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 PM2.5 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.gov 
Cleveland, 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 PM2.5 

NONATTAINMENT AREA 

Cuyahoga, Lake, Lorain, Medina, 

Portage, and Summit, Ohio 

Prepared by: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

May 2012 
 

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 i 

TABLE OF CONTENTS 

Chapter One 

Introduction ................................................................................................................................... 1 

Geographical description .............................................................................................................. 2 

Status of air quality ....................................................................................................................... 3 

Chapter Two 

Requirements for redesignation .................................................................................................... 4 

Chapter Three 

PM2.5 monitoring ............................................................................................................................ 9 

24-Hour PM2.5 NAAQS .................................................................................................................. 9 

Ambient data quality assured ...................................................................................................... 10 

Three complete years of data ..................................................................................................... 10 

Commitment to continue monitoring ........................................................................................... 17 

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 PM2.5, SO2, and NOx sources ........................................................................................... 51 

Chapter Seven 

Public participation ...................................................................................................................... 52 

Chapter Eight 

Conclusions ................................................................................................................................ 53 
 ii 

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 98th 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 PM2.5 Annual Mean National Trends......................................................... 17

TABLES 

Table 1 Monitoring Data for Cleveland-Akron-Lorain area for 2008 – 2010 ..................... 12 

Table 2 98th 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 .................... 25 

Table 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 SO2 and NOx EGU Emissions Between 2008 and 2009. ............. 29 

Table 12 Reductions in SO2 and NOx EGU Emissions Between the First Half of 2008 

 and 2010.... ......................................................................................................... 30 

Table 13 Cuyahoga County PM2.5 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 32 

Table 14 Lake County PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 32 

Table 15 Lorain County PM2.5 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ................................ 32 

Table 16 Medina County PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR ................ 33 

Table 17 Portage County PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 33 

Table 18 Summit County PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 33 

Table 19 Cleveland-Akron-Lorain PM2.5 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 34 

Table 20 Cuyahoga County NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 34 

Table 21 Lake County NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 34 

Table 22 Lorain County NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 35 

Table 23 Medina County NOx Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 35 

Table 24 Portage County NOx Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 35 
 iii 

Table 25 Summit County NOx Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 36 

Table 26 Cleveland-Akron-Lorain Area NOx Emission Inventory Totals for Base Year 

 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .......... 36 

Table 27 Cuyahoga County SO2 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 36 

Table 28 Lake County SO2 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 37 

Table 29 Lorain County SO2 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 37 

Table 30 Medina County SO2 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 37 

Table 31 Portage County SO2 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 38 

Table 32 Summit County SO2 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 38 

Table 33 Cleveland-Akron-Lorain Area SO2 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 PM2.5 Nonattainment 

Area 

D LADCO Technical Support Document 

E Incomplete Monitoring Data Substitution Analysis 

F Public Participation Documentation
 iv 

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REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 

CLEVELAND-AKRON-LORAIN 

24-HOUR PM2.5 NONATTAINMENT AREA 

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

CHAPTER ONE 

Introduction 

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

meet the 24-hour PM2.5

1

 National Ambient Air Quality 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 matter 2006. In 2006, U.S. EPA strengthened 

the primary 24-hour PM2.5 NAAQS from 65 μg/m3

 to 35 μg/m3, and retained the 

current primary annual PM2.5 NAAQS at 15.0 μg/m3. The revised 24-hour PM2.5

standard was published on October 17, 2006 (71 FR 61144) and became 

effective on December 18, 2006. The standard is based on the 3-year average of 

the 98th percentile of 24-hour concentrations. 

On November 13, 2009, U.S. EPA promulgated (74 FR 58688) the initial PM2.5

nonattainment areas designations for the 24-hour PM2.5 standard across the 

country (effective December 14, 2009). Unlike Subpart 2 of the CAA 

Amendments of 1990 which defined five ozone nonattainment classifications for 

the areas that exceed the NAAQS based on the severity of the ozone levels, 

PM2.5 nonattainment designations are simply labeled “nonattainment.” The CAA 

Amendments require states with PM2.5 nonattainment areas to submit a plan 

within three years of the effective date of the designations (December 14, 2012) 

detailing how the PM2.5 standard will be attained by December 14, 2014. 

However, areas that attain before the required date for submitting a plan may be 

exempt from certain otherwise applicable requirements. 

Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas to 

be redesignated to attainment provided certain criteria are met. The following are 

the criteria that must be met in order for an area to be redesignated from 

nonattainment to attainment: 

i) A determination that the area has attained the PM2.5 standard.

 

1 Particle pollution is a mixture of microscopic solids 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 chemicals, metals, soil or dust particles, and allergens (such as fragments 

of pollen or mold spores). 

Fine particle pollution or PM2.5 describes particulate matter that is 2.5 micrometers in diameter and 

smaller - 1/30th the diameter of a human hair. Fine particle pollution can be emitted directly or formed 

secondarily in the atmosphere.
 2 

ii) An approved State Implementation Plan (SIP) for the area 

under Section 110(k).

iii) A determination that the improvement in air quality is due to 

permanent and enforceable reductions in emissions resulting 

from implementation of the SIP and other federal requirements.

iv) A fully approved maintenance plan under Section 175(A).

v) A determination that all Section 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 PM2.5 standard. 

 The Cleveland-Akron-Lorain area has previously 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 PM2.5

standard of 65 μg/m3. On October 5, 2011, Ohio EPA submitted a redesignation 

request and maintenance plan for the 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 following counties: Cuyahoga, Lake, Lorain, 

Medina, Portage, and Summit. This area is shown in Figure 2 under Chapter 

Three. 

As a result of the 2009 PM2.5 designations, U.S. EPA designated the ClevelandAkron-Lorain area nonattainment for the 35 μg/m3 24-hour standard, and Ohio 

EPA is required to develop a plan to reduce oxides of nitrogen (NOx), sulfur 

dioxide (SO2) and direct PM2.5 emissions and to demonstrate that the area will 

meet the federal 24-hour air quality standard by December 14, 2014. Ohio’s 

main PM2.5 components are primary particles (organic carbon, crustal material, 

and elemental carbon), SO2 and NOx, which were included in the attainment 

demonstration analysis for the 1997 annual PM2.5 NAAQS submitted to U.S. EPA 

on July 16, 2008. Volatile organic compounds (VOCs) and ammonia (NH3) were 

not included in the analysis since they were not part of Ohio’s attainment 

strategy for PM2.5 (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 Implementation Rule U.S. EPA presumes 

NH3 emissions are not a PM2.5 attainment plan precursor and that States are not 

required to address VOC unless the State or U.S. EPA makes a technical 

demonstration that emissions of VOCs significantly contribute to nonattainment 

of the PM2.5 standard. This is also consistent with U.S. EPA’s “Implementation 

Guidance for the 2006 24-Hour Fine Particle (PM2.5) National Ambient Air Quality 

Standards (NAAQS)” memorandum issued on March 2, 2012 (hereafter referred 
 3 

to as “2006 Implementation Memo”). In this memorandum, U.S. EPA 

recommends that “the projected attainment inventory for the nonattainment area 

includes direct PM2.5, SO2, presumptively NOx, as well as other precursors that 

have been determined to be significant through the area’s SIP development 

process.” Furthermore, the 2006 Implementation Memo indicates that U.S. EPA 

believes the overall framework and policy approach of the 1997 Implementation 

Rule “continues to provide effective and appropriate guidance on the EPA’s 

interpretation of the general statutory requirements that states should address in 

their SIPs” and that they are “relevant to the statutory requirements” for the 2006 

24-hour PM2.5 standard. 

This document is intended to support Ohio’s request that the Cleveland-AkronLorain area be redesignated from nonattainment to attainment for the 24-hour 

PM2.5 standard. 

Status of Air Quality 

PM2.5 complete quality-assured ambient air quality monitoring data for the three 

(3) years, 2008 through 2010, demonstrate that the air quality has met the 

NAAQS for 24-hour PM2.5 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 guidance 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 plan are based on the redesignation 

guidance, supplemented with additional guidance received from staff of U.S. 

EPA Region 5. 

Below is a summary of each redesignation 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 ambient air quality data. The data 

that are used to demonstrate attainment should be the product of 

ambient monitoring that is representative of the 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 available to the public for review. 

 The second component relies 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 Appendix D contains the most 

recent modeling results showing future attainment and 

maintenance are provided. Chapter Three discusses this 

requirement in more detail and provides the attainment 

demonstration. 

ii.) Permanent and enforceable improvement in air quality (CAA Section 

107(d)(3)(E)(iii)) 

 The state must be able to reasonably attribute the improvement in 

air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures that 

have been adopted and implemented 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 rules recently that will have an 

impact on statewide PM2.5 emissions in the future: 
 5 

• Clean Air Interstate Rule (CAIR) 

• NOx SIP Call Rules 

 Ohio was subject to a Federal Implementation Plan under the 

CAIR replacement rule, the Cross-State Air Pollution Rule 

(CSAPR), that could have 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 court’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 state 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 nonattainment based on a violation 

of the NAAQS. Subpart 4 of Part D consists of more specific 

requirements applicable to particulate matter (specifically to 

address PM10). However, for the purpose of implementing the 

PM2.5 standard, U.S. EPA’s 1997 Implementation Rule stated 

Subpart 1, rather than Subpart 4, is appropriate for the purpose of 

implementing PM2.5.[72 FR 20589] 

 i.) Section 110(a) requirements 

Section 110(a) of Title I of the CAA contains the general 

requirements for a SIP. Section 110(a)(2) provides that the 

implementation plan submitted 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 limitations and other control 

measures, means or techniques necessary to meet the 

requirements of the CAA; provide for establishment and 

operation of appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 

provide for implementation of a source permit program to 

regulate the modification and construction of any stationary 

source within the areas covered by the plan; include 

provisions for the implementation of Part C, prevention of 

significant deterioration (PSD) and Part D, NSR permit 

programs; include criteria for stationary source emission 
 6 

control measures, monitoring, and reporting; include 

provisions for air quality modeling; 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 requires State plans to prohibit 

emissions from within the State which contribute 

significantly to nonattainment or maintenance areas in any 

other State, or which interfere with programs under Part C 

to prevent significant deterioration of air quality or to 

achieve reasonable progress toward the national visibility 

goal for Federal class I areas (national parks and 

wilderness areas). In order to assist States in addressing 

their obligations regarding regionally transported pollution, 

U.S. EPA finalized CAIR to reduce SO2 and NOx emissions 

from large electric generating units (EGU). Ohio has met 

the requirements of the federal CAIR to reduce NOx and 

SO2 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 3745-1092. On July 6, 2011, U.S. EPA 

finalized a replacement to the CAIR program, the CSAPR. 

 CSAPR could further assist States in addressing their 

obligations regarding regionally transported pollution by 

providing reductions in NOx and SO2 emissions in 2012 and 

2014. However, on December 30, 2011, the D.C. Circuit 

Court stayed CSAPR and ordered 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, identification of certain emissions 

increases, and other measures needed for attainment will 

not apply for redesignations because they only have 

meaning for areas not attaining the standard. The 

requirements for an emission inventory 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#3745-109 
 7 

 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 maintenance 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) further 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 deems necessary to ensure prompt 

correction of any violation of the NAAQS. At a minimum, the 

contingency measures must include a requirement that the state 

will implement all measures 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 required under 40 CFR Part 51, Subpart 

A. We expect that for many nonattainment areas, these annual 

inventories will serve as an appropriate starting point for the 

emission inventories used for SIP development. In contrast with 

the 1997 annual PM2.5 NAAQS, where states rely only on annual 

inventories in the implementation process, the 2006 24-hour PM2.5 

NAAQS is designed to protect against peak exposures. Thus, for 
 8 

the 2006 24-hour PM2.5 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 designation 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 PM2.5 monitoring data for the Cleveland-AkronLorain area to determine whether the exceedances occurred in only one 

season. As can be seen in Figure 1 below, exceedances between 2006 

and 2008, the years on which the nonattainment designation is based, 

occurred in the first, second, third and fourth quarters. During 

subsequent years, 2009 through 2010, exceedances have occurred in the 

first and third quarters. Based on this 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-Akron-Lorain 24-hour PM2.5 Exceedances 

 Chapter Six discusses this requirement in more detail.
 9 

CHAPTER THREE 

PM2.5 MONITORING 

CAA Section 107(d)(3)(E)(i) 

Requirement 1 of 4 

A demonstration that the NAAQS for 24-hour PM2.5, as published in 40 CFR 

50.7, has been attained. 

Background

 There are 13 monitors measuring PM2.5 concentrations in this 

nonattainment area. These monitors are operated by Ohio EPA 

Division of Air Pollution Control, 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 concentrations from 2008 through 

2010 and a listing of the design values based on the three-year 

average of the 98th percentile are is shown in Table 1. The

locations of the monitoring sites for this nonattainment area are 

shown on Figure 2. 
 10 

Demonstration

 

Figure 2 - Map of the Cleveland-Akron-Lorain nonattainment area and 

monitor locations 

Requirement 2 of 4 

Ambient monitoring data quality assured in accordance with 40 CFR 58.10, 

recorded in the U.S. EPA air quality system (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 other federal requirements. Ohio 

EPA has recorded the data in the AQS database and, therefore, the data 

are available to the public. 

Requirement 3 of 4 

A showing that the three-year average of the 98th percentile of 24-hour 

concentrations, based on data from all monitoring sites in the area or its affected 

downwind environs, are below 35 μg/m3

. (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 "Guideline 

on Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999. 

 In accordance with the CAA Amendments, three complete years of 

monitoring data are required to demonstrate attainment at a 

monitoring site. The 24-hour PM2.5 primary and secondary ambient 

air quality standards are met at an ambient air quality monitoring 

site when the three-year average of the 24-hour 98th percentile 

values are less than or equal to 35μg/m3

. While calculating design 

values, one decimal place must be carried in the computations, 

with final values rounded to the nearest 1 μg/m3

. Decimals 0.5 or 

greater are rounded up, and those less than 0.5 are rounded 

down, so that 35.349 μg/m3

 is the largest concentration that is less 

than, or equal to 35 μg/m3. Values at or below 35 μg/m3 meet the 

standard; values greater than 35 μg/m3 exceed the standard. An 

area is in compliance with the 24-hour PM2.5 NAAQS only if every 

monitoring site in the area meets the NAAQS. An individual site's 

3-year average of the 24-hour 98th percentile concentrations is 

also called the site's design value. 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 the 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 demolition of the building that hosted the monitor. USEPA 

approved the shut down without relocation. 

(b)Although this is one of the highest reading 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 miles 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 evaluate the candidate site [d] and approved the replacement 

request, authorizing with this replacement, the combination of ozone and fine particulate data from both sites for the 

purpose of calculating design values 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 for the Cleveland-Akron-Lorain area 

demonstrate that the 24-hour PM2.5 NAAQS has been attained. However, 

three monitor sites in Cuyahoga County, site 39-035-0060, site 39-035-

0065, and site 39-035-1002, did not comply with the 75% data capture 
 13 

requirement for the 2008-2010 period. Specifically, 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, the use of less than complete data 

may be approved by U.S. EPA considering such factors as monitoring 

site closures/moves, monitoring diligence, 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 the 24-hour standard using multiple 

imputations. Ohio EPA has imputed missing values for these sites and 

then performed an ordinary analysis as if the imputed values were real 

measurements. Multiple imputations use random 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 statistical analyses performed to show 

that the three-year average (2008 to 2010) of the 98th percentile 24-hour 

values, based on missing data imputations, are 32, 31, and 27 μg/m3, 

which are below the 35 μg/m3

 24-hour standard. 

Table 2 shows sites 39-035-0060, 39-035-0065, and 39-035-1002 before 

and after the imputation of missing data. Also the “new” sites (with 

imputed values) shows a passing 24-hour design value for 2008 to 2010 

of 32 μg/m3

. 
 14 

Table 2: 98th 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 results, 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 PM2.5 began in 1999. With respect the ClevelandAkron-Lorain area, there has been a clear downward trend in design 

values: 
 15 

Figure 3 - Cleveland-Akron-Lorain Area Highest 98th 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 PM2.5: Design Values 1999-2001 Through 

2008-2010 
 16 

Source: WVDEP: http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: 

PM25dv20082010Final.xls 

Design values have also trended downward nationally: 

Figure 5 - PM2.5 Annual Mean National Trends 
 17 

Source: http://www.epa.gov/airtrends/pm.html 

Requirement 4 of 4 

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

appropriate monitoring network to verify the maintenance of the attainment 

status. 

Demonstration

 Ohio EPA commits to continue monitoring PM2.5 levels at the Ohio 

sites indicated in Figure 2 and Table 1. Ohio EPA will consult with 

U.S. EPA Region 5 prior to making 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 central station and updates to the 

Ohio EPA web site3

 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 accordance with federal guidelines. 

 

3 www.epa.ohio.gov/dapc 
 18 

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 PM2.5 precursor emissions (primary particles (organic carbon, crustal 

matter, and elemental carbon), SO2 and NOx

4

) representative of the year when 

the area achieves attainment of the 24-hour PM2.5 air quality standard. Ohio also 

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

violations occurred and the year that attainment was achieved is based on 

permanent and enforceable emission reductions. Other emission inventory 

related requirements include a projection of the emission inventory to a year at 

least 10 years following redesignation; a demonstration that the projected level 

of emissions is sufficient to maintain the 24-hour PM2.5 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 mobile (on-road) emissions inventory and 

projections, identifies procedures used by Ohio EPA and the LADCO regarding 

emissions of all the counties in the Cleveland-Akron-Lorain area. All of these 

inventories and emissions projections were prepared using similar 

methodologies. Mobile emissions inventories 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 PM2.5, SO2 and NOx completed for the 

base year. 

Background

The point source data are taken from Ohio's annual emissions 

reporting program. The 2005 periodic inventory has been identified 

as one of the preferred databases for SIP development and 

coincides with nonattainment air quality in the Cleveland-AkronLorain area. 

Periodic inventories, which include emissions from all sectors - 

mobile, area, non-road, and point sources - are prepared every 

three years. 

 

4 VOC and NH3 are not addressed. 
 19 

Demonstration

The 2005 inventory is used as the base year for the purpose of 

this submittal and was submitted to U.S. EPA with Ohio’s PM2.5

attainment demonstration SIP submitted on July 18, 2008 and 

revised on June 7, 2010. The detailed emission inventory 

information for the Cleveland-Akron-Lorain area is provided in 

Appendix B. Emissions of PM2.5, SO2 and NOx 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 inventory for the Cleveland-AkronLorain area including area, mobile, and point sources for PM2.5, SO2 and 

NOx for base year 2005. The 2005 inventory was submitted to U.S. EPA 

on July 18, 2008 as part of Ohio’s PM2.5 attainment demonstration SIP for 

this area. The information below describes the procedures Ohio EPA 

used to generate the 2005 base year inventory and to develop SIP-ready 

modeling inventories and future year projections (Pechan Report5) based 

on a 2005 base year inventory. The report by Pechan generated future 

year estimates of annual emissions for each source sector using 

accepted growth surrogates. These inventories were provided to the 

LADCO and have been processed to develop average daily emissions for 

use in the air quality analyses. These processed modeling inventories 

have been identified as the correct iteration of the inventory 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 addressed by specific PM2.5 and NOx 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. Department of Commerce Bureau of 

Economic Analysis (BEA) growth factors, with some 

updated local information. 

• Mobile source emissions were calculated from 

MOVES2010 produced emission factors. Only PM2.5 and 

NOx necessitate emissions inventory analysis. As 

documented in Ohio EPA’s attainment demonstration SIP, 

Ohio EPA in consultation with U.S. EPA determined mobile 

 

5 

http://www.ladco.org/tech/emis/r5/reports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con

trols%20Report_Final.pdf 
 20 

sources are insignificant contributors for SO2. Consistent 

with Ohio EPA’s attainment demonstration, Ohio EPA 

continues to consider mobile source SO2 to be an 

insignificant contributor to fine particles for this 

nonattainment area. Based on the demonstration below, 

SO2 constitutes less than one percent (<1.21%) of the 

area’s total SO2 emissions in 2005, 2008, 2015 and 2022 

(ranging between 0.21% and 1.21%). 

• Point source information was compiled from Ohio EPA’s 

2005 annual emissions inventory database and the 2005 

U.S. EPA Air Markets acid rain database6

. 

• Biogenic emissions are not included in these summaries. 

• Non-road emissions were generated using U.S. EPA’s 

National Mobile Inventory Model (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 emissions for three (3) non-road 

categories not included in U.S. EPA’s non-road model. 

Emissions were estimated for 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 category were reviewed and 

updated based upon surveys completed in the Midwest, 

and the temporal allocation for 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 Metropolitan Area Transportation Study 

(AMATS) area, and by the Northeast Ohio Areawide Coordinating 

Agency (NOACA) for the counties of Cuyahoga, Lake, Lorain and 

Medina in its area. 

 

The inventories include county based, annual totals of PM2.5 and 

Oxides of Nitrogen (NOX) 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/acidrain 
 21 

Overview 

U.S.EPA published a Federal Register notice7 of availability on 

March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions 

Simulator), hereafter referred to as MOVES. Upon publication of 

the Federal Register notice, MOVES became U.S. EPA’s 

approved motor vehicle emission factor model for estimating 

VOCs, NOx, CO, PM10 and PM2.5 and other pollutants and 

precursors from cars, trucks, motorcycles, and buses by state and 

local agencies. MOVES is a computer program designed by the 

U.S. EPA to estimate air pollution emissions from mobile sources. 

MOVES replaces U.S. EPA’s previous emissions model for onroad mobile sources, MOBILE6.2. MOVES can be used to 

estimate exhaust and evaporative emissions as well as brake and 

tire wear emissions from all types of on-road vehicles. 

The CAA requires U.S. EPA to regularly update its mobile source 

emission models. U.S. EPA continuously collects data and 

measures vehicle emissions to make 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 several changes to the U.S. EPA’s 

approach to mobile source emission modeling based upon 

recommendations made to the Agency by the National Academy 

of Sciences. 

U.S.EPA believes that MOVES should be used in ozone, CO, PM, 

and nitrogen dioxide SIP development 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 period before MOVES is required for 

new transportation conformity analyses. 

The MOVES more detailed approach (when compared with the 

previous MOBILE model) to modeling allows U.S. EPA to easily 

incorporate large amounts of in-use data from a wide variety of 

sources, such as data from vehicle inspection and maintenance 

(I/M) programs, remote sensing device (RSD) testing, certification 

testing, portable emission measurement systems (PEMS), etc. 

This approach also allows users to incorporate a variety of activity 

data to better estimate emission differences such as those 

 

7 http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ab1f98 
 22 

resulting from changes to vehicle speed and acceleration patterns. 

MOVES has a graphical user interface which allows users to more 

easily set up and run the model. MOVES database-centered 

design provides users much greater flexibility regarding output 

choices. Unlike earlier models which 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-mile 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 impacts of individual transportation 

projects. The database-centered design also allows U.S. EPA to 

update emissions data incorporated 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 project-level PM2.5 emissions 

to be estimated. 

The annual PM2.5 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 Transportation Study (AMATS) and the 

Northeast Ohio Areawide Coordinating Agency (NOACA) areas is 

calibrated using the latest population and land use data available 

and are validated using corresponding traffic count data. Currently, 

the travel demand models are validated to year 2005. U.S.EPA’s 

emissions model MOVES is used for 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 would be based on a single-season 

approach. Since travel demand models produce average daily 

conditions, the daily emissions estimates are multiplied by 365 

days to produce annual emissions estimates expressed in tons per 

year. 

Finally, the regional emissions analysis includes emissions for 

Direct PM2.5 (exhaust, brake, and tire wear), and Oxides of 

Nitrogen (NOX).Sulfur Dioxide (SO2), Volatile Organic Compounds 

(VOCs) and Ammonia (NH3) are considered insignificant at this 

time. (Appendix C) 

NOACA maintains a PC-based regional travel demand forecasting 

model on the Citilabs CUBE platform for use in its urban 

transportation planning process. This model employs the 

traditional four step modeling process to project existing and future 

traffic volumes and travel patterns on the regional transportation 
 23 

networks. The four step process consists of trip generation, trip 

distribution, mode split, and route assignment. Output from the 

model is link-by-link directional volumes 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 prepares 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-level 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 files were generated for base year2005, attainment year-2008, interim year 2015, and maintenance 

year 2022. Assumptions for these 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 with the aid of several custom 

programs by ODOT. The process 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 involves running ODOT postcms.exe 

to calculate hourly link volumes 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. The 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 emissions for every network link for 

each hour. The final link on road vehicle emissions for the area is 

the sum of all individual link-hour emissions. 

 
 24 

The third step, (mvehicle.exe), calculates vehicle-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 onto 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 intrazonal trips of each zone. The 

zone is assumed circular and the radius of the circle is used as the 

average trip length for these intrazonal trips. Intrazonal emissions 

are then calculated by combining 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 emissions by 365 to produce an 

annual estimate. 

On-Road Mobile Emission Estimations 

Tables 2 through 8 contain the results of the emissions analysis for 

the appropriate years. All emissions estimations are expressed in 

tons per year (tpy). 

Table 3 – Cuyahoga County, Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 1,249.47 1,040.28 430.01 320.94

NOx (tpy) 36,545.59 28,227.20 12,371.38 6,065.83

SO2 (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 

PM2.5 (tpy) 283.09 241.78 122.02 69.42

NOx (tpy) 8,071.90 6,425.00 2,840.39 1,417.15

SO2 (tpy) 176.99 51.94 15.91 14.45

Annual VMT 2,113,418,985 2,155,625,760 2,180,087,695 2,251,831,000
 25 

Table 5 – Lorain County, Emissions Estimations for On-Road Mobile 

Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 319.85 274.43 143.34 81.69

NOx (tpy) 9,196.87 7,354.77 3,456.51 1,723.02

SO2 (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, Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 358.80 317.43 152.50 78.48

NOx (tpy) 9,328.78 7,603.83 3,306.35 1,677.58

SO2 (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, Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 187.71 160.90 87.54 49.45

NOx (tpy) 5,707.22 4,630.98 2,264.50 1,014.35

SO2 (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, Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 611.78 511.43 251.70 162.98

NOx (tpy) 17,377.28 13,609.82 6,170.32 3,059.45

SO2 (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 

PM2.5 (tpy) 3,010.70 2,546.25 1,187.11 762.96

NOx (tpy) 86,227.64 67,851.60 30,409.45 14,957.38

SO2 (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

0
 26 

Motor Vehicle Emission Budget 

Table 10 contains the motor vehicle 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 approximately 15.4 to 15.5% so that 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 PM2.5 standard. 

The above budgets for the Cleveland-Akron-Lorain area, agreed 

upon as part of the interagency consultation 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 PM2.5 and NOx in 2015 and 2022. 

In an effort to accommodate future variations in travel demand 

models and VMT forecast when no change to the network is 

planned, Ohio EPA consulted with U.S. EPA to determine a 

reasonable approach to address this variation. Based on this 

discussion, a 15.4 to 15.5 percent margin of safety allocation was 

agreed upon and has been added to the emissions estimates for 

this nonattainment area. 

All methodologies, the latest planning assumptions, and the safety 

margins allocations were determined through the interagency 

consultation process described in the Transportation Conformity 

Memorandum of Understanding (MOU) 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 variation in VMT forecast and 

potential estimated mobile source emissions due to expected 

modifications to TDM and mobile emissions models; and 2) the 

total decrease in emissions from all sources is sufficient to 

accommodate 15.4 to 15.5 percent allocation of safety margin (as 

defined in 40 CFR93.1018

) to mobile sources while still continuing 

 

8 "Safety margin" means the amount by which the total projected emissions from all sources of a given 

pollutant are less than the total emissions that would satisfy the applicable requirement for reasonable 

further progress, attainment, or maintenance.
 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 remain consistent with the 

budgets established under Ohio’s October 5, 2011 submittal for 

redesignation of this area under the 1997 annual PM2.5 standard. 

Safety margin, as defined by the conformity rule, looks at the total 

emissions from all sources in the 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 PM2.5 and 4,685.25 tpy for NOx for 

2015 and an additional 117.93 tpy for PM2.5 and 2,306.27 tpy for 

NOx 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 PM2.5 and NOx mobile budgets for the fine particle 

NAAQS will no longer be applicable either after the effective date 

of the approved redesignation or after the effective date of any 

U.S. EPA action approving a finding that the PM2.5 and NOx

conformity budgets included in this submittal are adequate for 

transportation conformity purposes, whichever date comes first. 

Finally, it is important to underline that all motor vehicle emission 

budgets in this Redesignation submittal, which are based on 

MOVES2010, will replace previous motor vehicle emission 

budgets on Attainment Demonstration submittals based on 

MOBILE6.2. 

Requirement 3 of 5 

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

PM2.5 standard. 

Background

In consultation with U.S. EPA, Ohio EPA selected the year 2022 

as the maintenance year for this redesignation request. This 

document contains projected emissions inventories for 2015 and 

2022. 
 28 

Emission projections for the Cleveland-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 Emissions Projections” U.S. 

EPA-45/4-91-019. 

• Emissions inventories are required 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 categories. 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 M9

). 

• For the 2008 attainment year emissions were grown from 

the 2005 LADCO modeling inventory, using LADCO’s 

growth factors, for all sectors except point sources 

(electrical generating units and non-electrical generating 

units). Point source emissions for 2008 were compiled from 

Ohio EPA’s 2008 annual emissions inventory database. 

The 2015 interim year emissions were estimated based on 

the 2009 and 2018 LADCO modeling 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 emissions projections for 2015 and 2022 

for EGUs with implementation of the CAIR program. U.S. EPA has 

raised concerns regarding the CAIR program and its remand. 

However, Ohio EPA believes these 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 administering CAIR pending the court’s 

resolution. It is believed that CSAPR will provide even greater 

reductions in emissions than the CAIR program once resolved; 

therefore, these emissions projections will be conservative. 

 

9

 http://www.ladco.org/tech/emis/current/index.php 
 29 

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 NOx and SO2. CAIR replaced the NOx SIP Call for 

EGUs. The intent of the CAIR program is for national NOx

emissions to 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 required to submit a CAIR SIP as part of this effort. 

Ohio submitted 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 action on September 25, 2009 (74 FR 48857). As 

a result of CAIR, U.S. EPA projects that in 2009 emissions of NOx

will decrease from a baseline of 264,000 tons per year to 93,000 

tons per year while in 2010 emissions of SO2 will decrease from a 

baseline of 1,373,000 tons per year to 298,000 tons per year, 

within Ohio. And by 2015 U.S. EPA projects emissions of NOx will 

decrease to 83,000 tons per year while emissions of SO2 will 

decrease to 208,000 tons per year, within Ohio10. 

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 NOx and 1,373,000 tons of SO2

emitted in 2005. In 2008 and 2009 facilities began preparing for 

and implementing control programs to address CAIR11 and 

consent decrees. 

Table 11 - Reductions in SO2 and NOx EGU Emissions 

Between 2008 and 2009 

SO2 NOx

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 Tracking12

Significant reductions also occurred regionally and nationally as 

can be seen from the above table. Data is also available for the 

first two quarters of 2010, the year SO2 reductions are to be 

implemented under CAIR: 

 

10 http://www.epa.gov/CAIR/oh.html 

11 Under CAIR, NOx reductions are to occur beginning in 2009 while SO2 reductions are to occur 

beginning in 2010.

12 http://www.epa.gov/airmarkets/quarterlytracking.html
 30 

Table 12 – Reductions in SO2 and NOx EGU Emissions 

Between the First Half of 2008 and 2010 

SO2 NOx

2008 

 (1st half) 

2010 

(1st half) 

Change 2008 

(1st half) 

2010 

(1st 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 Tracking13

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

“Based on emissions monitoring data, EPA has observed 

substantial reductions in SO2 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, the controls in place generally 

have continued to operate, helping to drive continued progress in 

reducing emissions.14” 

Ohio EPA is in agreement with the analysis by U.S.EPA that the 

CAIR program is providing real reductions at this time, Ohio 

believes these reductions have assisted with PM2.5 attainment in 

this nonattainment area and throughout Ohio. 

On July 6, 2011, U.S. EPA finalized a replacement to the CAIR 

program, the CSAPR. CSAPR would preserve those initial 

reductions achieved under CAIR and provide even greater 

reductions in NOx and SO2 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 NOx will decrease to 90,842 

tons per year and in 2014 to 85,744 tons per year while SO2 will 

decrease to 304,022 tons per year 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 this entire nonattainment area. 

However, on December 30, 2011, the 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 level of emissions is 

 

13 http://www.epa.gov/airmarkets/quarterlytracking.html

14 http://www.epa.gov/airmarkets/background.htm
 31 

sufficient to maintain the 24-hour PM2.5 standard by assessing 

future year emissions that include the CAIR program. 

The detailed inventory information for Cleveland-Akron-Lorain area 

for 2005 is in Appendix B. Emission trends are an important 

gauge for continued compliance with the PM2.5 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 tables are: Electrical Generating 

Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Area (Area); Marine; Aircraft; Rail 

(MAR); and On-road Mobile (On-road). 

Maintenance is demonstrated when the future-year (2022) 

projected emission totals are below the 2008 attainment year 

totals. 

The Ohio emissions data in the tables below are based on the 

following data sources: 

- All On-Road data source: NOACA and ODOT’s Transportation 

Unit. 

- 2008 EGU and non-EGU: Ohio EPA’s 2008 annual emissions 

inventory database. 

- All other data source: Lake Michigan Air Directors Consortium 

(LADCO). 

Demonstration

PM2.5 

The 2005 and 2008 actual PM2.5 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 

PM2.5 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. This step leads to a false perception 

of significant PM2.5 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 appropriate for the purposes of PM2.5 to 

evaluate future year emissions without the CAIR program. 
 32 

Table 13 - Cuyahoga County PM2.5 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 PM2.5 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 PM2.5 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 1222.34 255.26
 33 

Table 16 - Medina County PM2.5 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 PM2.5 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 PM2.5 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 1053.13 729.01 577.90 475.23
 34 

Table 19 – Cleveland-Akron-Lorain Area PM2.5 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 

PM2.5 TOTAL 8,420.42 7,853.86 6,190.18 5,474.40 2,379.46

NOx 

Table 20 - Cuyahoga County NOx 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 NOx 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 6,577.17

 
 35 

 

Table 22 - Lorain County NOx 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 NOx 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 NOx 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 4,928.69
 36 

Table 25 - Summit County NOx 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 NOx 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

SO2

Table 27 - Cuyahoga County SO2 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

‐

2,817.24

 
 37 

Table 28 - Lake County SO2 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 SO2 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 SO2 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 82.09
 38 
 39 

Table 31 - Portage County SO2 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 SO2 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 SO2 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 58,275.19
 40 

PM2.5, NOx, and SO2

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 

PM2.5 7,853.86 6,190.18 1,663.68 5,474.40 2,379.46 

NOx 127,284.20 80,385.58 46,898.62 55,891.22 71,092.15 

SO2 111,017.73 82,581.28 28,436.45 52,739.54 58,275.19 

As shown in the table above (Table 33), PM2.5 emissions in the 

nonattainment area are projected to decrease by 1,663.68 tpy in 

2015 and 2,379.46 tpy in 2022. NOx emissions in the 

nonattainment area are projected to decrease by 46,898.62 tpy in 

2015 and 71,092.15 tpy in 2022. SO2 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 increase 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 

Requirements15, Highway Heavy-Duty Engine Rule16, and the 

Non-Road Diesel Engine Rule17 are factored into the changes. 

In addition to the above, starting in September 2011, First 

Energy’s Eastlake plant will only be used in the future for 

emergency power purposes. The five units at this facility 

represent nearly half of the available 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.htm 
 41 

Requirement 4 of 5 

A demonstration that improvement in air quality between the year violations 

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

enforceable emission reductions and not on temporary adverse economic 

conditions or unusually favorable meteorology. 

Background 

Ambient air quality data from all monitoring sites indicate that air quality 

met the NAAQS for PM2.5 in 2008-2010. U.S. EPA’s redesignation 

guidance (p 9) states: “A state may generally demonstrate maintenance 

of the NAAQS by either showing that future emissions of a pollutant or its 

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

modeling to show that the future mix of sources and emissions rates will 

not cause a violation of the NAAQS.” 

Demonstration 

Permanent and enforceable reductions of PM2.5, NOx, and SO2 emissions 

have contributed to the attainment of the 24-hour PM2.5 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 NOx SIP Call, CAIR, and federal consent decrees 

required the reductions of SO2 and NOx emissions from utility sources. 

Reductions achieved are discussed in greater detail under Chapter Five. 

Table 35 - Cleveland-Akron-Lorain Area Comparison of 2005 base 

year and 2008 attainment year on-road, non-road and 

EGU reductions 

 2005 2008 

On-road PM2.5 3,010.70 2,546.25 

On-road NOx 86,227.64 67,851.60 

On-road SO2 1,849.23 554.10 

Non-road PM2.5 1,442.70 1,259.44 

Non-road NOx 17,967.34 15,338.96 

Non-road SO2 1,701.99 626.08 

EGU PM2.5 395.18 407.31 

EGU NOx 21,777.17 20,751.40 

EGU SO2 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 emission statement from major sources. 
 42 

Demonstration

In Ohio, major point sources in all counties are required to submit 

air emissions information annually, in accordance with U.S. EPA’s 

Consolidated Emissions Reporting Rule (CERR). Ohio EPA 

prepares a new periodic inventory for all PM2.5 precursor emission 

sectors every three years. These PM2.5 precursor inventories will 

be prepared for future years as necessary to comply with the 

inventory reporting requirements established in the CFR. 

Emissions information will be compared to the 2005 base year and 

the 2022 projected maintenance year inventories to assess 

emission trends, as necessary, and to assure continued 

compliance with the 24-hour PM2.5 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 Clean Air Act Amendments requires 

states with nonattainment areas to submit a SIP providing for 

implementation of all reasonably available control measures and 

as expeditiously as practicable (including such reductions in 

emissions from existing sources in the area as may be obtained 

through the adoption, at a minimum, 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, mobile, and area sources) that are 

technically and economically feasible, and that would collectively 

contribute to advancing the attainment 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 identify the attainment date that 

is as expeditious as practicable, and (3) selects the appropriate 

RACT and RACM. 

The 1997 Implementation Rule also provides for a presumption 

that in States that 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 measures 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 violations 
 44 

discovered by field office staff. The Ohio RACT rules for particulate 

matter are found in OAC Chapter 3745-1718. 

In addition, Ohio EPA promulgated NOx SIP Call rules (OAC 

Chapter 3745-1419), CAIR (OAC Chapter 3745-10920), and NOx

Reasonably Available Control Technology rules (OAC Chapter 

3745-11021) 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 NOx, PM2.5, and SO2 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 both ozone precursors and PM2.5 

precursors in Ohio, Illinois, Indiana, Michigan, and Wisconsin area. 

The first consultant, MACTEC, prepared a series of white papers22

researching different stationary source categories. The results 

were compiled into two reports23. The second consultant, Environ, 

investigated control options for mobile sources. The results were 

compiled into two reports24. The stationary and mobile source 

sectors (and associated control measures) were selected by the 

LADCO States based on several factors presented in the report 

(See Chapter 2). 

Photochemical modeling was then conducted (as part of LADCO 

Round 4 modeling) to assess the air quality benefit of the 

candidate control measures and a modeling report was 

developed25. Based on the results, the LADCO project team felt it 

would not be possible to advance the attainment date for PM2.5. 

Ohio EPA, in its attainment demonstration submitted on July 18, 

2008, demonstrated (using a weight of evidence approach) that 

 

18 http://www.epa.ohio.gov/dapc/regs/3745_17.aspx 

19 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 

20 http://www.epa.ohio.gov/dapc/regs/3745_109.aspx 

21 http://www.epa.ohio.gov/dapc/regs/3745_110.aspx

22 http://www.ladco.org/reports/control/white_papers 

23 

http://www.ladco.org/reports/control/final_reports/identification_and_evaluation_of_candidate_control_meas

ures_i_april_2005.pdf; 

http://www.ladco.org/reports/control/final_reports/identification_and_evaluation_of_candidate_control_meas

ures_ii_june_2006.pdf 

24

http://www.ladco.org/reports/control/final_reports/final_report_evaluation_of_candidate_mobile_source_cont

rol_measures_february_2006.pdf; 

http://www.ladco.org/reports/control/final_reports/final_report_evaluation_of_candidate_mobile_source_cont

rol_measures_for_ladco_states_in_2009_and_2012_march_2007.pdf

25 http://www.ladco.org/reports/control/modeling/round4_modeling.pdf
 45 

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 regulations and implement a control 

program prior to the projected attainment date. 

Requirement 2 of 6

Section 172(c)(2) of the 1990 CAA Amendments requires attainment 

demonstration SIPs for nonattainment areas 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 attains the standard 

prior to the requirement to submit an attainment demonstration, 

2012, an attainment demonstration 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 submit 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 revisions as determined necessary. 40 

CFR 51.1008 requires such inventory 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 PM2.5 attainment demonstration SIP submitted on July 

18, 2008. It was then subsequently revised and resubmitted on 

June 7, 2010. 

Ohio also updates its inventory in accordance with U.S. EPA’s 

CERR rule (i.e. emissions statements). Ohio EPA submitted its 
 46 

emissions statement SIP on March 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 (statements) every three years. 

Requirement 4 of 6

Evidence that control measures required in past PM2.5 SIP revisions have been 

fully implemented. 

Background

In addition to the historic RACT requirements for PM, the U.S. 

EPA NOx SIP Call required 22 states to pass rules that would 

result in significant emission reductions from large EGUs, 

industrial boilers, and cement kilns 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 monitoring program. Beginning in 2004, 

this rule accounts for a reduction of approximately 31 percent of all 

NOx emissions statewide compared to previous uncontrolled 

years. The other 21 states also 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 NOx and SO2. CAIR replaced the NOx SIP Call for 

EGUs. National NOx 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 required to submit a CAIR SIP as 

part of this effort. Ohio submitted 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 action on September 25, 2009 (74 FR 

48857). 

Demonstration

Controls for EGUs under the NOx SIP Call formally commenced 

May 31, 2004. Emissions covered by this program have been 

generally trending downward since 1998 with larger reductions 

occurring in 2002 and 2003. Data taken from the U.S. EPA Clean 

Air Markets web site, quantify the gradual NOx reductions that 

have occurred in Ohio as a result of Title IV of the 1990 CAA 

Amendments and the beginning of the NOx SIP Call Rule. Ohio 

developed the NOx Budget Trading Program rules in OAC Chapter 
 47 

3745-1426 in response to the SIP Call. OAC Chapter 3745-14 

regulates EGUs and certain non-EGUs under a cap and trade 

program based on an 85 percent reduction of NOx emissions from 

EGUs and a 60 percent reduction of NOx emissions from nonEGUs, compared to historical levels. 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 NOx SIP 

Call that establishes a budget for large (greater than 1 ton per day 

emissions) stationary internal combustion engines. Ohio EPA’s 

OAC rule 3745-14-12 addresses stationary 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 

NOx reduction from 1995 levels is anticipated. 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 light trucks, including sport utility 

vehicles (SUVs). Under this proposal, automakers will be required 

to sell cleaner cars, and refineries will be required to make 

cleaner, lower sulfur gasoline. This rule will apply nationwide. The 

federal rules will phase in between 2004 and 2009. U.S. EPA has 

estimated that NOx emission reductions will be approximately 77 

percent for passenger cars, 86 percent 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 approximately 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 gasoline and diesel trucks and buses. 

This rule will result in a 40 percent reduction in NOx from diesel 

trucks and buses, a large sector of the mobile sources NOx

 

26 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 
 48 

inventory. It also estimated 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 highway 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 percent of diesel particulate matter 

(PM) and 25 percent of NOx from mobile sources nationwide. 

Sulfur levels will be reduced in non-road diesel fuel by 99 percent 

from current levels, from approximately 3,000 parts per million 

(ppm) now to 15 ppm in 2009. New engine standards take effect, 

based on engine horsepower, starting in 2008. Together, these 

rules will substantially reduce local and regional sources of PM2.5

precursors. 

Requirement 5 of 6

Acceptable provisions to provide for new source review. 

Background

Ohio has a longstanding and fully implemented New Source 

Review (NSR) program. This is addressed in OAC Chapter 3745-

3127. The Chapter includes provisions 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. EPA 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 taken in demonstrating attainment, 

will not be allowed to construct, reopen, modify, or reconstruct 

without meeting all applicable NSR requirements. Once the area is 

redesignated, Ohio EPA will implement NSR through the PSD 

program. 

Requirement 6 of 6

 

27 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx 
 49 

Assure that all existing control measures will remain in effect after redesignation 

unless the State demonstrates through modeling that the standard can be 

maintained without one or more control measures. 

Demonstration

Ohio commits to maintaining the aforementioned control measures 

after redesignation. Ohio hereby commits that any changes to its 

rules or emission limits applicable to PM2.5, SO2, and NOx as 

required for maintenance of the 24-hour PM2.5 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 office, has the legal authority and 

necessary resources to actively enforce any violations of its rules 

or permit provisions. After redesignation, it intends to continue 

enforcing all rules that relate to the emission of PM2.5 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 plan 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 exceeding specified predetermined levels 

(triggers) or in the event that future violations 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 shall be prompted whenever the 98th

percentile 24-hour PM2.5 concentration of 35.5 μg/m3 occurs in a 

single calendar year within the maintenance area. A warning level 

response will consist of a study to determine whether the PM2.5

value indicates a trend toward higher PM2.5 values or whether 

emissions appear to be increasing. The study will evaluate 

whether the trend, if any, is likely to continue and, if so, the control 

measures necessary to reverse the 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 warning level study that action 

is necessary to reverse the noted trend, the procedures 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 98th percentile 24-hour PM2.5 concentration of 35.0 

μg/m3

 or greater occurs within the maintenance area. A violation of 
 51 

the standard (three-year average of the 98th percentile 24-hour 

PM2.5 concentration of 35.0 μg/m3 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 exceptional event, malfunction, or 

noncompliance with a permit condition or rule requirement, Ohio 

EPA in conjunction with the metropolitan planning organization or 

regional council of governments, will determine additional control 

measures needed to assure future attainment of the NAAQS for 

24-hour PM2.5. 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 close of the calendar year that prompted the 

action level. Ohio EPA will also consider 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 Selection 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 already 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 proposed measures are adequate to 

return the area to attainment. 

Requirement 3 of 4

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

event. 

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective 

at the time the selection is made. The selection of measures will 

be based on cost-effectiveness, emission reduction potential, 

economic and social considerations or other factors that Ohio EPA 

deems appropriate. Ohio EPA will solicit input from all interested 

and affected persons in the maintenance area prior to selecting 

appropriate contingency measures. Because it is not possible at 

this time to determine what control 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., liquid propane and compressed natural 

gas) and diesel retrofit programs for fleet vehicle operations. 

3) Tighter PM2.5, SO2, and NOx 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 NOx RACT statewide. 

No contingency measure shall be implemented without providing 

the opportunity for full public participation during which the relative 

costs and benefits of individual measures, at the time they are 

under consideration, can be fully evaluated. 

Requirement 4 of 4 

A list of PM2.5, SO2, and NOx sources potentially subject to future additional 

control requirements. 

Demonstration

The following is a list of PM2.5, SO2, and NOx sources potentially 

subject to future controls. 

• ICI Boilers - SO2 and NOx 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 redesignation petition and maintenance plan in the 

widely distributed county publications. 

The public hearing to receive comments 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 these 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 PM2.5 nonattainment area has attained the 

2006 24-hour NAAQS for PM2.5 and complied with the applicable provisions of 

the 1990 Amendments to the CAA regarding redesignations of PM2.5 

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, the Cleveland-Akron-Lorain 24-hour PM2.5 

nonattainment area meets the requirements for redesignation under the CAA 

and U.S. EPA guidance. Ohio has performed an analysis that shows the air 

quality improvements are due to permanent and enforceable measures. 

Furthermore, because this area is subject to significant transport of pollutants, 

significant regional SO2 and NOx reductions will ensure continued compliance 

(maintenance) with the standard with an increasing margin of safety. 

The State of Ohio hereby requests that the Cleveland-Akron-Lorain 24-hour 

PM2.5 nonattainment area be redesignated to attainment simultaneously with 

U.S. EPA approval of the maintenance plan provisions contained herein. 
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