1

Appendix M 

State and Local Control Measures 
2

Kentucky’s Regulations are located at: 

Open Burning 

http://www.lrc.ky.gov/kar/401/063/005.htm

Fugitive Dust 

http://www.lrc.ky.gov/kar/401/063/010.htm

LouMetro Air Pollution Control District’s Regulations are located at: 

Open Burning 

http://www.louisvilleky.gov/NR/rdonlyres/94818773-D227-4F1B-A30D-1B3D2A0D8488/0/111FV10.pdf

Fugitive Particulate Emissions 

http://www.louisvilleky.gov/NR/rdonlyres/BBE8C0CA-F988-4885-BB59-5775C7304B63/0/114fv2.pdf
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Fine Particle Air Quality Task Force 
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Fine Particle Air Quality Task Force 

Report and Plan of Action 

Executive Summary 

Fine particulate matter (PM2.5), a subset of inhalable particulate matter, is a mixture of 

solid particles and liquid droplets with diameters of 2.5 micrometers (μm) or less (for 

reference, the average human hair is about 70 μm in diameter – 30 times larger than the 

largest fine particle). PM2.5 is regulated as a criteria pollutant under the Clean Air Act. 

The federal primary annual standard for PM2.5 is 15 micrograms per cubic meter (μg/m3

). 

In April 2005, Jefferson and Bullitt Counties in Kentucky, and Clark, Floyd and portions 

of Jefferson County in Indiana, were designated nonattainment for the annual PM2.5

standard. Under federal law, Indiana and Kentucky are required to develop State 

Implementation Plan revisions (SIPs) due in April 2008, that outline how the Louisville 

nonattainment area will meet the annual PM2.5 standard by April 2010. There are many 

requirements for SIPs, such as identifying reasonably available control technologies and 

measures (RACT/RACM) for major sources and performing air quality modeling to 

demonstrate attainment of the annual standard. In addition to targeting PM2.5 control 

measures, states are also required to address controls for PM2.5 precursor emissions, such 

as sulfur dioxide and oxides of nitrogen that, under certain conditions, can lead to the 

formation of PM2.5 in the air. 

In April 2007, the Fine Particle Air Quality Task Force (Task Force) was created by 

Mayor Jerry Abramson to identify, evaluate and recommend strategies for reducing PM2.5

to achieve the annual PM2.5 standard. The Louisville Metro Air Pollution Control District 

(District) invited business leaders, environmental and health advocates, health 

professionals, neighborhood representatives and regional and local government 

representatives to participate in the Task Force. 

The Task Force formed working committees to perform central tasks such as: the 

characterization of PM2.5 pollution and its related health effects, collection and analysis 

of historical and projected air quality data, identification of major sources of PM2.5 and 

precursor emissions and strategies to reduce these emissions. As part of the development 

of such strategies, the committees of the Task Force compiled and synthesized 

information that may be used by the District in development of the SIP, such as an 

assessment of control measures to support the RACT/RACM analysis and modeling data 

to be included in the attainment demonstration. 

Committee reports and recommendations are included in Section 4 (Health Committee), 

Section 5 (Emissions Inventory and Modeling Data Committee), Section 6 (Stationary 

and Area Source Committee), Section 7 (Mobile and Nonroad Mobile Source 

Committee) and Section 8 (Report and Plan of Action Committee). These efforts served 

as the basis for building consensus on final Task Force recommendations. 

 i January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Section 9 (Plan of Action) includes 63 Task Force recommendations aimed at reducing 

PM2.5 and precursor pollution from a variety of sources. These recommendations cover a 

broad combination of strategies that can be accomplished through local, state and 

regional efforts. Eight of the 63 were selected as leading recommendations, or strategies, 

that the Task Force deemed as implementation priorities. Leading strategies include 

aggressive retrofit and replacement of onroad and nonroad diesel fleets, local adoption of 

onroad and nonroad idling regulations and enactment of local ordinances to prohibit open 

burning. Other leading strategies will require collaborative efforts, such as the District 

working with Kentucky and Indiana to reduce PM2.5 precursor emissions from major 

regional sources within 150 miles and working with local and regional planning agencies 

to expand the evaluation of development plan and subdivision proposals for air quality 

impacts. 

This Report and Plan of Action is the result of the collaborative efforts of Task Force 

members. The Task Force recognized that regional modeling groups project the 

Louisville nonattainment area to achieve the annual PM2.5 standard by the 2010 

attainment deadline with existing and planned controls from various programs, such as 

the Clean Air Interstate Rule (CAIR). The Task Force also recognized the need to reduce 

levels of PM2.5 below the annual standard to protect public health with an adequate 

margin of safety. This will require ongoing and continuous review of all sources of PM2.5

and precursor emissions. Considering the potential for significant reductions to ambient 

concentrations of PM2.5 from CAIR and other federal programs, the Task Force agreed to 

reconvene in 2010, after implementation of Phase I of CAIR, to review available 

monitoring data, modeling results and health studies and determine whether additional 

actions are advisable for the continuous improvement of air quality. 

 ii January 16, 2008 
Fine Particle Air Quality Task Force 

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Table of Contents 

Section 1 Introduction ..................................................................................................... 1 

1.1 Definition of Fine Particulate Matter and its Precursors ........................................ 1 

1.2 History of National Ambient Air Quality Standards for PM.................................. 2 

1.3 Overview of SIP Requirements .............................................................................. 3 

1.4 Pollutants to be Evaluated....................................................................................... 5 

Section 2 Related Federal, Regional, State and Local Actions.................................... 6 

2.1 Federal Actions....................................................................................................... 6 

2.1.1 Regulatory Programs .......................................................................................... 6 

2.1.2 Voluntary Programs............................................................................................ 7 

2.2 Regional Actions..................................................................................................... 9 

2.2.1 Association for Southeastern Integrated Planning Modeling ............................. 9 

2.2.2 Lake Michigan Air Directors Consortium Modeling........................................ 10 

2.3 State and Local Actions........................................................................................ 10 

2.3.1 Kentucky Division for Air Quality ................................................................... 10 

2.3.2 Indiana Department of Environmental Management........................................ 11 

2.3.3 Louisville Metro Air Pollution Control District ............................................... 12 

Section 3 Fine Particle Air Quality Task Force .......................................................... 13 

3.1 Development of the Task Force............................................................................ 13 

3.2 Committees of the Task Force .............................................................................. 13 

3.2.1 Health Committee ............................................................................................. 13 

3.2.2 Emissions Inventory and Modeling Data Committee....................................... 14 

3.2.3 Stationary and Area Source Committee............................................................ 14 

3.2.4 Mobile and Nonroad Mobile Source Committee.............................................. 14 

3.2.5 Report and Plan of Action Committee.............................................................. 14 

Section 4 Report of the Health Committee.................................................................. 15 

4.1 Background........................................................................................................... 15 

 iii January 16, 2008 
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4.2 Committee Actions............................................................................................... 16 

4.2.1 Scientific Literature Review ............................................................................. 16 

4.2.2 Goal or Standard ............................................................................................... 16 

4.2.3 Regional and Local Contributions to PM2.5 Pollution ...................................... 16 

4.2.4 Health-based Goal............................................................................................. 17 

4.3 Committee Recommendations.............................................................................. 18 

Section 5 Report of the Emissions Inventory and Modeling Data Committee......... 20 

5.1 Background........................................................................................................... 20 

5.2 Committee Actions............................................................................................... 20 

5.2.1 Historical Data .................................................................................................. 21 

5.2.1.1 Monitoring Data......................................................................................... 21 

5.2.1.2 Emissions Inventory Data .......................................................................... 25 

5.2.2 Projected Data................................................................................................... 27 

5.2.2.1 Boundaries and Assumptions..................................................................... 27 

5.2.2.2 Projected PM2.5 Design Values.................................................................. 28 

5.2.2.3 Emissions Inventory Data .......................................................................... 29 

5.3 Committee Recommendations.............................................................................. 30 

5.3.1 Information Needs ............................................................................................ 30 

5.3.2 Data Collection Process.................................................................................... 31 

5.3.3 Interpretation of Data........................................................................................ 31 

Section 6 Report of the Stationary and Area Source Committee.............................. 33 

6.1 Background........................................................................................................... 33 

6.2 Committee Actions............................................................................................... 33 

6.3 Committee Recommendations.............................................................................. 34 

6.3.1 Stationary Diesel Engines................................................................................. 34 

6.3.2 Emission Controls for Direct PM2.5 .................................................................. 34 

6.3.2.1 Direct PM2.5 Controls for Electric Generating Units................................. 34 

6.3.2.2 Direct PM2.5 Controls for Other Stationary Sources.................................. 35 

6.3.3 Improved Capture of Particulate Emissions ..................................................... 36 

6.3.4 Emissions Controls for PM2.5 Precursors.......................................................... 36 

 iv January 16, 2008 
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6.3.4.1 PM2.5 Precursor Controls for Electric Generating Units............................ 36 

6.3.4.2 PM2.5 Precursor Controls for Other Stationary Sources ............................ 37 

6.3.4.3 Reduced Sulfur Content of Fuels............................................................... 38 

6.3.5 Energy Efficiency Measures............................................................................. 38 

6.3.6 Measures to Reduce Fugitive Dust ................................................................... 40 

6.3.7 Open Burning.................................................................................................... 41 

6.3.8 Woodstoves, Fireplaces and Wood Boilers...................................................... 41 

6.3.9 Charbroiling and Other Commercial Cooking Operations............................... 42 

6.3.10 Use of Consumer Products................................................................................ 42 

6.3.11 Charcoal Grilling .............................................................................................. 42 

Section 7 Report of the Mobile and Nonroad Mobile Source Committee ................ 44 

7.1 Background........................................................................................................... 44 

7.2 Committee Actions............................................................................................... 44 

7.3 Committee Recommendations.............................................................................. 46 

7.3.1 Onroad and Nonroad Diesel Retrofit, Rebuild or Replacement ....................... 47 

7.3.2 Diesel Idling Programs ..................................................................................... 48 

7.3.3 Long-range Land Use and Transportation Planning Solutions......................... 48 

7.3.4 Emission Reductions or Accelerated Retirement of High Emitting Lawn and 

Garden Equipment ............................................................................................ 50 

7.3.5 Emissions Testing and Repair/Maintenance Programs..................................... 50 

7.3.6 Clean Burning Fuel Programs........................................................................... 50 

7.3.7 Contracting for Low Emissions Specifications................................................. 51 

Section 8 Report of the Report and Plan of Action Committee................................. 52 

8.1 Background........................................................................................................... 52 

8.2 Committee Actions............................................................................................... 52 

8.3 Committee Recommendations.............................................................................. 52 

Section 9 Plan of Action................................................................................................. 53 

9.1 Leading Recommendations................................................................................... 53 

9.2 Recommendations for Regional and State Action................................................ 55 

 v January 16, 2008 
Fine Particle Air Quality Task Force 

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9.2.1 Currently Achievable........................................................................................ 55 

9.2.2 Achievable in the Short-term............................................................................ 55 

9.2.3 Achievable in the Long-term ............................................................................ 56 

9.3 Recommendations for Louisville Metro Government Action .............................. 56 

9.3.1 Currently Achievable........................................................................................ 56 

9.3.2 Achievable in the Short-term............................................................................ 56 

9.3.3 Achievable in the Long-term ............................................................................ 57 

9.4 Recommendations for District Action .................................................................. 58 

9.4.1 Currently Achievable........................................................................................ 58 

9.4.2 Achievable in the Short-term............................................................................ 59 

9.4.3 Achievable in the Long-term ............................................................................ 63 

 vi January 16, 2008 
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List of Tables 

Table 1-1. Categories of Particulate Matter...................................................................1 

Table 5-1. Annual PM2.5 Means in μg/m3

 for Area FRM Monitors...........................21 

Table 5-2. Future Design Values for Local Monitors ..................................................28 

List of Figures 

Figure 5-1. Map of Area PM2.5 Monitors......................................................................21 

Figure 5-2. PM2.5 Design Values in μg/m3

 for Area FRM Monitors ..........................22 

Figure 5-3. Speciation Data for Louisville Metro and Kentucky, 2002 to 2006........23 

Figure 5-4. Monthly Speciation Data from Monitor 21-111-0043 in 2006.................23 

Figure 5-5. PM2.5 Composition and Estimated Urban Excess for U.S. Cities ...........24 

Figure 5-6. Source Apportionment, by Percent, of Total Emissions in Jefferson 

 County, KY Based on APCD 2005 Emissions Inventory Data ...............26 

Figure 5-7. Maps of ASIP and LADCO Regional Modeling Domains.......................27 

Figure 5-8. ASIP 2002, 2009 and 2018 Emissions for the State of Kentucky ............29 

Figure 5-9. ASIP 2002, 2009 and 2018 Emissions for Jefferson County, KY............30 

 vii January 16, 2008 
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List of Appendices 

Appendix 1: Acronyms and Abbreviations .................................................................66 

Appendix 2: Fine Particle Air Quality Task Force Members....................................69 

Appendix 3: Fine Particle Air Quality Task Force Committee Members................70 

Appendix 4: Record of Health Committee Meeting Attendance...............................71 

Appendix 5: List of source categories for starting point for identifying potentially 

 available control strategies for nonattainment area.............................72 

Appendix 6: Stationary/Area Source Reduction Strategy Evaluation Matrix ........74 

Appendix 7: DRAFT E.ON U.S. Planned Control Projects.......................................75 

Appendix 8: Current and Planned Pollutant Control Measures for Indiana 

 Utilities ......................................................................................................77 

Appendix 9: Energy Efficiency Programs and Projects.............................................79 

Appendix 10: Draft Idle Reduction Regulation ............................................................86 

Appendix 11: Report and Plan of Action Committee Leading Recommendations ...88 

 viii January 16, 2008 
Fine Particle Air Quality Task Force 

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Section 1 Introduction 

1.1 Definition of Fine Particulate Matter and its Precursors 

According to the United States Environmental Protection Agency (EPA)1

, particle 

pollution, also called particulate matter (PM), is a mixture of solid particles and liquid 

droplets found in the air. PM comes in many sizes and shapes and may contain many 

different chemicals. Particles are generally classified by their diameter, which is 

measured in micrometers (μm). The categories of PM are provided in Table 1-1. EPA 

monitors and regulates ambient concentrations of inhalable particles (PM10) and fine 

particles (PM2.5). 

Table 1-1. Categories of Particulate Matter 

Particle Category Diameter (μm) 

Inhalable (PM10) ≤ 10 

Coarse (PM10-2.5) 10 to 2.5 

Fine (PM2.5) ≤ 2.5 

Ultrafine (PM0.1) ≤ 0.1 

Fine particles can be emitted directly by a source and may include organic carbon (OC), 

elemental carbon (EC) and crustal material (e.g. dust, sea salt, metals and other trace 

elements). This pollution is referred to in this Report and Plan of Action (Report) as 

direct PM2.5. Fine particles can also be formed though chemical reactions of gaseous 

precursors in the atmosphere (e.g. ammonium nitrate and ammonium sulfate). Precursors 

include sulfur dioxide (SO2), oxides of nitrogen (NOx), volatile organic compounds 

(VOCs) and ammonia (NH3). In the Louisville nonattainment area, EPA has identified 

SO2 and NOx as significant precursors contributing to the monitored ambient 

concentration of PM2.5. These two pollutants are collectively referred to as precursors in 

this Report. VOCs and NH3 do not significantly contribute to the formation of PM2.5 in 

this area. 

The health effects associated with exposure to PM2.5 can be considerable. Particles less 

than or equal to 2.5 μm in diameter can be inhaled deep into the lungs and some may 

enter the bloodstream. Long-term exposure to PM2.5 has been associated with adverse 

health effects such as decreased lung function, development of chronic bronchitis and 

premature death. Short-term exposure (i.e. hours or days) to PM2.5 has been associated 

with a range of effects, including decreased lung function, increased respiratory 

symptoms, cardiac arrhythmias, heart attacks, emergency room visits for heart or lung 

disease and premature death. Although fine particles affect the general population to 

some degree, older adults, individuals with heart or lung disease and children are 

particularly sensitive to PM2.5 exposure. 

 

1

 A list acronyms and abbreviations is included in Appendix 1. 

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1.2 History of National Ambient Air Quality Standards for PM 

On July 18, 1997, EPA announced new National Ambient Air Quality Standards 

(NAAQS) for PM. EPA revised the primary, or health-based, PM standards by setting a 

new annual standard for PM2.5 of 15 micrograms per cubic meter (μg/m3) and a new 24-

hour PM2.5 standard of 65 μg/m3. The PM10 standards were also revised and monitoring 

requirements were issued using new federal reference methods. 

A number of events delayed the implementation of the 1997 PM NAAQS: 

 In 1998, the Transportation Equity Act for the 21st Century revised the 

deadline for publishing nonattainment designations to provide additional time 

to collect three years of air quality monitoring data. 

 In 1999, the 1997 PM NAAQS were challenged in court by the American 

Trucking Association, the U.S. Chamber of Commerce and other state and 

business groups. 

 In 2001, the Supreme Court upheld EPA's authority under the Clean Air Act 

(CAA) to set NAAQS that protect the American public from harmful effects 

of air pollution. The Supreme Court also sent the case back to the D.C. Circuit 

Court of Appeals to resolve several additional issues. 

 In 2002, the D.C. Circuit Court rejected all remaining legal challenges to 

EPA's 1997 PM NAAQS. 

Early in 2003, EPA provided guidance to states2 for recommending nonattainment area 

boundaries for the annual PM2.5 standard. Consistent with the CAA, the guidance gave 

states the following instruction: 

 Begin analysis of attainment and nonattainment area boundaries based on the 

boundaries of metropolitan areas. 

 Include nearby counties with sources of direct PM2.5 and precursor emissions 

in a metropolitan area’s nonattainment area. 

 Give consideration to the use of common boundaries for areas to be 

designated nonattainment for PM2.5 and 8-hour ozone to help coordinate 

future planning and implementation activities. 

 Give consideration to population density, traffic and commuting patterns, 

commercial development and area growth when areas are recommended for 

attainment and nonattainment designation. 

In mid-February 2004, states recommended areas to be designated nonattainment for the 

annual PM2.5 standard by EPA. After assessing three years of monitoring data from 2001 

to 2003, EPA designated areas not meeting the annual PM2.5 standard. The nonattainment 

designations became effective on April 5, 2005 for 39 metropolitan areas, affecting a 

population of approximately 88 million across 208 counties in the United States. The area 

that includes Jefferson and Bullitt Counties in Kentucky, and Clark, Floyd and portions 

 

2

 Throughout this Report, “states” is used to reference any jurisdiction with appropriate authority. 

Page 2 January 16, 2008 
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of Jefferson County in Indiana, was designated nonattainment (Louisville nonattainment 

area). This designation plays an important role in letting the public know whether air 

quality in their area is healthy and becomes an important component of state, local and 

tribal governments' efforts to reduce fine particle pollution. 

On October 17, 2006, EPA published revised PM NAAQS that significantly strengthened 

the 24-hour PM2.5 standard from 65 μg/m3 to 35 μg/m3 while retaining the annual PM2.5

standard of 15 μg/m3. In EPA’s judgment, the revised 24-hour standard provided 

adequate protection from short-term exposure to PM2.5. 

The federal government has made the reduction of PM2.5 a critical element of a 

comprehensive national clean air strategy. This strategy includes EPA's recent National 

Clean Diesel Campaign to reduce pollution from diesel engines and the Clean Air 

Visibility Rule and Clean Air Interstate Rule (CAIR) to reduce pollution from power 

plants in the eastern U.S. These initiatives are important components of EPA's efforts to 

help states and localities meet the more protective PM2.5 NAAQS through a largely 

regional approach. 

1.3 Overview of SIP Requirements 

By law, Indiana and Kentucky are subject to a number of requirements to reduce PM2.5, 

including submittal of State Implementation Plan revisions (SIPs), which outline how 

nonattainment areas, including the Louisville nonattainment area, will meet the annual 

PM2.5 standard. The SIP submission deadline is April 5, 2008, three years from the date 

of designation, as required by the CAA. 

On April 25, 2007, EPA published the Clean Air Fine Particle Implementation Rule3

(Implementation Rule), which describes the CAA framework and requirements that state, 

local and tribal governments must meet in developing their PM2.5 SIPs. For areas 

designated as nonattainment, states are required to attain the annual PM2.5 standard of 

15 μg/m3

 by April 2010, five years from the date of designation. As part of the SIP, states 

may propose an attainment date extension of up to five years. Those areas for which EPA 

approves an extension must achieve compliance as soon as possible, but no later than 

2015. The Implementation Rule does not specifically address implementation of the 24-

hour standard, revised in 2006. 

In compliance with 40 CFR 51 (sections numbers included below for reference), PM2.5

SIPs must include the following components: 

Attainment demonstration and modeling requirements (§51.1007) – States are 

required to submit attainment demonstrations consisting of: 

 

3

 Throughout this Report, underlined text indicates a link to related websites or documents. Links can be 

accessed in an electronic version of this Report available at http://www.louisvilleky.gov/APCD/TaskForce/

A detailed list of links to documents reviewed by the Task Force and committees can also be found there. 

Page 3 January 16, 2008 
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 Technical analyses that locate, identify and quantify sources of emissions 

contributing to nonattainment of the standard. 

 Analyses of future year emission reductions and air quality improvement resulting 

from already-adopted national and local programs, and from potential new local 

measures to meet RACT/RACM and RFP requirements (defined below). 

 Adopted emission reduction measures with schedules for implementation. 

 Contingency measures required under the CAA. 

Emissions inventory requirements (§51.1008) – States must include a complete 

emissions inventory for all sources of PM2.5 and precursor emissions in the nonattainment 

area. The inventory should include all source categories including stationary, onroad 

mobile, nonroad mobile and area sources. 

Reasonable further progress (RFP) requirements (§51.1009) – States demonstrating 

attainment by April 2010 will be considered to have satisfied RFP requirements. 

However, states requesting an extended attainment deadline must submit an RFP plan 

and supporting emissions inventory information, which describes incremental emission 

reductions needed to ensure progress towards attainment by the extended deadline. 

Reasonably available control technology (RACT) and reasonably available control 

measures (RACM) requirements (§51.1010) – RACT and RACM include emission 

reduction measures that are necessary to obtain the annual PM2.5 standard as 

expeditiously as practicable or that would advance attainment of the standard by at least 

one year. States define measures as “reasonably available” through an analysis including 

considerations for economic and technical feasibility. In the Implementation Rule, EPA 

presumes that implementation of CAIR control measures are reasonably available and 

would satisfy, with certain restrictions, RACT/RACM for SO2 and NOx emissions from 

power plants. However, states may impose additional requirements on a specific source, 

large or small, if it determines that these requirements are both necessary and reasonable 

to expeditiously attain the standard. 

Transportation conformity requirement (§51.390) – States are required to determine 

appropriate motor vehicle emissions budgets for PM2.5 and precursors to satisfy 

transportation conformity requirements. Transportation conformity, required under the 

CAA, ensures that federally supported highway and transit project activities reflect 

consideration for air quality issues. Conformity means that transportation activities will 

not cause new air quality violations, worsen existing violations or delay timely attainment 

of the relevant NAAQS (40 CFR 93). On March 10, 2006, EPA published a final rule that 

established transportation conformity criteria and procedures for determining which 

transportation projects must be analyzed for local air quality impacts in PM 

nonattainment areas (71 FR 12468). 

Contingency measures requirement (§51.1012) – States are required to include 

contingency measures, which are additional control measures to be implemented in the 

event that an area fails to meet RFP or fails to attain the standard by its attainment date. 

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States must show that contingency measures can be implemented without significant 

further action by the state or EPA. 

In addition, throughout 40 CFR 51 the basic requirements to receive federal approval of 

emission reduction measures in the SIP are defined as: 

 Surplus – Emission reductions are considered surplus as long as they are not 

otherwise relied on in air quality-related programs already included in the SIP.

 Enforceable – Emission reductions and other required actions must be enforceable 

against the source of emissions. State or local agencies are responsible for 

ensuring that voluntary emission reductions are achieved, making voluntary 

emission reductions enforceable against the agency. 

 Quantifiable – Emissions and emission reductions attributed to the measure are 

quantifiable if someone can reliably and replicably measure or determine them.

 Permanent – An emission reduction measure is considered permanent if it 

continues throughout the term that the credit is granted, unless it is replaced by 

another measure or the state demonstrates in a subsequent SIP revision that the 

emission reductions from the measure are no longer needed to attain and maintain 

compliance with the annual PM2.5 standard.

1.4 Pollutants to be Evaluated 

There are five main types of pollutants that may be addressed in the SIP: direct PM2.5, 

SO2, NOx, VOCs and NH3. The effect of reducing emissions varies depending on particle 

composition, emission levels and other area-specific factors. Therefore, EPA requires the 

following evaluation: 

 Direct PM2.5 must be evaluated for emission reduction measures in all 

nonattainment areas, but allows some flexibility after the initial evaluation. 

 SO2 must be evaluated for emission reduction measures in all nonattainment 

areas. 

 NOx must be evaluated for emission reduction measures in each area unless 

the state and EPA demonstrate that NOx is not a significant contributor to 

PM2.5 concentrations in a specific area. 

 VOCs are not required to be evaluated for emission reduction measures in 

each area unless the state or EPA demonstrates that VOCs significantly 

contribute to PM2.5 concentrations in a specific area. 

 NH3 is not required to be evaluated for emission reduction measures in each 

area unless the state or EPA demonstrates that NH3 significantly contributes to 

PM2.5 concentrations in a specific area. 

Demonstrations to show significance of VOCs and NH3 or insignificance of NOx must 

represent available information including speciation data analyses, air quality modeling 

studies, chemical tracer studies, emissions inventories or special atmospheric chemistry 

studies. Only direct PM2.5, SO2 and NOx are considered significant for the Louisville 

nonattainment area. 

Page 5 January 16, 2008 
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Section 2 Related Federal, Regional, State and Local Actions 

2.1 Federal Actions 

There are a number of national initiatives that are expected to reduce ambient PM2.5

concentrations. These regulatory and voluntary programs, promulgated by EPA, will 

reduce emissions of direct PM2.5 as well as precursor emissions. The following are among 

those expected to have the greatest effect. 

2.1.1 Regulatory Programs 

Clean Air Interstate Rule (CAIR) – CAIR is a two-phased program that dramatically 

reduces and permanently caps emissions of SO2 and NOx from coal-fired power plants in 

the eastern United States. Based on an assessment of the emissions contributing to 

interstate transport of air pollution and available control measures, EPA has determined 

that achieving required reductions in the identified states by controlling emissions from 

power plants is highly cost-effective. When fully implemented, CAIR will reduce SO2

emissions from power plants in 28 eastern states and the District of Columbia by more 

than 70% and NOx emissions by more than 60% from 2003 levels. For more information, 

please visit http://www.epa.gov/CAIR/basic.html. 

Clean Air Visibility Rule – On June 15, 2005, EPA finalized amendments to the July 

1999 regional haze rule. These amendments apply to the provisions of the regional haze 

rule that require emission controls known as best available retrofit technology (BART) 

for industrial facilities emitting air pollutants that reduce visibility by causing or 

contributing to regional haze. The pollutants include PM2.5 and compounds that 

contribute to PM2.5 formation, such as NOx, SO2, and under certain conditions, VOCs and 

NH3. EPA evaluated three possible scenarios of actions states may take to comply with 

this rule. Under the medium stringency scenario EPA estimates that implementation of 

BART controls will reduce annual emissions of NOx and SO2 by approximately 600,000 

and 400,000 tons, respectively. For more information, please visit 

http://www.epa.gov/air/visibility/index.html. 

Heavy-Duty Highway Diesel Rule – EPA established a comprehensive national control 

program that regulates a heavy-duty vehicle and its fuel as a single system. As part of this 

program, new emission standards took effect in model year 2007 and apply to heavy-duty 

highway engines and vehicles. These standards are based on the use of high-efficiency 

catalytic exhaust emission control devices or comparably effective advanced 

technologies. Because these devices are damaged by sulfur, EPA also mandated the 

reduction in the level of sulfur in highway diesel fuel by 97% in 2006. 

EPA projects a 2.6 million ton reduction of NOx emissions in 2030 when the current 

heavy-duty vehicle fleet is substantially replaced with newer heavy-duty vehicles that 

comply with these emission standards. By 2030, this program will reduce annual 

Page 6 January 16, 2008 
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emissions of non-methane hydrocarbons by 115,000 tons and PM by 109,000 tons. For 

more information, please visit http://www.epa.gov/otaq/diesel/index.htm. 

Clean Air Nonroad Diesel Rule – EPA's Clean Air Nonroad Diesel Rule requires 

stringent pollution controls on diesel engines used in industries such as construction, 

agriculture and mining, and will slash sulfur content of diesel fuel. This nonroad diesel 

program combines cleaner engine technologies with cleaner fuel, similar to the onhighway diesel program. The new standards will cut emissions from nonroad diesel 

engines by over 90%. Sulfur levels will be reduced in nonroad diesel fuel by 99% from 

2006 levels (from approximately 3,000 parts per million [ppm] in 2006 to 500 ppm in 

2007 to 15 ppm in 2010). The lower sulfur fuel will provide immediate public health 

benefits by reducing PM from engines in existing nonroad equipment. It also makes it 

possible for engine manufacturers to use advanced clean technologies, similar to catalytic 

technologies used in passenger cars. New engine standards take effect, based on engine 

horsepower, starting in 2008. EPA anticipates annual reductions of 738,000 tons of NOx

and 129,000 tons of PM. For more information, please visit 

http://www.epa.gov/otaq/diesel/index.htm. 

Tier 2 Vehicle and Gasoline Sulfur Program – Compared to Model Year 2003 and 

earlier, vehicles meeting the Tier 2 emission standards are much cleaner. For the first 

time, under this rule all passenger cars and light trucks are covered by the same emission 

standards. The key to meeting the stringent Tier 2 emission standards has been the large 

reduction of sulfur levels in gasoline. Sulfur in the fuel impairs the effectiveness of 

vehicle emission control systems. Vehicles meeting the Tier 2 emission standards are 77 

to 95% cleaner, depending on vehicle size, compared with model year 2003 and earlier. 

EPA expects this program to reduce emissions of NOx from vehicles by approximately 

74% (nearly 3 million tons) by 2030. For more information, please visit 

http://www.epa.gov/tier2/. 

Proposed Emissions Standards for Locomotives and Marine Compression-Ignition 

Engines – This EPA proposed rule is another aspect of its clean diesel program that 

already has established rules for highway and other nonroad diesel equipment. In its 

regulatory announcement, EPA estimates that by 2030 this comprehensive emission 

control program will reduce annual emissions of NOx and PM by 765,000 and 28,000 

tons, respectively, and the magnitude of these reductions could continue to grow well 

beyond 2030. For more information, please visit http://www.epa.gov/otaq/locomotv.htm. 

2.1.2 Voluntary Programs 

National Clean Diesel Campaign (NCDC) – Building on EPA’s regulatory and 

voluntary efforts to reduce emissions from diesel engines, EPA created NCDC. 

Participants are committed to reducing diesel emissions and finding innovative ways to 

protect human health and the environment. To address the challenges of reducing diesel 

emissions, NCDC is using a multi-pronged approach that includes regulations for clean 

diesel engines and fuels, EPA regional collaboratives and partnerships and voluntary 

programs for the existing diesel fleet. In addition to providing a framework for 

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partnerships and information for outreach and education, some of these programs also 

include grant money to support their goals. For more information, please visit 

http://www.epa.gov/cleandiesel/index.htm.

Southeast Diesel Collaborative (SEDC) – SEDC is a voluntary, public/private 

partnership involving federal, state and local government, the private sector and other 

stakeholders in Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South 

Carolina and Tennessee. SEDC is part of EPA’s National Clean Diesel Campaign. The 

goal of SEDC is to improve air quality and public health by encouraging the use of clean, 

renewable energy and technology and by reducing diesel emissions from existing engines 

and equipment from the agriculture, heavy construction and onroad sectors. For more 

information, please visit http://www.southeastdiesel.org. 

Clean School Bus USA – Clean School Bus USA brings together partners from business, 

education, transportation and public health organizations to work toward these goals: 

1. Encouraging policies and practices to eliminate unnecessary public 

 school bus idling. 

2. Upgrading (i.e. retrofitting) buses that will remain in the fleet with better 

 emission control technologies and/or fueling them with cleaner fuels. 

3. Replacing the oldest buses in the fleet with new, less polluting buses. 

For more information, please visit http://www.epa.gov/cleanschoolbus/.

Clean Ports USA – Clean Ports USA is an incentive-based, voluntary program designed 

to reduce emissions from existing diesel engines and non-road equipment at ports with 

comprehensive strategies and information for the diverse range of ports and their staff. 

For more information, please visit http://www.epa.gov/cleandiesel/ports/. 

Clean Construction USA – Clean Construction USA is a voluntary program designed to 

promote the reduction of diesel emissions from construction equipment and vehicles. 

Clean Construction USA encourages contractors, owners and operators of construction 

equipment to properly maintain their equipment, reduce idling, retrofit diesel engines 

with verified technologies, replace older equipment, use cleaner fuels and repower 

equipment (i.e. replace older engines with newer, cleaner engines). For more information, 

please visit http://www.epa.gov/cleandiesel/construction/. 

SmartWay Transport – The SmartWay Transport Partnership is a voluntary 

collaboration between EPA and the freight industry designed to increase energy 

efficiency while significantly reducing greenhouse gases and air pollution. There are 

three primary components of the program: creating partnerships, reducing all unnecessary 

engine idling and increasing the efficiency and use of rail and intermodal operations. 

Several members of the freight industry that operate locally are already partners in the 

SmartWay program. For example, UPS, which has a significant presence in Louisville 

Metro, is a charter member of the SmartWay program. For more information, please visit 

http://www.epa.gov/smartway/index.htm. 

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Voluntary Diesel Retrofit Technology Verification Program – This program offers 

information and technical support on retrofitting diesel engines to reduce toxic emissions. 

The objective of the voluntary Diesel Retrofit Technical Verification Program is to 

introduce verified technologies to the market as cost-effectively as possible, while 

providing customers with confidence that verified technologies will provide emission 

reductions as advertised. For more information, please visit 

http://www.epa.gov/otaq/retrofit. 

Best Workplaces for Commuters (BWC) – This is a voluntary business/government 

program that distinguishes and provides national recognition to employers offering 

outstanding commuter benefits such as free or low-cost bus passes, strong telework 

programs, carpool matching and vanpool subsidies. EPA and the United States 

Department of Transportation (DOT) assist participating employers by offering public 

recognition and promotion, technical assistance, training, web-based tools and forums for 

information exchange. 

Employers that meet EPA's National Standard of Excellence in commuter benefits are 

included on the BWC list, a fast-growing mark of excellence in environmental leadership. 

Sometimes outstanding commuter benefits are provided not by the employers themselves, 

but by another organization such as a business park, downtown district, developer or 

property manager. To recognize these areas for their leadership, EPA designates them a 

BWC District. 

Smart Growth Program – Through research, tools, partnerships, case studies, grants 

and technical assistance, EPA is helping America's communities turn their visions of the 

future into reality. Smart growth practices can lessen the environmental impacts of 

development with techniques that include compact development, reduced impervious 

surfaces and improved water detention, safeguarding of environmentally sensitive areas, 

mixing of land uses (e.g., homes, offices and shops), transit accessibility and improved 

pedestrian and bicycle amenities. For more information, please visit 

http://www.epa.gov/smartgrowth/index.htm. 

2.2 Regional Actions 

Draft guidance from EPA indicated that a significant requirement of PM2.5 SIPs would be 

attainment demonstrations using, at least in part, modeling analyses to define effective 

emissions control strategies and confirm that attainment can be achieved after 

implementation of the strategies. The following organizations conducted large scale 

regional modeling projects to help member states demonstrate projected attainment of the 

annual PM2.5 standard in their SIPs. 

2.2.1 Association for Southeastern Integrated Planning Modeling 

The Association for Southeastern Integrated Planning (ASIP) is a collaborative effort to 

develop information upon which to base the PM2.5 and 8-hour ozone attainment 

demonstrations. Collaborating states include Alabama, Florida, Georgia, Kentucky, 

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Mississippi, North Carolina, South Carolina, Tennessee, Virginia and West Virginia. 

Several local air regulatory agencies, including the Louisville Metro Air Pollution 

Control District (District), have also become signatory parties to this collaborative effort. 

ASIP operated regional scale, three-dimensional air quality models for ozone and PM2.5

that simulate the emissions, chemical transformations and transport of PM and gaseous 

precursors in the eastern United States. A key element of this work includes the 

integration of emissions inventories and models with regional transport models. Through 

regional modeling, ASIP worked with member states to demonstrate attainment of the 

annual PM2.5 standard. The ASIP regional ozone and PM2.5 modeling builds off of the 

Visibility Improvement State and Tribal Association of Southeast (VISTAS) Phase II 

2002 annual modeling. 

2.2.2 Lake Michigan Air Directors Consortium Modeling 

The Lake Michigan Air Directors Consortium (LADCO) was established in 1990 by the 

states of Illinois, Indiana, Michigan and Wisconsin. In March 2004, the states signed a 

new Memorandum of Agreement which added the state of Ohio as a member. The main 

purpose of LADCO is to provide technical assistance to its member states on problems of 

air quality; and to provide a forum for its member states to discuss air quality issues. 

LADCO's major pollutants of concern are ozone, fine particles and regional haze and 

their precursors; however, problems related to other pollutants (e.g. air toxics and 

greenhouse gases) may be assessed at the direction of the member states. LADCO's 

primary geographic focus is the area encompassed by its member states and any areas 

which affect air quality in its member states. For more information, please visit 

http://www.ladco.org/about.html. 

2.3 State and Local Actions 

In addition to the myriad of programs being administered at the federal level, there are 

regulatory and voluntary programs at the state and local level that have the potential to 

affect direct PM2.5 and precursor emissions in the Louisville nonattainment area. 

2.3.1 Kentucky Division for Air Quality 

Open Burning – The Kentucky Division for Air Quality’s (KY DAQ) open burning 

rules allow for some materials to be burned; however, many materials, including garbage, 

construction materials and tires, are illegal to burn. The state open burning rules impose 

limits on when and where burning can occur. It is illegal to conduct open burning in those 

counties that are designated as nonattainment for the 1-hour ozone, 8-hour ozone, PM10

or PM2.5 NAAQS during the months of May through September. Illegal burns are subject 

to a fine of up to $25,000. For more information, please visit 

http://www.air.ky.gov/homepage_repository/Open+Burning.htm. 

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2.3.2 Indiana Department of Environmental Management 

Open Burning – Open burning is generally prohibited in Indiana. However, there are 

exceptions, which are described in the rules on open burning, found in 326 IAC 4. In 

addition to the listed exceptions, permits may be obtained from the Indiana Department 

of Environmental Management (IDEM) to engage in open burning. Approval of an open 

burning permit is subject to evaluation based on several criteria including whether or not 

the burning site is located in a county that is designated nonattainment for PM10 or ozone. 

Residential open burning (i.e. household or yard waste) is totally banned in Lake, Porter, 

Clark and Floyd Counties, and no permits are granted for burning in those counties. For 

more information, please visit 

http://www.state.in.us/idem/your_environment/air_quality/openburning/. 

DieselWise Web Resource – As part of IDEM’s continuing education and outreach 

program associated with ozone and fine particles, the DieselWise web page provides a 

reference point for various diesel and alternative fuel topics. These topics include: health 

issues, idling issues, Indiana diesel reduction initiatives and projects, school-related 

programs, alternative fuels and diesel retrofit technologies. For more information, please 

visit http://www.state.in.us/idem/programs/air/dieselwise/index.html. 

State-Sponsored Retrofit Projects – In partnership with the Indiana Department of 

Transportation (INDOT), IDEM helped develop and implement a program to retrofit over 

500 INDOT heavy-duty diesel trucks, many of which operate out of the Seymour District 

in Southern Indiana. The emission reductions from this “lead by example” program will 

be realized on a regional, as well as local, level. 

School Bus Idle Reduction – In cooperation with the School Transportation Association 

of Indiana (STAI), IDEM introduced a voluntary reduced-idling program across Indiana. 

This policy was unanimously adopted by STAI members at its annual conference in 2004 

and is being implemented by the greater majority of Indiana schools, including those in 

Southern Indiana. Benefits of implementing this policy include: protecting the health of 

student passengers and school bus drivers, reducing air pollutants that contribute to high 

ozone and fine particles in a community, and saving money by lowering fuel 

consumption and maintenance costs. For more information, please visit 

http://www.state.in.us/idem/programs/air/dieselwise/schoolbuses.html. 

Rail and Port Projects – In partnership with The Ports of Indiana-Jeffersonville and MG 

Rail, Inc., IDEM received an EPA grant award to improve air quality and the quality of 

life in and around this Ohio River port. Four locomotives operate nearly 24 hours per 

day, 7 days per week at The Ports of Indiana-Jeffersonville facility. This project will add 

auxiliary power units to two of the locomotives to dramatically reduce unnecessary 

idling. In addition, two slug-units (i.e. non-powered locomotives with active 

electromotive drive) will be mated to existing locomotives allowing these mated pairs to 

move twice the number of rail cars per diesel powered locomotive, thereby making 

significant reductions in fuel consumption as well as harmful diesel emissions. 

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2.3.3 Louisville Metro Air Pollution Control District 

Open Burning – Open burning is generally prohibited in Louisville Metro. There are 

exceptions, however, including a broad acceptance of noncommercial cooking (e.g. 

backyard grilling), as well as specially permitted fires, such as bon fires, fire-training 

exercises and agricultural fires. For more information, please visit 

http://www.louisvilleky.gov/APCD/EE/OpenBurning.htm. 

Ozone Air Quality Task Force – The Ozone Air Quality Task Force was created in 

2003 to help develop a long-term strategy to improve Louisville Metro’s air quality. The 

group’s responsibility was to identify, evaluate and recommend strategies to the Air 

Pollution Control Board (Board) to be included in a new SIP for the 8-hour ozone 

standard. The task force presented the Board with a report in January 2006, which 

included recommendations for increased diesel retrofits, an idling regulation and 

reduction measures at airports, among others. Several of the task force’s 

recommendations could also help reduce emissions of PM2.5 throughout the Louisville 

nonattainment area. For more information, please visit 

http://www.louisvilleky.gov/APCD/Board/AirQualityTaskForce.htm. 

Strategic Toxic Air Reduction (STAR) Program – The District’s STAR program, 

designed to reduce toxic air contaminants, was created in response to several studies 

which demonstrated that Louisville Metro had unacceptably high levels of toxic 

chemicals in the air. There are three key components of the STAR program. The first 

component establishes the framework and methodologies for determining risk associated 

with toxic air pollution. The second regulates toxic emissions from large and moderate 

industrial and commercial operations. The third component addresses smaller sources 

(e.g., dry cleaners, diesel trucks, marine vessels) through the creation of a plan of action, 

including stakeholder involvement. The STAR 5.30 Stakeholder Group recommended 

strategies for reducing toxic emissions from these sources. Several of the group’s 

recommendations could also reduce emissions of PM2.5. For more information, please 

visit http://www.louisvilleky.gov/APCD/STAR. 

Partnership for a Green City (PGC) – The PGC began in August 2004, as a major step 

toward overcoming challenges to Louisville Metro's environmental practices. The PGC 

represents a collaborative effort to improve environmental education, health and 

management by three of Louisville Metro's largest public entities: Louisville Metro 

Government, the University of Louisville (U of L) and the Jefferson County Public 

Schools (JCPS). Together, these agencies own more than 500 buildings, 7,000 vehicles 

and 25,000 acres of land in Louisville Metro. Through the coordination of efforts and 

cooperation, the PGC has been able to realize results that will have long-term impacts on 

the health, education and well-being of Louisville Metro citizens. The PGC’s Climate 

Change Committee is preparing a community-wide plan for reducing greenhouse gases in 

the Louisville Metro area. Other PGC committees are working on improving energy 

efficiency, increasing green purchasing and decreasing fleet emissions among the partner 

entities. PGC efforts could also help reduce emissions of PM2.5. For more information, 

please visit http://www.jefferson.k12.ky.us/Departments/EnvironmentalEd/GreenCity/. 

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Section 3 Fine Particle Air Quality Task Force 

3.1 Development of the Task Force 

The Fine Particle Air Quality Task Force (Task Force) was created by Mayor Jerry 

Abramson in April 2007 to identify, evaluate and recommend strategies for reducing 

PM2.5 to achieve the annual PM2.5 standard. The District invited business leaders, 

environmental and health advocates, health professionals, neighborhood representatives 

and regional and local government representatives to participate in the Task Force. Dr. 

Robert Powell and Mr. Patrick Moran co-chaired the Task Force. A full list of Task Force 

members is included as Appendix 2. 

After initial meetings to review background information and establish goals and 

expectations, the Task Force formed working committees to perform central tasks such 

as: the characterization of PM2.5 pollution and its related health effects, collection and 

analysis of historical and projected air quality data, identification of major sources of 

direct PM2.5 and precursor emissions in the Louisville nonattainment area and the 

recommendation of strategies to reduce these emissions. As part of the development of 

such strategies, the committees compiled and synthesized information that may be used 

by the District in development of the SIP, such as an assessment of control measures to 

support the RACT/RACM analysis and modeling data to be included in the attainment 

demonstration. 

Throughout the process, the Task Force and its committees heard presentations on federal 

PM2.5 standards and implementation guidance, air quality monitoring, federal emission 

and fuel requirements, the co-benefits of local ozone and toxics programs, PM2.5

speciation data and regional modeling results. 

Committee reports and recommendations are included as Section 4 (Health Committee), 

Section 5 (Emissions Inventory and Modeling Data Committee), Section 6 (Stationary 

and Area Source Committee), Section 7 (Mobile and Nonroad Mobile Source 

Committee) and Section 8 (Report and Plan of Action Committee) of this Report. The 

members of each committee are listed in Appendix 3. 

As committee work concluded, committee reports and recommendations were submitted 

to the full Task Force for consideration. The Task Force members then began discussions 

on the plan of action that was recommended to the Board at its January 2008 meeting. 

3.2 Committees of the Task Force 

3.2.1 Health Committee 

The Health Committee was formed to focus on issues related to the health effects of 

PM2.5 exposure. The primary task of the Health Committee was to determine whether 

there is a theoretically “safe” level of ambient PM2.5 and whether public health concerns 

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related to PM2.5 exposure could be further addressed by setting a goal to reduce ambient 

PM2.5 to levels more stringent than the annual standard of 15 μg/m3. 

3.2.2 Emissions Inventory and Modeling Data Committee 

The Emissions Inventory and Modeling Data Committee was formed to support the Task 

Force and its committees with the collection, distribution and understanding of technical 

information related to PM2.5. 

3.2.3 Stationary and Area Source Committee 

The Stationary and Area Source Committee was formed to identify stationary and area 

sources of direct PM2.5 and precursor emissions and the control measures being 

implemented throughout the Louisville nonattainment area. The committee considered 

various educational, voluntary and regulatory strategies for reducing direct PM2.5 and 

precursor emissions. 

Stationary sources are generally industrial or commercial operations subject to the 

District’s permit requirements and include those companies with Title V, Federally 

Enforceable District Origin Operating Permits (FEDOOPs) and minor source permits. 

Area sources include anthropogenic sources of emissions that are not considered 

stationary, onroad mobile or nonroad mobile. Examples of area sources include backyard 

charcoal grilling, wood burning and commercial charbroiling. 

3.2.4 Mobile and Nonroad Mobile Source Committee 

The Mobile and Nonroad Mobile Source Committee was formed to identify onroad and 

nonroad mobile sources of direct PM2.5 and precursor emissions and the control measures 

being implemented throughout the Louisville nonattainment area. The committee 

considered various educational, voluntary and regulatory strategies for reducing direct 

PM2.5 and precursor emissions. 

Onroad mobile sources are motorized vehicles that are registered for use on public roads 

and highways, including automobiles, light- and heavy-duty trucks, buses and 

motorcycles. Nonroad mobile sources are motorized vehicles that are not registered for 

use on public roads and highways or any other equipment with a fossil fuel-fired engine 

that is not a point source. Examples include aircraft, boats, railroad engines, construction 

equipment and nonroad recreational equipment. 

 

3.2.5 Report and Plan of Action Committee 

The Report and Plan of Action Committee was formed to oversee documentation of the 

issues reviewed and the process undertaken by the Task Force to determine 

recommendations for reducing ambient concentrations of PM2.5. The work product of this 

Committee was this Fine Particle Air Quality Task Force Report and Plan of Action

which was submitted to the Board at its January 2008 meeting. 

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Section 4 Report of the Health Committee 

4.1 Background 

The task of the Health Committee (Committee) was to determine whether the community 

should address public health concerns related to ambient concentrations of PM2.5 by 

establishing a goal more stringent than the annual PM2.5 standard of 15 μg/m3. The 

Committee met and reviewed background information on PM2.5, peer-reviewed scientific 

literature regarding the health effects of PM and the actions of states and concerned 

organizations to address more stringent health-based goals and standards. A record of 

attendance at each meeting is included as Appendix 4. 

Several organizations (e.g. the Clean Air Scientific Advisory Committee [CASAC], the 

American Medical Association and the American Public Health Association) have 

determined that the annual PM2.5 standard of 15 μg/m3

 is not adequate for protecting 

public health and have recommended that more stringent standards are necessary. Other 

organizations (e.g. the Utility Air Regulatory Group, the National Association of 

Manufacturers and the U.S. Chamber of Commerce) believe the annual PM2.5 standard to 

be sufficiently protective of public health and have opposed any further reduction in the 

annual standard without adequate supporting scientific evidence. 

In the 2006 Review of the National Ambient Air Quality Standard for Particulate Matter, 

EPA technical staff recommended a primary annual standard between 15 and 12 μg/m3. 

CASAC also advised EPA to adopt a stricter annual PM2.5 standard, in the range of 14 to 

13 μg/m3. In a September 2006 letter to EPA Administrator Steven Johnson, CASAC 

cited: 

...clear and convincing scientific evidence that significant adverse human-health effects occur in 

response to short-term and chronic particulate matter exposures at and below 15 μg/m3

, the level 

of the current annual PM2.5 standard. 

The letter also stated that: 

It is the CASAC’s consensus scientific opinion that the decision to retain without change the 

annual PM2.5 standard does not provide an “adequate margin of safety ... requisite to protect the 

public health” (as required by the Clean Air Act), leaving parts of the population of this country 

at significant risk of adverse health effects from exposure to fine PM. Significantly, we wish to 

point out that the CASAC’s recommendations were consistent with the mainstream scientific 

advice... [T]o our knowledge there is no science, medical or public health group that disagrees 

with this very important aspect of the CASAC’s recommendations. 

After reviewing information and recommendations received from internal technical staff, 

CASAC and extensive public comments, EPA determined that the annual PM2.5 standard 

of 15 μg/m3

 was sufficient and met the requirement of the CAA to protect public health 

with an adequate margin of safety. This conclusion has been challenged and will be 

subject to judicial review. 

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Some states have implemented strategies to set forth more stringent health goals and 

standards. California has an annual PM2.5 standard of 12 μg/m3, Vermont is in the process 

of adopting an annual PM2.5 standard in the range of 14 to 13 μg/m3

 and New Jersey is in 

the process of adopting 12 μg/m3

 as an annual health-based goal for their SIP, citing no 

safe level of PM2.5. Additionally, the World Health Organization’s (WHO) guideline 

value for PM2.5 is 10 μg/m3. 

4.2 Committee Actions 

4.2.1 Scientific Literature Review 

To determine the advisability of a more stringent goal for the local area, the Committee 

reviewed available information on ambient PM2.5 concentrations, emission levels and 

related health effects. The Committee also performed a preliminary review of healthbased, peer-reviewed scientific literature. The Committee reviewed literature which 

stated that chronic and acute exposure to ambient PM2.5 concentrations below the current 

EPA regulatory standards correlated to increases in cardiovascular and lung cancer 

mortality, as well as increased incidence of: asthma, cough, pneumonia, chronic 

bronchitis, change in lung function, change in heart rhythm, doctor visits and 

hospitalization. 

4.2.2 Goal or Standard 

The Committee initially discussed the implications of setting a health-based goal rather 

than adopting a more stringent annual PM2.5 standard. The Committee decided that a 

health-based goal should be adopted and that the strategies recommended by the Task 

Force could give adequate consideration to what is achievable, or attainable, through 

implementation of control strategies on local and regional scales. 

Consistent with the structure and principles of the CAA, the adoption of health-based 

goals should not be confused with economic or technological considerations in 

achievement of regulatory standards, but should instead establish the goal based solely on 

protection of public health (including the health of sensitive subpopulations) with an 

adequate margin of safety to account for the uncertainties in scientific knowledge of lowdose exposure. Questions of implementation of measures to achieve those goals, and 

particularly of whether regulatory control measures are appropriate to achieve ambient 

PM2.5 concentrations below regulatory standards, are properly distinct from the healthbased goal, as has been reaffirmed by Congress and the courts. 

4.2.3 Regional and Local Contributions to PM2.5 Pollution 

The local contribution to the total ambient PM2.5 concentration in Jefferson County, 

Kentucky is estimated to vary between 10 and 20% (1.6 to 3.3 μg/m3

). The remaining 

contribution is generally attributed to regional transport. Therefore, lowering ambient 

PM2.5 concentrations to levels needed to protect public health will require coordinated 

efforts locally and throughout the regional airshed. Successful models exist for regulating 

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pollution to protect public health through a coordinated regional approach, such as the 

Ozone Transport Commission and the Ohio River Valley Water Sanitation Commission. 

The Committee recommends the Board develop such a strategy within and among the 

states to coordinate meaningful reductions in direct PM2.5, precursor emissions and other 

regional pollutants. 

4.2.4 Health-based Goal 

There is no theoretically “safe” level of exposure to PM2.5 in the ambient air. 

Epidemiologic evidence suggests adverse health effects of PM2.5 exposure at annual 

averages less than 15 μg/m3

, while EPA has identified significant uncertainties in 

modeled risk values for ambient PM2.5 concentrations below 13 μg/m3 (EPA/600/R06/063 and EPA/600/P-99/002aF-bF). 

The Committee was presented the most recent regional modeling results. A detailed 

explanation of the following results is included in Section 5 of this Report. ASIP 

projected that annual PM design values for monitors in the Louisville nonattainment 

area will decrease from the 2002 base-year design values of 16.8 to 14.9 

2.5

μg/m3, to 15.0 to 

13.1 μg/m3 as early as 2009, and 14.1 to 12.2 μg/m3 by 2018. LADCO reported that, due 

in part to implementation of CAIR, projected annual PM design values for monitors in 

the Louisville nonattinment area will decrease from the 2005 base-year design values of 

16.5 to 14.7 

2.5

μg/m3, to 13.6 to 12.1 μg/m3 as early as 2009, and 13.2 to 11.5 μg/m3 by 

2018. These results were considered by the Committee during discussion regarding the 

attainability of a goal lower than the annual standard.

Independent of air quality concerns, the Louisville Metro population continues to have 

higher reported incidence of asthma and other respiratory illnesses, cardiovascular 

illnesses and infant mortality, in addition to higher rates of tobacco use than other 

communities in the U.S., which has been historically documented for the local 

population4

. Furthermore, Louisville Metro aspires to be a world-class city, necessitating 

a healthy ambient environment to attract and maintain business and a productive 

workforce. Numerous opportunities for improved efficiencies and efficacies have yet to 

be fully employed throughout the airshed. In light of these findings, the Committee 

achieved consensus in support of a recommendation for establishing an ongoing and 

continuous process of review of all sources and categories of PM2.5 emissions, and 

developing and implementing strategies to continue progress towards reducing ambient 

PM2.5 concentrations, so as to protect public health with an adequate margin of safety. 

The Committee members also recognize that additional reductions below the annual 

PM2.5 standard may be advisable to provide an additional margin of safety that allows and 

compensates for scientific uncertainty, as well as the lack of precise predictions regarding 

the health impacts of air pollution on a multiplicity of potentially susceptible 

subpopulations. A majority of the Committee additionally decided to recommend an 

 

4

 As noted in the Louisville MSA Community Assessment Factbook produced by The Lewin Group on 

behalf of the UAW/Ford Motor Company. 

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interim health-based annual goal of 12 to 10 μg/m3, to be achieved by 2018, while the 

minority did not support establishing specific numeric goals or deadlines beyond the 

federally prescribed annual PM2.5 standard. 

4.3 Committee Recommendations 

The Committee met on October 25, 2007 and, except as noted below, reached consensus 

on the following recommendations to be presented to the full Task Force for its 

consideration. 

Recommendation 1: 

The District should reiterate the principle that ambient concentrations of fine 

particulate matter, expressed as PM2.5, should be reduced to levels sufficient to 

protect public health with an adequate margin of safety. Additional reductions 

below the federal primary annual standard of 15 μg/m3 are advisable to provide 

an additional margin of safety that allows and compensates for scientific 

uncertainty, as well as the lack of precise predictions regarding the health 

impacts of air pollutants on a multiplicity of potentially susceptible populations. 

The process and strategies set forth in Recommendation 2 below should be 

utilized to achieve this goal. In implementing these strategies, a strong emphasis 

should be placed on educational programs for the public. 

Recommendation 2: 

The District should establish an ongoing and continuous process of review of all 

sources of PM2.5 emissions from all sectors of the economy (including mobile 

sources, area sources, stationary sources, etc.), and develop and implement 

policies, practices and standards to continue progress towards reducing ambient 

concentrations of PM2.5 and precursors. In the development of such policies, 

practices and standards, those strategies that achieve lower emissions of 

hazardous air pollutants (HAPs) and ozone precursors in conjunction with 

reducing PM2.5 should be a priority. Stakeholder involvement in the development 

of such programs and processes should be an integral part of the process. 

Recommendation 3: 

In furtherance of achievement of reductions in PM2.5 and other regional 

pollutants, the District should initiate efforts to create an interstate commission to 

effectively reduce ambient PM2.5 through coordinated efforts within the 

Commonwealth and among states whose sources of PM2.5 are identified as 

contributing to the boundary pollution levels in Kentucky. 

Recommendation 4: 

The District should evaluate and, as appropriate, employ existing mechanisms 

under the Clean Air Act (CAA) to address identifiable contributing sources of fine 

particulates and particulate precursors that interfere with attainment and 

maintenance of healthful air quality in the Louisville Metro community. 

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Recommendation 5: 

The District should create a regionally based stakeholder advisory committee to 

continue to focus and advise on issues of air pollution and public health and to 

strategize on policies, practices and programs to reduce PM2.5 emissions. 

Recommendation 6: 

A majority of the Committee recommends adoption of an interim health-based 

annual goal of 12 to 10 μg/m3

, to be achieved by 2018, while the minority did not 

support establishing specific numeric goals or deadlines beyond the federally 

prescribed annual standard. 

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Section 5 Report of the Emissions Inventory and Modeling Data 

Committee 

5.1 Background 

The Emissions Inventory and Modeling Data Committee (Committee) was formed to 

support the Task Force and its committees with the collection, distribution and 

understanding of technical information related to PM2.5. The District, with cooperation 

from state and regional entities, compiled and disseminated available information at the 

request of the Committee for these purposes. 

5.2 Committee Actions 

The Committee reviewed available data related to direct PM2.5 and precursor emissions, 

SO2 and NOx. EPA determined other known PM2.5 precursors, including NH3 and VOCs, 

to be insignificant contributors to the ambient concentration of PM2.5 in this region. 

Therefore, the Committee did not review data concerning emissions of these precursors. 

Information was gathered from a variety of sources to provide insight into the spatial and 

temporal distribution of the target pollutants. Historical and projected data were obtained 

at local, state and regional levels. The Committee collected information including: 

ambient monitoring data and design values, speciated monitoring data, emissions 

inventories and source apportionment data. While a thorough technical review of all data 

collection methods was not included in this report, the Committee has noted limitations 

and uncertainties associated with these reviewed methods as appropriate. 

To demonstrate attainment, each SIP will require modeling to show that nonattainment 

areas will meet the annual PM2.5 standard of 15 μg/m3 by the attainment deadline of 2010. 

Fine particulate matter, by nature, has a large regional component such that an area’s 

attainment could be influenced by sources outside the designated nonattainment area. 

Realizing this, EPA funded regional modeling groups to support states with their regional 

haze, ozone and PM2.5 SIPs. Two of these groups have modeling domains that include the 

Louisville nonattainment area: ASIP, which supports Kentucky and other southeastern 

states, and LADCO, which supports Indiana and other midwestern states. 

To provide further technical analysis of the information, the Committee invited regional 

experts to speak to the Committee and other members of the Task Force. On September 

19, 2007, Pat Brewer, ASIP Technical Coordinator, presented ASIP’s regional modeling 

results and related work products. On September 28, 2007, Joel Huey, PM2.5 Expert for 

EPA Region 4, presented an overview of PM2.5 SIP requirements, current and proposed 

federal regulations impacting state attainment demonstrations and examples of other state 

and local actions to address control strategies for reducing PM. On October 11, 2007, 

Michael Koerber, Executive Director of LADCO, presented the most recent regional 

modeling results from LADCO. These presentations are available at 

http://www.louisvilleky.gov/APCD/TaskForce/AQTFPMDocuments.htm. 

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The following sections provide a summary of the information collected and reviewed by 

this committee. 

 

5.2.1 Historical Data 

5.2.1.1 Monitoring Data 

The Committee collected historical monitoring data from local ambient PM2.5 monitors in 

the area, including those used for the Federal Reference Method (FRM) and for 

speciation (similar to monitors in the Speciation Trends Network). The locations of local 

monitors are shown in Figure 5-1. The PM2.5 FRM is a gravimetric method that measures 

total PM2.5 mass on daily, three- or six-day schedules. Historical annual averages from 

local FRM monitors are provided in Table 5-1. 

Figure 5-1. Map of Area PM2.5 Monitors. 

Table 5-1. Annual PM2.5 Means in μg/m3 for Area FRM Monitors. 

Monitor Site 1999 2000 2001 2002 2003 2004 2005 2006

18-019-0005/6 Clark County, IN 16.6 18.6 16.9 16.0 15.8 15.1 18.5 15.0 

18-043-1004 Floyd County, IN 15.0 16.0 15.8 14.6 14.5 13.7 16.8 13.3 

21-029-0006 Bullitt County, KY 15.4 16.4 15.6 14.7 14.4 13.6 16.3 14.1 

21-111-0043 Jefferson County, KY 17.5 17.3 17.1* 17.2 16.0 14.5 16.7 15.0 

21-111-0044 Jefferson County, KY 16.9 16.7 17.7 17.5 15.4 14.1 16.5 15.2 

21-111-0048 Jefferson County, KY 17.2 16.7 16.9 16.4 15.5 13.7 16.8 14.0 

21-111-0051 Jefferson County, KY 15.2 16.8 16.3 15.7 14.9 12.6 16.5 13.7 

* Recovery below 75% due to renovation at the Southwick site in 2001

Valid data from FRM monitors for a given year are averaged on a quarterly basis to 

determine a monitor’s annual average. The design value (DV) is the mean of three 

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consecutive annual averages for each monitoring site. The highest design value in an area 

becomes the design value site from which attainment designations are made. Historical 

design values from local FRM monitors are provided in Figure 5-2. 

 

14.0

14.5

15.0

15.5

16.0

16.5

17.0

17.5

18.0

Annual PM2.5 Design Value (μg/m3)

18-019-0005/6 Clark County, IN 17.4 17.2 16.2 15.6 16.5 16.2

18-043-1004 Floyd County, IN 15.6 15.5 15 14.3 15 14.6

21-029-0006 Bullitt County, KY 15.8 15.6 14.9 14.2 14.8 14.7

21-111-0043 Jefferson County, KY 17.3 17.2 16.6 15.9 15.7 15.4

21-111-0044 Jefferson County, KY 17.1 17.3 16.9 15.7 15.3 15.3

21-111-0048 Jefferson County, KY 16.9 16.7 16.3 15.2 15.3 14.8

21-111-0051 Jefferson County, KY 16.1 16.3 15.6 14.4 14.7 14.3

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

 

Figure 5-2. PM2.5 Design Values in μg/m3 for Area FRM Monitors. 

The Committee used data collected from speciation monitors to identify individual 

components of PM2.5 measured at monitor sites. Annual data compiled from speciation 

monitors in Louisville Metro are compared to those in Kentucky in Figure 5-3. Analytical 

methods for PM2.5 speciation allow for quantification of the following components: 

sulfate (SO4), nitrate (NO3), ammonium (NH4), OC, EC and crustal (e.g. fine soil and 

trace elements). A simple mass balance is used to determine the portion of PM2.5 that is 

not accounted for by analytical methods. This portion is characterized as “other” and is 

unknown. Figure 5-4 shows the monthly variation in PM2.5 speciation for the monitor 21-

111-0043 in 2006. 

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0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

211110048 211110043

Barret 2002-2005

Average

Southwick 2002-2005

Average

All KY Monitors 2004-

2006 Average

Other

Crustal

component

Elemental

carbon

Organic

carbon

Ammonium

Sulfate

Nitrate

Figure 5-3. Speciation Data for Louisville Metro and Kentucky, 2002 to 2006. 

0

5

10

15

20

25

Jan Feb March April May June July August Sept Oct Nov Dec

Concentration ug/m3

Other

Crustal

component

Elemental

carbon

Organic

carbon

Ammonium

Sulfate

Nitrate

Figure 5-4. Monthly Speciation Data from Monitor 21-111-0043 in 2006. 

Local and regional sources contribute to monitored PM2.5 pollution. The contribution 

from local sources is usually greater in urban areas than in rural. PM2.5 in rural areas is 

generally attributed to regional transport. For instance, of the three major PM2.5

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components (sulfate, carbon and nitrate), greater levels of carbon and nitrate are typically 

monitored in urban areas and are generally attributed to local sources. 

The range of local contribution to total ambient PM2.5 concentrations was determined by 

subtracting background levels of PM2.5 from monitored concentrations within the 

Louisville nonattainment area. The background site for Kentucky is located at Camp 

Webb at Grayson Lake State Park in Carter County. The 2004-2006 design value for this 

site was 12.1 μg/m3

. The background site for Indiana is located in Knox County. The 

2004-2006 design value for this site was 13.8 μg/m3

. When subtracted from the 

Louisville nonattainment area’s 2004-2006 design value of 15.4 μg/m3, the local 

contribution, or urban excess component, ranges from 1.6 to 3.3 μg/m3

 for the Louisville 

nonattainment area. 

The relative contribution of PM2.5 from regional and local sources has been extrapolated 

from monitoring data made available by EPA. Figure 5-5 shows that the local, or urban, 

component of PM2.5 in Louisville is primarily organic carbon. A more refined 

understanding of the relative contribution of local and regional sources and the impact of 

various emission sources would require more detailed computer modeling of the area 

than currently available. 

Estimated PM2.5 Composition 

Figure 5-5. PM2.5 Composition and Estimated Urban Excess for U.S. Cities. 

Based on constructed mass (not SANDWICH), 2003 *Indicates areas with > 30% UE nitrates 

0% 20% 40% 60% 80% 100%

York, ; Harrisb, PA

Washington, DC

St, Louis, MO-IL

* Reading, LancasterPA;

Pittsb, Wheeling

Philadelphia, 

New York, NY-NJ-CT

Louisville, KY-IN

Knoxville, KY

* Indianapolis, IN

Hickory, NC

Greensboro, NC

* Evansville, IN-KY

* Detroit, MI

Columbus, OH; 

* Cleveland, OH

Cincinnati, OH-KY-IN

Chicago,IL-IN-WI; 

Chattanooga, TN-GA

Charleston, Hngtn,WV;

* Canton, Steuben OH/WV

Birmingham, AL

Baltimore, MD

Atlanta, GA; Macon, GA

0% 20% 40% 60% 80% 100%

York, ; Harrisb, PA

Washington, DC

St, Louis, MO-IL

Reading, LancasterPA;

Pittsb, Wheeling

Philadelphia, 

New York, NY-NJ-CT

Louisville, KY-IN

Knoxville, KY

Indianapolis, IN

Hickory, NC

Greensboro, NC

Evansville, IN-KY

Detroit, MI

Columbus, OH; 

Cleveland, OH

Cincinnati, OH-KY-IN

Chicago,IL-IN-WI; 

Chattanooga, TN-GA

Charleston, Hngtn,WV;

Canton, Steuben OH/WV

Birmingham, AL

Baltimore, MD

Atlanta, GA; Macon, GA

Carbon Sulfates Nitrates Crustal

Estimated Urban Excess 

Carbon Sulfates Nitrates Crustal 

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5.2.1.2 Emissions Inventory Data 

Stationary sources with Title V and FEDOOP permits are required to submit a report of 

their actual emissions of PM, SO2, carbon monoxide (CO), nitrogen dioxide (NO2), ozone 

precursor emissions of VOCs and NOx, lead (Pb), NH3 and all hazardous air pollutants 

(HAPs) each year. Minor sources are required to submit these reports every three years. 

The most recent required emissions inventory for all three categories of stationary 

sources was for calendar year 2005. 

Estimates of NOx and SO2 emissions are generally well understood, have standardized 

EPA emission factors and are therefore considered to be relatively accurate. Additionally, 

some sources utilize site-specific emission data such as stack tests and continuous 

emissions monitoring systems to directly quantify their emissions of these pollutants. 

Direct PM2.5 emissions are generated from fuel combustion, material handling, surface 

coating, vehicle travel across unpaved worksites and numerous other activities. Total 

particulate matter, and in some cases PM10, emission factors have been developed for a 

number of processes, but very little information exists for PM2.5. The lack of standardized 

emission factors along with the multitude of different PM2.5 sources requires a significant 

amount of engineering judgment to estimate stationary source emissions. Thus, the 

Committee noted significant variation in reported emissions estimates; whereas values 

reported by the District, in some cases, were two to three times higher than those reported 

by sources. Estimates of direct PM2.5 emissions from stationary sources were derived 

from District recalculations of the sources’ certified 2005 Emissions Inventory Statement 

using process rates provided by the individual sources and related emissions factors. 

While the District’s estimated values provide an understanding of where emissions are 

generated and a relative ranking of the various sources, direct PM2.5 data should be 

reviewed with the knowledge that uncertainties exist in emissions estimates. 

The most recent emissions inventory for area sources was generated for calendar year 

2005 using various source emissions factors and related activity levels. Emissions factors 

were obtained directly from EPA AP-42 or, in some cases, from well-documented 

methods, typically developed by public agencies. Emissions for area sources are 

generally estimated using activity levels, which are most commonly calculated using 

population data or the actual number of sources. Emissions were calculated for NOx, 

PM2.5 and SO2. 

The emissions inventory for onroad mobile sources was generated for calendar year 2005 

by using EPA’s MOBILE6.2 modeling software. Emission factors for NOx, SO2 and 

PM2.5 – including OC, EC, SO4 as speciates – were calculated for this process. MOBILE6 

calculates emission factors for twenty-eight individual vehicle types. These emission 

factor estimates depend on various conditions, such as ambient temperatures, travel 

speeds, operating modes, fuel volatility and mileage accrual rates. The emission factors 

derived from the MOBILE6 runs were multiplied by the vehicle miles traveled (VMT) 

for each county in the Louisville nonattainment area, supplied by the Kentuckiana 

Regional Planning and Development Agency (KIPDA), to obtain emission tonnage per 

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year for each pollutant of interest. MOBILE6 is the best attempt to date by EPA and the 

Federal Highway Administration to aid transportation planning and air quality conformity 

concerns. MOVES is the next generation of software to be available for use in the near 

future, which will more accurately account for PM, greenhouse gases and new vehicle 

technology. Tests have been underway to finalize the program’s ability to account for 

gasoline PM, which has been especially difficult to rank as to contributing factors. 

The most recent emissions inventory for nonroad mobile sources was generated for 

calendar year 2005 by using EPA’s National Mobile Inventory Model (NMIM). 

Emissions were calculated for NOx, PM2.5 and SO2. NMIM incorporated all the relevant 

variables developed by EPA which affect the emission factor outcome for the various 

emission sources, including engine characteristics, fuel formulation and a temperature 

and humidity database. 

The District provided the most recent emissions inventory for Jefferson County, 

Kentucky, from 2005. Separate inventories were combined for stationary sources, area 

sources, onroad mobile sources and nonroad mobile sources. Emissions inventories for 

other stationary sources in the Louisville nonattainment area were also provided by 

IDEM for the Indiana counties of Clark, Floyd and Jefferson, and by KY DAQ for Bullitt 

County. KY DAQ also provided the 2005 stationary source emissions inventory for the 

entire state of Kentucky. All 2005 emissions inventories for Jefferson County, Kentucky 

were combined and are shown in Figure 5-6. 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

*Data in table reported as tons per year (tpy)

Area 1272.6 0.0 645.9

Nonroad 12404.4 790.2 877.5

Mobile 19682.0 213.1 291.0

Stationary 25745.0 45313.1 2517.7

NOx SO2 PM2.5

Figure 5-6. Source Apportionment, by Percent, of Total Emissions in Jefferson 

County, KY, Based on APCD 2005 Emissions Inventory Data.

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Additional historical emissions inventory data are presented in Figures 5-8 and 5-9 

below. In these figures emissions for all counties in the ten ASIP member states, 

reflecting a base year of 2002, are compared to projected emissions inventories for 2009 

and 2018. 

5.2.2 Projected Data 

5.2.2.1 Boundaries and Assumptions 

The ASIP and LADCO regional models calculated projected annual design values and 

emissions inventories based on inputs to the model within a set boundary. The Louisville 

nonattainment area was included within the boundaries of both regional models. Maps of 

the model boundaries for ASIP and LADCO can be found in Figures 5-7. 

Figure 5-7. Maps of ASIP and LADCO Regional Modeling Domains. 

The base-years used for ASIP and LADCO regional modeling were 2002 and 2005, 

respectively. At the time of this report, the LADCO modeling results for base-year 2005 

were only recently made available for public review. While much of the information 

presented in this report involves results from ASIP modeling, the Committee would like 

to encourage full consideration of the limited outputs from LADCO’s base-year 2005 

model. The use of a more recent base-year allows for more accurate representation of 

projected data. It was the Committee’s view that the LADCO 2005 modeling reflected 

more recent monitoring data and more inclusive emissions inventories, utilized a more 

recent growth projection model and better accounts for the impacts of federal programs 

than ASIP’s 2002 model run. 

 

Imbedded in the ASIP and LADCO regional modeling outputs are many assumptions 

derived from planned reductions of direct PM2.5 and precursor emissions. These include 

reductions from federal rules and other regulations that are thought to have an impact on 

ASIP/VISTAS 12km Modeling Domain LADCO 12km Modeling Domain 

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ambient concentrations of PM2.5. The following assumptions were used in the ASIP and 

LADCO regional models. 

ASIP Assumptions – CAIR; Clean Air Mercury Rule; NOx SIP Call; NC Clean 

Smokestacks Act; Consent Agreements (TECO, VEPCO, Gulf Power Crist7); 1-hr ozone 

SIPs (Atlanta / Birmingham / Northern Kentucky); NOx RACT; Heavy-Duty Diesel 

(2007) Engine Standard; Tier 2 Tailpipe; Large Spark Ignition and Recreational Vehicle 

Rule; Nonroad Diesel Rule; Industrial Boiler/Process Heater/RICE MACT; Combustion 

Turbine MACT; VOC 2-, 4-, 7- and 10-year MACT Standards. 

LADCO Assumptions – Tier II/Low sulfur fuel; Inspection/Maintenance programs 

(nonattainment areas); Reformulated gasoline (nonattainment areas); Federal control 

programs incorporated into NONROAD model (e.g. Nonroad Diesel Rule) and 

evaporative Large Spark Ignition and Recreational Vehicle standards; Heavy-Duty Diesel 

(2007) Engine Standard/Low sulfur fuel; Federal railroad/locomotive standards; Federal 

commercial marine vessel engine standards; Title IV (Phases I and II); NOx SIP Call; 

CAIR; VOC 2-, 4-, 7- and 10-year MACT standards; Combustion turbine MACT; 

Industrial boiler/process heater/RICE MACT; Miscellaneous consent decrees and 

settlement agreements; Aerosol coatings (new rule); Architectural and industrial 

maintenance (AIM) coatings (amendments); Household and institutional consumer 

products (amendments); Portable fuel containers (Mobile Source Air Toxics Rule). 

The model protocols for ASIP and LADCO can be viewed on the District’s website at, 

http://www.louisvilleky.gov/APCD/TaskForce/AQTFPMDocuments.htm. 

5.2.2.2 Projected PM2.5 Design Values 

Future design values (DVF) were modeled for those monitors in the ASIP and LADCO 

regional modeling domains, which include the Louisville nonattainment area. Table 5-2 

shows projected PM2.5 design values from ASIP and LADCO modeling for local 

monitors. 

 Table 5-2. Future Design Values for Local Monitors. 

Monitor 

LADCO 

Base DV

LADCO 

2009 DVF

LADCO 

2018 DVF

ASIP 

Base DV 

ASIP 

2009 DVF

ASIP 

2018 DVF

18-019-0005/6 Clark County, IN 16.5 13.6 13.2 16.8 15.0 14.1 

18-043-1004 Floyd County, IN 14.9 12.1 11.5 14.9 13.1 12.3 

21-029-0006 Bullitt County, KY 14.9 12.4 12.0 14.9 13.2 12.2 

21-111-0043 Jefferson County, KY 15.7 12.8 12.1 --- --- --- 

21-111-0044 Jefferson County, KY 15.4 12.8 12.4 16.6 14.9 14.1 

21-111-0048 Jefferson County, KY 15.2 12.5 12.1 16.1 14.3 13.5 

21-111-0051 Jefferson County, KY 14.7 12.1 11.7 15.4 13.8 12.9 

18-083-0004 Knox County, IN* 14.1 11.6 11.1 --- --- --- 

21-043-0500 Carter County, KY* 12.2 9.9 9.5 12.2 10.3 8.9 

* Background Monitors for Indiana and Kentucky 

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5.2.2.3 Emissions Inventory Data 

ASIP projected 2009 and 2018 emissions summaries for all counties in the ten ASIP 

member states. Figures 5-8 and 5-9 compare these projected emissions summaries with 

actual inventory data from base year 2002 for the state of Kentucky and Jefferson 

County, Kentucky respectively. The Committee noted the similarity in state and county 

level trends in NOx and PM2.5 reductions. The Committee also noted the difference in 

reduction trends between state and county emissions of SO2. Controls for SO2 emissions 

are being added at many utilities around the state in compliance with Phase I of CAIR. 

For utilities in Jefferson County, SO2 controls were added to all units prior to base year 

2002, which explains the different trends shown in these figures. 

0

100000

200000

300000

400000

500000

600000

tons per year (tpy)

NonRoad Mobile 104570 94752 79391 14043 9180 8591 6045 5203 4256

Mobile 154633 100025 46992 6237 750 693 2666 1898 1157

Industrial 12203 12962 15277 24359 26945 31146 19256 20260 23147

Other Fuel Combustion 65712 66860 70083 51472 52555 53718 8814 8180 7695

Electric Generating Units 201928 91587 64377 495152 290192 226062 2847 4269 4433

Miscellaneous 354 1116 1143 91 300 309 14147 17418 17865

2002 2009 2018 2002 2009 2018 2002 2009 2018

NOx SO2 PM2.5

Figure 5-8. ASIP 2002, 2009 and 2018 Emissions for the state of Kentucky. 

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0

10000

20000

30000

40000

50000

60000

tons per year (tpy)

NonRoad Mobile 10989 9785 7865 1428 921 859 720 649 566

Mobile 25548 14335 4840 904 110 87 364 238 136

Industrial 2358 2018 2466 355 386 473 558 613 736

Other Fuel Combustion 1470 1500 1554 1211 1173 1209 100 84 89

Electric Generating Units 22084 16954 4898 39915 42127 40032 166 197 202

Miscellaneous 0 0 0 0 0 0 101 111 127

2002 2009 2018 2002 2009 2018 2002 2009 2018

NOx SO2 PM2.5

Figure 5-9. ASIP 2002, 2009 and 2018 Emissions for Jefferson County, KY. 

5.3 Committee Recommendations 

The Committee met on October 11, 2007 and reached consensus on the following 

recommendations to be presented to the full Task Force for its consideration. 

The results presented to this committee from the ASIP and LADCO regional modeling 

groups project that the Louisville nonattainment area will achieve the annual PM2.5 

standard by the 2010 federal attainment deadline with existing and planned controls. 

Implementation of planned controls over the next decade will continue to decrease VOC, 

NOx and SO2 emissions in the region and local PM2.5 levels. 

5.3.1 Information Needs 

The scientific and regulatory communities’ understanding of PM2.5 emissions, 

atmospheric reactions and modeling capabilities is not as mature as other criteria 

pollutants such as ozone. The ability to accurately and precisely estimate direct PM2.5

emissions has improved since 2002, but more work is needed. The following 

recommendations address improvements necessary in modeling and monitoring of PM2.5

to more accurately reflect an area’s issues and to identify appropriate control strategies. 

Recommendation 1: 

The District should work with EPA, the states of Kentucky and Indiana and local 

sources to improve methods to estimate local sources of PM2.5 emissions.

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Recommendation 2: 

The District should work with EPA and the states of Kentucky and Indiana to 

continue to fund existing, as well as increase the number of, PM2.5 speciation 

monitors in the area so as to better understand the local and regional 

contributors of PM2.5. 

Recommendation 3: 

The District should work with EPA, the regional modeling groups and local 

sources to conduct updated and more detailed regional and local modeling 

studies to gain a better understanding of the relative impact and timing of 

regional and local emission reductions, beyond planned controls, on local PM2.5

concentrations after 2009.

5.3.2 Data Collection Process 

The Committee did not have sufficient time during this process to collect, analyze and 

synthesize all the data that it would have liked in an effort to gain a full understanding of 

the relative contributors of PM2.5 levels in the region. The Committee did not have time 

to investigate any projected emissions or modeling data beyond annual information for 

the Louisville nonattainment area. 

Recommendation 4: 

In future Task Force planning groups, the Emissions Inventory and Modeling 

Data Committee should start its deliberations months before other committees to 

have sufficient time to collect, analyze and synthesize needed information.

5.3.3 Interpretation of Data 

Regional modeling predicts that the Louisville nonattainment area will reach attainment 

of the annual PM2.5 standard of 15 μg/m3

 by the 2010 deadline. While the area is 

predicted to be in attainment, the Health Committee recommended that a goal more 

stringent than the annual PM2.5 standard is necessary to protect public health in our 

community. A majority of the Health Committee suggested a range of 12 to 10 μg/m3

 as 

an appropriate health-based goal to be reached by 2018. 

Additionally, source apportionment and urban excess data presented to the Committee 

suggests that by 2009, OC and SO4 will be the two largest chemical constituents found in 

annual monitored PM2.5 locally. 

Based on this information, the Committee recommended the following starting points that 

may help the Louisville Metro area reach a more stringent health-based goal with the 

acknowledgement that multiple data gaps existed because of time and data availability 

constraints. 

Page 31 January 16, 2008 
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Recommendation 5: 

Based on the data reviewed, and the Health Committee recommendations, the 

District should pursue strategies to reduce the PM2.5 precursor emissions from 

major regional sources within a range of 150 miles, so as to reach a design value 

below 12 μg/m3 by 2018. 

Recommendation 6: 

Based on current monitoring and modeling data from local and regional sources, 

the data suggest that an important component of PM2.5 is local organic carbon. 

This suggests that pursuing local measures to reduce emissions of organic carbon 

may be worthwhile. The data also suggest that local SO2 precursor emissions 

have less effect on the local PM2.5 contribution in the area; therefore, measures 

for reducing sulfate contributions from sources outside the local area may be 

worthwhile. 

Recommendation 7: 

The Lake Michigan Air Directors Consortium (LADCO) projected design values 

should be given as much, or more, weight as the Association for Southeastern 

Integrated Planning (ASIP) projections, because the LADCO modeling is based 

on 2005 inventory data, vs. 2002 for ASIP, and for the other reasons listed in 

Section 5.2.2.1. 

Recommendation 8: 

The District should continue to monitor the progress of the regional modeling 

groups and other sources of PM2.5 data utilized by Task Force to look for 

additional information that will assist the community in improving its 

understanding of PM2.5 emissions and health impacts.

Page 32 January 16, 2008 
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Section 6 Report of the Stationary and Area Source Committee 

6.1 Background 

The Stationary and Area Source Committee (Committee) was formed to identify control 

measures in place in the community to reduce direct PM2.5 and precursor emissions and 

determine whether additional control strategies could be implemented throughout the 

region to achieve early attainment of the annual PM2.5 standard. The Committee met to 

review emissions data and interview representatives of several local stationary sources 

regarding current and future controls for direct PM2.5 and precursor emissions. The 

Committee also completed an informal RACT/RACM assessment for stationary and area 

sources in the Louisville nonattainment area in accordance with the Implementation Rule. 

6.2 Committee Actions 

The Committee reviewed data collected by the Emissions Inventory and Modeling Data 

Committee. Emissions inventories for Jefferson County, the state of Kentucky and the 

three nonattainment counties in southern Indiana were used to determine the top 90% of 

emitters for direct PM2.5, NOx and SO2. The Committee then developed a telephone 

questionnaire to learn more about current and planned future control strategies for these 

major sources of direct PM2.5 and precursor emissions. The following questions were 

included in the control measures questionnaire administered by District staff: 

 1. What are the sources of PM2.5, NOx and SO2 at your facility? 

 2. What assumptions are used in the calculation of emissions from these sources? 

 3. What control measures are currently in place for these sources? 

 4. Are there any plans for further reduction measures, mandatory or voluntary? 

 5. What are the costs associated with any future control measures? 

 6. What reductions are anticipated from the 2005 baseline emissions inventory? 

District staff received responses to the questionnaire from several companies including 

Duke Energy, General Electric (GE) and Süd-Chemie Inc. Other companies, including 

E.ON U.S., Kosmos Cement Company (Kosmos) and OxyVinyls, presented information 

on emissions and control strategies directly to the Committee. The Committee considered 

this information during its RACT/RACM assessment. 

The Committee used language from the Implementation Rule as a starting point for 

completing its RACT/RACM assessment of stationary and area sources for the Louisville 

nonattainment area. A copy of this language from the Implementation Rule is included as 

Appendix 5. The EPA starting point list was used in conjunction with EPA’s List of 

Potential Control Measures for PM2.5 and Precursors, the National Association of Clean 

Air Agencies’ (NACAA) Controlling Fine Particulate Under the Clean Air Act: A Menu 

of Options and responses to the control measures questionnaire to complete the 

assessment. Additionally, the Committee developed an evaluation matrix to aid in 

Page 33 January 16, 2008 
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quantifying and prioritizing control strategies necessary to reach attainment of the annual 

standard. The matrix is included as Appendix 6. 

6.3 Committee Recommendations 

The Committee met on October 24, 2007 and reached consensus on the following 

recommendations to be presented to the full Task Force for its consideration. 

6.3.1 Stationary Diesel Engines 

There are large numbers of stationary diesel engines throughout Jefferson County. These 

engines mainly serve as emergency generators which run less than 500 hours per year. 

The particulate emissions from stationary diesel engines are regulated under the District’s 

Strategic Toxic Air Reduction program and controlling this source for toxics emissions 

will satisfactorily control for direct PM2.5 emissions. 

The Committee also discussed emission reductions from switching to ultra low sulfur 

diesel (ULSD) fuel, which could significantly reduce SO2 emissions from stationary 

engines. There are federal regulations in place that require the phase-in of ULSD in 

nonroad sources. However, the Committee was reluctant to recommend that ULSD be 

used in all stationary diesel engines because of concerns about increased cost and the 

reliability of supply. 

Recommendation 1: 

The District should continue to address pollution from stationary diesel engine 

sources through compliance with Strategic Toxic Air Reduction (STAR) 

regulations (DR 5.21 and DR 5.22). 

6.3.2 Emission Controls for Direct PM2.5

6.3.2.1 Direct PM2.5 Controls for Electric Generating Units 

The Committee received responses to the control measures questionnaire from Kentucky 

and Indiana utilities regarding current controls for direct PM2.5 and definitive plans for 

future control measures. E.ON U.S, which operates several local utilities across 

Kentucky, has electrostatic precipitators (ESPs) on all units operating across the state of 

Kentucky including Mill Creek and Cane Run Stations, located in Jefferson County. 

Duke Energy, which operates the Gallagher Station in Floyd County, Indiana, is in the 

process of installing baghouse controls on all four units which should be completed by 

May 2008. 

The Committee also considered contributions of PM2.5 from regional sources including 

the Paradise Station in Muhlenberg County, Kentucky, which is operated by the 

Tennessee Valley Authority (TVA). TVA Paradise has three units, one of which has ESP 

controls. TVA removed ESPs from the other two units to make room for flue gas 

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desulfurization (FGD) controls. The FGDs are used primarily to remove SO2 from stack 

emissions. TVA reports that the FGDs may also reduce PM2.5 emissions. 

Recommendation 2: 

Louisville Metro Government should encourage the Tennessee Valley Authority’s 

(TVA’s) Paradise Station to look at cost-effective controls for direct PM2.5 in the 

future.

6.3.2.2 Direct PM2.5 Controls for Other Stationary Sources 

The Committee received responses to the control measures questionnaire from GE, 

OxyVinyls, Süd-Chemie and Kosmos. The following responses were considered by the 

Committee. 

GE operates a landfill/natural gas boiler with a backup coal-fired boiler. It is GE’s intent 

to eventually eliminate the use of coal in generating building heat and process steam. GE 

has obtained a permit from the District for the construction of an additional 

landfill/natural gas boiler, which will serve as a backup to the existing landfill/natural gas 

boiler. 

OxyVinyls operates one natural gas boiler and two coal-fired boilers, which provide 

steam to OxyVinyls and three other companies. One coal-fired boiler, built in the 1980’s, 

is controlled with a baghouse. The other coal-fired boiler, built in the 1960’s is controlled 

with a multicyclone. The company estimates that the 1960’s boiler is responsible for 80-

85% of its total suspended particulate (TSP) emissions, which is equal to 50 tons per year 

(tpy). OxyVinyls researched adding controls to the 1960’s boiler, including baghouse 

technology. Unfortunately, because of the proximity of this boiler to other structures, 

baghouse controls are cost prohibitive. 

Süd-Chemie’s direct PM2.5 emissions come from the production of catalysts which is 

regulated under the District’s STAR program. Unlike many industrial sources, a majority 

of Süd-Chemie’s direct PM2.5 emissions is valuable product. Süd-Chemie uses baghouses 

to reduce direct PM2.5 emissions and is in the process of installing high efficiency 

particulate air (HEPA) filters after the baghouses, where needed, to improve its capture 

efficiency. This improvement is being made to comply with STAR. 

Kosmos has made several improvements to its Louisville Metro facility since 2005, 

which the company reports has reduced emission of direct PM2.5. In 2005, baghouse dust 

collectors were replaced, a clinker storage facility was added and a truck wash was 

installed. In 2006, the company paved and curbed portions of the property and purchased 

a new sweeper to control dust from its outdoor operations. Finally, in 2007, Kosmos 

installed a wheel wash for trucks exiting the facility and submitted plans to convert from 

shaker to pulse jet dust collectors. Kosmos has permission from its corporate 

headquarters to purchase four pulse jet dust collectors and has begun the process to 

receive necessary permits from the District. Kosmos has over 100 dust collectors 

throughout its plant. These control devices are fitted with ten foot pleated dust collection 

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bags. In February of 2008, the company plans to upgrade to twelve foot pleated bags, 

which will increase the efficiency of the controls. Additionally, most transfer operations 

are controlled with covers and/or wet jets.

Recommendation 3: 

The District should prescreen permit applications and give review priority to 

pollution prevention projects, especially those that could reduce direct PM2.5 and 

precursor emissions. 

Recommendation 4: 

The District should review the current backlog of construction permit 

applications for pollution prevention projects that could reduce direct PM2.5 and 

precursor emissions. If any construction permit applications that meet this 

criteria are identified, the District should prioritize review of these applications 

so that a decision is made before the end of 2007 so that, if approved, these 

projects can be installed in early 2008.

Recommendation 5: 

The District should consider working in voluntary partnership with the owners of 

non-utility coal-fired boilers to research the cost-effectiveness of converting these 

boilers to alternative fuels and/or installing additional direct PM2.5 control 

devices. 

6.3.3 Improved Capture of Particulate Emissions 

EPA intended this category of the RACT/RACM analysis to consider the improved 

containment of pollutants by ductwork that delivers the gas stream to the control device. 

The Committee agreed that the District should continue to be mindful, in inspection and 

permitting processes, of situations where greater capture efficiency to control devices can 

be achieved; however, it believed that sufficient control measures are in place where 

necessary and did not wish to set forth any recommendations at this time. 

6.3.4 Emissions Controls for PM2.5 Precursors 

6.3.4.1 PM2.5 Precursor Controls for Electric Generating Units 

As noted above, the Committee received responses to the control measures questionnaire 

from Kentucky and Indiana utilities. The following responses from E.ON U.S. and Duke 

Energy were considered by the Committee. 

All E.ON U.S. units operating in Jefferson County, KY are controlled for SO2 and NOx

emissions. At the Mill Creek and Cane Run Stations, all units are controlled with an FGD 

system, which reduces the company’s SO2 emissions. E.ON U.S. controls NOx emissions 

at its Cane Run Station with low NOx burners on all units. At the Mill Creek Station, two 

units are controlled with low NOx burners and two units are controlled with selective 

catalytic reduction (SCR). These SCRs are only operated from May through September. 

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E.ON U.S. plans to operate the SCRs year round, beginning in 2009, to comply with 

CAIR requirements. Additionally, E.ON U.S. plans to voluntarily operate the SCRs 

approximately one extra month per unit in 2008. The District suggested that an extra 

month at the end of its scheduled operation would be more beneficial than an extra month 

at the beginning of the schedule. A complete list of E.ON U.S.’s current and planned 

control measures is included as Appendix 7. 

Duke Energy’s Gallagher Station does not have SO2 controls or plans for future controls. 

All units at the Gallagher Station operate with low NOx burners and there are no plans to 

upgrade these controls in the foreseeable future. A detailed list of current and planned 

control measures for Indiana utilities is included as Appendix 8. 

The majority of the Committee agreed that current and planned measures required to 

meet federal CAIR reductions sufficiently address RACT/RACM for electric generating 

unit (EGU) sources and that additional controls were not necessary in light of significant 

regional reductions to be observed with CAIR implementation. Two Committee members 

noted that local EGUs account for the majority of precursor emissions in the Louisville 

nonattainment area, and believed that local EGUs, such as Cane Run and Gallagher 

Stations, should be urged to make further emission reductions through increased control 

efficiencies or installation of modern controls to pursue attaining cleaner air than that 

achieved by meeting the minimum required by federal standards. 

Recommendation 6: 

E.ON U.S. and Duke Energy should continue to install control devices according 

to their current schedules, set forth to comply with Clean Air Interstate Rule 

(CAIR) requirements. 

Recommendation 7: 

The District should encourage electric generating units (EGUs) to achieve as 

many early reduction credits as possible for 2007 and/or 2008.

6.3.4.2 PM2.5 Precursor Controls for Other Stationary Sources 

As noted above, the Committee received several responses to the control measures 

questionnaire. The following responses from GE, OxyVinyls and Kosmos were 

considered by the Committee. 

GE operates one coal-fired boiler as a backup heat and energy source. The company 

plans to eventually eliminate the use of coal in its operation completely. Along with 

reduction of direct PM2.5 emissions, conversion from coal-fired to landfill/natural gas 

boilers should also reduce PM2.5 precursor emissions. 

OxyVinyls considered replacing its 1960’s coal-fired boiler with a natural gas boiler. The 

company estimated reductions of 75 tpy of NOx and 261 tpy of SO2. Based on a cost 

analysis, the company concluded that it can not afford to replace the 1960’s coal-fired 

boiler. 

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Kosmos installed a water sprayer in its cement kiln, which reduces thermal NOx coming 

from the main front burner. The company is interested in using selective non-catalytic 

recovery (SNCR) units to reduce NOx emissions an additional 30 to 40%. Kosmos has 

begun the process to receive the necessary permits from the District to install these 

controls. Additionally, in May 2008 Kosmos plans to test used tires as a fuel source for 

the cement kiln. The trial will measure the possible reduction of NOx emissions. If 

successful, tires could replace coal in the cement kiln permanently. 

Recommendation 8: 

The District should consider working in voluntary partnership with the owners of 

non-utility coal-fired boilers to research the cost-effectiveness of converting to 

alternative fuels and/or installing additional NOx and SO2 control devices.

6.3.4.3 Reduced Sulfur Content of Fuels 

The Committee determined that all coal-fired boilers in Jefferson County, Kentucky that 

are operating without FGD controls are required to burn low-sulfur coal. Those boilers in 

Jefferson County, Kentucky operating with FGD controls, including two E.ON U.S. 

facilities and a unit at American Synthetic Rubber Corporation (ASRC) are not required 

to burn low-sulfur coal. The E.ON U.S. facilities operate using coal with varying highersulfur contents. ASRC uses low-sulfur coal. The Committee agreed that low-sulfur coal is 

utilized where necessary and did not wish to set forth any recommendations at this time.

6.3.5 Energy Efficiency Measures 

The Committee recognized that increasing energy efficiency can indirectly reduce direct 

PM2.5 and precursor emissions. A decrease in energy use leads to a decrease in energy 

production, which reduces direct PM2.5 and precursor emissions from the burning of 

fossil fuels. The Committee discussed the evolution of energy efficiency measures in the 

Louisville nonattainment area over time. It was noted that historically, industrial 

operations have been implementing energy efficiency measures mainly because these 

measures translate into direct cost savings for the companies. Committee members also 

agreed that a general move toward energy efficiency in the commercial sector is 

underway but there is still room for improvement in the residential sector. 

A study by the Kentucky Pollution Prevention Center (KPPC) and the American Council 

for an Energy Efficient Economy was presented to the Committee indicating substantial 

untapped potential for more cost-effective energy efficiency measures to be implemented 

in the commercial and industrial sectors. Specifically, it lists 11 measures in the industrial 

sector which could cut Kentucky's industrial electricity usage by 15.5% at a cost of 3 

cents per kilowatt hour (KWh) or less. According to the study, similar opportunities for 

more efficiency are possible in the commercial and residential sectors. 

The Committee heard presentations from E.ON U.S. and Duke Energy on the 

implementation of demand side management (DSM) programs to capture the largely 

untapped energy efficiency possibilities in the residential sector. E.ON U.S.’s DSM 

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program includes programs, offerings and activities to reduce residential, business and 

industrial energy use. In addition, E.ON U.S. continues to increase its program and is 

working on several new DSM offerings. Duke Energy’s DSM program incorporates 

services, products, rebates, educational tools and other programs tailored to its 

residential, business and industrial customers. Complete listings of DSM programs for 

E.ON U.S. and Duke Energy are included as Appendix 9. 

The Committee also discussed other large scale energy efficiency initiatives throughout 

the community. PGC, which includes representatives from U of L, JCPS and Louisville 

Metro Government, is promoting energy efficiency measures throughout the partnering 

entities. The Energy Use Partnership (EUP), a committee of the PGC, has the goal of 

reducing energy usage in all three institutions by seeking out new technologies, practices 

and other opportunities for energy savings and by sharing this information among the 

participants. All of the partners have already undertaken projects to reduce their energy 

usage and are continuing to incorporate energy efficiency technologies and policies into 

their institutions’ practices. Several examples of these projects are discussed below. 

Louisville Metro Government has nearly completed a citywide project to convert all 

Metro-owned traffic lights from incandescent bulbs to light-emitting diodes (LEDs). 

These LEDs are energy efficient and reduce consumption by an average of 80%. 

Additionally, they save time and money by lowering maintenance costs significantly. 

LEDs last six or more years instead of an incandescent bulb’s lifespan of eight to twelve 

months. This retrofit project is expected to save 7.5 million kilowatt hours, enough to 

power 750 homes for a year. Additionally, Louisville Metro Government recently 

became an Energy Star Partner organization and committed to measure, track and 

improve the city’s energy performance. 

KPPC has performed energy audits on 17 PGC buildings. The purpose of these audits is 

to identify building conditions that are not optimal for energy efficiency and to prioritize 

the correction of these conditions based on cost and payback. 

U of L has installed Vending Misers on several beverage machines around campus. The 

Vending Miser is a device that can be added to any cold beverage vending machine to 

conserve electricity. By sensing the ambient temperature around the machine, as well as 

whether there is anyone in the vicinity of the machine, the Vending Miser will power the 

machine down when it is not necessary to cool the product or illuminate the sign. U of L 

will potentially save thousands of dollars a year from reduced electric consumption by 

these machines, without affecting the quality of the product delivered. 

JCPS has been exploring ways to take advantage of available solar resources. JCPS 

conducted pilot projects to test daylight harvesting ballasts and solar reflectors that throw 

sunlight from windows further into a classroom. After the results of these pilot projects 

were analyzed, JCPS decided that these technologies could be incorporated into new 

building construction and possibly even building renovations. JCPS has already installed 

and is operating a solar water heater at its Churchill Park Rehabilitation Center and plans 

are underway to include this technology in two new buildings. An early adopter in the 

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area of energy efficiency, JCPS has been investigating ways to incorporate energy saving 

technologies into buildings as they are built, a much more cost-effective alternative to 

retrofitting. This includes improvements to the building’s thermal envelope, more 

efficient HVAC technologies and lighting upgrades. A list of many of the projects 

planned for JCPS is included in Appendix 9. 

Recommendation 9: 

In the funding decisions of the Partnership for a Green City (PGC) entities, 

priority should be given to energy efficiency projects as specified by the 

committees of the PGC. 

Recommendation 10: 

The Partnership for a Green City (PGC) entities should increase funding for 

facility audits to determine where energy efficiency projects are needed most. 

Recommendation 11: 

The Board should encourage existing funding entities to increase funding of 

Project Warm. 

Recommendation 12: 

A partnership should be created, among state and local agencies and chambers of 

commerce, to increase awareness of and participation in electric utilities’ 

demand side management (DSM) programs. 

Recommendation 13: 

The District should explore partnership opportunities with companies specializing 

in energy efficient products and services to increase awareness of the benefits of 

energy efficiency for industrial, commercial and residential customers.

Recommendation 14: 

The District should work with Louisville, Kentucky and Indiana Home Builders 

Associations to educate members on the economic and environmental benefits of 

incorporating energy efficiency measures into building projects. 

Recommendation 15: 

The District should develop and implement a recognition program to reward 

energy efficiency initiatives and achievements throughout the community on a 

variety of scales.

6.3.6 Measures to Reduce Fugitive Dust 

The Committee reviewed the District’s regulation to control fugitive particulate 

emissions. While this regulation is not specific to emissions of PM2.5, enforcement of the 

regulation will help to reduce direct PM2.5 emissions. The regulation outlines preventative 

measures that must be taken to control fugitive dust from materials handling activities, 

unpaved roads and parking areas and other activities as specified. 

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Recommendation 16: 

The District should continue enforcement of its regulation to control fugitive 

particulate emissions (DR 1.14). 

6.3.7 Open Burning 

The Committee reviewed regulations regarding open burning throughout the Louisville 

nonattainment area. Jefferson County, Kentucky bans open burning without a permit 

from the District. The state of Kentucky allows for open burning in certain instances but 

restricts most open burning in PM2.5 nonattainment areas from May to September. Open 

burning is totally banned in Clark and Floyd Counties in Indiana and no variances for 

residential open burning are granted in these counties. The state of Indiana allows for 

open burning in certain instances but restricts burning on air pollution alert days. 

Recommendation 17: 

The District should continue enforcement of its regulation on control of open 

burning (DR 1.11).

Recommendation 18: 

The Kentucky Division for Air Quality (KY DAQ) should continue to enforce its 

regulation regarding open burning and should amend that regulation to prohibit 

all open burning of household waste and debris. (401 KAR 63:005). 

Recommendation 19: 

The Kentucky Division for Air Quality (KY DAQ) should consider amending its 

regulation to ban open burning in areas in nonattainment of the federal primary 

annual standard for PM2.5.

Recommendation 20: 

In the interim, when authorizing open burning in areas in nonattainment of the 

federal primary annual standard for PM2.5, the Kentucky Division for Air Quality 

(KY DAQ) should consider the local projected ambient concentration of PM2.5 in 

its decision making. 

6.3.8 Woodstoves, Fireplaces and Wood Boilers 

The Committee discussed the impact of woodstoves, fireplaces and wood boilers on the 

nonattainment of this area. Collectively, the impact from all these sources appears to be 

relatively low. However based on information from EPA, replacing twenty non-certified, 

older woodstoves with twenty EPA-certified woodstoves can prevent the emissions of 

one ton of fine particulate matter per year. The Committee determined that the potential 

for significant emission reductions from this source category exists and steps should be 

taken to reduce these emissions where possible. 

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Recommendation 21: 

The District should increase public awareness of the effects of the use of 

fireplaces and woodstoves on ambient concentrations of PM2.5 and NOx

Recommendation 22: 

The District should promote EPA’s Great American Woodstove Changeout 

program.

Recommendation 23: 

The District should increase outreach on the benefits of switching from 

woodstoves, fireplaces and wood boilers to more efficient sources of heat. 

6.3.9 Charbroiling and Other Commercial Cooking Operations 

The Committee determined that commercial charbroiling and cooking operations account 

for approximately 10% of total area source PM2.5 emissions within Jefferson County, 

Kentucky. However, the Committee believed strongly that they could not determine the 

feasibility of control measures for this source category without speaking to 

representatives from local restaurant associations. 

Recommendation 24: 

The District should meet with local restaurant associations to discuss potentially 

feasible and cost-effective PM2.5 control measures that that could reduce PM2.5

emissions from restaurants in Louisville Metro and southern Indiana, particularly 

those with commercial charbroilers. 

6.3.10 Use of Consumer Products 

The Committee determined that the use of solvents containing organic compounds such 

as toluene, xylene and trimethyl benzene in commercial and household applications did 

not appear to contribute significantly to total area source PM2.5 and precursor emissions 

in Jefferson County, Kentucky. However, the Committee believed that through education 

and outreach reductions may be achieved. 

Recommendation 25: 

Through outreach, the District should increase public awareness of alternatives 

to residential solvent usage and the benefits of avoiding household products 

containing organic compounds such as toluene, xylene and trimethyl benzene. 

6.3.11 Charcoal Grilling 

Although not included in the EPA starting point list, the Committee found that backyard 

charcoal grilling accounted for as much as 63% of direct PM2.5 and 11% of NOx

emissions from area sources in Jefferson County, Kentucky. Methods for estimating area 

source emissions are included in Section 5.2.1.2 of this Report. 

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Recommendation 26: 

The District should increase public awareness of the effects of charcoal grilling 

on ambient concentrations of PM2.5 and NOx.

Recommendation 27: 

The District should develop and implement a program to encourage replacement 

of charcoal grills in Jefferson County with gas and/or electric units through a 

rebate system similar to the Lawn Care for Cleaner Air program. 

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Section 7 Report of the Mobile and Nonroad Mobile Source Committee 

7.1 Background 

The Mobile and Nonroad Mobile Source Committee (Committee) was formed to identify 

control measures in place in the community to reduce direct PM2.5 and precursor 

emissions and determine whether additional control strategies could be implemented 

throughout the region to achieve early attainment of the annual standard. The Committee 

met to review emissions data and interview representatives of several large local fleets 

regarding current and future controls for direct PM2.5 and precursor emissions. The 

Committee also completed an informal RACT/RACM assessment for mobile and 

nonroad mobile sources in the Louisville nonattainment area in accordance with the 

Implementation Rule. 

7.2 Committee Actions 

The Committee reviewed PM2.5 and precursor source apportionment data, collected by 

the Emissions Inventory and Modeling Data Committee, for mobile and nonroad mobile 

sources to determine the source categories of greatest concern in Jefferson County, 

Kentucky. Onroad mobile5 sources were easily broken into four major vehicle categories 

including light- and heavy-duty diesel and light- and heavy-duty gasoline. For nonroad 

mobile6 sources, the top 90% of source categories were identified with the remaining 

considered as “other”. The Committee determined that Jefferson County, Kentucky 

nonroad mobile sources emit more direct PM2.5 and SO2 than mobile sources, while 

mobile sources are responsible for a majority of NOx emissions. The Committee also 

identified diesel vehicles and equipment, both onroad and nonroad, as the major sources 

of concern. 

The Committee also reviewed the work of previous air quality task forces, stakeholder 

groups and committees. In 2006, the Board adopted a set of recommendations for 

reducing ozone precursor emissions to lower ambient ozone concentrations in the 

Louisville Metro area. In 2007, the STAR Regulation 5.30 Stakeholder Group produced a 

Report and Plan of Action to reduce emissions of and exposure to toxic air contaminants. 

Finally, PGC’s Climate Change Committee is working to reduce greenhouse gas 

emissions. The Committee noted that these efforts involve similar pollutants, issues and 

sources. The Committee determined that many of the recommendations developed 

through these processes may also reduce direct PM2.5 and precursor emissions. 

Representatives of several large local fleets gave presentations to the Committee on 

current and future planned efforts to reduce direct PM2.5 and precursor emissions. The 

 

5

 Onroad mobile sources are motorized vehicles that are registered for use on public roads and highways, 

including automobiles, light- and heavy-duty trucks, buses and motorcycles. 

6

 Nonroad mobile sources are motorized vehicles that are not registered for use on the public roads and 

highways or any other equipment with a fossil fuel-fired engine that is not a point source. Examples include 

aircraft, boats, railroad engines, construction equipment, and nonroad recreational equipment. 

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representatives also helped the Committee to understand the investment and maintenance 

costs associated with certain control measures and technologies. The Committee heard 

presentations from the Transit Authority of the River City (TARC), JCPS, the Regional 

Airport Authority (RAA), the Kentucky Motor Transport Association (KMTA) and 

United Parcel Service (UPS). The Committee considered this information during its 

RACT/RACM assessment. 

TARC has an active fleet of 255 vehicles (e.g. diesel and hybrid diesel-electric buses and 

trolleys) and contracts the operation of 90 paratransit vehicles. TARC operates nine 

hybrid diesel buses, which use approximately 20% less fuel than a traditional transit bus. 

As new hybrids are purchased, TARC replaces the oldest, dirtiest buses in the fleet. 

TARC reports that the use of hybrids in its fleet has significantly reduced its total 

emissions. The transit authority also began using ULSD two full years before mandated 

by the federal government and retrofitted its entire fleet with diesel oxidation catalysts 

(DOCs) in the late 1990’s. TARC recently ordered six new buses that will be the first in 

the fleet to be fitted with diesel particulate filters (DPFs). TARC recognizes the pollutant 

reduction benefits of control technologies and continues to utilize these technologies in 

its fleet; however, TARC foresees the largest emission reductions coming from an 

increase in the use of public transit with a corresponding decrease in the use of single 

occupant vehicles. 

JCPS has a large school bus fleet, with more than 1,150 diesel buses running more than 

850 routes per day. JCPS reported that 648 of its buses are model year 2000 or newer and 

many of the older buses are used less frequently as a part of large spare fleet. The school 

system also operates a vehicle fleet of 471 cars and trucks, 246 of which are powered by 

diesel engines. Over its entire fleet, JCPS burns approximately 2.5 million gallons of fuel 

annually. In December 2006, JCPS began using a 2% biodiesel blend to fuel its entire 

diesel fleet. JCPS also has an idling policy that restricts idling at schools and limits idling 

at depots to that which is necessary for proper start up in cold weather. Through its 

maintenance program, JCPS ensures that all its buses have no more than a five pound 

variance in tire pressure, which helps to increase the fleet’s fuel economy. Average 

turnover for the fleet is fifteen years and JCPS is considering purchasing hybrid school 

buses in the future to reduce total fleet emissions. 

 

RAA is an independent, public agency that owns and operates Louisville International 

Airport and Bowman Field, both located in Louisville Metro. The larger of the two 

airports, Louisville International, has three active runways, 62,000 feet of taxiways and 

325 acres of concrete apron. RAA leases space to commercial airlines and other major 

tenants. According to Airports Council International statistics (2006), Louisville 

International is the 68th busiest airport for passenger travel and the 4th busiest cargo 

airport, largely because of UPS’s Worldport operation. Mobile emission sources at 

Louisville International include vehicles (e.g. taxis, buses, cars) while nonroad mobile 

sources include aircraft, ground support equipment (GSE), auxiliary power units (APU) 

and landscape maintenance equipment. In 2006, RAA published an emissions baseline 

for Louisville International, which outlines its contribution of criteria pollutants and 

HAPs to ambient concentrations. The inventory showed that the largest sources of direct 

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PM2.5 and NOx are the aircraft. The inventory also showed emissions from APUs and 

GSE. RAA is in the process of establishing an emissions baseline for Bowman Field. It 

anticipates using these baselines to apply for the Federal Aviation Administration’s 

(FAA) Voluntary Airport Low Emissions (VALE) program, which offers grants toward 

capital expenditures aimed at reducing emissions from airport activities. RAA is also 

implementing a clean fuels program to use biodiesel in appropriate airport vehicles. 

With approximately 450 members, KMTA supports the trucking industry through 

education, advocacy and career development. KMTA reported that the average local 

trucking company has a fleet of ten vehicles or less. There are 7,000 fleets in Kentucky 

with a combined gross weight of greater than 59,999 pounds per fleet. KMTA recognized 

a trend in the freight movement industry toward combining trucking and rail operations 

around the country. KMTA also noted that EPA’s SmartWay program is not being used 

effectively in Jefferson County or the state of Kentucky. In its opinion, most carriers in 

this area are too small to take advantage of the program and there is a general lack of 

awareness of the benefits of programs like these. KMTA also reported on the use of 

emission reduction technologies throughout the industry. While effective, DOCs and 

DPFs are slow in being accepted industry wide. The use of APUs, which provide power 

to a truck when the main engine is shut off to reduce emissions, is increasing but is more 

common in over-the-road trucks than local fleets. Another popular upgrade is to replace 

the traditional double wide-base tires with single wide-base tires, which reduces the 

weight of the vehicle and increases fuel economy. Retrofitting a truck with single widebase tires can be cost prohibitive and this upgrade is usually found on new trucks. 

UPS operates its Worldport global distribution hub out of Louisville International 

Airport. The system of distribution at this hub has transitioned in recent years from a 

labor and equipment intensive operation to a totally automated system of loading and 

unloading. The Worldport expansion will eliminate the use of 38 diesel loaders and 38 

diesel ground power units. As of December 2007, UPS is using a 5% biodiesel blend to 

fuel over 300 pieces of GSE. Additionally, UPS is considering alternative technologies 

available for nonroad equipment including fuel injection, 4-cylinder engines and nonroad 

vehicles certified to California Air Resources Board (CARB) standards. 

The Committee used language from the Implementation Rule as a starting point for 

completing its RACT/RACM assessment of mobile and nonroad mobile sources for the 

Louisville nonattainment area. A copy of this language from the Implementation Rule is 

included as Appendix 5. The EPA starting point list was used in conjunction with EPA’s 

List of Potential Control Measures for PM2.5 and Precursors and NACAA’s Controlling 

Fine Particulate Under the Clean Air Act: A Menu of Options to complete the 

assessment. 

7.3 Committee Recommendations 

The Committee met on October 22, 2007 and reached consensus on the following 

recommendations to be presented to the full Task Force for its consideration. 

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7.3.1 Onroad and Nonroad Diesel Retrofit, Rebuild or Replacement 

Recommendation 1: 

Local government and quasi-governmental agencies should adopt a plan for 

retrofit or replacement of all diesel fleet vehicles and equipment with state-of-theart technology and the use of alternative fuels.

Recommendation 2: 

Louisville Metro Government’s General Services Administration (GSA) should 

analyze the Metro fleet and create a plan to improve fleet emissions through 

diesel retrofit or replacement along with the use of alternative fuels. 

Recommendation 3: 

The Partnership for a Green City (PGC) entities should continue to move toward 

the use of alternative fuels and technologies, including retrofit and replacement 

options. 

Recommendation 4: 

The District should work with public and private fleet owners operating in 

Louisville Metro through education, incentives and grants to aggressively retrofit 

or replace both onroad and nonroad diesel fleets with state-of-the-art technology. 

Recommendation 5: 

State and local governments should create tax incentives, low interest loans and 

other financial incentives for the retrofit or replacement of onroad and nonroad 

diesel fleets.

Recommendation 6: 

Louisville Metro Government should explore the creation of a Louisville Metro 

Environmental Grant Partnership to aggressively coordinate, apply for and 

receive federal and state grants to reduce direct PM2.5 and precursor emissions 

from mobile and nonroad mobile sources. Federal political partnerships should 

be utilized to increase success. 

The Committee determined that marine and railroad operations are significant 

contributors of direct PM2.5 and precursor emissions in Jefferson County, Kentucky. 

However, the federal Clean Air Act does not provide regulatory authority for local 

jurisdictions, like the District, to further restrict or regulate these transportation sectors. 

The Committee believes that meaningful reductions of direct PM2.5 and precursor 

emissions from these sectors are possible and encourages reasonably available control 

measures be voluntarily taken at ports and switchyards throughout the Louisville 

nonattainment area. 

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Recommendation 7: 

The District should work in partnership with marine and railroad operations in 

the Louisville nonattainment area to identify and reduce direct PM2.5 and 

precursor emissions. 

7.3.2 Diesel Idling Programs 

Louisville Metro and the states of Kentucky and Indiana do not have idling restrictions or 

regulations. The Committee discussed the connection between idling reduction, 

especially of diesel vehicles, and reductions of direct PM2.5 and precursor emissions. The 

Committee agreed with the conclusion of the STAR 5.30 Stakeholder Group that an 

idling regulation is needed in this community. The Committee further addresses idling 

reduction in Section 7.3.3 of this Report. 

Recommendation 8: 

The District should initiate a stakeholder process for local adoption of an idling 

regulation with the proposed Draft Idle Reduction Regulation (included as 

Appendix 10) used as a starting point for discussion. 

7.3.3 Long-range Land Use and Transportation Planning Solutions 

The Committee discussed long-range land use and transportation planning solutions. 

Transportation control measures (TCMs), economic incentive packages (EIPs) and land 

use measures (LUMs) were all recognized by the Committee as tools that influence 

development patterns. The Committee considered that Louisville Metro could be eligible 

for SIP credits in these areas, but more information needs to be gathered from local 

agencies to make that determination. EPA endorses the creation of alternative growth 

scenarios that, when compared to business-as-usual scenarios, allow for quantification of 

TCMs, EIPs and LUMs for SIP credits. The Committee noted the importance of these 

data components for future task force committees charged with balancing emissions 

controls for stationary and mobile sources. Data on these topics and the framework 

necessary for cooperation between local agencies to obtain the requisite data does not 

currently exist. 

 

Recommendation 9: 

The District should cooperate with local and regional agencies to determine if 

any transportation control measures (TCMs), economic incentive packages 

(EIPs) and land use measures (LUMs) are currently being implemented that have 

not been included in the existing emissions budget and could be credited in the 

State Implementation Plan (SIP). 

Recommendation 10: 

The District should cooperate with local and regional planning agencies to 

evaluate major subdivision proposals and development plan proposals for all 

emission components, projected changes in vehicle miles traveled (VMT), 

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projected changes in average daily trips (ADT) and their corresponding impacts 

on the emissions budget. 

Recommendation 11: 

The District should cooperate with local and regional planning agencies to 

quantify the difference between emissions budgets that result from business-asusual and alternative growth scenarios using comparison guidelines provided by 

EPA. 

Recommendation 12: 

Louisville Metro Government should cooperate with regional transportation and 

planning agencies to identify opportunities to spur transit-oriented development 

through the implementation of economic incentive packages (EIPs) and land use 

measures (LUMs). 

Recommendation 13: 

District staff, as part of its development review, should review and comment on a 

project’s emissions related to PM2.5 and precursors, ozone, air toxics, greenhouse 

gases and vehicle miles traveled (VMT). 

Recommendation 14: 

The District should recognize those businesses that have implemented Best 

Workplaces for Commuters (BWC) practices to reduce the total vehicle miles 

traveled (VMT) by employees. 

Recommendation 15: 

Continue strict enforcement of current speed limits throughout the Louisville 

nonattainment area to reduce emissions of direct PM2.5 and precursors.

The Committee also agreed with the following recommendations of the STAR 5.30 

Stakeholder Group that address transportation planning measures to reduce vehicle idling 

and average commute duration. 

Recommendation 16: 

Improve and expand traffic light signalization synchronization throughout 

Louisville Metro to reduce average commute length and idling. 

Recommendation 17: 

Improve Traffic Response and Incident Management Assisting the River Cities 

(TRIMARC) incident management and roadside assistance to reduce idling on the 

highways. 

Recommendation 18: 

Encourage significant coordination among the Kentucky Transportation Cabinet 

(KTC), local transportation officials and private fleets during major highway 

repair or construction, including the Louisville-Southern Indiana Ohio River 

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Bridges project, to develop plans to minimize traffic backups and delays to reduce 

idling and toxic emissions. 

7.3.4 Emission Reductions or Accelerated Retirement of High Emitting 

Lawn and Garden Equipment 

The Committee recognized the efforts of the District’s Lawn Care for Cleaner Air 

program, which offers vouchers for the recycling of gasoline powered lawn care 

equipment and rebates toward the purchase of electric or battery powered mowers and 

string trimmers, reel mowers, electric blower/vacs and replacement batteries. The District 

also offers a manufacturer-sponsored rebate aimed at commercial users for purchase of 

Stihl’s 4-stroke gasoline powered engine line of products. 

Recommendation 19: 

The District should continue providing rebates, through the Lawn Care for 

Cleaner Air program, for the retirement of gasoline powered lawn and garden 

equipment and the purchase of low emissions equipment. 

Recommendation 20: 

The District should expand corporate sponsorship of the Lawn Care for Cleaner 

Air program to increase brands and products that are rebate eligible. 

7.3.5 Emissions Testing and Repair/Maintenance Programs 

The Committee discussed the effectiveness of vehicle emissions testing programs at 

reducing direct PM2.5 and precursor emissions. However, in light of state law restricting 

mandatory vehicle emissions testing, the Committee did not consider this measure to be a 

viable recommendation. Other maintenance programs including on-board diagnostic and 

tire pressure checks were also discussed. 

Recommendation 21: 

The District should consider including as contingency measures in the State 

Implementation Plan (SIP) for the annual PM2.5 standard those onroad and 

nonroad mobile contingency measures from the 8-hour Ozone SIP that will also 

reduce direct PM2.5 and precursor emissions. 

Recommendation 22: 

Provide free tire pressure stations, free air, free on-board diagnostics checks and 

free gas caps to promote increased fuel economy and reduce emissions of direct 

PM2.5 and precursors. 

7.3.6 Clean Burning Fuel Programs 

The Committee also agreed with the following recommendations of the STAR 5.30 

Stakeholder Group that address the use of alternative fuels and technologies to reduce 

direct PM2.5 and precursor emissions. 

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Recommendation 23: 

Expand the use of alternative fuels and technologies by all municipal and transit 

fleets, both onroad and nonroad, in Louisville Metro within one year.

Recommendation 24: 

Work in partnership with the Kentucky Petroleum Marketers Association, 

retailers, distributors and other stakeholders to evaluate, develop and achieve 

goals to provide biodiesel (ASTM standard) blends at retail stations throughout 

Louisville Metro. 

Recommendation 25: 

Develop a partnership, between rental car agencies and public and private 

entities utilizing rental fleets, to increase the use of biodiesel (ASTM standard) 

and/or alternative fuels and technologies in rental fleets. 

Recommendation 26: 

Create partnerships, tax incentives and other financial incentives to encourage 

the use of biodiesel (ASTM standard) and/or alternative fuels and technologies by 

private fleets. 

7.3.7 Contracting for Low Emissions Specifications 

In light of the rapid development of Louisville Metro and the surrounding areas, the 

Committee discussed opportunities for emission reductions through the incorporation of 

preference in contracts for lower project emission profiles. Louisville Metro Government 

uses a request for proposal system to evaluate purchasing and/or contracting options. The 

Committee noted that this system allows for adequate consideration of preferences 

beyond price. 

Recommendation 27: 

Louisville Metro Government should give preference to contractors that provide 

the best project emission profile through the use of diesel retrofits or newer 

equipment and alternative fuels. 

Recommendation 28: 

Encourage members of the Associated General Contractors (AGC) of Kentucky, 

The Association of Union Constructors (TAUC) and other trade associations to 

retrofit or replace both onroad and nonroad diesel equipment. 

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Section 8 Report of the Report and Plan of Action Committee 

8.1 Background 

The Report and Plan of Action Committee (Committee) was formed to oversee 

documentation of the issues reviewed and the process undertaken by the Task Force to 

determine recommendations for reducing ambient concentrations of PM2.5. The work 

product of this Committee was this Fine Particle Air Quality Task Force Report and Plan 

of Action. District staff, with input from Task Force committees, drafted the majority of 

the language contained in the Report. The Report reflects the information presented to the 

Task Force and committees throughout the process. The committee report sections and 

the Plan of Action reflect specific discussions that led to consensus on recommendations 

by the respective committees and the Task Force as a whole.

8.2 Committee Actions 

During initial meetings, the Committee discussed its role in the Task Force process and 

the operating timeline for the Task Force and committees. It also discussed and agreed 

upon the structure and content to be used in the Report. The Committee developed an 

outline for all sections of the Report, including background sections, committee reports, 

and the plan of action. The outline served as a reference for the District to begin drafting 

language to be included in the Report. 

At subsequent meetings, the Committee reviewed and commented on sections of the 

Report, as they became available, to ensure consistent language and proper flow 

throughout the Report. The final Report was adopted by all Task Force members on 

December 20, 2007. 

8.3 Committee Recommendations 

On December 13, 2007, the Committee reached consensus on the following 

recommendations to be presented to the full Task Force for its consideration. 

Recommendation 1: 

The Task Force should include the language included as Appendix 11 in Section 

9.1 of the Report and Plan of Action. 

 

Recommendation 2: 

All recommendations included in Section 9 of the Report and Plan of Action 

should be prioritized by the Task Force. 

 

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Section 9 Plan of Action 

The preceding committee reports and recommendations were presented to the full Task 

Force for its consideration. Each committee recommendation was discussed thoroughly 

and modifications were made where necessary to reach consensus. During this process, 

numerous changes were made to committee recommendations, including consolidation, 

revision, broadening/narrowing of scope and elimination of recommendations. This Plan 

of Action reflects the consensus of the full Task Force. It includes recommended 

strategies for regional, state and local level implementation to reduce direct PM2.5 and 

precursor emissions. 

9.1 Leading Recommendations 

In Section 8.3, the Report and Plan of Action Committee proposed eight leading 

recommendations (included as Appendix 11) to be given priority during the 

implementation process and recommended that the Task Force consider assigning priority 

to all consensus recommendations. While time did not allow for the prioritization of all 

consensus recommendations, the Task Force adopted the proposed leading 

recommendations with one exception, a substitution for Leading Recommendation 6. 

 

The following recommendations include strategies that should be given priority for 

implementation. These recommendations represent a diverse group of strategies 

addressing the full breadth of issues considered by the Task Force and its committees. It 

should be noted that the following eight recommendations were selected from the full list 

of 63 recommendations which are presented, without exclusion, in Sections 9.2 and 9.3 

below. 

Leading Recommendation 1: 

Building upon the Clean Air Act (CAA) principle that ambient concentrations of 

PM2.5 should be reduced to levels sufficient to protect public health with an 

adequate margin of safety, reductions below the federal primary annual standard 

of 15 μg/m3 are advisable to provide an additional margin of safety that allows 

and compensates for scientific uncertainty, including the potential health impacts 

on sensitive populations. To achieve these reductions, the District should 

establish an ongoing and continuous process of review of all sources of PM2.5

emissions (including onroad and nonroad mobile sources, area sources, 

stationary sources, etc.) and develop and implement policies, practices and 

standards to continue progress towards reducing ambient concentrations of PM2.5

and precursors. In the development of such policies, practices and standards, 

stakeholder involvement should be an integral part of the process. Those 

strategies that achieve lower emissions of hazardous air pollutants (HAPs) and 

ozone precursors in conjunction with reducing PM2.5 should be a priority and a 

strong emphasis should be placed on educational programs for the public. 

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Leading Recommendation 2: 

The District should create a diverse stakeholder advisory committee to continue 

to focus and advise the Board on issues of air pollution, public health and 

environmental justice related to PM2.5 and to strategize on policies, practices and 

programs to reduce PM2.5 ambient concentrations, as outlined in Leading 

Recommendation 1. 

Leading Recommendation 3: 

As a part of the ongoing process, a stakeholder group should be convened in 2010 

to review peer-reviewed health literature, ambient monitoring data and modeling 

results to determine whether interim numeric goals are advisable to achieve 

continued progress towards the reduction of ambient PM2.5 concentrations 

sufficient to protect public health with an adequate margin of safety. Six months 

prior to convening the 2010 review, committees responsible for synthesizing data 

shall be convened to have sufficient time to collect, analyze and synthesize needed 

information. 

Leading Recommendation 4: 

The District should work with the states of Kentucky and Indiana to pursue and 

develop strategies to reduce the PM2.5 precursor emissions from major regional 

sources within a range of 150 miles to achieve additional reductions in ambient 

PM2.5 concentrations to protect public health. 

Leading Recommendation 5: 

The District should work with public and private fleet owners operating in 

Louisville Metro through education, incentives and grants to aggressively retrofit 

or replace both onroad and nonroad diesel fleets with state-of-the-art technology 

that reduces emissions. 

Leading Recommendation 6:

The District should cooperate with local and regional planning agencies to 

evaluate major subdivision proposals and development plan proposals for all 

emission components (e.g. PM2.5 and precursors, ozone, air toxics, greenhouse 

gases), projected changes in vehicle miles traveled (VMT), projected changes in 

average daily trips (ADT) and their corresponding impacts on the emissions 

budget. 

Leading Recommendation 7:

The District should initiate a stakeholder process for local adoption of onroad 

and nonroad idling regulations, with the proposed Draft Idle Reduction 

Regulation (included as Appendix 10) used as a starting point for discussion. 

Leading Recommendation 8:

Counties and municipalities within the Louisville nonattainment area should 

enact local ordinances to prohibit open burning. To the extent it is allowed, open 

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burning should be restricted on days when PM2.5 concentrations are forecasted to 

be unhealthy for sensitive populations. 

9.2 Recommendations for Regional and State Action 

The following recommendations include those that can only be achieved with action from 

regional and state entities. Reductions below the federal standard would require a unified 

regional effort aimed at reducing direct PM2.5 and precursor emissions. 

9.2.1 Currently Achievable 

Recommendation 1: 

All regulated utilities should continue to install control devices according to their 

current schedules, set forth to comply with Clean Air Interstate Rule (CAIR) 

requirements. 

Recommendation 2: 

Local and regional authorities should strictly enforce current speed limits 

throughout the Louisville nonattainment area to reduce emissions of direct PM2.5

and precursors. 

Kentucky and Indiana have state regulations on open burning. Within the Louisville 

nonattainment area, open burning is strictly prohibited in Clark and Floyd Counties in 

Indiana. Jefferson County, Kentucky, also restricts open burning through regulation. 

Because direct emissions of PM2.5 from open burning can affect local ambient air quality, 

the Task Force recommends several strategies to reduce open burning throughout the 

entire Louisville nonattainment area. Issues of enforcement and response times were 

discussed and the Task Force determined that additional local ordinances could enhance 

state efforts to restrict open burning. 

Recommendation 3: 

The Kentucky Division for Air Quality (KY DAQ) and the Indiana Department of 

Environmental Management (IDEM) should continue to enforce regulations 

regarding open burning (401 KAR 63:005 and 326 IAC 4) 

9.2.2 Achievable in the Short-term 

Recommendation 4: 

Counties and municipalities within the Louisville nonattainment area should 

enact local ordinances to prohibit open burning. To the extent it is allowed, open 

burning should be restricted on days when PM2.5 concentrations are forecasted to 

be unhealthy for sensitive populations. 

Recommendation 5: 

The Kentucky Division for Air Quality (KY DAQ) should consider amending its 

regulation to ban open burning in areas in nonattainment of the federal primary 

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annual standard for PM2.5 and to prohibit all burning of household rubbish and 

waste. 

9.2.3 Achievable in the Long-term 

Recommendation 6: 

Federal, state and local governments should create tax incentives, low interest 

loans and other financial incentives for the retrofit or replacement of onroad and 

nonroad diesel fleets. 

9.3 Recommendations for Louisville Metro Government Action 

The following recommendations will require action by Louisville Metro Government. 

The Task Force recognizes that several of these recommendations are only achievable 

through regional collaboration initiated by Louisville Metro Government. 

9.3.1 Currently Achievable 

Recommendation 7: 

The Partnership for a Green City (PGC) entities should continue to move toward 

the use of alternative fuels and technologies that reduce onroad and nonroad 

mobile emissions, including retrofit and replacement options. 

9.3.2 Achievable in the Short-term 

Recommendation 8: 

In the funding decisions of the Partnership for a Green City (PGC) entities, 

priority should be given to energy efficiency projects as specified by the 

committees of the PGC. 

The Stationary and Area Source Committee proposed a recommendation to address direct 

PM2.5 emissions from a specific regional source generally thought to influence ambient 

concentrations of PM2.5 in the Louisville nonattainment area. The Task Force believed 

that the recommendation should not be limited to a single source and should be expanded 

to include precursor emissions. 

 

Recommendation 9: 

Louisville Metro Government should encourage all regional electric generating 

units (EGUs) to continue to look at cost-effective controls for direct PM2.5 and 

precursor emissions in the future. 

Recommendation 10: 

Encourage significant coordination among the Kentucky Transportation Cabinet 

(KTC), the Indiana Department of Transportation (INDOT), the Kentuckiana 

Regional Planning and Development Agency (KIPDA), local transportation 

officials and private fleets during major highway repair or construction, 

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including the Louisville-Southern Indiana Ohio River Bridges project, to develop 

plans to minimize traffic backups and delays to reduce emissions. 

Recommendation 11: 

Louisville Metro Government should explore the creation of a Louisville Metro 

Environmental Grant Partnership to aggressively coordinate, apply for and 

receive federal and state grants to reduce direct PM2.5 and precursor emissions 

from onroad and nonroad mobile sources. Federal political partnerships should 

be utilized to increase success. 

The Task Force discussed the many reasons for the use of alternative fuels and 

technologies, such as improving air quality, increasing fuel economy and reducing 

dependence on foreign oil. However the Task Force believed that only those alternative 

fuels and technologies that reduce air pollution emissions should be considered in this 

Report. 

Recommendation 12: 

Louisville Metro Government should give preference to contractors that provide 

the best project emission profile through the use of diesel retrofits or newer 

equipment and alternative fuels that reduce onroad and nonroad mobile 

emissions. 

Recommendation 13: 

Louisville Metro Government’s General Services Administration (GSA) should 

analyze the Metro fleet and create a plan to improve fleet emissions through 

diesel retrofit or replacement along with the use of alternative fuels that reduce 

onroad and nonroad mobile emissions. 

9.3.3 Achievable in the Long-term 

Recommendation 14: 

Louisville Metro Government and quasi-governmental agencies should adopt a 

plan to accelerate the retrofit or replacement of all diesel fleet vehicles and 

equipment with state-of-the-art technology and the use of alternative fuels that 

reduce onroad and nonroad mobile emissions. 

Recommendation 15: 

Create partnerships, tax incentives and other financial incentives to encourage 

the use of biodiesel (ASTM standard) or other alternative fuels and technologies 

that reduce onroad and nonroad mobile emissions by private fleets. 

Recommendation 16: 

Louisville Metro Government should cooperate with regional transportation and 

planning agencies to identify opportunities to spur transit-oriented development 

through the implementation of economic incentive packages (EIPs) and land use 

measures (LUMs). 

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Recommendation 17: 

Louisville Metro Government should work with the Kentucky Transportation 

Cabinet (KTC) and the Indiana Department of Transportation (IDEM) to improve 

and expand traffic signal synchronization throughout Louisville Metro to reduce 

average commute duration and idling. 

 

Recommendation 18: 

Louisville Metro Government should work with the Kentucky Transportation 

Cabinet (KTC), the Indiana Department of Transportation (INDOT) and the 

Federal Highway Administration to improve Traffic Response and Incident 

Management Assisting the River Cities (TRIMARC) incident management and 

roadside assistance to reduce idling on the highways. 

Recommendation 19: 

Louisville Metro Government should provide free tire pressure stations, free air, 

free on-board diagnostics checks and free gas caps to promote increased fuel 

economy and reduce emissions of direct PM2.5 and precursors. 

Recommendation 20: 

The Partnership for a Green City (PGC) entities should increase funding for 

facility audits to determine where energy efficiency projects are needed most. 

9.4 Recommendations for District Action 

The following recommendations will require action by the District. The Task Force 

recognizes that several of these recommendations are only achievable through 

collaborative efforts and partnerships initiated by the District. 

9.4.1 Currently Achievable 

Recommendation 21: 

The District should continue to address pollution from stationary diesel engine 

sources through compliance with Strategic Toxic Air Reduction (STAR) 

regulations (DR 5.21). 

Recommendation 22: 

The District should make enforcement of its regulation on control of open burning 

(DR 1.11) a priority in 2008 and 2009. 

Recommendation 23: 

The District should make enforcement of its regulation to control fugitive 

particulate emissions (DR 1.14) a priority in 2008 and 2009. 

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Recommendation 24: 

The District should continue providing rebates, through the Lawn Care for 

Cleaner Air Program, for the retirement of gasoline powered lawn and garden 

equipment and the purchase of low emissions equipment. 

In committee, consensus was reached for highlighting the regional modeling results from 

one regional planning organization over another based on the use of more recent data. 

While the majority of the Task Force agreed with the committee recommendation, one 

member of the Task Force cautioned against comparing results from two different 

regional models. While the two models project very different results, both models are 

technically sound and relevant to the Louisville nonattainment area, and thus, should be 

given proper consideration in the State Implementation Plan (SIP). The following 

recommendation represents the consensus of the full Task Force. 

Recommendation 25: 

Of the two regional modeling efforts considered by the Task Force, the District 

should give the Lake Michigan Air Directors Consortium (LADCO) projected 

design values as much, or more, weight as the Association for Southeastern 

Integrated Planning (ASIP) projections for reasons listed in Section 5.2.2.1. 

Recommendation 26: 

Based on current monitoring and modeling data from local and regional sources, 

it may be worthwhile for the District to pursue local measures to reduce 

emissions of organic carbon in addition to measures outside the local area to 

reduce emissions of SO2, a precursor of sulfate formation. 

Recommendation 27: 

The District should continue to monitor the progress of the regional modeling 

groups and other sources of PM2.5 data utilized by the Task Force to look for 

additional information that will assist the community in improving its 

understanding of PM2.5 emissions and health impacts. 

9.4.2 Achievable in the Short-term 

Recommendation 28: 

Building upon the Clean Air Act (CAA) principle that ambient concentrations of 

PM2.5 should be reduced to levels sufficient to protect public health with an 

adequate margin of safety, reductions below the federal primary annual standard 

of 15 μg/m3

 are advisable to provide an additional margin of safety that allows 

and compensates for scientific uncertainty, including the potential health impacts 

on sensitive populations. To achieve these reductions, the District should 

establish an ongoing and continuous process of review of all sources of PM2.5

emissions (including onroad and nonroad mobile sources, area sources, 

stationary sources, etc.) and develop and implement policies, practices and 

standards to continue progress towards reducing ambient concentrations of PM2.5

and precursors. In the development of such policies, practices and standards, 

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stakeholder involvement should be an integral part of the process. Those 

strategies that achieve lower emissions of hazardous air pollutants (HAPs) and 

ozone precursors in conjunction with reducing PM2.5 should be a priority and a 

strong emphasis should be placed on educational programs for the public. 

Recommendation 29: 

The District should create a diverse stakeholder advisory committee to continue 

to focus and advise the Board on issues of air pollution, public health and 

environmental justice related to PM2.5 and to strategize on policies, practices and 

programs to reduce PM2.5 ambient concentrations, as outlined in 

Recommendation 28. 

The Task Force agreed that there is no theoretically safe level of PM2.5 and that reducing 

ambient concentrations of PM2.5 to levels below the federal standard would further 

protect public health and welfare. Several Task Force members initially supported the 

notion of setting a numeric health-based annual goal of 12 to 10 μg/m3 by 2018. Several 

other members believed that setting an interim numeric goal was premature given the 

magnitude of emission reductions expected over the next few years with the 

implementation of federal rules, namely CAIR. In the end, many proponents of setting a 

numeric goal agreed that such an effort may be premature, noting that a goal more 

stringent than 12 to 10 μg/m3 by 2018 may be necessary given the anticipated reductions 

for ambient PM2.5. The following recommendation represents consensus of the full Task 

Force on this issue. 

Recommendation 30: 

As a part of the ongoing process, a stakeholder group should be convened in 2010 

to review peer-reviewed health literature, ambient monitoring data and modeling 

results to determine whether interim numeric goals are advisable to achieve 

continued progress towards the reduction of ambient PM2.5 concentrations 

sufficient to protect public health with an adequate margin of safety. Six months 

prior to convening the 2010 review, committees responsible for synthesizing data 

shall be convened to have sufficient time to collect, analyze and synthesize needed 

information. 

Recommendation 31: 

The District should work with the states of Kentucky and Indiana to pursue and 

develop strategies to reduce the PM2.5 precursor emissions from major regional 

sources within a range of 150 miles to achieve additional reduction in ambient 

PM2.5 concentrations to protect public health. 

Recommendation 32: 

The District should cooperate with local and regional planning agencies to 

evaluate major subdivision proposals and development plan proposals for all 

emission components (e.g. PM2.5 and precursors, ozone, air toxics, greenhouse 

gases), projected changes in vehicle miles traveled (VMT), projected changes in 

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average daily trips (ADT) and their corresponding impacts on the emissions 

budget. 

Recommendation 33: 

The District should initiate a stakeholder process for local adoption of onroad 

and nonroad idling regulations, with the proposed Draft Idle Reduction 

Regulation (included as Appendix 10) used as a starting point for discussion. 

Recommendation 34: 

The District should prescreen permit applications and give review priority to 

pollution prevention projects, especially those that could reduce direct PM2.5 and 

precursor emissions. 

Recommendation 35: 

The District should review the backlog of construction permit applications for 

pollution prevention projects that could reduce direct PM2.5 and precursor 

emissions. If any construction permit applications that meet these criteria are 

identified, the District should prioritize review of these applications so that, if 

approved, these projects can be installed in early 2008. 

Recommendation 36: 

The District should encourage electric generating units (EGUs) to achieve as 

many early reduction credits as possible for 2008. 

Recommendation 37: 

The District should cooperate with local and regional agencies to determine if 

any transportation control measures (TCMs), economic incentive packages 

(EIPs) and land use measures (LUMs) are currently being implemented that have 

not been included in the existing emissions budget and could be credited in the 

State Implementation Plan (SIP). 

Recommendation 38: 

The District should consider including as contingency measures in the State 

Implementation Plan (SIP) for the annual PM2.5 standard those onroad and 

nonroad mobile contingency measures from the 8-hour Ozone State SIP that will 

also reduce direct PM2.5 and precursor emissions. 

Recommendation 39: 

The District should evaluate and employ existing mechanisms under the Clean Air 

Act (CAA) to address identifiable contributing sources of fine particulates and 

particulate precursors that interfere with attainment and maintenance of healthful 

air quality in the Louisville Metro community. 

Recommendation 40: 

The District should work with EPA, the regional modeling groups and local 

sources to conduct updated and more detailed regional and local modeling 

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studies to gain a better understanding of the relative impact and timing of 

regional and local emission reductions, beyond planned controls, on local PM2.5

concentrations after 2009. 

Recommendation 41: 

The District should explore partnership opportunities with companies specializing 

in energy efficient products and services to increase awareness of the benefits of 

energy efficiency for industrial, commercial and residential customers. 

Recommendation 42: 

The District should work with Louisville, Kentucky and Indiana Home Builders 

Associations to educate members on the economic and environmental benefits of 

incorporating energy efficiency measures into building projects. 

Recommendation 43: 

The Board should encourage existing funding entities to increase funding of 

Project Warm. 

Recommendation 44: 

The District should increase public awareness of the effects of charcoal grilling 

on ambient concentrations of PM2.5 and NOx. 

Recommendation 45: 

The District should meet with Louisville and southern Indiana restaurant 

associations to discuss potentially feasible and cost-effective PM2.5 control 

measures that that could reduce PM2.5 emissions from local restaurants, 

particularly those with commercial charbroilers. 

Recommendation 46: 

The District should promote EPA’s Great American Woodstove Changeout 

program. 

Recommendation 47: 

The District should increase public awareness of the effects of using fireplaces, 

woodstoves and wood boilers on ambient concentrations of PM2.5 and NOx and 

the benefits of switching to more efficient sources of heat. 

Recommendation 48: 

The District should expand corporate sponsorship of the Lawn Care for Cleaner 

Air Program to increase brands and products that are rebate eligible. 

Recommendation 49: 

Through outreach, the District should increase public awareness of alternatives 

to residential solvent usage and the benefits of avoiding household products 

containing organic compounds such as toluene, xylene and trimethyl benzene. 

Page 62 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Recommendation 50: 

The District should recognize those businesses that have implemented Best 

Workplaces for Commuters (BWC) practices to reduce the total vehicle miles 

traveled by employees. 

Recommendation 51: 

The District should encourage members of the Associated General Contractors 

(AGC) of Kentucky, The Association of Union Constructors (TAUC) and other 

trade associations to retrofit or replace both onroad and nonroad diesel 

equipment. 

9.4.3 Achievable in the Long-term 

Recommendation 52: 

The District should work with public and private fleet owners operating in 

Louisville Metro through education, incentives and grants to aggressively retrofit 

or replace both onroad and nonroad diesel fleets with state-of-the-art technology 

that reduces emissions. 

Recommendation 53: 

A partnership should be created, among state and local agencies and chambers of 

commerce, to increase awareness of and participation in electric utilities’ 

demand side management (DSM) programs. 

Recommendation 54: 

The District should develop and implement a recognition program to reward 

energy efficiency initiatives and achievements throughout the community on a 

variety of scales. 

Recommendation 55: 

The District should consider working in voluntary partnership with the owners of 

non-utility coal-fired boilers to research the cost-effectiveness of converting these 

boilers to alternative fuels and/or installing additional direct PM2.5, NOx and SO2

control devices. 

Recommendation 56: 

The District should initiate efforts to create an interstate commission to reduce 

ambient PM2.5 and precursor emissions through coordinated regional efforts 

within and among states whose sources of direct PM2.5 and precursor emissions 

are identified as contributing to the boundary air pollution levels in the Louisville 

nonattainment area. 

Recommendation 57: 

The District should work with EPA, the states of Kentucky and Indiana and local 

sources to improve methods to estimate local sources of PM2.5 emissions. 

Page 63 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Recommendation 58: 

The District should work with EPA and the states of Kentucky and Indiana to 

continue to fund existing, as well as increase the number of, PM2.5 speciation 

monitors in the area so as to better understand the local and regional 

contributors of PM2.5. 

Recommendation 59: 

The District should develop and implement a program to encourage replacement 

of charcoal grills in Jefferson County with gas and/or electric units through a 

rebate system similar to the Lawn Care for Cleaner Air program. 

Recommendation 60: 

The District should cooperate with local and regional planning agencies to 

quantify the difference between emissions budgets that result from business-asusual and alternative growth scenarios using comparison guidelines provided by 

EPA. 

Recommendation 61: 

The District, in conjunction with Greater Louisville Inc. (GLI), should develop a 

partnership, between rental car agencies and public and private entities utilizing 

rental fleets, to increase the use of biodiesel (ASTM standard) or other alternative 

fuels and technologies that reduce emissions from rental fleets. 

Recommendation 62: 

The District should work in partnership with the Kentucky Petroleum Marketers 

Association, the Indiana Petroleum Marketers and Convenience Store 

Association, retailers, distributors and other stakeholders to evaluate, develop 

and achieve goals to provide biodiesel (ASTM standard) blends at retail stations 

throughout the Louisville nonattainment area. 

Recommendation 63: 

The District should work in partnership with marine and railroad operations in 

the Louisville nonattainment area to identify and reduce direct PM2.5 and 

precursor emissions. 

Page 64 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Appendices 

Page 65 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Appendix 1 Acronyms and Abbreviations 

ACI...................................Airports Council International 

ADT .................................Average daily trips 

AGC .................................Associated General Contractors 

APU..................................Auxiliary power unit 

ASIP.................................Association for Southeastern Integrated Planning 

ASRC ...............................American Synthetic Rubber Company 

ASTM Standard ...............Quality standard set by the American Society for Testing and 

 Materials 

BART...............................Best Available Retrofit Technology 

BWC ................................Best Workplaces for Commuters 

Board................................Air Pollution Control Board 

CAA .................................Clean Air Act, 42 USC 7401 et seq 

CAIR................................Clean Air Interstate Rule 

CARB...............................California Air Resources Board 

CASAC ............................Clean Air Scientific Advisory Committee 

CFR .................................Code of Federal Regulations 

CO....................................Carbon monoxide 

District..............................Air Pollution Control District 

DOC .................................Diesel oxidation catalyst 

DOT .................................United States Department of Transportation 

DPF ..................................Diesel particulate filter 

DR....................................District Regulation 

DSM.................................Demand side management 

DV....................................Design value 

DVF..................................Future Design Value 

EC ....................................Elemental carbon 

EGU .................................Electric generating unit 

EIP....................................Economic incentive packages 

EPA..................................U.S. Environmental Protection Agency 

ESP...................................Electrostatic precipitator 

EUP..................................Energy Use Partnership 

FAA..................................Federal Aviation Administration 

FEDOOP .........................Federally enforceable District origin operating permit 

FGD..................................Flue gas desulfurization 

FR.....................................Federal Register 

FRM .................................Federal Reference Method 

GE ....................................General Electric 

GLI...................................Greater Louisville Inc. (Chamber of Commerce) 

GSA..................................Louisville Metro General Services Administration 

GSE..................................Ground support equipment 

HAP..................................Hazardous air pollutant 

HEPA filter ......................High efficiency particulate air filter 

Page 66 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

IAC...................................Indiana Administrative Code 

IDEM ...............................Indiana Department of Environmental Management 

Implementation Rule........Clean Air Fine Particle Implementation Rule 

INDOT .............................Indiana Department of Transportation 

JCPS.................................Jefferson County Public Schools 

KAR .................................Kentucky Administrative Regulations 

KIPDA .............................Kentuckiana Regional Planning and Development Agency 

KMTA..............................Kentucky Motor Transport Association 

Kosmos ............................Kosmos Cement Company 

KPPC................................Kentucky Pollution Prevention Center 

KTC..................................Kentucky Transportation Cabinet 

KWh.................................Kilowatt hour 

KY DAQ ..........................Kentucky Division for Air Quality 

LED..................................Light-emitting diode 

LADCO............................Lake Michigan Air Directors Consortium 

LUM.................................Land use measures 

MACT..............................Maximum achievable control technology 

μm ....................................Micrometers

μg/m3................................Micrograms per cubic meter 

NAAQS............................National Ambient Air Quality Standard 

NACAA ...........................National Association of Clean Air Agencies 

NCDC ..............................National Clean Diesel Campaign (EPA program) 

NH3 ..................................Ammonia 

NH4 ..................................Ammonium 

NMIM ..............................National Mobile Inventory Model (EPA model) 

NO2 ..................................Nitrogen dioxide 

NO3 ..................................Nitrate 

NOx ..................................Nitrogen oxides 

OC....................................Organic carbon 

Pb .....................................Lead 

PGC..................................Partnership for a Green City 

PM....................................Particulate matter 

PM0.1 ................................Ultrafine particulate matter 

PM10 .................................Inhalable particulate matter 

PM10-2.5.............................Course particulate matter 

PM2.5 ................................Fine particulate matter 

ppm ..................................Parts per million 

RAA .................................Regional Airport Authority 

RACM..............................Reasonably Available Control Measures 

RACT...............................Reasonably Available Control Technology 

Report...............................Report and Plan of Action 

RFP ..................................Reasonable Further Progress 

SCR..................................Selective catalytic reduction 

SEDC ...............................Southeast Diesel Collaborative 

SIP....................................State Implementation Plan 

Page 67 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

SNCR ...............................Selective non-catalytic reduction 

SO2 ...................................Sulfur dioxide 

SO4 ...................................Sulfate 

STAI.................................School Transportation Association of Indiana 

STAR ...............................Strategic Toxic Air Reduction 

TARC...............................Transit Authority of River City 

Task Force........................Fine Particle Air Quality Task Force 

TAUC...............................The Association of Union Constructors 

TCM.................................Transportation control measures 

Tier #................................Represents the corresponding iteration of federal engine 

 requirements 

Title V, TV.......................Title Five of the Clean Air Act, 42 USC 7661 et seq. 

tpy ....................................Tons per year 

TRIMARC .......................Traffic Response and Incident Management Assisting the River 

 Cities 

TSP...................................Total suspended particulate 

TVA .................................Tennessee Valley Authority 

ULSD ...............................Ultra Low Sulfur Diesel 

U of L...............................University of Louisville 

UPS ..................................United Parcel Service 

VALE...............................Voluntary Airport Low Emissions 

VISTAS............................Visibility Improvement State and Tribal Association of the 

 Southeast 

VMT.................................Vehicle miles traveled 

VOC .................................Volatile organic compound 

WHO................................World Health Organization 

Page 68 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Appendix 2 Fine Particle Air Quality Task Force Members 

Tony Arnold 

University of Louisville 

 

Graham Baughman 

Thorntons Inc. 

 

John Brazel 

Associated General Contractors of Kentucky 

 

Lona Brewer 

Kentucky Division for Air Quality 

 

Christy Lee Brown

Community Representative 

Dennis Conniff 

Frost Brown Todd LLC 

Representing Greater Louisville, Inc. 

Air Toxics Task Force 

Tim Corrigan

The Rotunda Group 

Representing Greater Louisville, Inc. 

Pat Daniel 

Indiana Dept. of Environmental Management 

Sharon Dodson 

E.ON U.S. 

Alt. Gary Revlett 

Alt. Sarah Scheetz 

 

Jamie Fiepke

Kentucky Motor Transport Association 

 

Tom FitzGerald 

Kentucky Resources Council 

Alt. Sarah Lynn Cunningham 

Arnita Gadson 

University of Louisville 

West Jefferson County Community Task Force 

 

Tim Hagerty 

Frost Brown Todd LLC 

Representing Greater Louisville, Inc. 

Environmental Affairs Committee 

 

Dr. Lauren Heberle 

University of Louisville 

Alt. Isabella Christensen 

 

Regina Henry 

Cemex Kosmos Cement Company 

Alt. Shannon Graves 

Alt. Amy Osborn 

Wayne Hicks 

Transit Authority of the River City 

Alt. Geoffrey Hobin 

Mark Hussung 

General Electric 

Alt. Steve Marks 

Alt. Tim Hooker 

 

Bill Jacob 

United Parcel Service 

Rick Larkins 

Highview Fire District 

Dr. John Lewis 

Greater Louisville Medical Society 

 

Jesse Mayes 

Kentucky Transportation Cabinet 

 

Heidi McKenzie 

Ford Motor Company 

Alt. Greg Long 

 

Wallace McMullen 

Sierra Club 

 

Patrick Moran 

Community Representative 

Suzy Post 

Metropolitan Housing Coalition 

 

Dr. Robert Powell 

Norton Healthcare 

Representing Greater Louisville Medical Society 

& Louisville Metro Air Pollution Control Board 

Karen Scott 

Regional Airport Authority 

Alt. Bob Slattery 

Kevin Spangler 

OxyVinyls, L.P. 

Jim Vaughn 

Jefferson County Public Schools 

 

Dan Weiss 

Duke Energy 

 

Paul Wheatley 

One Southern Indiana

Page 69 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Appendix 3 Fine Particle Air Quality Task Force Committee Members

Report and Plan of Action Committee

Tony Arnold 

Dennis Conniff 

Tim Corrigan 

Arnita Gadson 

Lauren Heberle 

Heidi McKenzie 

Dr. Robert Powell 

Karen Scott (Chair) 

Kevin Spangler 

Health Committee

Christy Lee Brown 

Sharon Dodson 

Tom FitzGerald 

Arnita Gadson 

Tim Hagerty 

Dr. Lauren Heberle 

Dr. John Lewis (Chair)

Dr. Robert Powell (Vice-chair)

Stationary and Area Source Committee 

Tim Corrigan (Chair)

Sharon Dodson 

Tom FitzGerald 

Arnita Gadson 

Rick Larkins 

Wallace McMullen 

Heidi McKenzie 

Dr. Robert Powell 

Karen Scott 

Kevin Spangler 

Dan Weiss 

Paul Wheatley

Mobile and Nonroad Mobile Source Committee

Tim Corrigan 

Jamie Fiepke 

Tom FitzGerald (Chair)

Arnita Gadson 

Wayne Hicks 

Jim Vaughn 

Mark Hussung 

Bill Jacob 

Pat Moran 

Karen Scott 

Emissions Inventory and Modeling Data Committee

Tim Corrigan, GLI 

Sharon Dodson 

Arnita Gadson 

Regina Henry 

Wallace McMullen 

Pat Moran 

Karen Scott 

Dan Weiss (Chair)

Page 70 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Appendix 4 Record of Health Committee Meeting Attendance 

The following table is a record of Health Committee meeting attendance. A record of 

attendance is kept through meeting sign in sheets, which may be supplemented by 

District staff notes from each meeting. 

Member 19-Sep 26-Sep 3-Oct 10-Oct 25-Oct

Christy Lee Brown Y Y 

Sharon Dodson (Alt. Sarah Scheetz) Y Y Y Y 

Tom FitzGerald (Alt. Sarah Lynn Cunningham) Y Y Y Y Y 

Arnita Gadson Y Y Y Y 

Tim Hagerty Y Y 

Lauren Heberle Y Y Y Y Y 

Dr. John Lewis Y Y Y Y Y 

Suzy Post Y 

Dr. Robert Powell Y Y Y 

Dan Weiss Y 

Page 71 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Appendix 5 List of source categories for starting point for identifying 

potentially available control strategies for nonattainment area

Stationary source measures 

- Stationary diesel engine retrofit, rebuild or replacement, with catalyzed particle filter 

- New or upgraded emission control requirements for direct PM2.5 emissions at stationary 

sources (e.g., installation or improved performance of control devices such as a baghouse 

or electrostatic precipitator; revised opacity standard; improved compliance monitoring 

methods) 

- Improved capture of particulate emissions to increase the amount of PM2.5 ducted to 

control devices, and to minimize the amount of PM2.5 emitted to the atmosphere, for 

example, through roof monitors 

- New or upgraded emission controls for PM2.5 precursors at stationary sources (e.g., SO2

controls such as wet or dry scrubbers, or reduced sulfur content in fuel; desulfurization of 

coke oven gas at coke ovens; improved sulfur recovery at refineries; increasing the 

recovery efficiency at sulfuric acid plants) 

- Energy efficiency measures to reduce fuel consumption and associated pollutant 

emissions (either from local sources or distant power providers) 

- Measures to reduce fugitive dust from industrial sites 

Mobile source measures 

- Onroad diesel engine retrofits for school buses,34 trucks and transit buses using EPAverified technologies 

- Nonroad diesel engine retrofit, rebuild or replacement, with catalyzed particle filter35

- Diesel idling programs for trucks, locomotive, and other mobile sources36

- Transportation control measures (including those listed in section 108(f) of the CAA as 

well as other TCMs), as well as other transportation demand management and 

transportation systems management strategies37

- Programs to reduce emissions or accelerate retirement of high emitting vehicles, boats, 

and lawn and garden equipment 

- Emissions testing and repair/maintenance programs for onroad vehicles 

- Emissions testing and repair/maintenance programs for nonroad heavy-duty vehicles 

and equipment38

Page 72 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

- Programs to expand use of clean burning fuels39

- Low emissions specifications for equipment or fuel used for large construction 

contracts, industrial facilities, ship yards, airports, and public or private vehicle fleets 

- Opacity or other emissions standards for “gross-emitting” diesel equipment or vessels 

Area source measures 

- New open burning regulations and/or measures to improve program effectiveness such 

as programs to reduce or eliminate burning of land clearing vegetation 

- Programs to reduce emissions from woodstoves and fireplaces including outreach 

programs, curtailments during days with expected high ambient levels of PM2.5, and 

programs to encourage replacement of woodstoves when houses are sold 

- Controls on emissions from charbroiling or other commercial cooking operations 

- Reduced solvent usage or solvent substitution (particularly for organic compounds with 

7 carbon atoms or more, such as toluene, xylene, and trimethyl benzene) 

Category-Specific Guidelines on innovative approaches. 

The EPA has issued a number of category specific guidelines on approaches to taking 

into account innovative approaches to emissions reductions for purposes of SIPs. 

Categories currently covered by these guidelines include: (1) Electric-sector Energy 

Efficiency and Renewable Energy Measures (2) Long Duration Switch Yard Locomotive 

Idling (3) Long Duration Truck Idling (4) Clean Diesel Combustion Technology (5) 

Commuter Choice Programs. See 

http://www.epa.gov/ttn/airinnovations/measure_specific.html

34 See Clean School Bus USA program at http://www.epa.gov/cleanschoolbus/. See also: 

What You Should Know About Diesel Exhaust and School Bus Idling", (June 2003, 

EPA420-F-03-021) at http://www.epa.gov/otaq/retrofit/documents/f03021.pdf. 

35 See EPA’s voluntary diesel retrofit program web site at 

http://www.epa.gov/otaq/retrofit/overfleetowner.htm. 

36 See EPA’s voluntary diesel retrofit program web site at 

http://www.epa.gov/otaq/retrofit/idling.htm. 

37 See EPA’s website on transportation control measures at 

http://www.epa.gov/otaq/transp/traqtcms.htm. 

38 See EPA’s web site on nonroad engines, equipment, and vehicles at 

http://www.epa.gov/otaq/nonroad.htm. 

39 Fuels adopted in SIPs must be consistent with the Energy Policy Act of 2005 and EPA 

guidance on SIP-approved boutique fuels at 71 FR 78192 (December 28, 2006). 

Page 73 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Page 74 January 16, 2008 

Appendix 6 Stationary/Area Source Reduction Strategy Evaluation Matri

Suggested Emission Reduction Measure 

Strategy Type 

Responsible Entities and Potential Partners 

Impacted Pollutants (including Cobenefits) 

Ease of Implementation (political climate, stakeholder receptivness, challenges, additional resources required, available resources, etc.) 

Local Examples of Implementation

Additional APCD Resources Needed for Implementation

Current 

Control 

Reduction Contributin 

Current: Relative ranking (1-3: low to high) of current emissions from the source category affected by the reduction measure Control: Are there measures that could be implemented to reduce emissions, relative ranking (1-3: low to high) Reduction Contribution: How much emission reduction could be achieved compared to area emission, relative ranking (1-3: low Reduction Efficiency: How much emission reduction could be achieved compared to current emissions per source, relative rankM/V/P = Mandatory, Voluntary or Partnership Reasonableness-Social: How socially feasible are the measures? (1-3: low to high) Reasonableness-Political: How politically feasible are the measures? Cost-Effective: Relative cost-effectiveness measure (1-3: low to high) Total: Total points from the four relative ranking factors 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Appendix 7 DRAFT E.ON U.S. Planned Control Projects 

Planned NOx Control Projects 

Company Facility Unit Existing Controls Planned Controls Regulatory 

Driver 

Operating 

Year 

% Change 

(2005 

Baseline) 

2005 

Emission 

Projected 

Annual 

Emission 

Change in 

Tons 

LGE Cane Run 4 Low NOx Burners 2,115 

LGE Cane Run 5 Low NOx Burners 2,325 

LGE Cane Run 6 Low NOx Burners 2,601 

WKE Coleman 1 Rotary Over-Fire Air 1,655 

WKE Coleman 2 Advanced Over-Fire Air 1,723 

WKE Coleman 3 Advanced Over-Fire Air 1,755 

KU E.W. Brown 1 Low NOx Burners 1,694 

KU E.W. Brown 2 Low NOx Burners 1,607 

KU E.W. Brown 3 Low NOx Burners 2,504 

KU Ghent 1 SCR year round CAIR 2009 -81% 4,778 914 -3,864

KU Ghent 2 Low NOx Burners 3,736 

KU Ghent 3 SCR year round CAIR 2009 -75% 2,585 658 -1,927

KU Ghent 4 SCR year round CAIR 2009 -75% 2,810 701 -2,109

KU Green 1 Coal Re-burn year round CAIR 2009 -17% 3,041 2,524 -517

KU Green 2 Coal Re-burn year round CAIR 2009 -12% 2,650 2,332 -318

KU Green River 3 Low NOx Burners 900 

KU Green River 4 Low NOx Burners 655 

WKE Henderson 1 SCR year round CAIR 2009 -71% 1,574 456 -1,118

WKE Henderson 2 SCR year round CAIR 2009 -74% 2,133 555 -1,578

LGE Mill Creek 1 Low NOx Burners 3,205 

LGE Mill Creek 2 Low NOx Burners 2,845 

LGE Mill Creek 3 SCR year round CAIR 2009 -79% 3,280 674 -2,607

LGE Mill Creek 4 SCR year round CAIR 2009 -81% 3,738 724 -3,015

WKE Reid 1 Over-fire Air 1,097 

LGE Trimble County 1 SCR year round CAIR 2009 -74% 3,381 894 -2,487

KU Tyrone 3 Low NOx Burners 955 

WKE Wilson 1 SCR year round CAIR 2009 -80% 6,330 1,266 -5,064

 Reductions E.ON 

U.S. -36% 67,671 -24,604

Total/Ave at units 

with additional 

controls 

-68% 36,301 -24,604

Note: The following facilities plan to run existing SCR’s year round starting 2009: Henderson Units 1 & 2, Mill Creek Units 3 & 4, Ghent 1, 3 & 4, Trimble 1, 

Wilson 1. There will be significant increased operating costs to do this, although relatively little capital expense. KY ERC's available: 14,035 

Page 75 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Planned SO2 Control Projects 

Company Facility Unit Existing 

Controls 

Planned 

Controls 

Regulatory 

Driver 

Operating 

Year 

% Change 

(2005 

Baseline) 

2005 

Emission 

Projected 

Annual 

Emission 

Change 

in Tons 

Project Cost 

Original 

Estimates* 

(million $) 

LGE Cane Run 4 FGD 5,543 

LGE Cane Run 5 FGD 5,085 

LGE Cane Run 6 FGD 8,234 

WKE Coleman 1 FGD CAIR 2006 -97% 17,988 540 -17,448 $98 

WKE Coleman 2 FGD CAIR 2006 -97% 17,757 533 -17,224 

WKE Coleman 3 FGD CAIR 2006 -97% 21,069 632 -20,437 

KU E.W. Brown 1 FGD CAIR 2009 -96% 8,682 340 -8,342 $234 

KU E.W. Brown 2 FGD CAIR 2009 -95% 13,804 720 -13,084 

KU E.W. Brown 3 FGD CAIR 2009 -91% 20,376 1,860 -18,516 

KU Ghent 1 FGD 5,503 

KU Ghent 2 FGD CAIR 2009 -87% 13,960 1,780 -12,180 $150 

KU Ghent 3 FGD CAIR 2007 -87% 15,054 2,000 -13,054 $129 

KU Ghent 4 FGD CAIR 2008 -86% 15,669 2,200 -13,469 $146 

KU Green 1 FGD 1,434 

KU Green 2 FGD 846 

KU Green River 3 9,017 

KU Green River 4 6,901 

WKE Henderson 1 FGD 2,104 

WKE Henderson 2 FGD 2,637 

LGE Mill Creek 1 FGD 4,157 

LGE Mill Creek 2 FGD 4,270 

LGE Mill Creek 3 FGD 7,703 

LGE Mill Creek 4 FGD 7,903 

WKE Reid 1 9,280 

LGE Trimble County 1 FGD FGD 

upgrade 2006 -84% 5,236 862 -4,373 $7 

KU Tyrone 3 3,192 

WKE Wilson 1 FGD 11,008 

 

Subtotal Original 

Estimate 

-57% 244,409 

 

-138,127 $764 

 

Expected Increase 

in Costs 

 

 

 $240 

 

Current Estimate 

E.ON U.S. 

-57% 244,409 

 

-138,127 $1,004 

 

Total/Ave at units 

with additional 

controls 

-92% 149,594 

 

-138,127 $1,004 

The FGD’s being installed at Brown and Ghent are expected to achieve around 98% removal. However, since the units will be switching to higher sulfur 

coal than they burned in 2005, the net reduction compared to 2005 is somewhat less. 

*Project Cost Original Estimates includes estimated Costs for KU & LGE from PSC Testimony of John Malloy, Dec. 2004. 

Costs for FGDs at Brown and Ghent are now expected to be approx. $900 million, rather than the originally estimated ~ $660M. 

The total cost is now expected to be over $1 Billion. 

Page 76 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Appendix 8 Current and Planned Pollutant Control Measures for 

Indiana Utilities 

 Southern Indiana CAIR Policy Case Controls 

CAIR 

Costs 

(Millions$) 

 

Plant Name Capacity Existing Control* 

2008 2009 2010-12 2015 2018 2008-2025 

SIGECO A B BROWN: 1 

 

250 SCR+Scrubber 

SIGECO A B BROWN: 2 

 

250 SCR+Scrubber 

DUKE CAYUGA: 1 

 

500 Scrubber SCR 244.651 

DUKE CAYUGA: 2 

 

495 Scrubber SCR 242.984 

IKEC CLIFTY CREEK: 1 

 

199 SCR Scrubber 81.519 

IKEC CLIFTY CREEK: 2 

 

199 SCR Scrubber 81.519 

IKEC CLIFTY CREEK: 3 

 

199 SCR Scrubber 81.519 

IKEC CLIFTY CREEK: 4 

 

199 SCR Scrubber 81.519 

IKEC CLIFTY CREEK: 5 

 

199 SCR Scrubber 81.519 

IKEC CLIFTY CREEK: 6 

 

199 SCR+Scrubber 130.872 

DUKE EDWARDSPORT: 7-1 

 

40 Retire 

 

- 

DUKE EDWARDSPORT: 7-2 

 

40 Retire 

 

- 

DUKE EDWARDSPORT: 8-1 

 

40 Retire 

 

- 

IPL ELMER W STOUT: 50 

 

109 SNCR 3.817 

SIGECO F B CULLEY: 2 

 

90 Scrubber 

 

- 

SIGECO F B CULLEY: 3 

 

270 SCR+Scrubber 

 

- 

HEC FRANK E RATTS: 1SG1 

 

122 

 

- 

HEC FRANK E RATTS: 2SG1 

 

121 - 

DUKE GIBSON: 1 

 

630 SCR Scrubber 

 

181.820 

DUKE GIBSON: 2 

 

630 SCR Scrubber 

 

181.820 

DUKE GIBSON: 3 

 

630 SCR Scrubber 

 

181.820 

DUKE GIBSON: 4 

 

622 SCR+Scrubber 

 

- 

DUKE GIBSON: 5 

 

620 SCR+Scrubber 

 

- 

HEC MEROM: 1SG1 

 

507 SCR+Scrubber 

 

- 

HEC MEROM: 2SG1 

 

493 SCR+Scrubber 

 

- 

NIPSCO MICHIGAN CITY: 12 

 

469 SCR 

 

- 

IPL PETERSBURG: 1 

 

232 Scrubber 

 

- 

IPL PETERSBURG: 2 

 

407 Scrubber SCR 

 

78.600 

IPL PETERSBURG: 3 

 

510 Scrubber SCR 

 

91.050 

IPL PETERSBURG: 4 

 

545 Scrubber 

 

- 

DUKE R GALLAGHER: 1 

 

140 baghouse 

 

25.000 

DUKE R GALLAGHER: 2 

 

140 baghouse 

 

25.000 

Page 77 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

DUKE R GALLAGHER: 3 

 

140 baghouse 

 

25.000 

DUKE R GALLAGHER: 4 

 

140 baghouse 

 

25.000 

AEP ROCKPORT: MB1 

 

1,300 

 

- 

AEP ROCKPORT: MB2 

 

1,300 

 

- 

AEP TANNERS CREEK: U1 

 

140 

 

- 

AEP TANNERS CREEK: U2 

 

140 

 

- 

AEP TANNERS CREEK: U3 

 

200 

 

- 

AEP TANNERS CREEK: U4 

 

500 SCR+Scrubber 

 

244.651 

DUKE WABASH RIVER: 2 

 

85 SNCR 

 

3.245 

DUKE WABASH RIVER: 3 

 

85 SNCR 

 

3.245 

DUKE WABASH RIVER: 4 

 

85 SNCR 

 

3.245 

DUKE WABASH RIVER: 5 

 

95 

 

- 

DUKE WABASH RIVER: 6 

 

318 SCR+Scrubber 

 

565.446 

SIGECO WARRICK: 4 

 

150 SCR 

 

41.007 

Total Capital 

Dollars = 

 

2,705.865 

Run Year Structure: MY2008 = 2007-2008, MY2009 = 2009, MY2012 = 2010-2013, MY2015 = 2014-2017, MY2018=MY2018, MY2020 = 2019-2022 

Page 78 January 16, 2008 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Appendix 9 Energy Efficiency Programs and Projects 

Duke Energy Indiana Energy Efficiency & Conservation Initiatives 

A. Residential Customers 

Free Services 

Home Energy House Call 

Home Energy House Call is a free in-home energy analysis for Duke 

Energy homeowners who meet the guidelines. Sign up today and receive a 

free Energy Efficiency Starter Kit retail valued at $40. 

Refrigerator Replacement 

Duke Energy offers free installation of energy-efficient refrigerators for 

those customers meeting income qualifying guidelines and who live in 

single-family homes. 

Indiana Home Weatherization 

Duke Energy, in partnership with the State of Indiana, offers free energysaving home upgrades for customers meeting income qualifying 

guidelines. 

Products, Rebates & Other Programs 

Power Manager 

The Power Manager Program pays you annually for having your air 

conditioning cycled off-and-on a few days each summer and up to a $35 

installation credit. 

Smart $aver® 

Smart $aver promotes the use of high-efficiency heat pump and airconditioning systems for existing homes. Install a new high-efficiency 

heat pump and you may be eligible to receive a rebate up to $200. Smart 

$aver Eligibility and FAQs 

ENERGY STAR® New Home 

ENERGY STAR® is a government-backed symbol of quality that 

identifies a new home as being more energy efficient than a standard 

home. ENERGY STAR homes may qualify for Duke Energy Indiana’s 

ENERGY STAR incentives. ENERGY STAR® Eligibility & FAQs 

Online Energy Store 

Visit our Online Energy Store to purchase a variety of energy-efficient 

products including compact fluorescent bulbs, water conservation tools 

and much more. 

Energy Saving Tools 

Home Energy Calculator 

Page 79 January 16, 2008 
Fine Particle Air Quality Task Force 

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This tool provides a quick example of how energy saving measures could 

lower your energy costs. It estimates how new energy efficient practices 

and/or equipment in your home could save you money. 

Appliance Calculator 

Use this tool to estimate the cost of operating the electric appliances in 

your home. 

B. Business Customers - Energy Management Programs 

Energy Efficiency Incentive Program 

Reward your business for saving energy. Install qualifying high-efficiency 

lighting, cooling or motors/pumps at your facility, complete a short application 

form, and you will receive a rebate. 

Business Services Newsletter 

Our Duke Energy Business Services Newsline For Your Business is a free 

electronic newsletter filled with information about energy efficiency, industry 

trends and Duke Energy products and services. 

Energy Saving Tips 

Take advantage of these money-saving tips to help manage your energy costs. 

Business Energy Calculator 

This tool provides a quick example of how energy saving measures could 

lower your energy costs. It estimates how different business practices 

and/or equipment could save you money. 

Business Energy Systems Library 

This extensive library provides in-depth information on various business 

energy systems, building design, and energy technologies. 

Understanding Demand 

Learn more about how your demand for electricity can impact your 

electricity costs. This interactive tool explains the concept of demand and 

how the equipment you use add up each hour of the day. 

Power Quality 

From voltage fluctuations to flickering lights, our team of engineers and 

technicians can visit your business to evaluate your power supply or 

distribution system and answer any questions you may have. 

Products and Services 

News and Reports 

Information 

Contact Us 

Page 80 January 16, 2008 
Fine Particle Air Quality Task Force 

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C. Industrial Customers Energy Management Programs 

Energy-Saving Tips 

It's very simple! As a service to our customers, we put together a reference guide 

to help you better manage your electric bill. 

Cutting Your Energy Costs Calculator 

Use this calculator to estimate possible savings which may be gained from 

reducing your energy usage. 

PowerShare® 

PowerShare provides the opportunity for you to profit from curtailment of your 

energy usage. Duke Energy will work with you to help you better understand your 

unique energy consumption profile. Then, we can assist you in developing a 

customized plan that identifies potential curtailable loads. For more information 

or to enroll in PowerShare, contact our business service center at 1-800-774-1202. 

Page 81 January 16, 2008 
Fine Particle Air Quality Task Force 

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Page 82 January 16, 2008 

E.ON U.S. Energy Efficiency Programs 

Existing Programs 

Program / Offering / Activity Comment 

"Demand Conservation" Load 

Control Program 

This program provides for the installation of a switch 

on the customer air conditioning unit or water heater 

that permits LG&E/KU to cycle that load to manage 

demand at peak times. For participating, the customer 

receives either a $20 credit per year or a 

programmable thermostat. Program enrollment 

exceeds 80,000 at present and provides ~100 MW of 

peak demand savings. 

Residential Energy Audits This program provides energy audits for residential 

customers to identify areas in the home for reduction 

of wasted energy. 

Commercial Energy Audits This program provides energy audits for commercial 

customers to identify areas in the facility for 

reduction of wasted energy. 

Low-Income Weatherization 

(WeCare) 

This program provides for energy improvements at 

the homes of qualified low income customers. 

Online Home Energy Calculator This is an online web tool for customers to help them 

estimate their home energy bill and find savings. 

Online Commercial Energy 

Calculator 

This is an online web tool for customers to help them 

estimate their workplace energy bill and find savings. 

Online Home Energy Reference 

Library 

This is an online web tool for 'room by room' analysis 

of a typical home to help the customer find energy 

savings. 

Online Commercial Energy 

Reference Library 

This is an online web tool for 'room by room' analysis 

of a typical workplace to help the customer find 

energy savings. 

Energy Efficiency in E.ON U.S. 

Corporate Facilities 

E.ON U.S. has implemented energy efficiency 

initiatives at corporate facilities where conditions 

(leased facilities vs. company-owned) permit – 

including efficient lighting, load control switching, 

and/or programmable thermostats. 

Net Metering Tariff This tariff is available to customers who own, operate 

and maintain a solar, wind or hydroelectric 

generation system on their premises, in parallel with 

the Company’s electric system to provide all or part 

of their electrical requirements. 
Fine Particle Air Quality Task Force 

Report and Plan of Action 

Green Energy Program This program allows customers to contribute funds in 

$5 blocks (residential/commercial) or $13 blocks 

(industrial) for LG&E/KU to purchase Green Tags 

from qualified renewable resources (hydro, landfill 

gas, or wind) in KY and surrounding states. 

Responsive Pricing & Smart 

Metering Pilot Program 

This program combines the use of Smart Meters, 

Programmable Thermostats, Energy Use Displays, 

and a Time of Use Rate (with critical peak 

component) to provide customers greater control of 

their energy usage--and thus their energy bill. 

Carbon Footprint on the Bill Beginning July 2007, LG&E and KU are placing on 

customer bills the amount of carbon dioxide 

emissions associated with their consumption, coupled 

with monthly tips on what actions they can take to 

reduce the effects of those emissions. This is to help 

give customers greater awareness of and control over 

the impact of their energy usage. 

Hybrid Vehicle Addition to 

Company Fleet 

Beginning in July 2007, LG&E and KU began to add 

hybrid electric Ford Escape vehicles to the Company 

fleet; further additions will be subject to on-going 

economic analysis. 

Proposed Programs 

Program / Offering / Activity Comment 

Brownfield Tariff Filed with the Kentucky PSC on 5/10/07. This tariff 

provides an incentive to commercial/industrial 

customers to locate facilities at sites for which 

distribution infrastructure already exists but for 

which some environmental mitigation may be 

required. Under review by the KPSC at this time. 

Real-Time Pricing Pilot Program Filed with Kentucky PSC on 4/21/07. This program 

permits participating industrial customers to receive a 

real-time hourly price signal, to provide them the 

opportunity to modify consumption and control costs. 

Under review by the KPSC at this time. 

Energy Efficiency Program 

Filing: New Programs 

Filed with the Kentucky PSC on 07/19/07 for the 

2008 – 2014 time period. Under review by the KPSC 

at this time. 

Page 83 January 16, 2008 
Fine Particle Air Quality Task Force 

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Efficient Lighting 

Program 

Working with manufacturers and retailers, this 

program would provide incentives to put significant 

numbers of Compact Fluorescent Light ("CFL") 

bulbs into the residential market. Promotion of other 

forms of efficient lighting is included. Several 

million CFLs are contemplated over the first few 

years. 

HVAC Diagnostics/ 

Tune-Up 

The program would offer central air conditioning or 

heat pump diagnostics at a subsidized cost. 

Customers needing remediation could choose to have 

an “approved” dealer make repairs at a reduced cost. 

The program would focus on over- or underrefrigerant charge and air flow restrictions. This 

program would be available to residential and 

commercial customers. 

Residential New 

Construction 

Certification 

The Company would encourage builders to develop 

homes that meet the Energy Star standards. Homes 

would have to pass plan reviews as well as on-site 

inspections to ensure compliance. 

Dealer Referral Network This program would provide customers with a list of 

energy efficiency dealers who had agreed to meet 

certain minimum standards, such as insurance and 

bonding, but would also agree to perform the service 

according to manufacturer and industry standards and 

requirements. 

Energy Efficiency 

Education & Promotion 

This program would educate the public about energy 

efficiency. This includes a program for students, 

about sources of energy and energy efficiency in 

homes and schools through a curriculum provided to 

schools in the service territory. Teacher workshops 

are anticipated. The curriculum includes lesson plans, 

energy efficiency materials, and demonstration 

materials. 

Program Development 

and Administration 

This program would allow LG&E/KU to invest in 

energy efficiency program design that is not easily 

assigned to an individual program noted above, 

including research—e.g. new technologies for 

metering, control systems, appliances & home 

electronics, etc., as appropriate. 

Page 84 January 16, 2008 
Fine Particle Air Quality Task Force 

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Jefferson County Public Schools Recent, Current and Future Energy 

Efficiency Projects New School project Renovation Project 

Occupancy sensors cycling HVAC 

Occupancy sensors cycling lights 

Direct Digital Control building automation 

hot/cold AHU recovery wheels 

New high efficient chillers 

New high efficient boilers 

Lighting replacements 

New windows 

Variable frequency drive motors 

Solar domestic hot water 

Daylight harvesting ballast controls 

Shelf lighting 

Roof replacements 

Energy Star Award 

Dishwasher removal (Kitchen) 

Pot Scrubbers (Kitchen) 

Trash Compactors (Kitchen) 

Pulpers (Kitchen) 

Conway Middle 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Hartstern Elementary 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Klondike Elementary 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Luhr Elementary 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Pleasure Ridge Park Tech 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Ramsey Middle 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Ahrens/Brown 2007/08 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Barrett Middle 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Breckinridge Metro 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Farmer Elementary 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Myers Middle 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Price Elementary 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Johnsontown Road El 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Iroquois High 2007 ☻ 1994 ☻ ☻ ☻ ☻ 

Stopher Elementary 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Auburndale Elementary 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Churchill Park 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Gutermuth Elementary 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Highland Middle 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Watterson Elementary 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Wheeler Elementary 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

Shelby Elementary 2004 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ 

All 170 JCPS buildings Gas and Electric Usage/Cost are recorded and compiled into several reports by Energy Watchdog. 

All 170 JCPS buildings Gas, Electric, Water, Sewage, and Drainage Usage/Cost are recorded and monitored by the JCPS Energy Auditor. 

JCPS has over 1000 buses that travel a combined 85,000 miles a day. All JCPS diesel powered engines are using a bio-diesel blend. 

JCPS is open to alternative fuels as they are made available. 

JCPS hopes to include Vending machine energy saving devices in the upcoming district wide contract. 

JCPS replaced lighting in 13 buildings, and windows in 11 buildings as part of a 2001 Energy Performance contract. 

The Performance contract has guaranteed an annual savings of nearly $400,000. 

Page 85 January 16, 2008 
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Appendix 10 Draft Idle Reduction Regulation 

(a) Purpose: The purpose of this law is to protect public health and the environment by 

reducing emissions while conserving fuel and maintaining adequate rest and safety of all 

drivers of diesel vehicles. 

(b) Applicability: This law applies to commercial diesel vehicles which are designed to 

operate on highways (as defined under 49 CFR 390.5), and to locations where 

commercial diesel vehicles load or unload (hereinafter referred to as “load/unload 

locations”). 

(c) General Requirement for Load/Unload Locations: No load/unload location owner 

shall cause vehicles covered by this rule to idle for a period greater than 30 minutes while 

waiting to load or unload at a location under their control. 

(d) General Requirement for Vehicles: No owner or operator of a vehicle shall cause or 

permit vehicles covered by this rule to idle for more than 5 minutes in any 60 minute 

period except as noted in sections (e) and (f), and except as provided in section (c) in the 

case of a load/unload location. 

(e) Exemptions: Section (d) does not apply for the period or periods where: 

(1) A vehicle idles while forced to remain motionless because of on-highway traffic, 

an official traffic control device or signal, or at the direction of a law enforcement 

official. 

(2) A vehicle idles when operating defrosters, heaters, air conditioners, or installing 

other equipment solely to prevent a safety or health emergency, and not as part of 

a rest period. 

(3) A police, fire, ambulance, public safety, military, other emergency or law 

enforcement vehicle, or any vehicle being used in an emergency capacity, idles 

while in an emergency or training mode and not for the convenience of the 

vehicle operator. 

(4) The primary propulsion engine idles for maintenance, servicing, repairing, or 

diagnostic purposes if idling is necessary for such activity. 

(5) A vehicle idles as part of a state or federal inspection to verify that all equipment 

is in good working order, provided idling is required as part of the inspection. 

(6) Idling of the primary propulsion engine is necessary to power work-related 

mechanical or electrical operations other than propulsion (e.g., mixing or 

processing cargo or straight truck refrigeration). This exemption does not apply 

when idling for cabin comfort or to operate non-essential on-board equipment. 

Page 86 January 16, 2008 
Fine Particle Air Quality Task Force 

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(7) An armored vehicle idles when a person remains inside the vehicle to guard the 

contents, or while the vehicle is being loaded or unloaded. 

(f) Conditional Exemptions: Subsection (d) does not apply for the period or periods 

where: 

(1) A passenger bus idles a maximum of 15 minutes in any 60 minute period to 

maintain passenger comfort while non-driver passengers are onboard. The 

exemption expires 5 years after implementing a state financial assistance program 

for idle reduction technologies or strategies. 

(2) An occupied vehicle with a sleeper berth compartment idles for purposes of air 

conditioning or heating during rest or sleep period, until 5 years after 

implementing a state financial assistance program for idle reduction technologies 

or strategies, whereupon this exemption expires. 

(3) An occupied vehicle idles for purposes of air conditioning or heating while 

waiting to load or unload, until 5 years after implementing a state financial 

assistance program for idle reduction technologies or strategies, whereupon this 

exemption expires. 

(4) A vehicle idles due to mechanical difficulties over which the driver has no 

control; provided that the vehicle owner submits the repair paperwork or product 

receipt (by mail; within 30 days) to the appropriate authority verifying that the 

mechanical problem has been fixed. 

(g) Auxiliary Power Units 

(1) Generally, operating an auxiliary power unit or generator set as a means to heat, 

air condition, or provide electrical power as an alternative to idling the main 

engine is not an idling engine, per se. 

(2) Operating an auxiliary power unit or generator set on all model year 2006 or older 

commercial diesel vehicles is allowed. [Reserved for possible inclusion of criteria 

for APU use on 2007 and subsequent model year commercial vehicles] 

(h) Penalties: The owner and/or operator of a vehicle, and/or the owner of a load/unload 

location, that is in violation of this law is responsible for penalties as follows. 

(1) First offense: Warning ticket issued to vehicle driver and owner, and where 

applicable, the load/unload facility owner. 

(2) Second and subsequent offenses: $150 citation is issued to the vehicle driver; 

and/or, $500 citation issued to the registered vehicle owner or load/unload 

location owner. 

Page 87 January 16, 2008 
Fine Particle Air Quality Task Force 

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Appendix 11 Report and Plan of Action Committee Leading 

Recommendations 

The following recommendations include strategies that should be given priority for 

implementation. These recommendations represent a diverse group of strategies 

addressing the full breadth of issues considered by the Task Force and its committees. It 

should be noted that the following eight recommendations were selected from the full list 

of 63 recommendations which are presented, without exclusion, in Sections 9.2 and 9.3 

below. 

Leading Recommendation 1: 

Building upon the Clean Air Act (CAA) principle that ambient concentrations of 

PM2.5 should be reduced to levels sufficient to protect public health with an 

adequate margin of safety, reductions below the federal primary annual standard 

of 15 μg/m3

 are advisable to provide an additional margin of safety that allows 

and compensates for scientific uncertainty, including the potential health impacts 

on sensitive populations. To achieve these reductions, the District should 

establish an ongoing and continuous process of review of all sources of PM2.5

emissions (including onroad and nonroad mobile sources, area sources, 

stationary sources, etc.) and develop and implement policies, practices and 

standards to continue progress towards reducing ambient concentrations of PM2.5

and precursors. In the development of such policies, practices and standards, 

stakeholder involvement should be an integral part of the process. Those 

strategies that achieve lower emissions of hazardous air pollutants (HAPs) and 

ozone precursors in conjunction with reducing PM2.5 should be a priority and a 

strong emphasis should be placed on educational programs for the public. 

Leading Recommendation 2: 

The District should create a diverse stakeholder advisory committee to continue 

to focus and advise the Board on issues of air pollution, public health and 

environmental justice related to PM2.5 and to strategize on policies, practices and 

programs to reduce PM2.5 ambient concentrations, as outlined in Leading 

Recommendation 1. 

Leading Recommendation 3: 

As a part of the ongoing process, a stakeholder group should be convened in 2010 

to review peer-reviewed health literature, ambient monitoring data and modeling 

results to determine whether interim numeric goals are advisable to achieve 

continued progress towards reducing ambient PM2.5 concentrations sufficient to 

protect public health with an adequate margin of safety. Six months prior to 

convening the 2010 review, committees responsible for synthesizing data shall be 

convened to have sufficient time to collect, analyze and synthesize needed 

information. 

Page 88 January 16, 2008 
Fine Particle Air Quality Task Force 

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Leading Recommendation 4: 

The District should work with the states of Kentucky and Indiana to pursue and 

develop strategies to reduce the PM2.5 precursor emissions from major regional 

sources within a range of 150 miles to achieve additional reduction of ambient 

PM2.5 concentrations to protect public health. 

Leading Recommendation 5: 

The District should work with public and private fleet owners operating in 

Louisville Metro through education, incentives and grants to aggressively retrofit 

or replace both onroad and nonroad diesel fleets with state-of-the-art technology 

that reduces emissions. 

Leading Recommendation 6:

The District should cooperate with local and regional planning agencies to 

quantify the difference between emissions budgets that result from business-asusual and alternative growth scenarios using comparison guidelines provided by 

EPA. 

Leading Recommendation 7:

The District should initiate a stakeholder process for local adoption of onroad 

and nonroad idling regulations, with the proposed Draft Idle Reduction 

Regulation (included as Appendix 10) used as a starting point for discussion. 

Leading Recommendation 8:

Counties and municipalities within the Louisville nonattainment area should 

enact local ordinances to prohibit open burning. To the extent it is allowed, open 

burning should be restricted on days when PM2.5 concentrations are forecasted to 

be unhealthy for sensitive populations. 

Page 89 January 16, 2008