Environmental Protection Agency

John**~:~.** 1Casich, Governor !\(aiy Lt. Governor

ScoH J.**Nzd~v·~** Director



### MAY 3 0 2012

Ms. Susan Hedman Regional Administrator U.S. EPA Region 5 77 W. Jackson Blvd. Chicago, IL 60604

Re: Redesignation Request for the 24-Hour 

### PM2.s Standard for the Cleveland· Akron-Lorain Area

Dear Administrator Hedman:

I am writing to formally request a redesignation to attainment for the Cleveland-AkronLorain area (Cuyahoga, Lake, Lorain, Medina, Portage, and Summit Counties) with respect to the 2006 24-Hour PM2.s standard. The enclosed submittal combines the redesignation request and the required maintenance plan for this area. Ohio EPA is also requesting U.S. EPA make a clean data determination to ensure the requirement to submit an attainment demonstration SIP will not be applicable in the event the redesignation request and maintenance plan is not approved prior to the attainment demonstration SIP submittal deadline of December 14, 2012.

Monitoring of existing air quality indicates that the 2006 National Ambient Air Quality Standard (NMOS) for PM 2

. 5 has been attained throughout this area based on 2008- 2010 air quality data. Emissions projections indicate that current controls, existing State rules, existing federal rules, and Ohio's PSD program will be more than sufficient to maintain the NAAQS indefinitely into the future. These programs will, therefore, constitute the attainment and maintenance plan for the Cleveland-Akron-Lorain area.

The enclosed information, compiled by the Ohio Environmental Protection Agency (Ohio EPA) in cooperation with the Ohio Department of Transportation (Ohio DOT), shows significant emission reductions in point and mobile sources since ambient exceedances have occurred. A significant portion of the improved air quality can be attributed to federal programs for the mobile source sector, the regional reductions associated with the NOx Trading Program, and the Clean Air Interstate Rule (CAIR).

Ohio EPA notified the public of the draft and the opportunity to provide comments on April 12, 2012. This notice was also published in a newspaper of general circulation in

50 West Town street, Suite 700 P.O. Box 1049 Columbus, OH 43216-1049 614 1 644 3020 6141644 3184 (fax) www.epa.ohio.govCleveland, Ohio. The public hearing for this package was held on May 21, 2012 in Twinsburg, Ohio. Testimony was provided at the hearing and written comments were received regarding the redesignation request. The comments received and Ohio EPA's
response can be found in Appendix F. If you have questions, please contact Jennifer Dines in our Division of Air Pollution Control at (614) 644-3696.

Sincerely,

# ~ Director

Cc: Bob Hodanbosi, Chief, Division of Air Pollution Control, Ohio EPA

Enclosure

# REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE CLEVELAND-AKRON-LORAIN 24-HOUR PM 2.5 

# NONATTAINMENT AREA

Cuyahoga, Lake, Lorain, Medina, Portage, and Summit, Ohio

Prepared by: Ohio Environmental Protection Agency Division of Air Pollution Control

May 2012This page left intentionally blanki 

### TABLE OF CONTENTS

Chapter One Introduction .................................................................................................................. ................. 1 Geographical description ...................................................................................................... ........ 2 Status of air quality ......................................................................................................... .............. 3

Chapter Two Requirements for redesignation ................................................................................................ .... 4

Chapter Three PM 2.5 monitoring ................................................................................................................... ......... 9 24-Hour PM 2.5 NAAQS .................................................................................................................. 9 Ambient data quality assured ...................................................................................................... 10 Three complete years of data .................................................................................................. ... 10 Commitment to continue monitoring ........................................................................................... 1 7

Chapter Four Emission inventory ............................................................................................................ .......... 18 Base year inventory ........................................................................................................... ......... 18 Emission projections .......................................................................................................... ......... 19 Demonstration of maintenance .................................................................................................. . 27 Permanent and enforceable emissions reductions ..................................................................... 40 Provisions for future updates ................................................................................................. ..... 40

Chapter Five Control measures and regulations .............................................................................................. 42 Nonattainment areas to implement RACM and RACT ................................................................ 42 Show Reasonable Further Progress (RFP) ................................................................................ 44 Emission inventories .......................................................................................................... ......... 44 Implementation of past SIP revisions .......................................................................................... 45 New source review provisions ................................................................................................. .. 47 Assurance of continued controls ............................................................................................... .. 48

Chapter Six Contingency measures .......................................................................................................... ..... 49 Commitment to revise plan ..................................................................................................... .... 49 Commitment for contingency measures ..................................................................................... 49 Potential contingency measures ................................................................................................ . 50 List of PM 2.5 , SO 2 , and NO x sources ........................................................................................... 51

Chapter Seven Public participation .......................................................................................................... ............ 52

Chapter Eight Conclusions ................................................................................................................... ............. 53ii FIGURES

Figure 1 Cleveland-Akron-Lorain 24-Hour PM 2.5 Exceedances .......................................... 8 Figure 2 Map of the Cleveland-Akron-Lorain nonattainment area and monitor locations .. 10 Figure 3 Cleveland-Akron-Lorain Area Highest 98 th Percentile Value in the Year for the County ................................................................................................................. 15 Figure 4 Ohio 24-Hour PM 2.5 Design Values 1999-2001Through 2008-2010 .................. 16 Figure 5 PM 2.5 Annual Mean National Trends......................................................... 17

TABLES

Table 1 Monitoring Data for Cleveland-Akron-Lorain area for 2008 – 2010 ..................... 12 Table 2 98 th Percentile and Design Value Before and After Imputation ........................... 14 Table 3 Cuyahoga County Emission Estimations for On-road Mobile Sources ............... 24 Table 4 Lake County Emission Estimations for On-road Mobile Sources ........................ 24 Table 5 Lorain County Emission Estimations for On-road Mobile Sources ...................... 25 Table 6 Medina County Emission Estimations for On-road Mobile Sources .................... 25 Table 7 Portage County Emission Estimations for On-road Mobile Sources ................... 25 Table 8 Summit County Emission Estimations for On-road Mobile Sources .................... 25Table 9 Emission Estimations Totals for On-road Mobile Sources for the ClevelandAkron-Lorain Area ............................................................................................... 25 Table 10 Mobile Vehicle Emission Budget ......................................................................... 26 Table 11 Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2009. ............. 29 Table 12 Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010.... ......................................................................................................... 30 Table 13 Cuyahoga County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 32 Table 14 Lake County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 32 Table 15 Lorain County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ................................ 32 Table 16 Medina County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR ................ 33 Table 17 Portage County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 33 Table 18 Summit County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 33 Table 19 Cleveland-Akron-Lorain PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 34 Table 20 Cuyahoga County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 34 Table 21 Lake County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 34 Table 22 Lorain County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 35 Table 23 Medina County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 35 Table 24 Portage County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 35iii Table 25 Summit County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 36 Table 26 Cleveland-Akron-Lorain Area NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .......... 36 Table 27 Cuyahoga County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 36 Table 28 Lake County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 37 Table 29 Lorain County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 37 Table 30 Medina County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 37 Table 31 Portage County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 38 Table 32 Summit County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 38 Table 33 Cleveland-Akron-Lorain Area SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ........... 38 Table 34 Cleveland-Akron-Lorain Area Comparison of 2008 attainment year and 2015 and 2022 projected emission estimates (tpy) ...................................................... 39 Table 35 Cleveland-Akron-Lorain Area Combined Comparison of 2005 base year and 2008 attainment year on-road, non-road and EGU reductions ............................ 40

APPENDICES

A Air Quality System (AQS) Data B Ohio 2005 SIP Base Year Inventory Discussion C Mobile Source Emissions Inventory for the Cleveland-Akron-Lorain PM 2.5 Nonattainment Area D LADCO Technical Support Document E Incomplete Monitoring Data Substitution Analysis F Public Participation Documentationiv This page left intentionally blankREDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE CLEVELAND-AKRON-LORAIN 24-HOUR PM 2.5 NONATTAINMENT AREA

Cuyahoga, Lake, Lorain, Medina, Portage, and Summit Counties, Ohio



### CHAPTER ONE

Introduction The Clean Air Act (CAA), as amended, requi res each State with areas failing to meet the 24-hour PM 2.5 1 National Ambient Air Q uality Standard (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard. The United States Environmental Protection Agency (U.S. EPA) revised the NAAQS for particulate ma tter 2006. In 2006, U.S. EPA strengthened the primary 24-hour PM 2.5 NAAQS from 65 μg/m 3 to 35 μg/m 3 , and retained the current primary annual PM 2.5 NAAQS at 15.0 μg/m 3 . The revised 24-hour PM 2.5 standard was published on October 17, 2006 (71 FR 61144) and became effective on December 18, 2006. The standar d is based on the 3-year average of the 98 th percentile of 24-hour concentrations.

On November 13, 2009, U.S. EPA promulgated (74 FR 58688) the initial PM 2.5 nonattainment areas designations for the 24-hour PM 2.5 standard across the country (effective December 14, 2009). Unlike Subpart 2 of the CAA Amendments of 1990 which defined five oz one nonattainment classifications for the areas that exceed the NAAQS based on the severity of the ozone levels, PM 2.5 nonattainment designations are simp ly labeled “nonattainment.” The CAA Amendments require states with PM 2.5 nonattainment areas to submit a plan within three years of the effective date of the designations (December 14, 2012) detailing how the PM 2.5 standard will be attained by December 14, 2014. However, areas that attain before the required date for subm itting a plan may be exempt from certain other wise applicable requirements. Section 107(d)(3)(E) of the CAA allows st ates to request nonattainment areas to be redesignated to attainment provided cert ain criteria are met. The following are the criteria that must be met in or der for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has attained the PM 2.5 standard.

1 Particle pollution is a mixture of microscopic solid s and liquid droplets suspended in air. This pollution, also known as particulate matter, is made up of a number of components, including acids (such as nitrates and sulfates), organic chem icals, metals, soil or dust particles, and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is 2.5 micrometers in diameter and smaller - 1/30th the diameter of a human hair. Fine particle pollution c an be emitted directly or formed secondarily in the atmosphere.2 ii) An approved State Im plementation Plan (SIP) for the area under Section 110(k). iii) A determination that the improvem ent in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Sect ion 110 and Part D requirements have been met.

This document addresses each of these requirements, and provides additional information to support continued compliance with the 24-hour PM 2.5 standard.

The Cleveland-Akron-Lorain area has prev iously been subject to nonattainment area rulemakings for the 1997 fine particle NAAQS. Ohio was only subject to requirements to address the annual standard under the 1997 fine particle NAAQS as there were no monitors in Ohio that violated the 1997 24-hour PM 2.5 standard of 65 μ g/m3. On October 5, 2011, Ohio EPA submitted a redesignation request and maintenance plan for t he Cleveland-Akron-Lorain 1997 annual standard nonattainment area.

Geographical Description and Background The current Cleveland-Akron-Lorain nonattainment area is located in northeastern Ohio and includes the follo wing counties: Cuy ahoga, Lake, Lorain, Medina, Portage, and Summit. This area is shown in Figur e 2 under Chapter Three.

As a result of the 2009 PM 2.5 designations, U.S. EPA designated the ClevelandAkron-Lorain area nonatta inment for the 35 μ g/m 3 24-hour standard, and Ohio EPA is required to develop a plan to reduce oxides of nitrogen (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and to demons trate that the area will meet the federal 24-hour air quality st andard by December 14, 2014. Ohio’s main PM 2.5 components are primary particles (o rganic carbon, crustal material, and elemental carbon), SO 2 and NO x , which were included in the attainment demonstration analysis for the 1997 annual PM 2.5 NAAQS submitted to U.S. EPA on July 16, 2008. Volatile organic com pounds (VOCs) and ammonia (NH3) were not included in the analysis since they we re not part of Ohio’s attainment strategy for PM 2.5 (although controls for VOCs have been implemented for ozone nonattainment). This is consistent with U.S. EPA’s “Clean Air Particle Implementation Rule” [74 FR 20856] (hereafter referred to as “1997 Implementation Rule”). In the 1997 Impl ementation Rule U. S. EPA presumes NH3 emissions are not a PM 2.5 attainment plan precurso r and that States are not required to address VOC unless the St ate or U.S. EPA makes a technical demonstration that emissions of VOCs si gnificantly contribute to nonattainment of the PM 2.5 standard. This is also consist ent with U.S. EPA’s “Implementation Guidance for the 2006 24-Hour Fine Particle (PM 2.5 ) National Ambient Air Quality Standards (NAAQS)” memorandum issued on March 2, 2012 (hereafter referred3 to as “2006 Implementation Memo”). In this memorandum, U.S. EPA recommends that “the projected attainment inventory for the nonattainment area includes direct PM 2.5 , SO 2 , presumptively NO x , as well as other precursors that have been determined to be significant through the area’s SIP development process.” Furthermore, the 2006 Implement ation Memo indicates that U.S. EPA believes the overall framework and po licy approach of the 1997 Implementation Rule “continues to provide effect ive and appropriate guidance on the EPA’s interpretation of the general statutory requi rements that states should address in their SIPs” and that they are “relevant to the statutory require ments” for the 2006 24-hour PM 2.5 standard.

This document is intended to support Oh io’s request that the Cleveland-AkronLorain area be redesignated from nonattainm ent to attainment for the 24-hour PM 2.5 standard.

Status of Air Quality PM 2.5 complete quality-assured ambient ai r quality monitoring data for the three (3) years, 2008 through 2010, demonstrate that the air quality has met the NAAQS for 24-hour PM 2.5 in this nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter Four, supports a redesignation to attainment for the Cleveland-Akron-Lorain area based on the requirements in Section 107( d)(3)(E) of the CAA as amended.4 

### CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Directors. The redesignation request and maintenance pl an are based on the redesignation guidance, supplemented with additional guidanc e received from staff of U.S. EPA Region 5.

Below is a summary of each redesignat ion criterion as it applies to the Cleveland-Akron-Lorain area.

i.) Attainment of the standard (CAA Section 107(d)(3)(E)(i)) There are two components involved in making this demonstration. The first component relies on ambi ent air quality dat a. The data that are used to demonstrate atta inment should be the product of ambient monitoring that is repr esentative of t he area of highest concentration. The data should be collected and quality-assured in accordance with 40 CFR 58 and recorded in the Air Quality System (AQS) in order for it to be avail able to the public for review.

The second component relie s upon supplemental U.S. EPAapproved air quality modeling. While no modeling is required for redesignating nonattainment areas , the redesignation guidance states it is “generally necessary” for particulate matter redesignations. Appendix C and A ppendix D contains the most recent modeling results sho wing future attainment and maintenance are provided. C hapter Three discusses this requirement in more detail and provides the attainment demonstration.

ii.) Permanent and enforceable improvem ent in air quality (CAA Section 107(d)(3)(E)(iii)) The state must be able to reasonabl y attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should estimate the percent reduction achieved from federal m easures as well as control measures that have been adopted and implement ed by the state.

It was not necessary for Ohio to adopt or implement control measures for these counties beyond the federal measures.

Ohio EPA has adopted several rule s recently that will have an impact on statewide PM 2.5 emissions in the future:5 • Clean Air Interstate Rule (CAIR)

• NO x SIP Call Rules

Ohio was subject to a Feder al Implementation Plan under the CAIR replacement rule, the Cr oss-State Air Pollution Rule (CSAPR), that could hav e resulted in even greater reductions than the CAIR program. However, on December 30, 2011, the D.C. Circuit Court stayed CSAPR and ordered U.S. EPA to continue administering CAIR pending the cour t’s resolution. In addition, since the initial designations were made federally enforceable consent decrees have resulted in reductions in emissions from utilities across the state.

Chapters Four and Five discuss this requirement in more detail.

iii.) Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v)) For purposes of redesignation, a st ate must meet all requirements of Section 110 and Part D that were applicable prior to submittal of the complete redesignation request.

Subpart 1 of Part D consists of general requirements applicable to all areas which are designated nonat tainment based on a violation of the NAAQS. Subpart 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 ). However, for the purpos e of implementing the PM 2.5 standard, U.S. EPA’s 1997 Impl ementation Rule stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 .[72 FR 20589]

i.) Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Secti on 110(a)(2) provides that the implementation plan submitt ed by a state must have been adopted by the state after reasonable public notice and hearing, and that, among other things, it must include enforceable emission limitat ions and other control measures, means or techniques necessary to meet the requirements of the CAA; pr ovide for establishment and operation of appropriate dev ices, methods, systems and procedures necessary to m onitor ambient air quality; provide for implementation of a source permit program to regulate the modification and cons truction of any stationary source within the areas cove red by the plan; include provisions for the implementati on of Part C, prevention of significant deterioration (PSD) and Part D, NSR permit programs; include criteria fo r stationary source emission6 control measures, monito ring, and reporting; include provisions for air quality m odeling; and provide for public and local agency participation in planning and emission control rule development. In Ohio’s December 5, 2007 and September 4, 2009 infrastructure SIP submissions, Ohio verified that the State fulfills the requirements of Section 110(a)(2) of the Act.

Section 110(a)(2)(D) also requi res State plans to prohibit emissions from within t he State which contribute significantly to nonattainment or maintenance areas in any other State, or which interf ere with programs under Part C to prevent significant deterio ration of air quality or to achieve reasonable progress towa rd the national visibility goal for Federal class I areas (national parks and wilderness areas). In order to assist States in addressing their obligations regarding r egionally transported pollution, U.S. EPA finalized CAIR to reduce SO 2 and NO x emissions from large electric generating units (EGU). Ohio has met the requirements of the f ederal CAIR to reduce NO x and SO 2 emissions contributing to downwind states. On February 1, 2008, U.S. EPA approved Ohio’s CAIR program, which can be found in Ohio Administrative Code (OAC) Chapter 3745-109 2 . On July 6, 2011, U.S. EPA finalized a replacement to t he CAIR program, the CSAPR. CSAPR could further assist States in addressing their obligations regarding regiona lly transported pollution by providing reductions in NO x and SO 2 emissions in 2012 and 2014. However, on December 30, 2011, the D.C. Circuit Court stayed CSAPR and order ed U.S. EPA to continue administering CAIR pending the court’s resolution.

ii.) Section 172(c) requirements This Section contains general requirements for nonattainment plans. The requirements for reasonable further progress, identificat ion of certain emissions increases, and other measur es needed for attainment will not apply for redesignations because they only have meaning for areas not atta ining the standard. The requirements for an emission in ventory will be satisfied by the inventory requirements of the maintenance plan. Chapters Four and Five discuss this requirement in more detail.

2 http://www. epa.ohio.gov/dapc/regs /regs.aspx#3745-1097 iii.) Conformity The state must work with U.S. EPA to show that its SIP provisions are consistent with the Section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedures in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state must commit to follow U.S. EPA’s conformity regulation upon issuance, as applicable.

iv.) Maintenance plans (CAA Section 107(d)(3)(E)(iv)) Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a ma intenance plan that meets the requirements of Section 175( A). The maintenance plan will constitute a SIP revision and must provide for maintenance of the relevant NAAQS in the area for at least 10 years after redesignation. Section 175 (A) furt her states that the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures as the Administrator d eems necessary to ensure prompt correction of any violation of t he NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all meas ures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a.) attainment inventory; b.) maintenance demonstration; c.) monitoring network; d.) verification of continued attainment; and e.) contingency plan.

U.S. EPA’s 2006 Implementation Memo states:

As mentioned earlier in this memorandum, statewide annual emission inventories are requir ed under 40 CFR Part 51, Subpart A. We expect that for many nonattainment areas, these annual inventories will serve as an appropr iate starting point for the emission inventories used for SIP development. In contrast with the 1997 annual PM 2.5 NAAQS, where states rely only on annual inventories in the implementati on process, the 2006 24-hour PM 2.5 NAAQS is designed to protect against peak exposures. Thus, for8 the 2006 24-hour PM 2.5 NAAQS, there are some circumstances in which EPA believes that seasonal inventories may be useful for SIP planning purposes. For example, we have observed that in some nonattainment areas, all of the highest fine particle concentrations over the course of a year occur in one season.

If exceedances occur during only one season for each of the years on which the nonattainment designat ion is based, and this is the case for all subsequent years, we recommend that states develop a seasonal inventory and that they use this inventory for SIP planning purposes....

Ohio EPA analyzed the PM 2.5 monitoring data for the Cleveland-AkronLorain area to determine whether t he exceedances occurred in only one season. As can be seen in Figur e 1 below, exceedances between 2006 and 2008, the years on which the nona ttainment designation is based, occurred in the first, second, th ird and fourth quarters. During subsequent years, 2009 through 2010, ex ceedances have occurred in the first and third quarters. Based on th is analysis and in consultation with U.S. EPA, it was determined that an annual inventory would be sufficient for SIP planning, and that a seasonal inventory would not be required.

Figure 1 – Cleveland-Ak ron-Lorain 24-hour PM 2.5 Exceedances

Chapter Six discusses this requirement in more detail.9 

### CHAPTER THREE

PM 2.5 MONITORING CAA Section 107(d)(3)(E)(i)

Requirement 1 of 4 A demonstration that t he NAAQS for 24-hour PM 2.5 , as published in 40 CFR 50.7, has been attained.

Background There are 13 monitors measuring PM 2.5 concentrations in this nonattainment area. These moni tors are operated by Ohio EPA Division of Air Pollution Contro l, Northeast District Office, the Cleveland Department of Public Health, the Lake County General Health District, and the Akron Regional Air Quality Management District. A listing of the design values based on the three-year average of the annual mean conc entrations from 2008 through 2010 and a listing of the design va lues based on the three-year average of the 98 th percentile are is show n in Table 1. The locations of the monitoring site s for this nonattainment area are shown on Figure 2.10 Demonstration

Figure 2 - Map of the Cleveland-Ak ron-Lorain nonattainment area and monitor locations

Requirement 2 of 4 Ambient monitoring data quality assur ed in accordance with 40 CFR 58.10, recorded in the U.S. EPA air quality syst em (AQS) database, and available for public view.

Demonstration Ohio EPA has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and all ot her federal requirements. Ohio EPA has recorded the data in the AQ S database and, therefore, the data are available to the public.

Requirement 3 of 4 A showing that the thr ee-year average of the 98 th percentile of 24-hour concentrations, based on data from all monito ring sites in the area or its affected downwind environs, are below 35 μ g/m 3 . (This showing must rely on three complete, consecutive calendar years of quality assured data.)11 Background

The following information is taken from U.S. EPA's "Guidelineon Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999.

In accordance with the CAA Amendm ents, three comp lete years of monitoring data are required to demonstrate attainment at a monitoring site. The 24-hour PM 2.5 primary and sec ondary ambient air quality standards are met at an ambient air quality monitoring site when the three-year aver age of the 24-hour 98th percentile values are less than or equal to 35 μ g/m 3 . While calculating design values, one decimal place must be carried in the computations, with final values rounded to the nearest 1 μ g/m 3 . Decimals 0.5 or greater are rounded up, and t hose less than 0.5 are rounded down, so that 35.349 μ g/m 3 is the largest concent ration that is less than, or equal to 35 μ g/m 3 . Values at or below 35 μ g/m 3 meet the standard; values greater than 35 μ g/m 3 exceed the standard. An area is in complianc e with the 24-hour PM 2.5 NAAQS only if every monitoring site in the area meets the NAAQS. An individual site's 3-year average of t he 24-hour 98th percentile concentrations is also called the site's design val ue. The air quality design value for the area is the highest design value among all sites in the area.

Table 1 shows the monitoring data for 2008 – 2010 that were retrieved from the U.S. EPA AQS.12 Demonstration

Table 1 - Monitoring Data for th e Cleveland-Akron-Lorain area for 2008 – 2010

Annual Standard 24-Hour Standard

Year Average 2008-2010 Year Average 2008-2010 Site County 2008 2009 2010 2008 2009 2010

39-035- 0027 (a)

Cuyahoga 13.2 10.6 37.7 23.0

39-035- 0034 10.9 10.2 10.9 10.7 31.5 24.7 26.8 28

39-035- 0038 14.1 12.8 14.0 13.6 39.4 29.9 30.5 33

39-035- 0045 13.7 11.8 13.3 12.9 35.3 23.5 32.7 31

39-035- 0060 (b) 14.1 12.3 13.7 13.4 36.9 28.9 30.9 32

39-035- 0065 14.6 12.4 13.2 13.4 33.8 28.9 27.3 30

39-035- 1002 ( c) 12.0 10.9 11.3 11.4 30.1 20.5 26.5 26

39-085- 0007 (d) Lake 10.4 10.4 10.8 19.8 26.9 25 39-085- 3002 (e) 11.5 27.5

39-093- 3002 Lorain 11.4 9.9 10.4 10.6 32.1 21.5 24.4 26

39-103- 0003 Medina 11.8 10.8 10.8 11.1 30.3 25.7 28.8 28

39-133- 0002 Portage 12.1 11.1 11.2 11.5 29.4 23.8 31.9 28

39-153- 0017 Summit 13.8 12.6 13.4 13.3 37.6 25.2 31.9 33

39-153- 0023 12.9 11.4 12.5 12.3 32.7 24.8 30.2 29

Less than 75% capture in at least one quarter

(a) This site was shut down in 7/2009 due to the demo lition of the building that hosted the monitor. USEPA approved the shut down without relocation. (b)Although this is one of the highest readi ng monitor sites in the area, data from previous years show a decreasing trend in monitor readings. Ohio believes that had the missing data been collected it would not have resulted in a design value that exceeds the standard. (c ) Historically this monitor has been one of the, if not the, lowest reading monitor in Cuyahoga County. This monitor is located in a suburban-residential setting, approximately 2 miles away from the Cleveland Hopkins airport but more than 0.8 mile s away from Cleveland's heaviest industrial area. Ohio believes that had the missing data been collected this monitor would not have resulted in a design value that would exceed the standard. (d) and (e) Site(e) was relocated to site[d]. USEPA eval uate the candidate site [d] and approved the replacement request, authorizing with this replacemen t, the combination of ozone and fine particulate data from both sites for the purpose of calculating design val ues for NAAQS determinations. The three-year average (2008-2010) from combining the data from both sites is 25 ug/m3 of PM2.5.

Source: U.S. EPA Air Quality System (AQS); http:// www. epa.gov/ttn/airs/airsaqs/index.htm

The design values calculated fo r the Cleveland-Akron-Lorain area demonstrate that the 24-hour PM 2.5 NAAQS has been attained. However, three monitor sites in Cuyahoga C ounty, site 39-035-0060, site 39-035- 0065, and site 39-035-1002, did not co mply with the 75% data capture13 requirement for the 2008-2010 period. S pecifically, site 39-035-0060 has only 48% and 63% capture in the second and third quarter of 2009, respectively. Site 39-035-0065 has only 74% capture in the third quarter of 2010, and site 39-035-1002 has only 71% capture in the first quarter of 2008 and 73% capture in the third quarter of 2009. These monitoring sites experienced instrument malfunctions during the low percentage capture periods.

Under 40 CFR Part 50, Appendix N, t he use of less than complete data may be approved by U.S. EPA consider ing such factors as monitoring site closures/moves, monitoring d iligence, and nearby concentrations in determining whether to use such data. However, in order to further demonstrate that this monitor has attained the standard, Ohio EPA prepared a statistical analysis of t he 24-hour standard using multiple imputations. Ohio EPA has imputed mi ssing values for these sites and then performed an ordinary analysis as if the imputed values were real measurements. Multiple imputations use r andom draws from the conditional distribution of the target variable given the other variables. When a regression model is used for imputation, the process involves adding a random residual to the “best guess” for missing values, to yield the same conditional variance as the original variable. Appendix E describes, and includes, the full stat istical analyses performed to show that the three-year aver age (2008 to 2010) of the 98 th percentile 24-hour values, based on missing data imput ations, are 32, 31, and 27 μ g/m 3

, which are below the 35 μ g/m 3 24-hour standard.

Table 2 shows sites 39-035-0060, 39-035-0065, and 39-035-1002 before and after the imputation of missing dat a. Also the “new” sites (with imputed values) shows a passing 24- hour design value for 2008 to 2010 of 32 μ g/m 3

.14 Table 2: 98 th Percentile and Design Value Before and After Imputation

39

‐ 035

‐ 0060 2003 2004 2005 2006 2007 2008 2009 2010 2003

‐ 2005 2004

‐ 2006 2005

‐ 2007 2006

‐ 2008 2007

‐ 2009 2008

‐ 2010

Old Creditable 112 120 116 114 108 106 91 114
Old 98th 45.5 42.2 49.5 31 38.7 36.9 28.9 30.9

New Creditable 112 120 116 114 108 106 123 114

New 98th 45.5 42.2 49.5 31 38.7 36.9 27.0 30.9

39

‐ 035

‐ 0065

Old Creditable 111 117 62 58 106 118 118 110
Old 98th 39.1 36.1 47.9 27.8 37.5 33.8 28.9 27.3

New Creditable 111 117 62 58 106 118 118 129

New 98th 39.1 36.1 47.9 27.8 37.5 33.8 28.9 29.9

39

‐ 035

‐ 1002

Old Creditable 113 116 62 54 100 109 107 108
Old 98th 31.9 30.5 41.6 27.7 35.2 30.1 20.5 26.5

New Creditable 113 116 62 60 100 121 120 108

New 98th 31.9 30.5 41.6 27.7 35.2 30.1 23.7 26.5

less than 75% capture in at least one quarter

Year includes one or more quarters with imputed values 32 YEAR 24

‐ Hour Design Value

46 41 40 36 35 32

46 41 40 36 34

31 41 37 38 33 33 30

41 37 38 33 33

27 35 33 35 31 29 26

35 33 35 31 30

With the data imputation analysis and re sults, Requirement 3 of 4 has been met.

The area’s design values have trended downward as emissions have declined due to cleaner automobiles and fuels, and controls for EGUs.

National monitoring for PM 2.5 began in 1999. With re spect the ClevelandAkron-Lorain area, there has been a clear downward trend in design values:15 Figure 3 - Cleveland-Akr on-Lorain Area Highest 98 th Percentile Value in the Year for the County

10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.0 50.0 55.0

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 

## Cleveland

‐ Akron

‐ Lorain Highest 98th
Percentile Value in the Year for the County

Summit

Portage

Cuyahoga

Lorain

Lake

The same trend can be seen within Ohio a whole:

Figure 4 - Ohio 24-Hour PM 2.5 : Design Values 1999-2001 Through 2008-201016 Source: WVDEP: http://www.epa.gov/airtrends/values.html , from Excel spreadsheet: PM25dv20082010Final.xls

Design values have also trended downward nationally:

Figure 5 - PM 2.5 Annual Mean National Trends17 Source: http://www. epa.gov/airtrends/pm.html

Requirement 4 of 4 A commitment that once redesignated, the state will cont inue to operate an appropriate monitoring network to verify the maintenance of the attainment
status.

Demonstration Ohio EPA commits to continue monitoring PM 2.5 levels at the Ohio sites indicated in Figure 2 and T able 1. Ohio EPA will consult with U.S. EPA Region 5 prior to ma king changes to the existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. Connection to a c entral station and updates to the Ohio EPA web site 3 will provide real time availability of the data and knowledge of any exceedances . Ohio EPA will enter all data into AQS on a timely basis in a ccordance with federal guidelines.

3 www. epa.ohio.gov/dapc18 

### CHAPTER FOUR

EMISSION INVENTORY CAA Section 107(d)(3)(E)(iii)

U.S. EPA’s redesignation guidance requires the submittal of a comprehensive inventory of PM 2.5 precursor emissions (primary par ticles (organic carbon, crustal matter, and elemental carbon), SO 2 and NO x 4 ) representative of the year when the area achieves attain ment of the 24-hour PM 2.5 air quality standard. Ohio also must demonstrate that the improvement in air qualit y between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable em ission reductions. Other emission inventory related requirements include a projection of the emission invent ory to a year at least 10 years following redesignation; a demonstration that t he projected level of emissions is sufficient to maintain the 24-hour PM 2.5 standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the 10-year maintenance period.

The emissions inventory development and emissions projection discussion below, with the exception of the mob ile (on-road) emi ssions inventory and projections, identifies procedures us ed by Ohio EPA and the LADCO regarding emissions of all the countie s in the Cleveland-Akron-Lor ain area. All of these inventories and emissions projecti ons were prepared using similar methodologies. Mobile emissions invent ories and projections for all counties were prepared by the Northeast Ohio Areawide Coordinating Agency (NOACA) and the Ohio Department of Transportation (ODOT).

Requirement 1 of 5 A comprehensive emission inventory of PM 2.5 , SO 2 and NO x completed for the base year.

Background The point source data are tak en from Ohio's annual emissions reporting program. The 2005 periodi c inventory has been identified as one of the preferred databas es for SIP development and coincides with nonattainment air quality in the Cleveland-AkronLorain area.

Periodic inventories, which incl ude emissions from all sectors - mobile, area, non-road, and point sources - are prepared every three years.

4 VOC and NH 3 are not addressed.19 Demonstration The 2005 inventory is used as t he base year for the purpose of this submittal and was submitt ed to U.S. EPA with Ohio’s PM 2.5 attainment demonstration SIP submitted on July 18, 2008 and revised on June 7, 2010. The det ailed emission inventory information for the Cleveland-Akr on-Lorain area is provided in Appendix B. Emissions of PM 2.5, SO 2 and NO x for 2005 are identified under Requirement Three of this Chapter.

Requirement 2 of 5 A projection of the emission inventory to a year at least 10 years following redesignation.

Background Ohio EPA prepared a comprehensive in ventory for the Cleveland-AkronLorain area including area, mob ile, and point sources for PM 2.5 , SO 2 and NO x for base year 2005. The 2005 invent ory was submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM 2.5 attainment demonstration SIP for this area. The information below describes the procedures Ohio EPA used to generate the 2005 base year in ventory and to develop SIP-ready modeling inventories and future y ear projections (Pechan Report 5 ) based on a 2005 base year inventory. T he report by Pechan generated future year estimates of annual emissions for each source sector using accepted growth surrogates. These in ventories were provided to the LADCO and have been processed to develop average daily emissions for use in the air quality analyses. T hese processed modeling inventories have been identified as the correct iterat ion of the inventor y for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organization. Note thatthe on-road mobile source sector was addr essed by specific PM 2.5 and NO x modeling as discussed below.

• Area sources were taken from the Ohio 2005 periodic inventory submitted to U.S. EPA. These projections were made from the U.S. Departm ent of Commerce Bureau of Economic Analysis (BEA) grow th factors, with some updated local information.

• Mobile source emissions were calculated from MOVES2010 produced emission factors. Only PM 2.5 and NO x necessitate emissions inventory analysis. As documented in Ohio EPA’s atta inment demonstration SIP, Ohio EPA in consultation with U.S. EPA determined mobile

5 http://www.ladco.org/tech/emis/r5/r eports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con trols%20Report_Final.pdf20 sources are insignificant contributors for SO 2 . Consistent with Ohio EPA’s attainment demonstration, Ohio EPA continues to consider mobile source SO 2 to be an insignificant contributor to fine particles for this nonattainment area. Based on the demonstration below, SO 2 constitutes less than one percent (<1.21%) of the area’s total SO 2 emissions in 2005, 2008, 2015 and 2022 (ranging between 0.21% and 1.21%).

• Point source information wa s compiled from Ohio EPA’s 2005 annual emissions inv entory database and the 2005 U.S. EPA Air Markets acid rain database 6

.

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generated using U.S. EPA’s National Mobile Inventory M odel (NMIM) 2002 application. To address concerns about the accuracy of some of the categories in U.S. EPA’s non-road emissions model, LADCO contracted with two (2) companies to review the base data and make recommendations. One of the contractors also estimated emi ssions for three (3) non-road categories not included in U.S. EPA’s non-road model. Emissions were estimated fo r aircraft, commercial marine vessels, and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment ca tegory were reviewed and updated based upon surveys completed in the Midwest, and the temporal allocation fo r agricultural sources also was updated.

Demonstration

On-Road Emission Estimations The on-road emission estimations for this nonattainment area where performed by the Ohio Department of Transportation (ODOT) for the Akron Metropo litan Area Transportation Study (AMATS) area, and by the Northeas t Ohio Areawide Coordinating Agency (NOACA) for the counties of Cuyahoga, Lake, Lorain and Medina in its area.

The inventories include count y based, annual totals of PM 2.5 and Oxides of Nitrogen (NO X ) for the base year 2005, the attainment year 2008, the interim year 2015, and the maintenance period horizon year 2022.

6 http://www. epa.gov/airmarkets/acidrain21 Overview U.S.EPA published a Federal Register notice 7 of availability on March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions Simulator), hereafter referred to as MOVES. Upon publication of the Federal Register notic e, MOVES became U.S. EPA’s approved motor vehicle emission factor model for estimating VOCs, NO x , CO, PM 10 and PM 2.5 and other pollutants and precursors from cars, trucks, mo torcycles, and buses by state and local agencies. MOVES is a com puter program designed by the U.S. EPA to estimate air pollution emissions from mobile sources. MOVES replaces U.S. EPA’s prev ious emissions model for onroad mobile sources, MOBI LE6.2. MOVES can be used to estimate exhaust and evaporative em issions as well as brake and tire wear emissions from all types of on-road vehicles.

The CAA requires U.S. EPA to regul arly update its mobile source emission models. U.S. EPA c ontinuously collects data and measures vehicle emissions to ma ke sure the Agency has the best possible understanding of mobile source emissions. This assessment, in turn, informs the development of U.S. EPA’s mobile source emission models. MOVES represents the Agency’s most up-to-date assessment of on -road mobile source emissions. MOVES also incorporates seve ral changes to the U.S. EPA’s approach to mobile source emission modeling based upon recommendations made to the A gency by the National Academy of Sciences.

U.S.EPA believes that MOVES shoul d be used in ozone, CO, PM, and nitrogen dioxide SIP developm ent as expeditiously as possible. The CAA requires that SIP inventories and control measures be based on the most current information and applicable models that are available when a SIP is developed. Regarding transportation conformity, U.S. EPA and U.S. DOT intend to establish a two-year grace per iod before MOVES is required for new transportation conformity analyses.

The MOVES more detailed approac h (when compared with the previous MOBILE model) to mode ling allows U.S. EPA to easily incorporate large amounts of in-u se data from a wide variety of sources, such as data from vehicle inspection and maintenance (I/M) programs, remote sensing dev ice (RSD) testing, certification testing, portable emission meas urement systems (PEMS), etc. This approach also allows users to incorporate a variety of activity data to better estimate emissi on differences such as those

7 http://www.r egulations.gov/search/Regs/hom e.html#document Detail?R=0900006480ab1f9822 resulting from changes to vehicl e speed and acceleration patterns. MOVES has a graphical user interfac e which allows users to more easily set up and run the m odel. MOVES database-centered design provides users much gr eater flexibility regarding output choices. Unlike earlier models whic h provided emission factors in grams-per-mile in fixed output formats, MOVES output can be expressed as total mass (in tons, pounds, kilograms, or grams) or as emission factors (grams-per-m ile and in some cases grams-pervehicle). Output can be easily aggregated or disaggregated to examine emissions in a range of scales, from national emissions impacts down to the emissions impac ts of individual transportation projects. The database-centered des ign also allows U.S. EPA to update emissions data incorporat ed in MOVES more easily and will allow users to incorporate a much wider array of activity data to improve estimation of local emissions. For example, the improvements in MOVES will allow pr oject-level PM2.5 emissions to be estimated.

The annual PM 2.5 inventory runs meet the latest planning assumption requirement. The travel forecast modeling processes used to develop vehicles miles of travel (VMT) for the Akron Metropolitan Area Transportati on Study (AMATS) and the Northeast Ohio Areawide Coordinating Agency (NOACA) areas is calibrated using the latest popul ation and land use data available and are validated using corresponding traffic count data. Currently, the travel demand models are va lidated to year 2005. U.S.EPA’s emissions model MOVES is used fo r all mobile source emission analyses with inputs and output needs being established at various interagency consultation meetings . It was also established that annual emission estimates woul d be based on a single-season approach. Since travel dem and models produce average daily conditions, the daily emissions es timates are multiplied by 365 days to produce annual emissions esti mates expressed in tons per
year.

Finally, the regional emissions analysis includes emissions for Direct PM 2.5 (exhaust, brake, and tire wear), and Oxides of Nitrogen (NO X ).Sulfur Dioxide (SO 2 ), Volatile Organic Compounds (VOCs) and Ammonia (NH 3 ) are considered insignificant at this time. (Appendix C)

NOACA maintains a PC-based regional travel demand forecasting model on the Citilabs CUBE pla tform for use in its urban transportation planning process. This model employs the traditional four step modeling proce ss to project existing and future traffic volumes and travel patterns on the regional transportation23 networks. The four step process consists of trip generation, trip distribution, mode split, and rout e assignment. Output from the model is link-by-link directional vo lumes for four time periods: AM peak, Midday, PM peak, and Night and is added together to create 24-hour traffic volumes for the existing or future regional transportation networks. The ODOT holds the transportation model for the AMATS area. AMATS pr epares and submits networks for its planning area to ODOT. ODOT's modeling is also run on a PCbased CUBE platform.

Socio-economic variables were developed for all areas based on 2000 Census data and 2030 county-le vel Ohio Department of Development population projections . Minor adjustments to 2005 data have been made in an effort to have this data correspond to 2005 estimates released by the US Census Bureau.

Using MOVES, emission factor file s were generated for base year2005, attainment year-2008, in terim year 2015, and maintenance year 2022. Assumptions for thes e runs include an I/M program in all counties. Programs and corresponding MOVES parameters were developed in consultation with Ohio EPA. I/M program information was supplied by Ohio EPA. The I/M program was applied to all analysis years for every geography.

Total emissions were computed wit h the aid of several custom programs by ODOT. The proc ess uses data on daily and directional traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM).

The first step in the process in volves running ODOT postcms.exe to calculate hourly link volume s based on the percentage of the daily volume (travel demand model output) determined by a link’s facility and area type. Link speeds from the travel demand model are not used in the analysis. T he speeds are estimated as a postprocess to the model based on HCM methods using a link’s volume-to-capacity ratio and link group code.

The second step (mmoves.exe) uses a combination of the MOVES emission factors and the hourly link volumes that are output of the postcms.exe program. The hourly volumes are multiplied by the MOVES emission factor for the corresponding hour of day, speed bin, and road type to calculate emi ssions for every network link for each hour. The final link on road v ehicle emissions for the area is the sum of all individual link-hour emissions.24 The third step, (mvehicle.exe), ca lculates vehicl e-based emissions for each source type for each hour of the day. The vehicle source type is based on a combination of local and default data. The final vehicle emissions for each county are the sum of all individual hourly emissions for all vehicle types.

Intrazonal trips do not get loaded ont o the network, so the fourth step in the process requires a separate method to account for those trips that use local roads to travel within a zone. The mintra.exe program uses intrazonal trips to estimate VMT using the area in square miles and intraz onal trips of each zone. The zone is assumed circular and the radius of the circle is used as the average trip length for these intraz onal trips. Intrazonal emissions are then calculated by combin ing MOVES generated emissions with estimated intrazonal VMT. The emission rates are the same as those used to calculated link based emissions.

The final step is to summarize link, vehicle, and intrazonal emissions for each county, pollutant, and analyzed year, and to multiply annual average daily em issions by 365 to produce an annual estimate.

On-Road Mobile Emission Estimations Tables 2 through 8 contain the resu lts of the emissions analysis for the appropriate years. All emissions estimations are expressed in tons per year (tpy).

Table 3 – Cuyahoga County, Emi ssions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 1,249.47 1,040.28 430.01 320.94

NO x (tpy) 36,545.59 28,227.20 12,371.38 6,065.83

SO 2 (tpy) 846.76 253.16 76.36 68.07

Annual VMT 10,619,449,065 10,658,861,035 10,602,063,020 10,701,988,340

Table 4 – Lake County, Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 283.09 241.78 122.02 69.42

NO x (tpy) 8,071.90 6,425.00 2,840.39 1,417.15

SO 2 (tpy) 176.99 51.94 15.91 14.45

Annual VMT 2,113,418,985 2,155,625,760 2,180,087,695 2,251,831,00025 Table 5 – Lorain County, Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 319.85 274.43 143.34 81.69

NO x (tpy) 9,196.87 7,354.77 3,456.51 1,723.02

SO 2 (tpy) 200.28 60.17 18.51 16.83

Annual VMT 2,473,782,025 2,525,280,240 2,555,465,010 2,638,018,155

Table 6 – Medina County, Emi ssions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 358.80 317.43 152.50 78.48

NO x (tpy) 9,328.78 7,603.83 3,306.35 1,677.58

SO 2 (tpy) 208.74 57.65 17.63 16.83

Annual VMT 2,112,372,530 2,241,630,710 2,322,864,380 2,505,814,790

Table 7 – Portage County, Emi ssions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 187.71 160.90 87.54 49.45

NO x (tpy) 5,707.22 4,630.98 2,264.50 1,014.35

SO 2 (tpy) 96.74 30.52 13.23 7.40

Annual VMT 1,761,085,222 1,811,101,624 1,935,234,601 2,036,373,863

Table 8 – Summit County, Emissi ons Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 611.78 511.43 251.70 162.98

NO x (tpy) 17,377.28 13,609.82 6,170.32 3,059.45

SO 2 (tpy) 319.72 100.66 42.76 39.57

Annual VMT 5,505,977,908 5,635,781,676 5,992,078,124 6,246,851,092

Table 9 – Emissions Estimations Totals for On-Road Mobile Sources for the Cleveland-Akron-Lorain Area

2005 2008 2015 2022

PM 2.5 (tpy) 3,010.70 2,546.25 1,187.11 762.96

NO x (tpy) 86,227.64 67,851.60 30,409.45 14,957.38

SO 2 (tpy) 1,849.23 554.10 184.40 163.15

Annual VMT 24,586,085,735 25,028,281,045 25,587,792,830 26,380,877,24
026 Motor Vehicle Emission Budget

Table 10 contains the motor v ehicle emissions budgets for the Cleveland-Akron-Lorain area.

Table 10 - Mobile Vehicle Emissions Budget

2015 Estimated Emissions 2015 Mobile Safety Margin

Allocation* 2015 Total Mobile Budget 2022 Estimated Emissions 2022 Mobile Safety Margin

Allocation* 2022 Total Mobile Budget
PM2.5 (tpy) 1,187.11 184.24 1,371.35 762.96 117.93 880.89

NOx (tpy) 30,409.45 4,685.25 35,094.70 14,957.38 2,306.27 17,263.65
*The margin of safety was selected at approximat ely 15.4 to 15.5% so t hat the total 2015 and 2022 budgets would remain consistent with the budgets established under Ohio’s October 5, 2011 submittal for redesignation of this area under the 1997 annual PM 2.5 standard.

The above budgets for the Clevel and-Akron-Lorain area, agreed upon as part of the interagency c onsultation process, include the emission estimates calculated for 2015 and 2022 (from Table 2 and Table 8) with an additional 15.4 to 15.5 percent margin of safety allocated for PM 2.5 and NO x in 2015 and 2022.

In an effort to accommodate futu re variations in travel demand models and VMT forecast when no change to the network is planned, Ohio EPA consulted wit h U.S. EPA to determine a reasonable approach to address this variation. Based on this discussion, a 15.4 to 15.5 percent ma rgin of safety allocation was agreed upon and has been added to the emissions estimates for this nonattainment area.

All methodologies, the latest planni ng assumptions, and the safety margins allocations were determined through the interagency consultation process described in the Transportation Conformity Memorandum of Understanding (MO U) among NOACA, AMATS, Ohio DOT, and Ohio EPA.

A 15.4 to 15.5 percent margin of safety is appropriate because: 1) there is an acknowledged potential va riation in VMT forecast and potential estimated mobile sour ce emissions due to expected modifications to TDM and mobile emissions models; and 2) the total decrease in emissions from all sources is sufficient to accommodate 15.4 to 15.5 percent allocation of safety margin (as defined in 40 CFR93.101 8 ) to mobile sources while still continuing

8 "Safety margin" means t he amount by which the total projected em issions from all sources of a given pollutant are less than the total em issions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance.27 to maintain the total emissions in the Cleveland-Akron-Lorain area well below the 2008 attainment level of emissions.

The 15.4 to 15.5 percent margin of safety was selected so that the total 2015 and 2022 budgets would rema in consistent with the budgets established under Ohio’s Oc tober 5, 2011 submittal for redesignation of this area under the 1997 annual PM 2.5 standard. Safety margin, as defined by the c onformity rule, looks at the total emissions from all sources in t he nonattainment area. The actual allocation is less than 15 percent of the total emission reduction from all sources as can be seen from Table 33.

In summary, the mobile budget safety margin allocation translates into an additional 184.24 tpy for PM 2.5 and 4,685.25 tpy for NO x for 2015 and an additional 117.93 tpy for PM 2.5 and 2,306.27 tpy for NO x for 2022.

When compared to the overall safety margin, as defined in 40 CFR 93.101, discussed under “Requirement 3 of 5” below, it is evident this allocation is significantly below the total safety margin for this

area.

The current PM 2.5 and NO x mobile budgets for the fine particle NAAQS will no longer be applicable eit her after the effective date of the approved redesignat ion or after the effective date of any U.S. EPA action approving a finding that the PM 2.5 and NO x conformity budgets included in th is submittal are adequate for transportation conformity purposes, whichever date comes first.

Finally, it is important to underli ne that all motor vehicle emission budgets in this Redesignation subm ittal, which are based on MOVES2010, will replace previous motor vehicle emission budgets on Attainment Demonstr ation submittals based on MOBILE6.2.

Requirement 3 of 5 A demonstration that the projec ted level of emissions is sufficient to maintain the PM 2.5 standard.

Background In consultation with U.S. EPA, Ohio EPA selected the year 2022 as the maintenance year for th is redesignation request. This document contains projected em issions inventories for 2015 and 2022.28 Emission projections for the Cle veland-Akron-Lorain area were performed using the following approaches:

• As performed by NOACA and ODOT, mobile source emission projections are based on the U.S. EPA MOVES model. The analysis is described in more detail in Appendix C. All projections were made in accordance with “Procedures for Preparing Em issions Projections” U.S. EPA-45/4-91-019.

• Emissions inventories are requi red to be projected to future dates to assess the influence growth and future controls will have. LADCO has developed growth and control files for point, area, and non-road categorie s. These files were used to develop the future-year emissions estimates used in this document. This was done so the inventories used for redesignation are consistent with modeling performed in the future. Appendix D contains LADCO’s technical support document detailing the analysis used to project emissions (Base M 9 ).

• For the 2008 attainment year emissions were grown from the 2005 LADCO modeling inv entory, using LADCO’s growth factors, for all se ctors except point sources (electrical generating units and non-electrical generating units). Point source emissions for 2008 were compiled from Ohio EPA’s 2008 annual emissi ons inventory database. The 2015 interim year emissions were estimated based on the 2009 and 2018 LADCO modeli ng inventory, using LADCO’s growth factors, for all sectors. The 2022 maintenance year is based on emissions estimates from the 2018 LADCO modeling.

Ohio EPA is identifying emissi ons projections for 2015 and 2022 for EGUs with implementation of the CAIR program. U.S. EPA has raised concerns regarding the CA IR program and its remand. However, Ohio EPA believes thes e are the most appropriate and accurate future projections. Although CSAPR has been stayed by the D.C. Circuit Court (December 30, 2011), the Court has ordered U.S. EPA to continue administe ring CAIR pending the court’s resolution. It is believed that CSAPR will provide even greater reductions in emissions than t he CAIR program once resolved; therefore, these emissions pr ojections will be conservative.

9 http://www.ladco.org/tech/emis/current/i ndex.php29 On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. The intent of the CAIR program is for national NO x emissions to be cut from 4.5 milli on tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were required to submit a CA IR SIP as part of this effort. Ohio submitted a CAIR SIP wh ich was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final action on Sept ember 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA projec ts that in 2009 emissions of NO x will decrease from a baseline of 264,000 tons per year to 93,000 tons per year while in 2010 emissions of SO 2 will decrease from a baseline of 1,373,000 tons per y ear to 298,000 tons per year, within Ohio. And by 2015 U.S. EPA projects emissions of NO x will decrease to 83,000 tons per y ear while emissions of SO 2 will decrease to 208,000 tons per year, within Ohio 10

.
On December 23, 2008, U.S. EPA’ s CAIR program was remanded without vacatur by the D.C. Circuit Court.

As can be seen in Table 10 below , Ohio has seen a significant decline in the 264, 000 tons of NO x and 1,373,000 tons of SO 2 emitted in 2005. In 2008 and 2009 facilities began preparing for and implementing control programs to address CAIR 11 and consent decrees.

Table 11 - Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2009
SO 2 NO x 2008 2009 Change 2008 2009 Change Ohio 709,444 601,101 15% 235,018 96,351 59% LADCO States 2,019,036 1,620,071 20% 702,384 393,930 44% National 7,616,262 5,747,353 25% 2,996,287 1,990,385 34% Source: Clean Air Markets Quarterly Emissions Tracking 12

Significant reductions also occu rred regionally and nationally as can be seen from the above table. Data is also available for the first two quarters of 2010, the year SO 2 reductions are to be implemented under CAIR:

10 http://www. epa.gov/CAIR/oh.html 11 Under CAIR, NOx reductions are to occur begi nning in 2009 while SO2 reductions are to occur beginning in 2010. 12 http://www. epa.gov/airmarkets/quarterlytracking.html30 Table 12 – Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010
SO 2 NO x 2008 (1 st half) 2010 (1 st half) Change 2008 (1 st half) 2010 (1 st half) Change

Ohio 373,798 279,854 25% 130,598 53,187 59% LADCO States 1,190,497 854,282 28% 419,114 220,907 47% National 3,895,472 2,502,965 36% 1,487,179 930,148 37% Source: Clean Air Markets Quarterly Emissions Tracking 13

The following was reported by U.S. EPA’s Clean Markets Division:

“Based on emissions monitoring data, EPA has observed substantial reductions in SO 2 emissions from 2005 to 2009 and in the first two quarters of 2010 as companies installed more controls, electric demand declined, and low natural gas prices made combined-cycle gas-fired units more competitive in several parts of the country. Thus, even after CAIR's vacatur and subsequent remand in late 2008, t he controls in place generally have continued to operate, helping to drive continued progress in reducing emissions. 14 ”

Ohio EPA is in agreement with t he analysis by U.S.EPA that the CAIR program is providing real reductions at this time, Ohio believes these reductions have assisted with PM 2.5 attainment in this nonattainment area and throughout Ohio.

On July 6, 2011, U.S. EPA finaliz ed a replacement to the CAIR program, the CSAPR. CSAPR woul d preserve those initial reductions achieved under CAIR and provide even greater reductions in NO x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2. As a result of CSAPR, U.S. EPA projected that in 2012 emissions of NO x will decrease to 90,842 tons per year and in 2014 to 85,744 tons per year while SO 2 will decrease to 304,022 tons per y ear in 2012 and 134,333 tons per year in 2014, within Ohio. In addition, U.S. EPA projections indicated that as a result of implementation of CSAPR, there will be no maintenance issues within th is entire nonattainment area. However, on December 30, 2011, t he D.C. Circuit Court stayed CSAPR and ordered U.S. EPA to continue administering CAIR pending the court’s resolution.

Therefore, it is Ohio EPA’s belief it is most appropriate to evaluate Ohio EPA’s demonstration that the projected le vel of emissions is

13 http://www. epa.gov/airmarkets/quarterlytracking.html 14 http://www. epa.gov/airmarkets/background.htm31 sufficient to maintain the 24-hour PM 2.5 standard by assessing future year emissions that include the CAIR program.

The detailed inventory informati on for Cleveland-Akron-Lorain area for 2005 is in Appendix B. Em ission trends are an important gauge for continued compliance with the PM 2.5 standard. Therefore, Ohio EPA performed an initial comparison of the inventories for the base year and maintenance years. Mobile source emission inventories are described in Appendix C.

Sectors included in the following tabl es are: Electrical Generating Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Ar ea (Area); Marine; Aircraft; Rail (MAR); and On-road Mobile (On-road).

Maintenance is demonstrated w hen the future-year (2022) projected emission totals are below the 2008 attainment year totals.

The Ohio emissions data in t he tables below are based on the following data sources: - All On-Road data source: NOAC A and ODOT’s Transportation Unit. - 2008 EGU and non-EGU: Ohio EPA’s 2008 annual emissions inventory database. - All other data source: Lake Mich igan Air Directors Consortium (LADCO).

Demonstration

PM 2.5

The 2005 and 2008 actual PM 2.5 emissions data below generally contains particulate fraction emissions only and not the condensable fractions as Ohio EPA did not have a consistent reporting requirement during those years. U.S. EPA IPM modeling was used to generate future year EGU emissions with the CAIR program. The IPM modeling added additional PM 2.5 condensable emissions into future years. Therefore, comparing base and attainment year emissions with the future year predictions is not accurate in the IPM CAIR modeling. Th is step leads to a false perception of significant PM 2.5 emissions growth. Modeling performed by LADCO, without CAIR, did not incorporate added condensable fraction emissions. Although Ohio EPA has stated that it is most appropriate to evaluate future year emissions that include the CAIR program, because of this flaw it will be more accurate and appropr iate for the purposes of PM 2.5 to evaluate future year emissions without the CAIR program.32 Table 13 - Cuyahoga County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 81.43 99.40 29.82 0.00 99.40
Non-EGU 807.55 805.11 896.14 969.39

‐ 164.28
Non-road 630.80 553.24 433.84 308.64 244.60
Area 558.62 593.73 606.91 626.56

‐ 32.83

MAR 111.89 103.52 67.75 33.51 70.01
On-road 1,249.47 1,040.28 430.01 320.94 719.34

TOTAL 3439.76 3195.28 2464.47 2259.04 936.24

Table 14 - Lake County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 215.93 209.96 228.06 241.39

‐ 31.43
Non-EGU 30.67 23.23 32.67 38.62

‐ 15.39
Non-road 136.94 118.35 87.81 56.06 62.29
Area 132.09 137.25 138.11 140.01

‐ 2.76

MAR 36.49 31.82 18.43 5.28 26.54
On-road 283.09 241.78 122.02 69.42 172.36

TOTAL 835.21 762.39 627.10 550.78 211.61

Table 15 - Lorain County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 97.82 97.95 101.50 104.45

‐ 6.50
Non-EGU 428.05 471.83 513.52 559.22

‐ 87.39
Non-road 206.78 178.79 127.92 75.70 103.09
Area 401.71 404.47 397.99 392.72 11.75
MAR 57.49 50.13 29.17 8.56 41.57
On-road 319.85 274.43 143.34 81.69 192.74

TOTAL 1511.70 1477.60 1313.44 1222.34 255.2633 Table 16 - Medina County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 96.33 101.55 111.23 121.38

‐ 19.83
Non-road 118.08 102.70 70.71 38.35 64.35
Area 267.67 268.45 263.38 258.96 9.49
MAR 11.00 9.67 5.73 1.86 7.81
On-road 358.80 317.43 152.50 78.48 238.95
TOTAL 851.88 799.80 603.55 499.03 300.77

Table 17 - Portage County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 23.59 23.42 30.04 31.11

‐ 7.69
Non-road 116.90 103.27 72.36 41.38 61.89
Area 253.00 253.83 249.01 240.15 13.68
MAR 28.11 24.24 13.66 3.22 21.02
On-road 187.71 160.90 87.54 49.45 111.45
TOTAL 609.31 565.66 452.61 365.31 200.35

Table 18 - Summit County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 35.45 35.95 35.47 35.29 0.66
Non-road 233.20 203.09 144.73 85.25 117.84
Area 264.95 278.15 281.96 288.30

‐ 10.15
MAR 27.19 24.51 15.15 6.08 18.43
On-road 611.78 511.43 251.70 162.98 348.45
TOTAL 1172.57 1053.13 729.01 577.90 475.2334 Table 19 – Cleveland- Akron-Lorain Area PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and projected 2015 and 2022 (tpy) – Without CAIR

PM2.5 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin
Cuyahoga 3,439.76 3,195.28 2,464.47 2,259.04 936.24

Lake 835.21 762.39 627.1 550.78 211.61

Lorain 1,511.70 1,477.60 1,313.44 1,222.34 255.26

Medina 851.88 799.80 603.55 499.03 300.77
Portage 609.31 565.66 452.61 365.31 200.35

Summit 1,172.56 1,053.13 729.01 577.90 475.23
COMBINED PM 2.5 TOTAL 8,420.42 7,853.86 6,190.18 5,474.40 2,379.46

NO x
Table 20 - Cuyahoga County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 1,848.36 3,844.25 4,491.88 4,769.43

‐ 925.18
Non-EGU 3,081.22 2,990.08 2,890.16 2,724.22 265.86
Non-road 8,152.55 6,959.06 4,839.11 2,656.68 4,302.38
Area 5,103.40 5,162.21 5,203.60 5,254.00

‐ 91.79

MAR 3,672.47 3,463.56 2,376.29 1,345.39 2,118.17
On-road 36,545.59 28,227.20 12,371.38 6,065.83 22,161.37

TOTAL 58,403.59 50,646.36 32,172.42 22,815.55 27,830.81

Table 21 - Lake County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 12,969.08 11,211.15 11,819.69 11,562.04

‐ 350.89
Non-EGU 471.65 660.35 414.98 244.81 415.54
Non-road 1,873.78 1,638.69 1,228.21 804.76 833.93
Area 848.09 856.84 861.87 868.34

‐ 11.50

MAR 1,065.83 981.02 632.84 298.78 682.24
On-road 8,071.90 6,425.00 2,840.39 1,417.15 5,007.85

TOTAL 25,300.33 21,773.05 17,797.98 15,195.88 6,577.1735 Table 22 - Lorain County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 6,959.73 5,696.00 2,730.14 1,459.05 4,236.95
Non-EGU 926.84 774.05 850.81 847.90

‐ 73.85
Non-road 2,507.76 2,175.67 1,521.52 856.02 1,319.65
Area 981.14 992.64 1,000.63 1,010.38

‐ 17.74
MAR 1,711.08 1,578.76 1,025.10 494.46 1,084.30
On-road 9,196.87 7,354.77 3,456.51 1,723.02 5,631.75

TOTAL 22,283.42 18,571.89 10,584.71 6,390.83 12,181.06

Table 23 - Medina County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 0.00 0.00 2.14 3.89

‐ 3.89
Non-EGU 72.84 96.42 63.45 39.34 57.08
Non-road 1,295.08 1,104.33 698.29 288.57 815.76
Area 577.42 583.55 587.11 591.69

‐ 8.14

MAR 331.57 308.06 202.58 101.85 206.21
On-road 9,328.78 7,603.83 3,306.35 1,677.58 5,926.25
TOTAL 11,605.69 9,696.19 4,859.92 2,702.92 6,993.27

Table 24- Portage County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 83.19 83.68 83.47 82.05 1.63
Non-road 1,184.58 1,001.73 635.48 263.55 738.18
Area 559.86 565.77 568.13 571.56

‐ 5.79

MAR 908.80 838.60 543.41 260.56 578.04
On-road 5,707.22 4,630.98 2,264.50 1,014.35 3,616.63
TOTAL 8,443.65 7,120.76 4,094.99 2,192.07 4,928.6936 Table 25 - Summit County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 1,456.66 643.25 650.08 653.01

‐ 9.76
Non-road 2,953.59 2,459.48 1,520.22 560.88 1,898.60
Area 2,034.66 2,056.80 2,071.34 2,089.36

‐ 32.56

MAR 762.05 706.60 463.60 231.27 475.33
On-road 17,377.28 13,609.82 6,170.32 3,059.45 10,550.37
TOTAL 24,584.24 19,475.95 10,875.56 6,593.97 12,881.98

Table 26 - Cleveland- Akron-Lorain Area NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

NOx 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin Cuyahoga 58,403.59 50,646.36 32,172.42 22,815.55 27,529.98

Lake 25,300.33 21,773.05 17,797.98 15,195.88 6,577.17

Lorain 22,283.42 18,571.89 10,584.71 6,390.83 12,181.06

Medina 11,605.69 9,696.19 4,859.92 2,702.92 6,993.27
Portage 8,443.65 7,120.76 4,094.99 2,192.07 4,928.69

Summit 24,584.24 19,475.95 10,875.56 6,593.97 12,881.98
COMBINED NOx TOTAL 150,620.92 127,284.20 80,385.58 55,891.22 71,092.15

SO 2

Table 27 - Cuyahoga County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 2,991.78 9,920.92 12,145.34 13,098.66 ‐ 3,177.74
Non-EGU 5,156.40 5,163.15 5,343.87 5,494.26

‐ 331.11
Non-road 736.73 271.28 47.13 12.64 258.64
Area 291.45 291.73 289.69 287.90 3.83

MAR 423.44 368.20 246.51 124.15 244.05
On-road 846.76 253.16 76.36 68.07 185.09

TOTAL 10,446.56 16,268.44 18,148.90 19,085.68 ‐ 2,817.2437 Table 28 - Lake County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 80,187.84 57,730.81 42,363.35 17,921.95 39,808.86
Non-EGU 736.41 939.89 765.31 670.80 269.09
Non-road 162.20 59.94 10.78 3.24 56.70
Area 94.92 93.60 90.23 86.88 6.72

MAR 159.67 135.58 88.03 39.68 95.90
On-road 176.99 51.94 15.91 14.45 37.49

TOTAL 81,518.03 59,011.76 43,333.61 18,737.00 40,274.76

Table 29 - Lorain County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 42,437.09 22,604.10 8,631.3
2 2,642.99 19,961.11
Non-EGU 547.68 485.35 541.89 573.40

‐ 88.05
Non-road 249.83 91.90 15.51 3.64 88.26
Area 50.97 49.74 47.45 45.11 4.63

MAR 252.94 214.35 138.69 61.69 152.66
On-road 200.28 60.17 18.51 16.83 43.34

TOTAL 43,738.79 23,505.61 9,393.3
7 3,343.66 20,161.95

Table 30 - Medina County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 142.11 149.84 163.54 178.04

‐ 28.20
Non-road 143.41 52.54 8.41 1.49 51.05
Area 88.82 87.65 84.06 80.55 7.10

MAR 29.01 28.47 22.59 17.15 11.32
On-road 208.74 57.65 17.63 16.83 40.82
TOTAL 612.09 376.15 296.23 294.06 82.093839 Table 31 - Portage County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 10.24 13.01 13.60 14.93

‐ 1.92
Non-road 122.16 44.87 7.39 1.54 43.33
Area 143.62 141.66 134.24 127.08 14.58

MAR 78.55 76.83 60.86 46.01 30.82
On-road 96.74 30.52 13.23 7.40 23.12
TOTAL 451.31 306.89 229.32 196.96 109.93

Table 32 - Summit County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00
Non-EGU 10,866.52 11,102.30 10,899.96 10,835.99 266.31
Non-road 287.66 105.55 17.38 3.65 101.90
Area 174.88 172.54 168.39 164.11 8.43

MAR 66.17 64.83 51.36 38.86 25.97
On-road 319.72 100.66 42.76 39.57 61.09
TOTAL 11,714.95 11,545.88 11,179.85 11,082.18 463.70

Table 33 - Cleveland-Akron-Lorain Area SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

SO2 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

Cuyahoga 10,446.56 16,268.44 18,148.90 19,085.68

‐ 2,817.24

Lake 81,518.03 59,011.76 43,333.61 18,737.00 40,274.76

Lorain 43,738.79 23,505.61 9,393.37 3,343.66 20,161.95

Medina 612.09 376.15 296.23 294.06 82.09
Portage 451.31 306.89 229.32 196.96 109.93

Summit 11,714.95 11,545.88 11,179.85 11,082.18 463.70
COMBINED SO2 TOTAL 148,481.73 111,014.73 82,581.28 52,739.54 58,275.1940 PM 2.5 , NO x , and SO 2

Table 34 - Cleveland-Akron-Lorain Area Comparison of 2008 attainment year and 2015 and 2022 projected emission estimates (tpy)

2008 Attainment 2015 Interim 2015 Projected Decrease 2022 Maintenance 2022 Projected Decrease

PM 2.5 7,853.86 6,190.18 1,663.68 5,474.40 2,379.46

NO x 127,284.20 80,385.58 46,898.62 55,891.22 71,092.15
SO 2 111,017.73 82,581.28 28,436.45 52,739.54 58,275.19

As shown in the t able above (Table 33), PM 2.5 emissions in the nonattainment area are projected to decrease by 1,663.68 tpy in 2015 and 2,379.46 tpy in 2022. NO x emissions in the nonattainment area are projected to decrease by 46,898.62 tpy in 2015 and 71,092.15 tpy in 2022. SO 2 emissions in the nonattainment area are projected to decline by 28,436.45 tpy in 2015 and 58,275.19 tpy in 2022.

Area source emissions and point source emissions for some pollutants show a slight increas e due to expectations that the population will grow in this area; however, cleaner vehicles and fuels are expected to be in place in 2009 and 2018, and the CSAPR will be implemented in 2012 and 2014 and these programs should cause an overall drop in all three pollutants emissions. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 15 , Highway Heavy-Duty Engine Rule 16 , and the Non-Road Diesel Engine Rule 17 are factored into the changes.

In addition to the above, star ting in September 2011, First Energy’s Eastlake plant will onl y be used in the future for emergency power purposes. The fi ve units at this facility represent nearly half of the ava ilable megawatts for the entire area (1,233 of 2,494 megawatts).

15 http://www. epa.gov/fedrgstr/EPA-AIR/2000/ February/Day-10/a19a.htm 16 http://www. epa.gov/fedrgstr/EPA-AIR/1997 /October/Day-21/a27494.htm 17 http://www. epa.gov/fedrgstr/EPA-AIR/1998 /October/Day-23/a24836.htm41 Requirement 4 of 5 A demonstration that improvement in air quality bet ween the year violations occurred and the year attainment wa s achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background Ambient air quality data from all monito ring sites indicate that air quality met the NAAQS for PM 2.5 in 2008-2010. U.S. EPA’s redesignation guidance (p 9) states: “A state ma y generally demonstrate maintenance of the NAAQS by either showing that fu ture emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the future mix of sources and emissions rates will not cause a violation of the NAAQS.”

Demonstration Permanent and enforceable reductions of PM 2.5 , NO x , and SO 2 emissions have contributed to the atta inment of the 24-hour PM 2.5 standard. Some of these reductions were realized due to the application of tighter federal standards on non-road diesel vehicles (Clean Air Non-road Diesel Rule) and the application of tighter federal standards on new vehicles. Also Title IV of the CAA, the NO x SIP Call, CAIR, and f ederal consent decrees required the reductions of SO 2 and NO x emissions from utility sources. Reductions achieved are discussed in greater detail under Chapter Five.

Table 35 - Cleveland-Akron-Lorai n Area Comparison of 2005 base year and 2008 attainment year on-road, non-road and EGU reductions
2005 2008 On-road PM 2.5 3,010.70 2,546.25 On-road NO x 86,227.64 67,851.60 On-road SO 2 1,849.23 554.10 Non-road PM 2.5 1,442.70 1,259.44 Non-road NO x 17,967.34 15,338.96 Non-road SO 2 1,701.99 626.08 EGU PM 2.5 395.18 407.31 EGU NO x 21,777.17 20,751.40 EGU SO 2 125,616.71 90,255.83

Requirement 5 of 5 Provisions for future annual updates of the inventory to enable tracking of the emission levels, including an annual emissi on statement from major sources.42 Demonstration In Ohio, major point sources in a ll counties are required to submit air emissions information annually, in accordance with U.S. EPA’s Consolidated Emissions Reporti ng Rule (CERR). Ohio EPA prepares a new periodic inventory for all PM 2.5 precursor emission sectors every three years. These PM 2.5 precursor inventories will be prepared for future years as necessary to comply with the inventory reporting requirement s established in the CFR. Emissions information will be compared to the 2005 base year and the 2022 projected maintenance y ear inventories to assess emission trends, as necessary, and to assure continued compliance with the 24-hour PM 2.5 standard.43 

### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS CAA Section107 (d)(3)(E)(ii), 107( d)(3)(iv), and 107(d)(3)(E)(v)

Requirement 1 of 6 Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with nonattainment areas to implement RACM and RACT.

Background Section 172(c)(1) of the 1990 Cl ean Air Act Amendments requires states with nonattainment areas to submit a SIP providing for implementation of all reasonably av ailable control measures and as expeditiously as practicable (including such reductions in emissions from existing source s in the area as may be obtained through the adoption, at a mini mum, of reasonable available control technology).

U.S. EPA’s 1997 Implementation Rule interprets this requirement in great detail. Under U.S. EPA’ s approach, RACT is determined as part of the broader RACM analysis and identification of all measures (for stationary, mob ile, and area sources) that are technically and economically feasib le, and that would collectively contribute to advancing the attain ment date (i.e. by one year or more). States are required to use a combined approach to RACT and RACM, that (1) identifies potential measures that are reasonable, (2) uses modeling to i dentify the attainment date that is as expeditious as practicabl e, and (3) selects the appropriate RACT and RACM.

The 1997 Implementation Rule also provides for a presumption that in States t hat fulfill their CAIR emission reduction requirements, EGU compliance with CAIR is equivalent to RACM/RACT.

Demonstration In 1972, 1980, and 1991, Ohio promulgated rules requiring reasonably available controls meas ures for particulate emissions from stationary sources.

Statewide RACT rules have been applied to all new sources locating in Ohio since that time. RACT requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations44 discovered by field office staff. The Ohio RACT rules for particulate matter are found in OAC Chapter 3745-17 18

. In addition, Ohio EPA promulgated NO x SIP Call rules (OAC Chapter 3745-14 19 ), CAIR (OAC Chapter 3745-109 20 ), and NO x Reasonably Available Control Technology rules (OAC Chapter 3745-110 21 ) over the past five years. Emissions from EGUs make up a significant contribution to Ohio ’s inventory. Beginning in 2009, Ohio implemented CAIR which has, and will, provide for significant reductions in NO x , PM 2.5 , and SO 2 until such time CSAPR is implemented. Then the CSAPR will provide for even greater reductions.

As part of a larger initiative , LADCO, in consultation with two contractors, performed a series of studies exploring control measures for reducing bot h ozone precursors and PM 2.5 precursors in Ohio, Illinois, I ndiana, Michigan, and Wisconsin area. The first consultant, MACTEC, pr epared a series of white papers 22 researching different stationary source categories. The results were compiled into two reports 23 . The second consultant, Environ, investigated control options for m obile sources. The results were compiled into two reports 24 . The stationary and mobile source sectors (and associated control m easures) were selected by the LADCO States based on several fa ctors presented in the report (See Chapter 2).

Photochemical modeling was t hen conducted (as part of LADCO Round 4 modeling) to assess t he air quality benefit of the candidate control measures and a modeling report was developed 25 . Based on the results, the LA DCO project team felt it would not be possible to advance the attainment date for PM 2.5

. Ohio EPA, in its attainment dem onstration submitted on July 18, 2008, demonstrated (using a weight of evidence approach) that

18 http://www. epa.ohio.gov/dapc/r egs/3745_17.aspx 19 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx 20 http://www. epa.ohio.gov/dapc/r egs/3745_109.aspx 21 http://www. epa.ohio.gov/dapc /regs/3745_110.aspx 22 http://www.ladco.org/r eports/control/white_papers 23 http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_i_april_2005.pdf; http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_ii_june_2006.pdf 24 http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_february_2006.pdf; http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_for_ladc o_states_in_2009_and_2012_march_2007.pdf 25 http://www.ladco.org/r eports/control/mode ling/round4_modeling.pdf45 attainment would be achieved in this area by 2009. Because of a projected 2009 attainment date, it would not have been reasonably possible or practicable for Ohio to develop RACT/RACM requirements, promulgate regulat ions and implement a control program prior to the proj ected attainment date.

Requirement 2 of 6 Section 172(c)(2) of the 1990 CAA Amendments requires attainment demonstration SIPs for nonattainment ar eas to show reasonable further progress (RFP).

Background U.S. EPA’s 1997 Implementation Rule requires RFP only for any area which a State projects an attainment date beyond 2014. If a State demonstrates attainment will occur by 2014 or earlier, U.S. EPA considers the attainment demonstration to demonstrate achievement of RFP. However, if a State a ttains the standard prior to the requirement to subm it an attainment demonstration, 2012, an attainment demonstr ation is not required.

Demonstration The Cleveland-Akron-Lorain area has attained the standard prior to the deadline for submitting an attainment demonstration; and therefore, it was not necessary to submit a separate RFP plan.

Requirement 3 of 6 Section 172(c)(3) requires states to subm it a comprehensive inventory of actual emissions.

Background Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions in the area, including the requirement for periodic revisi ons as determined necessary. 40 CFR 51.1008 requires such inventor y to be submitted within three years of designation and requires a baseline emission inventory for calendar year 2005 or other suitable year to be used for attainment planning.

Demonstration The 2005 comprehensive inventory was submitted to U.S. EPA with Ohio’s PM 2.5 attainment demonstrati on SIP submitted on July 18, 2008. It was then subsequently revised and resubmitted on June 7, 2010.

Ohio also updates its inventor y in accordance with U.S. EPA’s CERR rule (i.e. emissions stat ements). Ohio EPA submitted its46 emissions statement SIP on Ma rch 18, 1994 which was approved by U.S. EPA on October 13, 1995 ( 59 FR 51863). As discussed in Chapter 4 (Requirement 4), Ohio EPA submits, and commits to submit, emission inventories (sta tements) every three years.

Requirement 4 of 6 Evidence that control meas ures required in past PM 2.5 SIP revisions have been fully implemented.

Background In addition to the historic RACT requirements for PM, the U.S. EPA NO x SIP Call required 22 states to pass rules that would result in significant emissi on reductions from large EGUs, industrial boilers, and cement kiln s in the eastern United States. Ohio passed this rule in 2001. NOx SIP Call requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff. Compliance is tracked through the Clean Air Markets data monitori ng program. Beginning in 2004, this rule accounts for a reduction of approximately 31 percent of all NO x emissions statewide compar ed to previous uncontrolled years. The other 21 states al so have adopted these rules.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. National NO x emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were r equired to submit a CAIR SIP as part of this effort. Ohio submi tted a CAIR SIP which was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final acti on on September 25, 2009 (74 FR 48857).

Demonstration Controls for EGUs under the NO x SIP Call formally commenced May 31, 2004. Emissions cove red by this program have been generally trending downward since 1998 with larger reductions occurring in 2002 and 2003. Data ta ken from the U.S. EPA Clean Air Markets web site, quantify the gradual NO x reductions that have occurred in Ohio as a resu lt of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter47 3745-14 26 in response to the SI P Call. OAC Chapter 3745-14 regulates EGUs and certain non-EGUs under a cap and trade program based on an 85 percent reduc tion of NOx emissions from EGUs and a 60 percent reduction of NO x emissions from nonEGUs, compared to historical le vels. This cap was in place through 2008, at which time the CAIR program superseded it as discussed above. Requirement 3 of 5 under Chapter 4 above discussed the reductions Ohio has seen as a result of CAIR.

On April 21, 2004, U.S. EPA published Phase II of the NO x SIP Call that establishes a budget for la rge (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio EPA’s OAC rule 3745-14-12 addresses stat ionary internal combustion engines, all used in natural gas pipeline transmissions. U.S. EPA approved this revision to the SIP on April 4, 2008. An 82 percent NO x reduction from 1995 levels is ant icipated. Completion of the compliance plan occurred by May 1, 2006, and the compliance demonstration began May 1, 2007.

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and li ght trucks, including sport utility vehicles (SUVs). Under this pr oposal, automakers will be required to sell cleaner cars, and refiner ies will be required to make cleaner, lower sulfur gasoline. Th is rule will apply nationwide. The federal rules will phase in bet ween 2004 and 2009. U.S. EPA has estimated that NO x emission reductions will be approximately 77 percent for passenger cars, 86 per cent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. The sulfur content of gasoline is estimated to be reduced by up to 90 percent. VOC emission reductions will be approxim ately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoli ne and diesel trucks and buses. This rule will result in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x

26 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx48 inventory. It also estima ted the level of sulfur in highway diesel fuel will be reduced by 97 percent by mid-2006.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highw ay diesel program. The new standards will cut emissions from non -road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this rule, currently accounts for 47 perc ent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwide. Sulfur levels will be reduced in non -road diesel fuel by 99 percent from current levels, from appr oximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starti ng in 2008. Together, these rules will substantially reduce lo cal and regional sources of PM 2.5 precursors.

Requirement 5 of 6 Acceptable provisions to provide for new source review.

Background Ohio has a longstanding and fu lly implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745- 31 27 . The Chapter includes provis ions for the Prevention of Significant Deterioration (PSD) permitting program in OAC rules 3745-31-01 to 3745-31-20. Ohio's PSD program was conditionally approved on October 10, 2001 (66 FR 51570) and received final approval on January 22, 2003 (68FR 2909) by U.S. E PA as part of the SIP.

Demonstration Any facility that is not listed in the 2005 emission inventory, or for the closing of which credit was ta ken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable NSR r equirements. Once the area is redesignated, Ohio EPA will impl ement NSR through the PSD
program.

Requirement 6 of 6

27 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx49 Assure that all existing control measures will remain in effect after redesignation unless the State demonstrates thr ough modeling that the standard can be maintained without one or more control measures.

Demonstration Ohio commits to maintaining t he aforementioned control measures after redesignation. Ohio hereby co mmits that any changes to its rules or emission limits applicable to PM 2.5 , SO 2 , and NO x as required for maintenanc e of the 24-hour PM 2.5 standard in the Cleveland-Akron-Lorain area, will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal offi ce, has the legal authority and necessary resources to actively enf orce any violations of its rules or permit provisions. After redesi gnation, it intends to continue enforcing all rules that rela te to the emission of PM 2.5 precursors in the Cleveland-Akron-Lorain area.50 

### CHAPTER SIX

CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v)

Requirement 1 of 4 A commitment to submit a revised pl an eight years after redesignation.

Demonstration Ohio hereby commits to review its maintenance plan eight years after redesignation, as required by Section 175(A) of the CAA

.
Requirement 2 of 4 A commitment to expeditiously enact and implement additional contingency control measures in response to ex ceeding specified predetermined levels (triggers) or in the event that future vi olations of the ambient standard occur.

Demonstration Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response: A warning level response sha ll be prompted w henever the 98 th percentile 24-hour PM 2.5 concentration of 35.5 μ g/m 3 occurs in a single calendar year within the ma intenance area. A warning level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 values or whether emissions appear to be increas ing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse t he trend taking into consideration ease and timing for implementation as well as economic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expeditiously as possible, but in no event later than 12 months from the conclusion of the most recent calendar year.

Should it be determined through the wa rning level study that action is necessary to reverse the noted trend, the procedur es for control selection and implementation outlined under “action level response” shall be followed.

Action Level Response: An action level response shall be prompted whenever a two-year average of the 98 th percentile 24-hour PM 2.5 concentration of 35.0
μ g/m 3 or greater occurs within the maintenance area. A violation of51 the standard (three-year average of the 98 th percentile 24-hour PM 2.5 concentration of 35.0 μ g/m 3 or greater) shall also prompt an action level response. In the event that the action level is triggered and is not found to be due to an exc eptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metr opolitan planning organization or regional council of governments, will determine additional control measures needed to assure future attainment of the NAAQS for 24-hour PM 2.5 . In this case, measures that can be implemented in a short time will be selected in order to be in place within 18 months from the clos e of the calendar year that prompted the action level. Ohio EPA will also c onsider the timing of an action level trigger and determine if additional, significant new regulations not currently included as part of the maintenance provisions will be implemented in a timely manner and will constitute our response.

Control Measure Sele ction and Implementation Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking.

If a new measure/control is alr eady promulgated and scheduled to be implemented at the federal or State level, and that measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Ohio will submit to U.S. EPA an analysis to demonstrate the propos ed measures are adequate to return the area to attainment.

Requirement 3 of 4 A list of potential contingen cy measures that would be implemented in such an event.

Demonstration Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the selection is m ade. The selection of measures will be based on cost-effectiveness, em ission reduction potential, economic and social cons iderations or other factors that Ohio EPA deems appropriate. Ohio EPA will solic it input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Be cause it is not possible at this time to determine what cont rol measures will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not exhaustive.52 1) Diesel reduction emission strategies. 2) Alternative fuel (e.g., li quid propane and compressed natural gas) and diesel retrofit programs for fleet vehicle operations. 3) Tighter PM 2.5 , SO 2 , and NO x emissions offsets for new and modified major sources. 4) Impact crushers located at recycle scrap yards – upgrade wet suppression. 5) Concrete manufacturing – upgrade wet suppression. 6) Additional NO x RACT statewide.

No contingency measure shall be implemented without providing the opportunity for full public partici pation during which the relative costs and benefits of individual meas ures, at the time they are under consideration, can be fully evaluated.

Requirement 4 of 4 A list of PM 2.5 , SO 2 , and NO x sources potentially subject to future additional control requirements.

Demonstration The following is a list of PM 2.5 , SO 2 , and NO x sources potentially subject to future controls.

• ICI Boilers - SO 2 and NO x controls;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• other sources greater than 100 tons per year;

• fleet vehicles;

• concrete manufacturers;

• aggregate processing plants;53 

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesignat ion petition and maintenance plan in the widely distributed county publications.

The public hearing to receive comment s on the redesignation request was held on May 21, 2012, at the Ohio EPA Northeast District Offices, 2110 East Aurora Road, Twinsburg, Ohio. The public comment period closed on May 21, 2012. Testimony was provided at the public hearing as were written comments received. Ohio EPA’s response to t hese comments can be found in Appendix F along with a copy of the public notice and the transcript from the public hearing.54 

### CHAPTER EIGHT

CONCLUSIONS

The Cleveland-Akron-Lorain 24-hour PM 2.5 nonattainment area has attained the 2006 24-hour NAAQS for PM 2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA r egarding redesignations of PM 2.5 nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepared a redesignation request and maintenance plan that meet the requirements of Section 110 (a)(1) of the 1990 CAA.

Based on this presentation, t he Cleveland-Akron-Lorain 24-hour PM 2.5 nonattainment area meets the requirem ents for redesignation under the CAA and U.S. EPA guidance. Oh io has performed an analysis that shows the air quality improvements ar e due to permanent and enforceable measures. Furthermore, because this area is subject to significant transport of pollutants, significant regional SO 2 and NO x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of Ohio hereby requests that the Cleve land-Akron-Lorain 24-hour PM 2.5 nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenance plan provisions contained herein.This page left intentionally blank