5 emissions below base 

year levels. 

The Tennessee Valley Authority has also recently entered into a consent decree with U.S. EPA 

that establishes system-wide annual tonnage limits for NOx and SO2 for its eleven coal-fired 

power plants located in Alabama, Kentucky, and Tennessee. NOx will be limited to 100,600 tons 

per year beginning in 2011 and capped at 52,000 tons per year in 2018 and each year thereafter. 

SO2 will be limited to 285,000 tons per year beginning in 2011 and capped at 110,000 tons per 

year in 2019 and each year thereafter. This will result in significant regional NOx and SO2

reductions, further ensuring that the area will continue to maintain compliance with the standard 

with an increasing margin of safety. Graphs and data tables of emissions from the EGU source 

category can be found in Appendix D. 
25

Graph 4.17 

Comparison of 2005, 2008, 2015, and 2025 Projected NOx Emissions, Clark, Floyd, and 

Jefferson Counties, Indiana 

Graph 4.18 

Comparison of 2005, 2008, 2015, and 2025 Projected SO2 Emissions, Clark, Floyd, and 

Jefferson Counties, Indiana 

0

10,000

20,000

30,000

40,000

50,000

60,000

2005 2008 2015 2025

Tons per Year

Nitrogen Oxides Year

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

2005 2008 2015 2025

Tons per Year

Sulfur Dioxide Year
26

Graph 4.19 

Comparison of 2005, 2008, 2015, and 2025 Projected Direct PM2.5 Emissions, Clark, Floyd, 

and Jefferson Counties, Indiana 

Graph 4.20 

Comparison of 2005, 2008, 2015, and 2025 Projected NOx, SO2, and Direct PM2.5 Emissions, 

Clark, Floyd, and Jefferson Counties, Indiana 

0

500

1,000

1,500

2,000

2005 2008 2015 2025

Tons per Year

Fine Particles Year

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

2005 2008 2015 2025

Tons per Year

Nitrogen Oxides Sulfur Dioxide Fine Particles

Year
27

Graph 4.21 

Comparison of 2005, 2008, 2015, and 2025 Projected NOx Emissions, Louisville Area 

Graph 4.22 

Comparison of 2005, 2008, 2015, and 2025 Projected SO2 Emissions, Louisville Area 

0

20,000

40,000

60,000

80,000

100,000

120,000

2005 2008 2015 2025

Tons per Year

Nitrogen Oxides Year

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

2005 2008 2015 2025

Tons per Year

Sulfur Dioxide Year
28

Graph 4.23 

Comparison of 2005, 2008, 2015, and 2025 Projected Direct PM2.5 Emissions, 

Louisville Area 

Graph 4.24 

Comparison of 2005, 2008, 2015 and 2025 Projected NOx, SO2, and 

Direct PM2.5 Emissions, Louisville Area 

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

10,000

2005 2008 2015 2025

Tons per Year

Fine Particles Year

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

2005 2008 2015 2025

Tons per Year

Nitrogen Oxides Sulfur Dioxide Fine Particles

Year
29

NOx emissions within Clark, Floyd, and Jefferson counties, Indiana are projected to decline by 

47.70% between 2008 and 2025. NOx emissions within the Louisville Area are projected to 

decline by 39.04% between 2008 and 2025. Emission reduction benefits from U.S. EPA rules 

covering the NOx SIP Call, Tier 2 Motor Vehicle Emission Standards and Gasoline Sulfur 

Control Requirements, Heavy-Duty Highway Engine Rule, and the Nonroad Diesel Engine Rule

are factored into the changes. Additionally, due to implementation of the NOx SIP Call across 

the eastern United States, NOx and fine particle levels entering the Louisville Area will also be 

decreased. SO2 emissions within Clark, Floyd, and Jefferson counties, Indiana are projected to 

decrease by 69.52% between 2008 and 2025. SO2 emissions within the Louisville Area are 

projected to decline by 49.78% between 2008 and 2025. Direct PM2.5 emissions within Clark, 

Floyd, and Jefferson counties, Indiana are projected to decrease by 12.35% between 2008 and 

2025. Direct PM2.5 emissions within the Louisville Area are projected to decline by 24.81% 

between 2008 and 2025. 

Table 4.1 

Comparison of 2008 Estimated and 2025 Projected Emission Estimates, 

Clark, Floyd, and Jefferson Counties, Indiana (Tons per Year) 

 2008 2025 Change % Change 

NOx 37,526.06 19,627.44 -17,898.62 47.70% decrease 

SO2 109,372.52 33,340.99 -76,031.53 69.52% decrease 

Direct PM2.5 1,202.47 1,054.00 -148.47 12.35% decrease 

Table 4.2 

Comparison of 2008 Estimated and 2025 Projected Emission Estimates, 

Louisville Area (Tons per Year)

 2008 2025 Change % Change 

NOx 97,533.93 59,455.17 -38,078.76 39.04% decrease 

SO2 151,503.01 76,082.07 -75,420.94 49.78% decrease 

Direct PM2.5 6,724.02 5,055.61 -1,668.41 24.81% decrease 

4.4 Demonstration of Maintenance

Quality-assured ambient air quality data from all the monitoring sites indicate that air quality in 

Indiana’s portion of the nonattainment area met the annual standard for fine particles for the 

three-year period ending in 2010. U.S. EPA’s Redesignation Guidance states, “A state may 

generally demonstrate maintenance of the NAAQS by either showing that future emissions of a 

pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling 

to show that the future mix of sources and emission rates will not cause a violation of the 

NAAQS”. Section 3.0 of this document shows that the Louisville Area has, in fact, measured 

attainment for fine particles for the three consecutive periods ending in 2008, 2009, and 2010. 

Additionally, emission projections outlined in Section 4.0 of this document clearly illustrate that 

regional NOx, SO2, and direct PM2.5 emissions in the area will continue to decline leading to 
30

local reductions between 2008 (base year) and 2025 (maintenance plan horizon). Section 7.0 

further discusses the implications of these emission trends and provides an analysis to support 

these conclusions. 

 

In Indiana, major point sources in all counties are required to submit emissions information once 

every three years, or annually, if the NOx or SO2 potential to emit is greater than 2,500 tons per 

year, in accordance with the Emission Reporting Rule, 326 IAC 2-6. IDEM prepares a new 

periodic inventory for all precursor emission sectors every three years. These precursor emission 

inventories will be prepared for 2011, 2014, and 2017, as necessary, to comply with the 

inventory reporting requirements established in the CAA. Emissions information will be 

compared to the 2008 base year and the 2025 projected maintenance year inventories to assess 

emission trends, as necessary, to assure continued compliance with the annual standard for fine 

particles. 

4.5 Permanent and Enforceable Emission Reductions

Permanent and enforceable reductions of NOx and SO2 have contributed to the attainment of the 

annual standard for fine particles. Some of these reductions were due to the implementation of 

the NOx SIP Call rule and some were due to the application of tighter federal standards on motor 

vehicles and fuels. 

Section 6.0 identifies the emission control measures specific to Clark, Floyd, and Jefferson 

counties, Indiana, as well as the implementation status of each measure. 

4.6 Provisions for Future Updates 

 

As required by Section 175A(b) of the CAA, Indiana commits to submit to the Administrator, 

eight years after redesignation, an additional revision of this SIP. The revision will contain 

Indiana's plan for maintaining the national primary fine particles air quality standard for ten years 

beyond the first ten-year period after redesignation. 

5.0 TRANSPORTATION CONFORMITY BUDGETS 

U.S. EPA requirements outlined in 40 CFR 93.118(e)(4) stipulate that motor vehicle emission 

budgets (MVEBs) for direct PM2.5 and NOx be established as part of a SIP. The MVEBs are 

necessary to demonstrate conformance of transportation plans and improvement programs with 

the SIP. 

The following is a summary of the detailed mobile input and output calculation files located in 

Appendix F. 

5.1 Onroad Emission Estimates

KIPDA is the Metropolitan Planning Organization (MPO) for Clark and Floyd Counties in 

Indiana, as well as Bullitt, Jefferson, and Oldham Counties in Kentucky. All of the MPO 
31

counties except for Oldham County are in the nonattainment area for fine particles. Madison 

Township in Jefferson County, Indiana is also in the nonattainment area. KIPDA maintains a 

travel demand forecast model that is used to simulate the traffic in the area and to predict what 

traffic would be in future years given growth expectations. The model is used mostly to identify 

where travel capacity will be needed and to determine the infrastructure requirements necessary 

to meet that need. It is also used to support the calculation of mobile source emissions. The 

travel demand forecast model is used to predict the total daily vehicle miles traveled (VMT) and 

the U.S. EPA software program referred to as MOVES is used to produce emission factors to 

calculate the emissions per mile. The product of these two outputs, once combined, is the 

estimated total amount of pollution emitted by the onroad vehicles for the area analyzed. 

Madison Township in Jefferson County, Indiana does not fall under the jurisdiction of KIPDA. 

In cases such as this, INDOT’s Highway Performance Monitoring System (HPMS) baseline data 

is used to estimate and project mobile source emissions. This is a national program that requires 

state Departments of Transportation to collect traffic counts throughout the state on a regular 

basis under a certain regulated method. This HPMS data is collected and provided by INDOT 

and was used for these areas beyond KIPDA’s jurisdiction. 

5.2 Overview 

Broadly described, MOVES is used to generate “emission factors”, which are the average 

emissions per mile (grams/mile) for fine particle precursors, including NOx, SO2, and direct 

PM2.5. There are numerous variables that can affect the emission factors. The vehicle fleet 

(vehicles on the road), age, and the vehicle types have a major effect on the emission factors. 

The facility-type on which vehicles are traveling (MOVES facility types are Freeway, Arterial, 

Local, and Ramp) and the vehicle speeds also affect the emission factor values. Meteorological 

factors such as air temperature and humidity affect emission factors, as does fuel type, such as 

low Reid Vapor Pressure gasoline. These data are estimated using the best available data to 

create emission factors for NOx, SO2, and direct PM2.5. After emission factors are generated, 

they must be multiplied by the VMT to determine the quantity of vehicle-related emissions. This 

information is derived from the travel demand model (TDM). 

It should be noted that each year analyzed will have different emission factors, volumes, speeds, 

and likely results in additional modeling. MOVES input summary and RunSpec parameters can 

be found in Appendix F. The full MOVES modeling package, including input and output 

documentation, is provided electronically in Appendix F. 

5.3 Emission Estimations

Table 5.1 outlines the onroad emission estimates for the entire nonattainment area for the years 

2005, 2008 (base/attainment year), 2015 (interim year), and 2025 (horizon year). The following 

emission estimates are based on the actual TDM network runs for the years 2005, 2008, 2015, 

and 2025. 
32

Table 5.1 

Emission Estimations for Onroad Mobile Sources for the Louisville Area 

Kentucky Emissions 

(Bullitt and Jefferson County) 2005 2008 2015 2025 

Direct PM2.5 (tons/year) 805.38 712.46 395.37 217.84

NOx (tons/year) 25,193.80 21,914.85 12,042.31 6,285.38

Indiana Emissions 

(Madison Township in Jefferson 

County, Clark and Floyd Counties) 

Direct PM2.5 (tons/year) 250.23 210.91 109.58 63.93

NOx (tons/year) 7,550.76 6,245.60 3,349.82 1,811.80

Louisville Area Emission Totals 

Direct PM2.5 (tons/year) 1,055.61 923.37 504.95 281.77

NOx (tons/year) 32,744.56 28,160.45 15,392.13 8,097.18

Table 5.2 contains the MVEBs for the entire nonattainment area for the years 2015 and 2025. 

Table 5.2 

Motor Vehicle Emission Budgets for the Louisville Area 

2015 2025 

Direct PM2.5 

(tons/year) 580.69 324.04 

NOx (tons/year) 17,700.95 9,311.76 

Consistent with the federal implementation rule for fine particles, IDEM does not consider 

mobile source SO2 emissions to be a significant contributor to fine particles for this 

nonattainment area, as SO2 from mobile sources constitutes less than 0.2% of the area’s total 

anthropogenic SO2 emissions for the years 2005, 2008, 2015, and 2025. 

This document creates an interim year budget for 2015 and a horizon year budget for 2025 for 

the entire nonattainment area. These budgets are based on the 2008 onroad source emission 

inventory used to support photochemical modeling for the same year, and has incorporated an 

appropriate safety margin as described below. 

In an effort to accommodate future variations in TDMs and the VMT forecast when no change to 

the network is planned, IDEM consulted with the interagency consultation group, including U.S. 

EPA Region V, to determine a reasonable approach to address this variation. The interagency 

consultation group approved a 15% safety margin for direct PM2.5 mobile source emission 

estimates for the years 2015 and 2025, and a 15% safety margin for NOx mobile source emission 

estimates for the years 2015 and 2025. 
33

The safety margins are appropriate because: 1) there is an acknowledged potential variation in 

the VMT forecast and potential estimated mobile source emissions due to expected modifications 

to TDM and mobile emissions models; and, 2) the total decrease in emissions from all sources is 

sufficient to accommodate the safety margin allocations detailed above to mobile sources while 

still continuing to maintain total emissions in the Louisville Area well below the 2008 attainment 

level of emissions. These safety margins were calculated by adding a straight-line percentage to 

the mobile source emission estimates for the years 2015 and 2025. Safety margin, as defined by 

the conformity rule, looks at the total emissions from all sources in the nonattainment area. The 

resulting 2015 and 2025 MVEBs for direct PM2.5 and NOx emissions remain well below the 

2008 base year emissions referenced in Table 5.1. 

In summary, for Indiana and Kentucky combined, the mobile budget safety margin allocation 

translates into: 

 An allocation of 75.74 tons/year for PM2.5 and 2,308.82 tons/year for NOx for 2015. 

 An allocation of 42.27 tons/year for PM2.5 and 1,214.58 tons/year for NOx for 2025. 

The federal rule at 40 CFR 93.101 defines safety margin as the amount by which the total 

projected emissions from all sources of a given pollutant are less than the total emissions that 

would satisfy the applicable requirement for reasonable further progress, attainment, or 

maintenance. When compared to the overall safety margin as defined by 40 CFR 93.101, it is 

evident that this allocation to mobile sources is significantly below the total safety margin for all 

sources in the Louisville Area as detailed in Table 4.2. 

While IDEM believes that this is sufficient to support the requested increase, IDEM and its 

partners will be conducting additional air quality modeling which will include the adjusted 

mobile source emissions, as well as any additional corrections and modifications that may be 

necessary due to the constant review and evaluation of the model inputs. 

All methodologies, latest planning assumptions, and margins of safety were determined to be 

appropriate through the interagency consultation process. 

6.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures that have been or will be 

implemented in Jefferson County (Madison Township) and Clark and Floyd counties, Indiana, 

including CAA requirements and additional state or local measures implemented beyond CAA 

requirements. 

6.1 Reasonably Available Control Technology (RACT)

 As required by Section 172 of the CAA, in the mid-1990s, Indiana promulgated rules requiring 

RACT for emissions of VOCs. There were no specific rules required by the CAA, such as 

RACT for existing sources, beyond statewide rules. Statewide RACT rules have applied to all 
34

new sources locating in Indiana since that time. The Indiana rules are found in 326 IAC 8. The 

following is a listing of applicable rules: 

 326 IAC 8-1-6 Best Available Control Technology for Non-Specific Sources 

326 IAC 8-2 Surface Coating Emission Limitations 

326 IAC 8-3 Solvent Degreasing Operations 

326 IAC 8-4 Petroleum Sources 

326 IAC 8-5 Miscellaneous Operation 

326 IAC 8-6 Organic Solvent Emission Limitations 

Since Jefferson County (Madison Township) and Clark and Floyd counties, Indiana attained the 

annual standard for fine particles prior to an Attainment SIP or RACT SIP being due, and since 

the Implementation Rule for fine particles stipulates that states are only required to draft and 

implement RACT rules for the precursor emission reductions necessary to attain the standard, no 

further RACT rules are required for this area. These Indiana rules are CAA requirements already 

in the SIP and provide secondary benefits for PM2.5. 

6.2 Implementation of Past SIP Revisions

The Louisville Area was designated nonattainment for the annual standard for fine particles in 

2003 and the area attained the standard well in advance of its attainment deadline of 2010. As a 

result, Indiana is no longer required to develop and submit an Attainment SIP or RACT SIP for 

this area under the annual NAAQS for fine particles. 

6.3 Nitrogen Oxides Rule

The U.S. EPA NOx SIP Call required twenty-two states to adopt rules that would result in 

significant emission reductions from large EGUs, industrial boilers, and cement kilns in the 

eastern United States. The Indiana rule was adopted in 2001. Beginning in 2004, this rule 

accounts for a reduction of approximately 31% of all NOx emissions statewide compared to 

previous uncontrolled years. 

Twenty-one other states have also adopted these rules. The result is that significant reductions 

have occurred regionally and within the nonattainment area because of the number of affected 

units within the region. From Graphs 4.13 and 4.15, it can be seen that emissions covered by this 

program have been trending downward since 1999. Table 6.1, compiled from data taken from 

the U.S. EPA Clean Air Markets web site, quantifies the gradual NOx reductions that have 

occurred in Indiana as a result of Title IV (Acid Rain) of the CAA and the NOx SIP Call Rule. 

The NOx SIP Call cap stayed in place through 2008, at which time the caps in the CAIR 

program superseded it. Since CAIR is a regional cap and trade program, it cannot be predicted at 

this time what affect this will have on EGU units located in the nonattainment area or other 

upwind counties. 

Further, U.S. EPA published Phase II of the NOx SIP Call that established a budget for large 

(emissions of greater than 1 ton per day) stationary internal combustion engines. In Indiana, the 

rule decreases emissions statewide from natural gas compressor stations by 4,263 tons during the 
35

ozone season (April through September). The Indiana Phase II NOx SIP Call Rule became 

effective February 26, 2006 and implementation began in 2007. 

Table 6.1 

Trends in EGU NOx Emissions Statewide in Indiana 

Year NOx Emissions (tons/year) 

1999 347,216.5 

2000 334,522.1 

2001 315,419.7 

2002 281,146.1 

2003 260,980.0 

2004 224,311.3 

2005 207,981.6 

2006 202,728.0 

2007 196,553.1 

2008 196,134.5 

2009 110,968.9 

Budget 2009-2014 108,935 

Budget 2015 and later 90,779 

6.4 Measures Beyond Clean Air Act SIP Requirements

Reductions in fine particle precursor emissions have occurred, or are anticipated to occur, as a 

result of local and federal programs. These additional control measures include those listed in 

this section. 

Tier 2 Vehicle Standards2

Federal Tier 2 motor vehicle standards require all passenger vehicles in a manufacturer’s fleet, 

including light-duty trucks and sport utility vehicles (SUVs), to meet an average standard of 0.07 

grams of NOx per mile. Implementation began in 2004 and was completed in 2007. The Tier 2 

standards also cover passenger vehicles over 8,500 pounds gross vehicle weight rating (larger 

pickup trucks and SUVs), which are not covered by the current Tier 1 standards. For these 

vehicles, the standards were phased in beginning in 2008, with full compliance in 2009. The 

new standards require vehicles to be 77% to 95% cleaner than those on the road prior to the 

program. The Tier 2 standards also reduced the sulfur content of gasoline to 30 parts per million 

(ppm) beginning in January 2006. Most gasoline sold in Indiana prior to January 2006 had a 

sulfur content of about 500 ppm. Sulfur occurs naturally in gasoline, but interferes with the 

operation of catalytic converters on vehicles resulting in higher NOx emissions. Lower sulfur 

gasoline is necessary to achieve the Tier 2 vehicle emission standards. 

 

2 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm
36

Heavy-Duty Gasoline and Diesel Highway Vehicle Standards3

New U.S. EPA standards designed to reduce NOx and VOC emissions from heavy-duty gasoline 

and diesel highway vehicles took effect in 2004. A second phase of standards and testing 

procedures that began in 2007, reduced PM2.5 emissions from heavy-duty highway engines and 

also reduced highway diesel fuel sulfur content to 15 ppm since the sulfur can damage emission 

control devices. The total program is expected to achieve a 90% reduction in direct PM2.5

emissions and a 95% reduction in NOx emissions for these new engines using low sulfur diesel,

compared to existing engines using higher sulfur content diesel. There will also be SO2

reductions from these rules although U.S. EPA has not quantified the expected reductions. 

Large Nonroad Diesel Engine Standards4

In May 2004, U.S. EPA promulgated new rules for large nonroad diesel engines, such as those 

used in construction, agricultural, and industrial equipment, to be phased in between 2008 and 

2014. The nonroad diesel rules also reduce the allowable sulfur in nonroad diesel fuel by over 

99%. Prior to 2006, nonroad diesel fuel averaged approximately 3,400 ppm sulfur. This rule 

limited nonroad diesel sulfur content to 500 ppm by 2006 with a further reduction to 15 ppm by 

2010. The combined engine and fuel rules will reduce NOx and PM emissions from large 

nonroad diesel engines by over 90%, compared to current nonroad engines using higher sulfur 

content diesel. 

Nonroad Spark-Ignition Engines and Recreational Engine Standards

This standard, effective in July 2003, regulates NOx, VOCs, and carbon monoxide (CO) for 

groups of previously unregulated nonroad engines. The standard applies to all new engines sold 

in the United States and imported after the standards went into effect. The standard applies to 

large spark-ignition engines (forklifts and airport ground service equipment), recreational 

vehicles (off-highway motorcycles and all-terrain vehicles), and recreational marine diesel 

engines. The regulation varies based upon the type of engine and vehicle. 

The emissions from large spark-ignition engines contribute to ozone formation and ambient CO 

and PM2.5 levels in urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 

started in 2007. Like the large spark-ignition engines, emissions from recreational vehicles 

contribute to ozone and fine particle formation and ambient CO and PM2.5 levels. For Model 

Year 2006 off-highway motorcycles and all-terrain vehicles, at least 50% of a manufacture’s 

fleet was required to meet the new exhaust emissions standard and 100% of the fleet was 

required to meet the standards in 2007. Recreational marine diesel engines over 37 kilowatts are 

used in yachts, cruisers, and other types of pleasure craft. Emissions from recreational marine 

engines contribute to ozone formation and PM levels, especially surrounding marinas. 

When all of the nonroad spark-ignition engines and recreational engine standards are fully 

implemented, an overall 72% reduction in VOC, 80% reduction in NOx, and 56% reduction in 

CO emissions is expected by 2020.

 

3 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 4 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm
37

Reciprocating Internal Combustion Engine Standards5

This new standard, effective in May 2010, regulates emissions of air toxics from existing diesel 

powered stationary reciprocating internal combustion engines that meet specific site rating, age, 

and size criteria. These engines are typically used at industrial facilities (e.g. power, chemical, 

and manufacturing plants) to generate electricity for compressors and pumps and to produce 

electricity to pump water for flood and fire control during emergencies. 

The standard applies to stationary diesel engines: (1) used at area sources of air toxics and 

constructed or reconstructed before June 12, 2006; (2) used at major sources of air toxics, having 

a site rating of less than or equal to 500 horsepower, and constructed or reconstructed before 

June 12, 2006; and, (3) used at major sources of air toxics for non-emergency purposes, having a 

site rating of greater than 500 horsepower, and constructed or reconstructed before December 19, 

2002. 

Operators of existing engines will be required to: (1) install emissions control equipment that 

would limit air toxics up to 70% for stationary non-emergency engines with a site rating greater 

than 300 horsepower; (2) perform emission tests to demonstrate engine performance and 

compliance with rule requirements; and, (3) burn ultra-low sulfur fuel in stationary nonemergency engines with a site rating greater than 300 horsepower. 

When all of the reciprocating internal combustion engine standards are fully implemented in 

2013, U.S. EPA estimates that emissions from these engines will reduce air toxics by 

approximately 1,000 tons per year (tpy), PM2.5 by 2,800 tpy, CO by 14,000 tpy, and VOC by 

27,000 tpy. 

Category 3 Marine Diesel Engine Standards6

This new standard, effective in June 2010, promulgates more stringent exhaust emission 

standards for new large marine diesel engines with per-cylinder displacement at or above 30 

liters (commonly referred to as Category 3 compression-ignition marine engines) as part of a 

coordinated strategy to address emissions from all ships that affect U.S. air quality. These 

emission standards are equivalent to those adopted in the amendments to Annex VI to the 

International Convention for the Prevention of Pollution from Ships (MARPOL Annex VI). The 

emission standards apply in two stages—near-term standards for newly built engines will apply 

beginning in 2011; long-term standards requiring an 80% reduction in NOx emissions will begin 

in 2016. 

U.S. EPA is adopting changes to the diesel fuel program to allow for the production and sale of 

diesel fuel with up to 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. 

 

5 http://www.epa.gov/ttn/atw/rice/fr03mr10.pdf

6 http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ae43a6
38

U.S. EPA is also adopting provisions to apply some emission and fuel standards to foreignflagged and in-use vessels that are covered by MARPOL Annex VI. 

When this strategy is fully implemented in 2030, U.S. EPA estimates that NOx and PM2.5

emissions in the U.S. will be reduced by approximately 1.2 million tpy and 143,000 tpy, 

respectively. 

Clean Air Interstate Rule (CAIR)

On May 12, 2005, U.S. EPA promulgated the “Rule to Reduce Interstate Transport of Fine 

Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to Acid Rain Program; 

Revisions to the NOx SIP Call”; Final Rule (70 FR 25162). This rule established the requirement 

for states to adopt rules limiting the emissions of NOx and SO2 and provided a model rule for the 

states to use in developing their rules to meet federal requirements. The purpose of CAIR was to 

reduce interstate transport of precursors to fine particles and ozone. 

CAIR applies to: (1) any stationary, fossil-fuel-fired boiler or stationary, fossil-fuel-fired 

combustion turbine, a generator with a nameplate capacity of more than 25 megawatt electrical 

(MWe) producing electricity for sale; and (2) a unit that qualifies as a cogeneration unit during 

the 12-month period starting on the date that the unit first produces electricity and continues to 

qualify as a cogeneration unit, a cogeneration unit serving at any time a generator with a 

nameplate capacity of more than 25 MWe and supplying in any calendar year more than onethird of the unit’s potential electric output capacity or 219,000 megawatt hours (MWh), 

whichever is greater, to any utility power distribution system for sale. 

This rule provides annual state caps for NOx and SO2 in two phases, with the Phase I caps for 

NOx and SO2 starting in 2009 and 2010, respectively. Phase II caps become effective in 2015. 

U.S. EPA is allowing the caps to be met through a cap and trade program if a state chooses to 

participate in the program. 

In response to U.S. EPA’s rulemaking, IDEM adopted a state rule in 2006 based on the model 

federal rule. IDEM’s rule includes annual and seasonal NOx trading programs, and an annual 

SO2 trading program. This rule requires compliance effective January 1, 2009. 

SO2 emissions from power plants in the 28 eastern states and the District of Columbia covered 

by CAIR will be cut by 4.3 million tons by 2009 and reduced by an additional 5.4 million tons in 

2015. NOx emissions will be cut by 1.7 million tons by 2009 and reduced by an additional 1.3 

million tons in 2015. The D.C. Circuit court’s vacatur of CAIR in July of 2008 and subsequent 

remand without vacatur of CAIR in December of 2008 directs U.S. EPA to revise or replace 

CAIR in order to properly address the deficiencies outlined by the court. 

Since the court’s opinion made it clear that CAIR is deficient and must be revised or replaced, 

the program cannot be defined as permanent and enforceable for SIP purposes. On July 6, 2010, 

U.S. EPA proposed the Clean Air Transport Rule to replace CAIR. The Clean Air Transport 

Rule will result in even greater benefits than CAIR and than what is assumed within the emission 

inventories and modeling. 
39

Together, these rules will substantially reduce local and regional sources of fine particle 

precursors. The modeling analyses discussed in Section 7.0 include these rules and show the 

reductions in annual fine particle concentrations expected to result from the implementation of 

these rules. 

6.5 Controls to Remain in Effect

IDEM commits to maintain the control measures listed above after redesignation, or submit to 

U.S. EPA, as a SIP revision, any changes to its rules or emission limits applicable to NOx, SO2, 

or direct PM2.5 sources as required for maintenance of the annual standard for fine particles in 

Jefferson County (Madison Township) and Clark and Floyd counties, Indiana. 

Indiana, through IDEM’s Office of Air Quality and its Compliance and Enforcement Branch, has 

the legal authority and necessary resources to actively enforce any violations of its rules or 

permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the 

emission of fine particles and fine particle precursors in Jefferson County (Madison Township) 

and Clark and Floyd counties. 

6.6 New Source Review Provisions

Indiana has a long standing and fully implemented New Source Review (NSR) program that is 

outlined in rule 326 IAC 2. The rule includes provisions for the Prevention of Significant 

Deterioration (PSD) permitting program in 326 IAC 2-2 and the emissions offset rule in 326 IAC 

2-3. Indiana's PSD program was conditionally approved on March 3, 2003 (68 FR 9892) and 

received final approval on May 20, 2004 (69 FR 29071) by U.S. EPA as part of the SIP. 

Any emission unit that is not listed in the 2005 emission inventory, or for which credit through 

the shutdown or curtailment of operations was taken in demonstrating attainment, will not be 

allowed to construct, reopen, modify, or reconstruct without meeting all applicable permit rule 

requirements. The review process will be identical to that used for new sources. Once the area 

is redesignated, OAQ will implement NSR through the PSD program, which requires an air 

quality analysis to evaluate whether the new source will threaten the NAAQS. 

7.0 MODELING AND METEOROLOGY 

Although U.S. EPA Redesignation Guidance does not require modeling for fine particle 

nonattainment areas seeking redesignation, extensive modeling has been performed for the 

Louisville Area to determine the effect of national emission control strategies on fine particle 

levels. These modeling analyses determined that the Louisville Area, including Clark and Floyd 

counties, Indiana, are significantly impacted by regional transport of fine particles and its 

precursors, and that regional NOx and SO2 reductions are an effective way to attain the annual 

standard for fine particles in this area. Future year modeled annual fine particle concentrations 

are expected to be reduced by 0.3 to 0.9 μg/m3

 from baseline design values. Examples of these 

modeling analyses are described in this section and can also be found in Appendix J. 
40

7.1 Summary of Modeling Results to Support Rulemakings

U.S. EPA Modeling for Clean Air Transport Rule 20107

U.S. EPA performed modeling to support the emission reductions associated with the proposed 

Clean Air Transport Rule. U.S. EPA used the Comprehensive Air Quality Model with 

Extensions (CAMx, version 5), applied to the 2005 meteorology, as processed by the Mesoscale 

Model (MM5), version 3.7.4. Emissions input into CAMx included SO2, NOx, VOCs, NH3, and 

direct PM2.5 for 2005. The modeling was based on the annual fine particle design values 

calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year 

modeling was conducted, which included the Louisville Area, and the future year design values 

for 2012 and 2014 were evaluated for attainment of the annual NAAQS for fine particles of 15 

μg/m3

, as shown in Table 7.1. Fine particle concentrations are accounted for by modeling both 

the base future year emissions and then the emission reductions associated with the Clean Air 

Transport Rule. U.S. EPA found that the model performance met the suggested benchmark 

performance goals within or close to the ranges found in other comparable modeling 

applications. 

Table 7.1 

Clean Air Transport Rule Modeling Results from U.S. EPA 

(Using 2003 through 2007 Design Values) 

SITE ID SITE NAME COUNTY 

Design Value 

2003 – 2007 

(μg/m3) 

Future Design 

Value 

2012 Base 

(μg/m3) 

Future Design 

Value 

2014 Base 

(μg/m3) 

18-019-0006 Jeffersonville – Walnut St. Clark. 16.40 15.96 15.46 

18-043-1004 New Albany Floyd 14.80 14.50 14.04 

21-029-0006 Carpenter Street Bullitt – KY 14.90 14.58 14.07 

21-093-0006 Elizabethtown Hardin – KY 13.58 13.34 12.82 

21-111-0043 Southern Avenue Jefferson – KY 15.53 15.19 14.71 

21-111-0044 Wyandotte Park Jefferson – KY 15.31 14.93 14.45 

21-111-0048 Barret Avenue Jefferson – KY 15.25 14.87 14.38 

21-111-0051 Watson Elementary Jefferson – KY 14.70 14.43 13.95 

Modeling results show that the base future year modeling with emission reductions from the 

Clean Air Transport Rule will account for a 0.3 to 0.4 μg/m3

 decrease in concentrations for 2012, 

as well as a 0.8 to 0.9 μg/m3 decrease in concentrations for 2014 in the Louisville Area. 

While results of U.S. EPA’s Clean Air Transport Rule modeling show modeled PM2.5

concentrations above the standard with base case emissions at the Jeffersonville, Indiana – 

Walnut Street PM2.5 monitor (Clark County), it should be noted that the base year design value 

used by U.S. EPA was taken from 2003 through 2007 and is higher than current 2006 through 

2010 design values in the Louisville Area. Graph 7.1 shows the downward trend of the design 

values from 1999 through 2010 from the PM2.5 monitors in the Louisville Area. In fact, all 

design values are below the annual standard for fine particles. 

 

7 http://www.epa.gov/airquality/transport/pdfs/TR_AQModeling_TSD.pdf
41

Graph 7.1 

PM2.5 Design Value Trends for the Louisville Area, 1999 to 2010 

The resulting decrease of the design value at the Jeffersonville, Indiana – Walnut Street PM2.5

monitor is 1.74 μg/m3 and 1.92 μg/m3 at the New Albany, Indiana PM2.5 monitor (Floyd 

County). The annual PM2.5 design values for the Louisville Area monitors have dropped with the 

2006 through 2010 design values ranging from 1.29 μg/m3

 to 1.93 μg/m3 less than the 2003 

through 2007 design values modeled by U.S. EPA. Therefore, U.S. EPA’s Clean Air Transport 

Rule modeling, using the current 2006 through 2010 design values, showed lower modeled 

concentrations approaching the annual NAAQS for fine particles (15.0 μg/m3). Results of this 

modeling are shown below in Table 7.2 and are based on the relative response factors (RRFs) 

calculated from the annual PM2.5 future year base case results divided by the 2003 through 2007 

PM2.5 base case design values. This is a simplistic version of PM2.5 RRF calculations and is used 

only as a weight of evidence demonstration of future year modeled results. 

Table 7.2 

Clean Air Transport Rule Modeling Results from U.S. EPA 

 (Using 2006 through 2010 Design Values) 

SITE ID SITE NAME COUNTY 

Design 

Value 

2006-2010 

(μg/m3) 

2012 

RRF 

Future 

Design 

Value 

2012 Base 

(μg/m3) 

2014 

RRF 

Future 

Design 

Value 

2014 Base 

(μg/m3) 

18-019-0006 Jeffersonville – 

Walnut Street 

Clark 

14.71 0.973 14.31 0.943 13.49 

18-043-1004 New Albany Floyd 12.93 0.980 12.67 0.949 12.02 

21-029-0006 Carpenter Street Bullitt – KY 13.32 0.979 13.03 0.944 12.31 

21-111-0043 Elizabethtown Jefferson – KY 13.62 0.978 13.37 0.947 12.63 

21-111-0044 Southern Avenue Jefferson – KY 13.75 0.975 13.45 0.944 12.74 

21-111-0048 Wyandotte Park Jefferson – KY 13.41 0.975 13.08 0.943 12.35 

21-111-0051 Barret Avenue Jefferson – K Y 13.42 0.982 13.08 0.949 12.34 

12.00

14.00

16.00

18.00

1999‐2003 2000‐2004 2001‐2005 2002‐2006 2003‐2007 2004‐2008 2005‐2009 2006‐2010

Concentrations(ug/m3)

Design Value Years

Jeffersonville ‐ Walnut St. Charlestown State Park New Albany

Shepherdsville Southern Avenue Wyandotte Park

Barret Avenue/Cannon Lane Watson Elementary Annual NAAQS
42

As can be seen, modeled results are lower when current annual fine particle design values are 

used to determine future year modeling. Using the 2006 through 2010 design values, all 

Louisville Area PM2.5 monitoring sites would not exceed the annual NAAQS for fine particles in 

2012 and remain below the annual PM2.5 NAAQS in 2014.

LADCO Modeling for the Clean Air Interstate Rule (CAIR)

LADCO conducted modeling to determine the impact of CAIR in the Midwest. LADCO’s 

modeling used the CAMx model applied to the year 2005 meteorology, as processed by the 

MM5. Emissions input into CAMx included SO2, NOx, VOCs, NH3, and direct PM2.5 for 2005. 

The modeling was based on 2003 through 2007 design values. Future year modeling for 2012 

and 2018 was conducted and the future year design values were determined without the emission 

reductions associated with CAIR (Round 6), as shown in Table 7.3. The U.S. Clean Air 

Transport Rule is expected to provide reductions above and beyond CAIR. 

Table 7.3 

LADCO Round 6 Modeling Results 

for Annual PM2.5 – Without CAIR Emission Reductions

(Using 2003 – 2007 Design Values) 

SITE ID SITE NAME COUNTY 

Design Value 

2003-2007 

(μg/m3) 

Base-case 

2012 

(μg/m3) 

Base-case 

 2018 

(μg/m3) 

18-019-0006 Jeffersonville – Walnut St. Clark 16.5 15.6 15.5 

18-043-1004 New Albany Floyd 14.9 14.0 13.8 

21-029-0006 Carpenter Street Bullitt – KY 14.9 14.2 14.1 

21-093-0006 Elizabethtown Hardin – KY 13.6 12.8 12.7 

21-111-0043 Southern Avenue Jefferson – KY 15.6 14.6 14.4 

21-111-0044 Wyandotte Park Jefferson – KY 15.3 14.5 14.4 

21-111-0048 Barret Avenue Jefferson – KY 15.1 14.3 14.2 

21-111-0051 Watson Elementary Jefferson – KY 14.8 13.9 13.8 

LADCO based its Round 6 modeling on annual design values from 2003 through 2007. Current 

annual fine particle design values have dropped since this design value period, as shown 

previously in Graph 7.1. A decrease of the design values from 2003 through 2007 to 2006 

through 2010 at the Jeffersonville – Walnut Street PM2.5 monitor of 1.74 μg/m3

 and 1.92 μg/m3

at the New Albany, Indiana PM2.5 monitor occurred. The design values for the Louisville Area 

monitors have dropped with the 2006 through 2010 design values ranging from 1.29 μg/m3 to 

1.93 μg/m3

 less than the 2003 through 2007 design values. The 2006 through 2010 design 

values were multiplied by the RRFs calculations, based on the future year design values divided 

by the 2003 through 2007 design value. These results are shown in Table 7.4. 
43

Table 7.4 

LADCO Round 6 Modeling Results 

for Annual PM2.5 – Without CAIR Emission Reductions 

(Using 2006 – 2010 Design Values) 

SITE ID SITE NAME COUNTY 

Design 

Value 

2006-2010 

(μg/m3) 

2012 

RRF 

Base-case 

2012 

(μg/m3) 

2018 

RRF 

Basecase 

2018 

(μg/m3) 

18-019-0006 Jeffersonville – Walnut St. Clark 14.71 0.945 13.9 0.939 13.8 

18-043-1004 New Albany Floyd 12.93 0.940 12.1 0.926 12.0 

21-029-0006 Carpenter Street Bullitt – KY 13.32 0.953 12.7 0.946 12.6 

21-111-0043 Southern Avenue Jefferson – KY 13.62 0.936 12.7 0.923 12.6 

21-111-0044 Wyandotte Park Jefferson – KY 13.75 0.948 13.0 0.941 12.9 

21-111-0048 Barret Avenue/Cannon Lane Jefferson – KY 13.41 0.947 12.7 0.940 12.6 

21-111-0051 Watson Elementary Jefferson – KY 13.42 0.939 12.6 0.932 12.5 

As can be seen, annual PM2.5 modeled results are lower when current design values are used to 

determine future year modeling. Using the 2006 through 2010 design values, all Louisville Area 

monitoring sites will be below the annual NAAQS for fine particles by 2012 and will continue to 

decrease thereafter. 

7.2 LADCO Round 5 Speciated Modeled Attainment Test Results

The Speciated Modeled Attainment Test (SMAT) is the attainment test for annual fine particles. 

To determine the future year annual fine particle concentrations, speciated data is calculated. 

The different species that were modeled and are associated with fine particles include sulfates, 

nitrates, organic carbon, elemental carbon, ammonium, particle bound water, “other” primary 

inorganic fine particles, and passively collected mass. The SMAT results from LADCO’s Round 

5 modeling are listed below. Round 5 modeled the emission reductions associated with CAIR so 

the results reflect the impacts from CAIR. Percent ranges of the model results from the 

Jeffersonville, Indiana – Walnut Street and New Albany PM2.5 monitors in Clark and Floyd 

counties, Indiana, were broken down into the speciated constituents of fine particle emissions. 

The percent change from the observed speciated data in 2005 to the future year modeled results 

for 2009 are listed in Table 7.5. While these modeling results are outdated, this weight of 

evidence demonstration shows the reduction potential from national emission control measures 

for the PM2.5 species in southern Indiana. An updated analysis will be conducted at a later time, 

using more current emissions and meteorological data and for a relevant future year projection. 
44

Table 7.5 

LADCO Round 5 SMAT Modeling Results for Southern Indiana 

(Percent decrease from observed to modeled concentrations) 

Species of PM2.5 2009 

Sulfates 30% 

Nitrates 0% 

Organic Carbon 0% 

Elemental Carbon 14% - 16% 

Ammonium 24% - 26% 

Particle Bound Water 25% - 29% 

The results demonstrate that sulfate, ammonium, elemental carbon, and particle bound water 

concentration decreases are projected to be at least 14% in the future year 2009. LADCO 

modeling shows good performance for sulfates and elemental carbon predicted baseline 

concentrations, slight over-prediction for nitrate concentrations, and under-predictions of organic 

carbon concentrations. Overall, model performance is adequate for SIP planning and gives a 

good idea of the effects of emission reductions from national emission control measures on 

southern Indiana. 

7.3 LADCO Round 5 Particulate Source Apportionment Results

Particulate Source Apportionment (PSAT) modeling was conducted by LADCO. The results of 

the PSAT modeling show the regional contributions by emission sectors on each monitor that 

was modeled. Chart 7.1 displays the PSAT modeling results for the Jeffersonville –Walnut 

Street fine particle monitor in Clark County, Indiana. Kentucky was the biggest regional 

contributor to the monitor with Indiana, Ohio, and the remaining Visibility Improvement State 

and Tribal Association of the Southeast (VISTAS) Regional Planning Organization states 

(Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, 

Virginia, and West Virginia and the Eastern Band of the Cherokee Indians) also being significant 

contributors. 

The PSAT Round 5 modeling results indicate that the majority of Indiana’s emission sector 

contributions to fine particle concentrations come from EGUs, ammonium emission sources, 

mobile, non-EGU sources, off-road (including marine, aircraft, and railroad), and area emission 

sources. These results are considered to be representative of Clark, Floyd, and Jefferson 

counties, Indiana as EGU, ammonium, and non-EGU emissions impact the entire area. 
45

Chart 7.1 

Regional/Emission Sector Particulate Source Apportionment Technology (PSAT) Test 

Results, Jeffersonville, Indiana – Walnut Street PM2.5 Monitor 

The following pie charts depict the contribution by species to fine particle concentrations at the 

Louisville Area monitors. The pie charts include both the observed 2005 contributions and 2009 

modeled contributions for each monitor. Since the monitors are in close proximity to each other, 

results are fairly similar in the distribution of species concentrations among the monitors. Charts 

7.2 through 7.9 cover the eight fine particle monitors in the Louisville Area that are used to 

determine compliance with the annual NAAQS for fine particles. 

The speciation listed in the pie charts include SO4 – sulfate mass, NO3 – nitrate mass, OC – 

organic carbon mass, EC – elemental carbon mass, Soil – crustal material mass, NH4 – 

ammonium mass, PBW – particle bound water mass, and BLAN – passively collected mass.
46

Chart 7.2 

Modeled Contributions by Species at the Jeffersonville, Indiana 

Walnut Street PM 2.5 Monitor 

(Observed Concentrations = 16.2 μg/m3

) (Modeled Concentrations =13.6 μg/m3) 

 

Chart 7.3 

Modeled Contribution by Species at the New Albany, Indiana PM2.5 Monitor 

(Observed Concentrations = 14.5 μg/m3) (Modeled Concentrations =12.1 μg/m3) 

 

so4

35%

no3

7%

oc

23% ec

4%

soil

4%

nh4

13%

pbw

11%

blan

3%

Observed 2005 Contributions at 

the New Albany PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

29%

no3

8% oc

28%

ec

4%

soil

5%

nh4

12%

pbw

10%

blan

4%

2009 Modeled Contributions at the 

New Albany PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

27%

no3

oc 9%

31%

ec

4%

soil

4%

nh4

12%

pbw

9%

blan

4%

2009 Modeled Contributions at the 

Jeffersonville PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

33%

no3

7%

oc

26%

ec

4%

soil

3%

nh4

13%

pbw

11%

blan

3%

Observed 2005 Contributions at 

the Jeffersonville PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan
47

Chart 7.4

Modeled Contribution by Species at the Carpenter Street – Shepherdsville, 

Kentucky PM2.5 Monitor 

(Observed Concentrations = 14.7 μg/m3

) (Modeled Concentrations =12.4 μg/m3) 

Chart 7.5 

Modeled Contribution by Species at the Elizabethtown, Kentucky 

PM2.5 Monitor 

(Observed Concentrations = 13.4 μg/m3

) (Modeled Concentrations =11.2 μg/m3) 

 

so4

35%

no3

7%

oc

24%

ec

4%

soil

3%

nh4

13%

pbw

11%

blan

3%

Observed 2005 Contributions at 

the Shepherdsville PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

28%

no3 oc 8%

29%

ec

5%

soil

6%

nh4

11%

pbw

9%

blan

4%

2009 Modeled Contributions at the 

Shepherdsville PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

29%

no3 oc 8%

29%

ec

4%

soil

5%

nh4

12%

pbw

9%

blan

4%

2009 Modeled Contributions at the 

Elizabethtown PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

35%

no3

7%

oc

24%

ec

4%

soil

3%

nh4

12%

pbw

11%

blan

4%

Observed 2005 Contributions at 

the Elizabethtown PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan
48

Chart 7.6 

Modeled Contribution by Species at the Southern Avenue – Louisville, 

Kentucky PM2.5 Monitor 

(Observed Concentrations = 15.3 μg/m3

) (Modeled Concentrations =12.8 μg/m3) 

Chart 7.7 

Modeled Contribution by Species at the Wyandotte Park – Louisville, 

Kentucky PM2.5 Monitor 

(Observed Concentrations = 15.2 μg/m3) (Modeled Concentrations =12.8 μg/m3) 

so4

35%

no3

7%

oc

24%

ec

4%

soil

3%

nh4

13%

pbw

11%

blan

3%

Observed 2005 Contributions at 

the Southern Avenue PM2.5

Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

29%

no3

8%

oc

28%

ec

5%

soil

5%

nh4

12%

pbw

9%

blan

4%

2009 Modeled Contributions at the 

Southern Avenue PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

34%

no3

7%

oc

25%

ec

4%

soil

3%

nh4

13%

pbw

11%

blan

3%

Observed 2005 Contributions at 

the Wyandotte Park PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

28%

no3

8% oc

29%

ec

5%

soil

5%

nh4

12%

pbw

9%

blan

4%

2009 Modeled Contributions at 

Wyandotte Park PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan
49

Chart 7.8 

Modeled Contribution by Species at the Barret Avenue – 

Louisville, Kentucky PM2.5 Monitor 

(Observed Concentrations = 14.8 μg/m3

) (Modeled Concentrations =12.6 μg/m3) 

 

Chart 7.9 

Modeled Contribution by Species at the Watson Elementary – 

Louisville, Kentucky PM2.5 Monitor 

(Observed Concentrations = 14.6 μg/m3

) (Modeled Concentrations =12.0 μg/m3) 

 

Results of the Round 5 PSAT modeling for the Louisville Area fine particle monitors show the 

highest pollutant contributors to base-case and future year fine particle concentrations are sulfate, 

organic carbon, ammonium, and nitrate. Future year modeling shows decreases in sulfates (due 

to the emission reductions from CAIR) and ammonium. The future year modeling did show 

slight increases in nitrates from the base-case modeled concentrations. 

so4

34%

no3

7%

oc

25%

ec

4%

soil

3%

nh4

13%

pbw

11%

blan

3%

Observed 2005 Contributions at 

the Barret Avenue PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

28%

no3

oc 8%

29%

ec

5%

soil

5%

nh4

12%

pbw

9%

blan

4%

2009 Modeled Contributions at the 

Barret Avenue PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

35%

no3

7%

oc

23%

ec

4%

soil

4%

nh4

13%

pbw

11%

blan

3%

Observed 2005 Contributions at the 

Watson Elementary PM2.5 Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan

so4

29%

no3

9% oc

28%

ec

4%

soil

5%

nh4

12%

pbw

9%

blan

4%

2009 Modeled Concentrations at 

the Watson Elementary PM2.5

Monitor

so4

no3

oc

ec

soil

nh4

pbw

blan
50

7.4 Summary of Existing Modeling Results

U.S. EPA and LADCO modeling for future year design values have consistently shown that 

existing national emission control measures will bring the Louisville Area into attainment of the 

annual NAAQS for fine particles. Emission control measures to be implemented in the next 

several years will help air quality meet the standard in the future. Modeling support for CAIR 

has shown that future year design values for the Louisville Area will continue to attain the annual 

standard for fine particles with modeled future year design values below 15 μg/m3. U.S. EPA 

future year modeling of national emission control strategies, based on current design values, 

shows that the Louisville Area will approach the annual NAAQS for fine particles. Future 

national and local emission control strategies will ensure that the Louisville Area will maintain 

lower fine particle concentrations with an increasing margin of safety. 

7.5 Meteorological Analysis for the Louisville Area

Meteorological conditions are one of the most important factors that influence development and 

transport of fine particles. Stagnant surface conditions during any time of the year and upper air 

ridging provides conducive conditions for development and transport of fine particles. 

Ultimately, passage of surface cold fronts with a clean air mass change will lower fine particle 

readings in the Louisville Area. 

7.6 Surface Air Conditions Present during High Fine Particle Concentration Days

Higher annual concentrations of fine particles tend to correlate with warmer temperatures and 

lighter wind speeds, although high fine particle episodes can occur in the summer or winter. It 

should be noted that higher annual fine particle concentrations are driven by individual days with 

higher fine particle concentrations throughout the monitored year. Therefore, it is difficult to 

attribute higher fine particle concentrations to annualized meteorological rankings. Review of 

several of the higher fine particle concentration episodes over the past few years reveals that 

conditions were hot in the summer with temperatures in the middle 80os Fahrenheit (oF) or higher 

and average wind speeds were fairly light. Fall and winter days with higher fine particle 

concentrations had near normal temperatures, but wind speeds were very light and humidity was 

higher. 

7.7 Upper Air Conditions Present during High Fine Particle Concentration Days

Upper air ridges and more stagnant surface wind conditions predominately affect development 

and build up of fine particles. Slow moving upper air ridges can effectively suppress mixing 

within the many levels of the atmosphere and cause pollutants to build up over time. Inversions 

or increases in temperature with a rise in altitude will prevent mixing with air from the upper 

atmosphere. These conditions can occur at any time of the year and are evident in elevated fine 

particle episodes in spring, summer, fall, and winter months. Review of surface and upper air 

features of higher fine particle concentration days showed stagnant surface conditions and upper 

air ridges existed on those days and helped in the buildup of fine particle concentrations. 
51

7.8 Analyses of Atmospheric Conditions during High Fine Particle Concentration Days

Analyses were conducted to determine the atmospheric conditions that are most prevalent during 

higher fine particle concentration days in Indiana. LADCO applied a Classification and 

Regression Tree (CART) analysis to data from Indiana that correlated different levels of fine 

particle concentrations to meteorological conditions from 1999 to 2004 (Donna Kenski, 2005). 

This type of analysis evaluates meteorological conditions, such as temperature, pressure, wind 

speed, wind direction, relative humidity, and dew point temperatures at the surface, as well as 

morning and evening mixing heights in the upper atmosphere which were present when higher 

concentrations of fine particles were monitored. Results of this CART analysis indicated factors 

that played a larger role in higher fine particle concentrations in Indiana were warm-weather 

conditions with high dew points, southwest winds, and high evening mixing heights. Previous 

day’s concentrations of fine particles play a key role in higher impacts as well. 

Fine particles are made up of several constituents, including direct PM2.5, sulfates, nitrates, 

ammonium, organic carbon, and elemental carbon. Depending on the time of the year, 

concentrations of fine particle constituents vary, with nitrates being more prevalent in the winter 

and sulfates more prevalent in the summer. Sulfates and nitrates emission reductions have the 

biggest impact on lower future year fine particle concentrations. 

7.9 Summary of Air Quality Index Days for the Louisville Area

An analysis was conducted to review the daily fine particle concentrations over a year to 

determine the Air Quality Index (AQI) trends. Chart 7.10 shows by year (2000 through 2010), 

the percentage of days during the calendar year on which fine particle concentrations reached the 

AQI ranges for “Good” (0 to 15.3 μg/m3), “Moderate” (15.4 μg/m3 to 40.4 μg/m3), and 

“Unhealthy for Sensitive Groups (USG)” (40.5 μg/m3 to 65.4 μg/m3). There were no days that 

fine particle levels reached the “Unhealthy” level of 65.5 μg/m3

 to 150.4 μg/m3. 

Chart 7.10 

Distribution of PM2.5 Concentration Days on the Air Quality Index (AQI) 

Levels of Health Concern for the Louisville Area 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Percentage of Days

Year

Good Moderate USG
52

Table 7.6 shows how the years ranked for the three AQI ranges. The year 2009 had the most 

“Good” concentration days during the 11-year period analyzed (2000 through 2010). The year 

2000 had the most “Moderate” concentration days and the year 2005 had the most “USG” 

concentration days with no days recorded in 2006, 2008, and 2009. As can be seen, weather 

plays a large role in fine particle concentration development and transport as 2001, 2002, 2005, 

and 2007 were warmer than normal summers which translated to moderate and unhealthy for 

sensitive group levels of air quality. 

Table 7.6 

Ranking and Percentage of Highest Number of Days 

at AQI Levels of Health Concern 

Ranking Good Moderate Unhealthy for 

Sensitive Group 

1st 2009 – 76% 2000 – 52% 2005 – 3% 

2nd 2008 – 65% 2005 – 51% 2002 – 3% 

3rd 2006 – 64% 2001 – 47% 2000 – 2% 

4th 2002 – 63% 2007 – 46% 2001 – 2% 

5th 2010 – 61% 2004 – 41% 2007 – 2% 

6th 2003 – 59% 2003 – 40% 2003 – 1% 

7th 2004 – 58% 2010 – 38% 2010 – 1% 

8th 2007 – 52% 2006 – 36% 2004 – 1% 

9th 2001 – 51% 2008 – 35% 

10th 2005 – 46% 2002 – 34% 

11th 2000 – 46% 2009 – 24% 

7.10 Summary of Meteorological Analysis for the Louisville Area

Annual fine particle concentrations in the Louisville Area are driven by higher fine particle 

concentration days that can occur during any time of the year. Conditions that are most 

prevalent during higher fine particle concentration days are lighter winds, higher relative 

humidity, and above average temperatures in the summer, and near normal temperatures in the 

fall, winter, or spring. Approximately 70% of the days when PM2.5 concentrations were in the 

USG range occurred in the summer months with maximum high temperatures of 80oF or above. 

Weather plays a large role in fine particle concentration development and transport as 2001, 

2002, 2005, and 2006 were warmer than normal summers which translated to more days of 

“moderate and unhealthy for sensitive group” levels of air quality and near normal temperatures 

in the fall, winter, or spring. Upper air weather patterns generally include ridging over the area 

with stagnant conditions at the surface caused by lower mixing heights and stable conditions for 

summer episodes and ridging or troughs over the area in the fall, winter, or spring episodes. 

Surface winds from any direction can transport pollutants from surrounding areas into the 

Louisville Area. Nitrates are bigger contributors to fine particle concentrations in the winter and 

sulfates are bigger contributors to fine particle concentrations in the summer. 
53

8.0 CORRECTIVE ACTIONS 

8.1 Commitment to Revise Plan

As noted in Section 4.6, IDEM commits to review and revise, as appropriate, its Maintenance 

Plan eight years after redesignation, as required by Section 175A of the CAA. 

8.2 Commitment for Contingency Measures

IDEM will monitor fine particle concentrations to determine whether trends indicate higher 

values or whether emissions appear to be increasing. If it is determined that fine particle levels 

and emissions are increasing and action is necessary to reverse that trend, IDEM will take action 

to reverse the noted trend, prior to a violation of the standard occurring. 

IDEM commits to adopt and expeditiously implement necessary corrective action in accordance 

with an Action Level Response described below. 

Action Level Response

An Action Level Response shall be prompted whenever a violation of the standard (three-year 

average annual arithmetic mean value of 15.1 μg/m3 or greater) occurs. In the event that the 

Action Level is triggered and is not found to be due to an atypical unfavorable meteorological 

condition, exceptional event, malfunction, or noncompliance with a permit condition or rule 

requirement, IDEM will determine additional control measures needed to assure future 

attainment of the annual NAAQS for fine particles. In this case, measures that can be 

implemented in a short time will be selected in order to be in place within eighteen months from 

the end of the year that prompted the Action Level Response. 

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal 

processes. This process will include publication of notices, an opportunity for public hearing, 

and other measures required by Indiana law for rulemaking by state environmental boards. 

If a new measure or control is already promulgated and scheduled to be implemented at the 

federal or state level, and that measure or control is determined to be sufficient to address the 

upward trend in air quality, additional local measures may be unnecessary. Furthermore, IDEM 

will submit to U.S. EPA an analysis to demonstrate that the proposed measures are adequate to 

return the area to attainment. 

8.3 Contingency Measures

Contingency measures to be considered will be selected from a comprehensive list of measures 

deemed appropriate and effective at the time the selection is made. Listed below are example 

measures that may be considered. The selection of measures will be based upon costeffectiveness, emission reduction potential, economic and social considerations, or other factors 
54

that IDEM deems appropriate. IDEM will solicit input from interested and affected persons in 

the maintenance area prior to selecting appropriate contingency measures. All of the listed 

contingency measures are potentially effective or proven methods of obtaining significant 

reductions of fine particle precursor emissions. Because it is not possible at this time to 

determine what control measure will be appropriate at an unspecified time in the future, the list 

of contingency measures outlined below is not comprehensive. IDEM anticipates that if 

contingency measures should ever be necessary, it is unlikely that a significant number (i.e., all 

those listed below) will be required. 

1) Vehicle inspection and maintenance program. 

2) Alternative fuel and diesel retrofit programs for fleet vehicle operations. 

3) Require NOx or SO2 emission offsets for new and modified major sources. 

4) Require NOx or SO2 emission offsets for new and modified minor sources. 

5) Increase the ratio of emission offsets required for new sources. 

6) Require NOx or SO2 controls on new minor sources (less than 100 tons). 

7) Wood stove change out program. 

8) Various emission reduction measures or dust suppressant for unpaved roads and/or 

parking lots. 

9) Idling Restrictions. 

10) Broader geographic applicability of existing measures. 

11) One or more transportation control measures sufficient to achieve at least a 0.5% 

reduction in actual area-wide precursor emissions. Transportation measures will be 

selected from the following, based upon the factors listed above, after consultation with 

affected local governments: 

a) Trip reduction programs, including, but not limited to, employer-based 

transportation management plans, area wide rideshare programs, work schedule 

changes, and telecommuting. 

b) Transit improvements. 

c) Traffic flow improvements. 

d) Other new or innovative transportation measures not yet in widespread use that 

affected state and local governments deem appropriate. 

No contingency measure shall be implemented without providing the opportunity for full public 

participation during which the relative costs and benefits of individual measures, at the time they 

are under consideration, can be fully evaluated. 

9.0 PUBLIC PARTICIPATION

Indiana published notification for a public hearing and solicitation for public comment 

concerning the draft Redesignation Petition and Maintenance Plan on IDEM’s website8

 on April 

27, 2011, with publication in the following newspapers on the following dates: 

 

 

8 http://www.in.gov/idem/4658.htm
55

1) The Indianapolis Star, Indianapolis, Indiana (May 5, 2011). 

2) The New Albany Tribune, New Albany, Indiana (April 26, 2011). 

3) The Evening News, Jeffersonville, Indiana (April 26, 2011). 

4) The Madison Courier, Madison, Indiana (April 22, 2011). 

A public hearing to receive comments concerning the redesignation request was conducted on 

May 26, 2011, at the Jefferson Township Public Library, Clarksville Branch in Clarksville, 

Indiana. No comments were received at the public hearing. The public comment period closed 

on May 29, 2011. One comment letter was received during the public comment period. 

Appendix K includes a copy of the public notice, public hearing script, certifications of 

newspaper publication of the public notice, the official transcript from the public hearing, and a 

detailed summary of and response to substantive comments.

10.0 CONCLUSIONS 

Jefferson County (Madison Township) and Clark and Floyd counties, Indiana, have attained the 

annual NAAQS for fine particles. This petition demonstrates that Jefferson County (Madison 

Township) and Clark and Floyd counties, Indiana, have complied with the applicable provisions 

of the CAA regarding redesignation of nonattainment areas for fine particles. IDEM has 

prepared a State Implementation and Maintenance Plan that meets the requirement of Section 

110(a)(1) of the CAA. 

Indiana has performed an analysis that shows the air quality improvements are due to permanent 

and enforceable measures and that additional significant regional NOx and SO2 reductions 

following implementation of the Phase II NOx SIP Call rule and CAIR or its replacement rule 

will ensure continued compliance (maintenance) with the standard. Furthermore, emission 

projections indicate that NOx and SO2 emissions will continue to decline, ensuring that the area 

continues to maintain compliance with the standard and provide for an increased margin of 

safety. Based on this presentation, Jefferson County (Madison Township) and Clark and Floyd 

counties, Indiana, meet the requirements for redesignation under the CAA (Section 107(d)(3)) 

and U.S. EPA guidance for fine particles. 

Consistent with the authority granted to U.S. EPA, the State of Indiana requests that Jefferson 

County (Madison Township) and Clark and Floyd counties, Indiana, be redesignated to 

attainment for the annual fine particles standard simultaneously with U.S. EPA approval of this 

State Implementation and Maintenance Plan.