Environmental
Protection Agency

John Kasich
1 Governor

Mary Taylor, Lt. Governor

Scott J. Nally, Director



# JUN 01 

# 2011

Ms. Susan Hedman Regional Administrator
U.S. EPA Region V

77 W. Jackson Blvd. Chicago, IL 

### 60604

Re: PM 2

. 5 redesignation request for the 

### 1997 PM2.5 Annual Standard for the DaytonSpringfield Area

Dear Administrator Hedman:

I am writing to formally request a redesignation to attainment of the Dayton-Springfield

area (Clark, Greene, and Montgomery Counties) with respect to the 

### 1997 PM 2

. 5 annual
standard. The enclosed submittal combines the redesignation request and the required
maintenance plan for this area.

Monitoring of existing air quality indicates that the 

### 1997 National Ambient Air Quality
Standard (NMQS) 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 NMQS indefinitely into the future. These programs will, therefore,
constitute the attainment and maintenance plan for the Dayton-Springfield area.

The enclosed information, compiled by the Ohio Environmental Protection Agency (Ohio EPA), Ohio Department of Transportation, and the Miami Valley Regional Planning
Commission (MVRPC), 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 March 

### 29, 2011. The public hearing for this package was held on May 3, 

### 2011, in Dayton, Ohio.

50 West Town street, SURe 700 P.O. Box 1049 Columbus,OH 43216-1049 614 1 644 3020
61416443184 (fax) www.epa.ohio.govIf you have questions, please contact Jennifer Hunter in our Division of Air Pollution
Control at (614) 644-3696.

Sincerely,

# ~~IY Director

Enclosure

# REDESIGNATION REQUEST AND
MAINTENANCE PLAN FOR
THE DAYTON-SPRINGFIELD
ANNUAL PM 2.5 

# NONATTAINMENT AREA

Clark, Greene, and Montgomery Counties, Ohio

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

May 2011This page left intentionally blankii TABLE OF CONTENTS

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

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

Chapter Three
PM 2.5 monitoring ................................................................................................................... ......... 8
Annual PM 2.5 NAAQS .................................................................................................................... 8 Ambient data quality assured ........................................................................................................ 9 Three complete years of data .................................................................................................. ..... 9 Commitment to continue monitoring ........................................................................................... 1 4

Chapter Four Emission inventory ............................................................................................................ .......... 15 Base year inventory ........................................................................................................... ......... 15 Emission projections .......................................................................................................... ......... 16
Demonstration of maintenance .................................................................................................. . 24
Permanent and enforceable emissions reductions ..................................................................... 33 Provisions for future update .................................................................................................. ...... 34

Chapter Five Control measures and regulations .............................................................................................. 35 Marginal nonattainment areas to implement RACM and RACT .................................................. 35 Show Reasonable Further Progress (RFP) ................................................................................ 37
Emission inventories .......................................................................................................... ......... 37 Implementation of past SIP revisions .......................................................................................... 38 New source review provisions ................................................................................................. .. 40
Assurance of continued controls ............................................................................................... .. 41

Chapter Six Contingency measures .......................................................................................................... ..... 42 Commitment to revise plan ..................................................................................................... .... 42 Commitment for contingency measures ..................................................................................... 42 Potential contingency measures ................................................................................................ . 43
List of PM 2.5 , SO 2 , and NO
x sources ........................................................................................... 44

Chapter Seven Public participation .......................................................................................................... ............ 45

Chapter Eight
Conclusions ................................................................................................................... ............. 46iii FIGURES

Figure 1 Map of the Dayton-Springfield nonattainment area and monitor locations ............ 9 Figure 2 PM 2.5 Annual Mean Trends LADCO States ......................................................... 12 Figure 3 PM 2.5 Annual Mean Trends Midwest States ........................................................ 13 Figure 4 PM 2.5 Annual Mean National Trends .................................................................. 13

TABLES

Table 1 Monitoring Data for Dayton-Springfield area for 2008 - 2010 .............................. 11 Table 2 Comparison Between Original and Imputed Values for Monitor 39-057-0005
from 2004 to 2010 .............................................................................................. 12 Table 3 Clark County, Ohio Emission Estimations for On-road Mobile Sources .............. 21 Table 4 Greene County, Ohio Emission Estimations for On-road Mobile Sources .......... 21 Table 5 Montgomery County, Ohio Emission Estimations for On-road Mobile Sources .. 22Table 6 Emission Estimations Totals for On-road Mobile Sources for the DaytonSpringfield Area ................................................................................................... 22 Table 7 Mobile Vehicle Emission Budget ......................................................................... 22 Table 8 Reductions in SO 2 and NO
x EGU Emission Between 2008 and 2009 ................ 26
Table 9 Reductions in SO 2 and NO
x EGU Emissions Between the First Half of 2008
and 2010....... ..................................................................................................... 26 Table 10 Clark County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 28 Table 11 Greene County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 28 Table 12 Montgomery County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ..... 29 Table 13 Dayton-Springfield Area PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 29 Table 14 Clark County, Ohio NO
x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 29 Table 15 Greene County, Ohio NO
x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 30 Table 16 Montgomery County, Ohio NO
x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 30 Table 17 Dayton-Springfield Area NO
x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 30 Table 18 Clark County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 31 Table 19 Greene County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 31 Table 20 Montgomery County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 31 Table 21 Dayton-Springfield Area SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 32 Table 22 Dayton-Springfield Area Comparison of 2008 attainment year and 2015 and 2022 projected emission estimates (tpy) ............................................................. 32 Table 23 Dayton-Springfield Area Comparison of 2005 base year and 2008 attainment year on-road and EGU reductions ....................................................................... 33iv APPENDICES

A Air Quality System (AQS) Data B Ohio 2005 SIP Base Year Inventory Discussion C Mobile Source Emissions Inventory for the Dayton-Springfield PM 2.5 Nonattainment Area D LADCO Technical Support Document E Incomplete Monitoring Data Substitution Analysis F Public Participation Documentationv This page left intentionally blank1 REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE
DAYTON-SPRINGFIELD
ANNUAL PM 2.5 NONATTAINMENT AREA

Clark, Greene, and Montgomery Counties, Ohio



### CHAPTER ONE

Introduction The Clean Air Act (CAA), as amended, requi res each State with areas failing to meet the National Ambient Air Qualit y Standards (NAAQS) for the annual PM 2.5 1 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 in July 1997. It replaced the existing PM 10 standard with a health-based PM 2.5 standard and retained the PM 10 standard as a particulate standard protecting welfare. The stan dards include an annual standard set at 15.0 microgr ams per cubic meter (μg/m 3 ), based on the 3-year average of annual mean PM 2.5 concentrations, and a 24-hour standard of 65 μg/m 3 , based on the 3-year average of the 98 th percentile of 24-hour
concentrations.

The revised NAAQS was legally challenged in the U.S. Court of Appeals for the
District of Columbia Circuit (the D.C. Circuit). On May 14, 1999, the D.C. Circuit remanded, without vacatur, the standards back to U.S. EPA. The remand did not question the level at which U.S. EPA set the st andards but rather the constitutionality of the CAA provision that authorizes U.S. EPA to set national air quality standards. U.S. EPA requested a rehearing wh ich the D.C. Circuit denied. Therefore, in December 1999, U.S. EPA appealed the D.C. Circuit decision to the U.S. Supreme Court. The U.S. Supreme Court issued a decision on February 27, 2001 that unanimously affi rmed the constitutionality of the CAA provision but did remand several other i ssues back to the D.C. Circuit, including
the issue of whether U.S. EPA acted arbitrarily and capric iously in establishing the specific levels of the standards.

The D.C. Circuit heard arguments in this remanded case in December 2001, and issued its decision on March 26, 2002. The D. C. Circuit rejected the claims that

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 acid s (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 PM 2.5 describes particulate matter that is 2. 5 micrometers in diameter and smaller -
1/30 th the diameter of a human hair. Fine particle pollution can be emitt ed directly or formed secondarily in the atmosphere.2 the U.S. EPA had acted arbitr arily and capriciously in setting the levels of the
standards.

On December 17, 2004, U.S. EPA promulgated the initial PM 2.5 nonattainment areas designations for the PM 2.5 standards across the country. Modifications to those designations were made and an effect ive date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendment s of 1990 which defined five ozone
nonattainment classifications for the ar eas that exceed the NAAQS based on the severity of the ozone levels, PM 2.5 nonattainment designations are simply
labeled “nonattainment.” The CAA Amendments require states with PM 2.5 nonattainment areas to submit a plan within three years of the effective date of the designations (April 5, 2008) detailing how the PM 2.5 standards will be attained by April 5, 2010. Ohio EPA subm itted its attainment demonstration for the entire State of Ohio on July 16, 2008.

Section 107(d)(3)(E) of the CAA allows st ates to request nonattainment areas to be redesignated to attainment provided cert ain criteria are met. The following are
the criteria that must be met in or der for an area to be redesignated from
nonattainment to attainment:

i) A determination that the area has attained the PM 2.5 standard. ii) An approved State Im plementation Plan (SIP) for the area under Section 110(k). iii) A determination that the improvem ent in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Sect ion 110 and Part D requirements
have been met.

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

Geographical Description and Background The current Dayton-Springfield nonattainment area is located in southwest Ohio and includes the following counties: Cla rk, Greene, and Montgom ery. This area is shown in Figure 1 under Chapter Three.

The Dayton-Springfield area has not pr eviously been subject to nonattainment area rulemakings for fine particles.

As a result of the 2005 PM 2.5 designations, U.S. EPA designated the DaytonSpringfield area nonattain ment for the 15.0 μg/m 3 annual standard 2 , and Ohio EPA was required to develop a plan to reduce oxides of nitrogen (NO x ), sulfur

2 There were no monitors in Ohio that violated the 1997 24-hour PM 2.5 standard of 65μg/m 3

.3 dioxide (SO 2 ) and direct PM 2.5 emissions and to demons trate that the area will
meet the federal annual ai r quality standard by April 5, 2010. Ohio’s main PM 2.5 components are primary particles (or ganic carbon, crustal material, and elemental carbon), SO 2 and NO x , which were included in the attainment demonstration analysis. Volatile organi c compounds (VOCs) and ammonia (NH 3 ) were not included in the analysis since t hey were not part of Ohio’s current attainment strategy for PM 2.5 (although controls for VOCs have been implemented for ozone nonattainment). This is consistent with U.S. EPA’s “Clean Air Particle Implementation Rule” [ 74FR 20856] (hereafter referred to as “Implementation Rule”). In the Implem entation Rule U.S. EPA presumes NH3
emissions are not a PM 2.5 attainment plan precurso r and that States are not required to address VOC unless the State or U.S. EPA makes technical
demonstration that emissions of VOCs si gnificantly contribute to nonattainment
of the annual PM 2.5 standard.

This document is intended to support Ohio ’s request that the Dayton-Springfield area be redesignated from nonattainment to attainment for the annual PM 2.5 standard.

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

### CHAPTER TWO

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

Below is a summary of each redesignat ion criterion as it applies to the Dayton-Springfield 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 am bient air quality data. The data
that are used to demonstrate atta inment should be the product of ambient monitoring that is repr esentative of t he area of highest
concentration. The data should be collected and quality-assured
in accordance with 40 CFR 58 and recorded in the Air Quality System (AQS) in order for it to be avail able to the public for review.

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

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

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

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

• NO x SIP Call Rules

In addition, since the initial designations were made federally
enforceable consent decrees hav e resulted in reductions in
emissions from utilities across the state.

Chapters Four and Five discuss this requirement in more detail.

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

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

i.) Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Secti on 110(a)(2) provides that the implementation plan submitt ed by a state must have been adopted by the state after reasonable public notice and hearing, and that, among other things, it must include
enforceable emission limitat ions and other control measures, means or techniques necessary to meet the requirements of the CAA; pr ovide for establishment and operation of appropriate dev ices, methods, systems and procedures necessary to m onitor ambient air quality; provide for implementation of a source permit program to regulate the modification and c onstruction of any stationary
source within the areas cove red by the plan; include provisions for the implementati on of Part C, prevention of significant deterioration (PSD) and Part D, NSR permit programs; include criteria fo r stationary source emission control measures, monito ring, and reporting; include provisions for air quality mode ling; and provides 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, Ohio6 verified that the State fulfills the requirements of Section 110(a)(2) of the Act.

Section 110(a)(2)(D) also requi res State plans to prohibit
emissions from within t he State which contribute significantly to nonattainment or maintenance areas in any other State, or which interf ere with programs under Part C to prevent significant deterio ration of air quality or to achieve reasonable progress towa rd the national visibility goal for Federal class I areas (national parks and wilderness areas). In order to assist States in addressing their obligations regarding r egionally transported pollution,
U.S. EPA finalized CAIR to reduce SO 2 and NO x emissions from large electric generating units (EGU). Ohio has met the requirements of the f ederal CAIR to reduce NO x and
SO 2 emissions contributing to downwind states. On February 1, 2008, U.S. EPA approved Ohio’s CAIR program, which can be found in Ohio Administrative Code (OAC) Chapter 3745-109 3 . On July 6, 2010, U.S. EPA proposed a replacement to the CAIR program, the Transport Rule. [75 FR 45210] Upon finalization, it will
further assist States in addressing their obligations regarding regionally transport ed pollution by providing
reductions in NO x and SO 2 emissions in 2012 and 2014.

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

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

3 http://www. epa.ohio.gov/dapc/regs /regs.aspx#3745-1097 redesignation request, the state must commit to follow U.S. EPA’s conformity regulation upon issuance, as applicable.

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

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

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

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

Chapter Six discusses this requirement in more detail.8 

### CHAPTER THREE

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

Requirement 1 of 4 A demonstration that the NAAQS for annual PM 2.5 , as published in 40 CFR 50.7,
has been attained.

Background
There are three m onitors measuring PM 2.5 concentrations in this nonattainment area, with are operated by the Regional Air Pollution Control Agency (RAPCA) 4 , which is part of the Montgomery County Health Depar tment. A listing of the design values based on the three-y ear average of the annual mean concentrations from 2008 through 2010 is shown in Table 1. The locations of the monitoring site s for this nonattainment area are shown on Figure 1.

4 RAPCA is a Local Air Agency that contracts with Ohio EPA and receives grants from U.S. EPA to enforce state and local air pollution c ontrol regulations in the six-count y region (Preble, Darke, Miami, Montgomery, Clarke, and Greene).9 Demonstration

Figure 1 - Map of the Dayton-Springfield nonattainment area and
monitor locations

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

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

Requirement 3 of 4 A showing that the three-year av erage of the annual mean values, based on data from all monitoring sites in the ar ea or its affected downwind environs, are below 15.0 μg/m 3 . (This showing must rely on three complete, consecutive calendar years of quality assured data.)10 Background The following information is taken from U.S. EPA's "Guidelineon Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999.

In accordance with the CAA Amendm ents, three comp lete years of monitoring data are required to demonstrate attainment at a monitoring site. The annual PM 2.5 primary and secondary ambient air quality standards are met at an ambient air quality monitoring site when the three-year aver age of the annual average is less than 15.0 μg/m 3 . While calculating design values, three significant digits must be carried in the co mputations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, and those less than 0. 05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than, or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard; values equal to or greater than 15.1 μg/m 3 exceed the standard. An area is in comp liance with the annual PM 2.5 NAAQS only if every monitoring site in the area meets the NAAQS. An individual site's 3-year average of the annual average concentrations is also called the site's design value. T he 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. The air quality design value for the area is the highest design value among all sites in the area.11 Demonstration

Table 1 - Monitoring Data for the Dayton-Springfield area for 2008
– 2010

Average

2008 2009 2010 2008-2010
39-023-0005 Clark 12.7 12.4 13.1 12.7

39-057-0005 Greene 11.6 11.5 13.2 12.1 39-113-0032 Montgomery 13.2 12.4 14.0 13.2 Less than 75% capture in at least one quarter Annual Standard

Site County Year

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

The design values calculated for the Dayton-Springfield area shows that
the annual PM 2.5 NAAQS has been attained. However, the monitor site in Greene County (site 39-057-0005) did not meet the 75% data capture requirement in 2010 although it should be noted it has t he lowest threeyear average of all sites in this area for PM 2.5 , in this area. Specifically, the third quarter of 2010 achieved only 45% capture due to roofing repairs necessitated by the property owner between August 12, 2010 and September 29, 2010.

Under 40 CFR Part 50, Appendix N, t he use of less than complete data may be approved by U.S. EPA consider ing such factors as monitoring site closures/moves, monitoring d iligence, and nearby concentrations in determining whether to use such data. As noted above, construction at the property necessitated temporary su spension of monitoring activities. This site has historically been a low m onitoring site. Since 2005, this site has always met the 75% data capture requirement with the exception of this third quarter of 2010. The design values for the previous three-year periods have also shown attain ment of the st andard: 13.6 μg /m 3 for the 2005 to 2007 period, 12.3 μg /m 3 for the 2006 to 2008 period, and 12.1 μg
/m 3 for the 2007 to 2009 period. However, in order to further demonstrate
that this monitor has attai ned the standard, Ohio EPA prepared a statistical analysis using multiple imputations. Ohio EPA has imputed missing values for this site and t hen done an ordinary analysis as if the imputed values were real measurem ents. Multiple imputations use
random draws from the conditional distri bution 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 av erage (2008 to 2010) of the annual mean values, based on missing data imputations, is below 15.0 μg/m 3

.

Table 2 shows site 39-057-0005 befor e and after the imputation of12 missing data. Also the “new” site ( with imputed values) shows a passing design value for 2008 to 2010 of 11.8 μg/m 3

.

Table 2 – Comparison Between Original and Imputed Values for
Monitor 39-057-0005 from 2004 to 2010

Annual Design Value

Site Year 2004

‐ 2006 2005

‐ 2007 2006

‐ 2008 2007

‐ 2009 2008

‐ 2010 2004 2005 2006 2007 2008 2009 2010

OLD 39

‐ 057

‐ 0005 12.1 15.5 11.9 13.3 11.6 11.5 13.2 13.2 13.6 12.3 12.1 12.1

NEW 39

‐ 057

‐ 0005 11.7 15.2 11.9 13.5 11.6 11.5 12.2 12.9 13.5 12.3 12.2 11.8

incomplete data (quarter with <75% capture)

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

National monitoring for PM 2.5 began in 1999. With respect to each of the Lake Michigan Air Directors Consortium (LADCO) states, there has been a clear downward trend in design values:

Figure 2 - PM 2.5 Annual Mean Trends LADCO States

Source: LADCO; Recent Ozone and PM2.5 Trends – Aug 26 2010.pptx

The same trend can be seen within the Midwest States as a whole:13 Figure 3 - PM 2.5 Annual Mean Trends Midwest States

Source: LADCO; Recent Ozone and PM25 Trends - Aug 26 2010.pptx

Design values have also trended downward nationally:

Figure 4 - PM 2.5 Annual Mean National Trends

Source: http://www. epa.gov/airtrends/pm.html14 Requirement 4 of 4 A commitment that once redesignated, the state will cont inue to operate an appropriate monitoring network to verify the maintenance of the attainment

status.

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

5 www. epa.ohio.gov/dapc15 

### CHAPTER FOUR

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

U.S. EPA’s redesignation guidance require s the submittal of a comprehensive inventory of PM 2.5 precursor emissions (primary par ticles (organic carbon, crustal matter, and elemental carbon), SO 2 and NO x 6 ) representative of the year when
the area achieves attainment of the annual PM 2.5 air quality standard. Ohio also
must demonstrate that the improvement in air qualit y between the year that
violations occurred and the year that attainment was achieved is based on permanent and enforceable em ission reductions. Other emission inventory related requirements include a projection of the emission invent ory to a year at least 10 years following redesignation; a demonstration that t he projected level
of emissions is sufficient to maintain the annual PM 2.5 standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the 10-year maintenance period.

The emissions inventory development and emissions projection discussion below, with the exception of the mob ile (on-road) emi ssions inventory and projections, identifies procedures us ed by Ohio EPA and the LADCO regarding
emissions of all the count ies in the Dayton-Springfie ld area. All of these inventories and emissions projecti ons were prepared using similar methodologies. Mobile emissions invent ories and projections for all counties were prepared by the Ohio Department of Transportation (ODOT) and the Miami Valley Regional Planning Commission (MVRPC) 7

.

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

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

area.

6 VOC and NH 3 are not addressed. 7 The Dayton-Springfield Annual PM2.5 nonattainment ar ea is comprised of the counties of Clark, Greene, and Montgomery. Clark County Springf ield Transportation Coordinating Committee (CCS-TCC) serves as the Metropolitan Planning Organization (MPO) for Clark County while MVRPC serves as the MPO for the remainder counties: Greene and Montgomery.16 Periodic inventories, which incl ude emissions from all sectors - mobile, area, non-road, and point sources - are prepared every three years.

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

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

Background Ohio EPA prepared a comprehensive inv entory for the Dayton-Springfield area including area, mobile, and point sources for PM 2.5 , SO 2 and NO x for base year 2005. The 2005 inventory wa s submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM 2.5 attainment demonstration SIP for this
area. The information below describes the procedures Ohio EPA used to generate the 2005 base year invent ory and to develop SIP-ready modeling inventories and future y ear projections (Pechan Report 8 ) 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 in ventories were provided to the LADCO and have been processed to develop average daily emissions for use in the air quality analyses. Thes e processed modeling inventories
have been identified as the correct iterat ion of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organizati on. Note, the on-road mobile
source sector was addr essed by specific PM 2.5 and NO x modeling as
discussed below.

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

8 http://www.ladco.org/tech/emis/r5/r eports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con trols%20Report_Final.pdf17 • Mobile source emissions were calculated from MOVES2010 -produced emission factors. Only PM 2.5 and
NO x necessitate emissions inventory analysis. As
documented in Ohio EPA’s atta inment demonstration SIP,
Ohio EPA in consultation with U.S. EPA determined mobile sources are insignificant contributors for SO 2 . Consistent with Ohio EPA’s attainment demonstration, Ohio EPA
continues to consider mobile source SO 2 to be an insignificant contributor to fine particles for this
nonattainment area. Based on the demonstration below,
SO 2 constitutes less than four percent (<4%) of the area’s
total SO 2 emissions in 2005 (3.8%), 2008 (1.3%), 2015 (0.6%) and 2022 (0.6%).

• Point source information wa s compiled from Ohio EPA’s
2005 annual emissions inv entory database and the 2005
U.S. EPA Air Markets acid rain database 9

.

• Biogenic emissions are not included in these summaries.

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

Demonstration

On-Road Emission Estimations In coordination with the ODOT, MV RPC utilizes a regional travel
demand forecast model to simulate traffic in the area and to forecast traffic flows for given growth expectations. The model has been validated to observed traffic volumes for the model base year 2000 (CCS-TCC) or year 2005 (MVRPC) depending on available data. The model is primarily us ed as a long range planning tool to evaluate the transportation system including determination of

9 http://www. epa.gov/airmarkets/acidrain18 locations where additional trav el capacity may be needed and to determine the infrastructure require ments necessary to meet that
need. It is also used as a tool fo r air quality purposes to estimate the total emissions of pollution caus ed by vehicles in the area. The travel demand forecasting model is used to predict traffic volumes vehicle miles traveled (VMT), vehicle trips, and a U.S. EPA computer program called MOVES is used to calculate emissions per mile. The product of these is the total amount of pollution emitted by the on-road vehicles for the area.

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

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

U.S. EPA believes that MOVES s hould 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 ava ilable when a SIP is developed.

10 http://www.r egulations.gov/search/Regs/hom e.html#document Detail?R=0900006480ab1f9819 Regarding transportation confo rmity, 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 appr oach (when compared with the previous MOBILE model) to mode ling allows U.S. EPA to easily incorporate large amount s of in-use data from a wide variety of sources, such as data from vehicle inspection and maintenance (I/M) programs, remote sensing dev ice (RSD) testing, certification testing, portable emission meas urement systems (PEMS), etc. This approach also allows users to incorporate a variety of activity
data to better estimate emissi on differences such as those resulting from changes to vehicle speed and acceleration patterns. MOVES has a graphical user interfac e which allows users to more easily set up and run the m odel. MOVES database-centered design provides users much gr eater flexibility regarding output
choices. Unlike earlier models whic h provided emission factors in grams-per-mile in fixed output formats, MOVES output can be expressed as total mass (in tons, pounds, kilograms, or grams) or as emission factors (grams-pe r-mile and in some cases gramsper-vehicle). Output can be easily aggregated or disaggregated to examine emissions in a range of scales, from national emissions impacts down to the emissions impac ts of individual transportation projects. The database-centered des ign also allows U.S. EPA to update emissions data incorporat ed in MOVES more easily and will allow users to incorporate a mu ch wider array of activity data to improve estimation of loca l emissions. For example, the improvements in MOVES will allow project-level PM 2.5 emissions
to be estimated.

CCS-TCC and MVRPC maintain regional travel demand forecasting models for use in the urban transportation planning process. The models employ t he traditional four step modeling process to project existing and fu ture traffic volumes and travel patterns on the regional transporta tion network. The four step process consists of trip generation, trip distribution, modal split, and route assignment. Output from the urban models is link-by-link
directional 24-hour traffic volumes.

During 2000-2002 MVRPC, in cooperat ion with the Ohio Kentucky Indiana Regional Council of Governm ents (OKI), updated its travel demand model. The new model includes the combined regions under the jurisdictions of OKI and MVRPC. In 2005, the combined model was updated again to incorporate the results of a household interview survey in the MV RPC Region, change the model interface to Cube Voyager, and im prove model functionality. The20 changes primarily affected trip gener ation distribution functions in the MVRPC Region. In 2007 in preparation for the 2008 Transportation Plan Update the m odel was validated using circa
2005 traffic counts. The 2005 Cube Vo yager model with the latest planning assumptions (networks and socio-economic data) is used
to calculate 2005-2022 emissions in the MVRPC Region. Similarly, the Springfield Region also has a new travel demand model that combined with the latest planni ng assumptions was used to generate emissions in Clark C ounty. The new travel demand
model now covers all of Cla rk County and was validated in
December 2005. More details on the use of MOVES are found on Appendix C.

Travel analysis zones are the basic geographic unit for estimating travel in the Dayton-Springfield model. A variety of socioeconomic
data items are used in the Da yton-Springfield transportation planning process. These data are used primarily to forecast future travel patterns by serving as independent variables in DaytonSpringfield trip generation equations.

The principal data requirements of the Dayton-Springfield travel demand forecasting model are popul ation and employment, from
these variables other characte ristics including household, labor force, and personal vehicles may be derived.

Both CCS-TCC and MVRPC’s socioeconomic model variables reflect the current and expect ed future regional land uses. Independent variables are available for 4 analysis years (2000, 2005, 2010, and 2030) and the travel demand model has the ability of interpolating data for any year between available data sets. A summary of MVRPC’s soci o-economic data is available in Appendix C - Table 5. From that Table, population and households are expected to decline over t he planning period with employment making modest gains through 2010 and then remaining fairly constant until 2030. Both popul ation and employment are expected to decline in the older urban areas of the region as the trend to develop in the suburban fr inges and rural areas continues.Appendix C - Table 6 shows a summary of CCS-TCC’s socioeconomic data. This summary show s a slight decline in population, while households and employment show a moderate gain.

Dayton-Springfield model uses OKI’s Travel Demand Model, which
has been validated to observed traffi c volumes for the model base year 2005. The modeling netwo rk encompasses the entire PM 2.5 nonattainment area. The modeling network also includes Greene, Miami and Montgomery counties in Ohio and the remainder of21 Dearborn County, Indiana. The differences between estimated vehicle miles traveled (VMT) and 2005 observed VMT is less than 1%. A highway screenline analysi s compares the screenline
observed and simulated traffic vo lume discrepancies with the Ohio Department of Transportation (ODOT) standard of maximum desirable deviation. The compar ison shows that the model performs at a satisfactory level and all the errors were under the ODOT curve (OKI’s 2007 report, “OKI/MVRPC Travel Demand Model Methodology/Validation Report”).

Total emissions (post processing) were computed with the aid of several custom programs by OD OT. The process uses data on daily and directional traffic distribut ions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM). This process also uses rewritten code able to handle the
newer model network forma ts and MOVES generated emission
factors.

On-Road Mobile Emission Estimations Tables 3 through 6 contain the result s of the emissions analysis for the appropriate years. All emissions esti mations are expressed in tons per year (tpy).

Table 3 - Clark County, Emissions Estimations for On-Road
Mobile Sources

2005* 2008 2015 2022

PM 2.5 (tpy) 165.42 138.01 68.73 42.74

NO x (tpy) 5,636.55 4,598.38 2,393.85 1,166.50

SO 2 (tpy) 83.66 26.06 11.46 11.06 *2005 emissions include I/M program

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

2005* 2008 2015 2022

PM 2.5 (tpy) 166.48 140.31 67.89 45.22

NO x (tpy) 5,330.02 4,334.23 2,112.11 1,043.75

SO 2 (tpy) 81.69 25.62 10.69 10.84 *2005 emissions include I/M program

Table 5 – Montgomery County, Emissions Estimations for OnRoad Mobile Sources22 2005* 2008 2015 2022

PM 2.5 (tpy) 539.18 446.43 215.06 139.28

NO x (tpy) 17,089.70 13,721.08 6,681.47 3,242.48

SO 2 (tpy) 258.31 79.79 32.81 32.23 *2005 emissions include I/M program

Table 6 – Emissions Estimations Totals for On-Road Mobile Sources for the Dayton-Springfield Area

2005* 2008 2015 2022

PM 2.5 (tpy) 871.08 724.75 351.68 227.24

NO x (tpy) 28,056.27 22,653.69 11,187.43 5,452.73

SO 2 (tpy) 423.66 131.47 54.96 54.13 *2005 emissions include I/M program

Motor Vehicle Emission Budget

Table 7 contains the motor v ehicle emissions budgets for the Dayton-Springfield area.

Table 7 - 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) 351.68 52.75 404.43 227.24 34.09 261.33 NOx (tpy) 11,187.43 1,678.11 12,865.54 5,452.73 817.91 6,270.64 *The 15 percent margin of safety was calculated by taking 15 percent of the mobile source emission
estimates.

The above budgets for the Dayton- Springfield area, agreed upon as part of the interagency cons ultation process, include the emission estimates calculated for 2015 and 2022 (from Table 6) with an additional 15 percent margin of safety allocated to PM 2.5 and NO x 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 wit h U.S. EPA to determine a reasonable approach to address this variation. Based on this discussion, a 15 percent margin of safety allocation was agreed upon and has been added to the emissions estimates for this
nonattainment area.

All methodologies, the latest planni ng assumptions, and the safety margins allocations were determined through the interagency23 consultation process described in the Transportation Conformity Memorandum of Understanding (MOU) among MVRPC, Ohio DOT, and Ohio EPA.

A 15 percent margin of safety is appropriate because: 1) there is an acknowledged potential variation in VMT forecast and potential
estimated mobile source emissi ons due to expected modifications
to TDM and mobile emissions model s; and 2) the to tal decrease in
emissions from all sources is su fficient to accommodate this 15 percent allocation of safety margin (as defined in 40 CFR
93.101 11 ) to mobile sources while still continuing to maintain the total emissions in the Dayton-Spri ngfield area well below the 2008
attainment level of emissions.

The 15 percent margin of safety was calculated by taking 15 percent of the mobile source emi ssion estimates. 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 emissi on reduction from all sources as
can be seen from Table 22.

In summary, the mobile budget safety margin allocation translates into an additional 52.75 tpy for PM 2.5 and 1,678.11 tpy for NO x for 2015 and an additional 34.09 tpy for PM 2.5 and 817.91 tpy for NO x for 2022.

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

area.

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

Finally, it is important to underline that all motor vehicle emission budgets in this redesignation s ubmittal, which are based on MOVES2010, will replace previous motor vehicle emission budgets on Attainment Demonstr ation submittals based on
MOBILE6.2.

11 "Safety margin" means t he amount by which the total projected em issions from all sources of a given pollutant are less than the total em issions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance.24 Requirement 3 of 5 A demonstration that the projec ted level of emissions is sufficient to maintain the
PM 2.5 standard.

Background In consultation with U.S. EPA, Ohio EPA selected the year 2022 as the maintenance year for th is redesignation request. This document contains projected em issions inventories for 2015 and
2022.

Emission projections for the Dayton-Springfield area were performed using the following approaches:

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

• Emissions inventories are requi red to be projected to future dates to assess the influence growth and future controls will have. LADCO has developed grow th and control files for point, area, and non-road categorie s. These files were used to develop the future-year emissions estimates used in this
document. This was done so the inventories used for redesignation are consistent with modeling performed in the future. Appendix D contains LADCO’s technical support document detailing the analysis used to project emissions (Base M 12 ).

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

12 http://www.ladco.org/tech/emis/current/i ndex.php25 The detailed inventory information for Dayton-Springfield area for 2005 is in Appendix B. Emissi on trends are an important gauge for continued compliance with the PM 2.5 standard. Therefore, Ohio EPA performed an initial comparison of the inventories for the base year and maintenance years. Mobile source emission inventories are described in Section 5 of Appendix B.

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

Ohio EPA is identifying emissi ons projections for 2015 and 2022 for EGUs without the implementati on of the CAIR program. U.S. EPA has raised concerns regardi ng the CAIR program and its
remand. As discussed below , with the proposed CAIR replacement, the Transport Rule , Ohio EPA believes additional reductions will be occurring in the future.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28
eastern states and the District of Columbia to significantly reduce
emissions of NO x and SO 2 . CAIR replaced the NOx SIP Call for
EGUs. The intent of the CAIR program is for national NO x emissions to be cut from 4.5 milli on tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were required to submit a CA IR SIP as part of this effort.
Ohio submitted a CAIR SIP wh ich was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final action on Sept ember 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA projec ts that in 2009 emissions of NO x will decrease from a baseline of 264,000 tons per year to 93,000 tons per year while in 2010 emissions of SO 2 will decrease from a baseline of 1,373,000 tons per y ear to 298,000 tons per year, within Ohio. And by 2015 U.S. EPA projects emissions of NO x will decrease to 83,000 tons per y ear while emissions of SO 2 will decrease to 208,000 tons per year, within Ohio 13

.

On December 23, 2008, U.S. EPA’ s CAIR program was remanded without vacatur by the D.C. Circu it Court. As mentioned above, Ohio EPA has not incorporated t hese expected CAIR reductions into this redesignation request. It should also be noted that Ohio’s SIP-approved NOx SIP Ca ll program and regulat ions are still in

13 http://www. epa.gov/CAIR/oh.html26 place. Ohio EPA is currently in the process of revising these regulations to provide a “back st op” for the reinst atement of the NOx SIP Call program in the event the CAIR program, or an equivalent, is no longer implemented by U.S. EPA.

As can be seen in Table 8 below, Ohio has seen a significant decline in the 264, 000 tons of NO x and 1,373,000 tons of SO 2 emitted in 2005. In 2008 and 2009 facilities began preparing for and implementing control programs to address CAIR 14 and
consent decrees.

Table 8 - Reductions in SO 2 and NO x EGU Emissions Between
2008 and 2009

SO 2 NO
x 2008 2009 Change 2008 2009 Change

Ohio 709,444 601,101 15% 235,018 96,351 59%
LADCO States 2,019,036 1,620,071 20% 702,384 393,930 44%
National 7,616,262 5,747,353 25% 2,996,287 1,990,385 34% Source: Clean Air Markets Quarterly Emissions Tracking 15

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

Table 9 – Reductions in SO 2 and NO x EGU Emissions
Between the First Half of 2008 and 2010

SO 2 NO
x 2008 (1 st half) 2010 (1 st half) Change 2008 (1 st half) 2010 (1 st half) Change

Ohio 373,798 279,854 25% 130,598 53,187 59%
LADCO States 1,190,497 854,282 28% 419,114 220,907 47%
National 3,895,472 2,502,965 36% 1,487,179 930,148 37% Source: Clean Air Markets Quarterly Emissions Tracking 16

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

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

14 Under CAIR, NOx reductions are to occur begi nning in 2009 while SO2 reductions are to occur beginning in 2010.
15 http://www. epa.gov/airmarkets/quarterlytracking.html
16 http://www. epa.gov/airmarkets/quarterlytracking.html27 have continued to operate, helping to drive continued progress in reducing emissions.” 17

On July 6, 2010, U.S. EPA propos ed a replacement to the CAIR program, the Transport Rule. [75 FR 45210] U.S. EPA intends to finalize the Transport Rule in time for reductions to begin in 2012. As proposed, the Transport Rule will preserve those initial
reductions achieved under CAIR and provide more reductions in
NO x and SO 2 emissions in 2012 and 2014, ahead of the 2015
CAIR Phase 2.

Ohio EPA is in agreement with t he analysis by U.S. EPA that the CAIR program is providing real reductions at this time, Ohio EPA
believes these reductions have assisted with PM 2.5 attainment in
this nonattainment ar ea and throughout Ohio. It is also Ohio EPA’s belief that the Transport Rule, when finalized, will continue to provide the necessary reduc tions, and likely even greater reductions, that will be necessary for maintenance of the annual
PM 2.5 standard to occur. As stat ed by U.S. EPA regarding the proposed Transport Rule, “the result s of the air quality modeling
indicate that all but one site 18 is projected to be in attainment and only one site 19 is projected to have a maintenance problem for
annual PM2.5 in 2014 with the em issions reductions expected from this proposal.” [75 FR 45345] Furthermore, modeling conducted as part of the Transpor t Rule projects the counties
within this area will not have maintenance issues in 2014 even without the Transport Rule (or CAIR) 20

.

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

The Ohio emissions data in t he tables below are based on the following data sources:
- All On-Road data source: The MVRPC and the ODOT’s Division of Transportation Syst em Development-Modeling and Forecasting Section.
- 2008 EGU and non-EGU: Ohio EPA’s 2008 annual emissions inventory database.
- All other data source: Lake Mich igan Air Directors Consortium (LADCO).

17 http://www. epa.gov/airmarkets/background.htm
18 Allegheny, PA
19 Birmingham, AL 20 See supplemental table “Impac ts of the Proposed Transport Rule on Counties with Monitors Projected to have Ozone and/or Fine Particle Air Quality Problems.”28 Demonstration

PM 2.5

Table 10 - Clark County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 3.16 2.40 2.19 2.11 0.29

Non-road 66.40 56.55 37.85 18.75 37.80

Area 132.50 134.97 133.93 131.76 3.21

MAR 9.96 9.04 5.84 2.74 6.30

On-road 165.42 138.01 68.73 42.74 95.27

TOTAL 377.44 340.97 248.54 198.10 142.87

Table 11 - Greene County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 96.44 101.90 116.95 131.79

‐ 29.89

Non-road 92.72 79.01 52.29 25.07 53.94

Area 133.39 135.86 134.65 134.09 1.77

MAR 2.12 1.83 1.04 0.27 1.56

On-road 166.48 140.31 67.89 45.22 95.09

TOTAL 491.15 458.91 372.82 336.44 122.47

Table 12 - Montgomery County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR29 Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 173.19 173.28 182.74 190.49

‐ 17.21

Non-EGU 110.86 126.55 117.01 112.92 13.63

Non-road 232.23 199.93 141.92 82.28 117.65

Area 435.20 445.64 443.65 437.26 8.38

MAR 25.91 23.57 14.76 6.27 17.30

On-road 539.18 446.43 215.06 139.28 307.15

TOTAL 1,516.57 1,415.40 1,115.14 968.50 446.90

Table 13 – Dayton-Springfield Area PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and projected 2015 and 2022 (tpy) – Without CAIR

PM2.5 2005
Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

Clark 377.44 340.97 248.54 198.10 142.87

Greene 491.15 458.91 372.82 336.44 122.47

Montgomery 1,516.5

7 1,415.40 1,115.14 968.50 446.90

COMBINED

PM 2.5 TOTAL 2,385.1

6 2,215.28 1,736.50 1,503.04 712.24

NO x

Table 14 - Clark County, Ohio NO x 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 52.22 53.04 55.75 58.30

‐ 5.26

Non-road 806.83 686.72 439.04 188.29 498.43

Area 554.05 560.20 564.02 568.84

‐ 8.64

MAR 277.53 261.32 177.64 98.27 163.05

On-road 5,636.55 4,598.38 2,393.85 1,166.50 3,431.88

TOTAL 7,327.18 6,159.66 3,630.30 2,080.20 4,079.4630 Table 15 - Greene County, Ohio NO x 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 2,530.80 2,671.64 2,910.81 3,186.30

‐ 514.66

Non-road 1,016.05 881.39 565.19 249.19 632.20

Area 504.30 509.58 512.17 515.68

‐ 6.10

MAR 67.80 62.60 40.66 19.65 42.95

On-road 5,330.02 4,334.23 2,112.11 1,043.75 3,290.48

TOTAL 9,448.97 8,459.44 6,140.94 5,014.57 3,444.87

Table 16 - Montgomery County, Ohio NO x 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 2,835.31 1,870.13 1,717.61 1,224.22 645.91

Non-EGU 1,481.03 1,513.71 1,491.85 1,466.81 46.90

Non-road 3,141.22 2,607.86 1,586.11 543.42 2064.44

Area 1,886.52 1,907.49 1,921.02 1,937.87

‐ 30.38

MAR 931.14 879.59 606.49 347.74 531.85

On-road 17,089.70 13,721.08 6,681.47 3,242.48 10,478.60

TOTAL 27,364.92 22,499.86 14,004.55 8,762.54 13,737.32

Table 17 - Dayton-Springfield Area NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - Without CAIR

NOx 2005
Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

Clark 7,327.18 6,159.66 3,630.30 2,080.20 4,079.46

Greene 9,448.97 8,459.44 6,140.94 5,014.57 3,444.87

Montgomery 27,364.92 22,499.86 14,004.55 8,762.54 13,737.32

COMBINED
NOx TOTAL 44,141.07 37,118.96 23,775.79 15,857.31 21,261.65

SO 231 Table 18 - Clark County, Ohio SO 2 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 12.94 13.12 13.56 13.99

‐ 0.87

Non-road 80.70 29.69 4.80 0.85 28.84

Area 79.06 77.92 74.27 70.71 7.21

MAR 22.45 22.08 17.55 13.36 8.72

On-road 83.66 26.06 11.46 11.06 15.00

TOTAL 278.81 168.87 121.64 109.97 58.90

Table 19 - Greene County, Ohio SO 2 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 2,046.74 2,116.50 2,248.36 2,304.87

‐ 188.37

Non-road 122.29 44.78 6.98 1.00 43.78

Area 87.71 86.36 81.72 77.23 9.13

MAR 5.76 5.63 4.46 3.37 2.26

On-road 81.69 25.62 10.69 10.84 14.78

TOTAL 2,344.19 2,278.89 2,352.21 2,397.31

‐ 118.42

Table 20 - Montgomery County, Ohio SO 2 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 5,914.75 5,069.93 5,176.34 4,900.70 169.23

Non-EGU 1,883.72 1,865.78 1,870.70 1,876.61

‐ 10.83

Non-road 307.32 112.67 18.33 3.59 109.08

Area 206.17 203.43 197.26 191.07 12.36

MAR 83.13 81.86 64.71 48.88 32.98

On-road 258.31 79.79 32.81 32.23 47.56

TOTAL 8,653.40 7,413.46 7,360.15 7,053.08 360.38

Table 21 - Dayton-Springfield Area SO 2 Emission Inventory Totals32 for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) - Without CAIR

SO2 2005
Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

Clark 278.81 168.87 121.64 109.97 58.90

Greene 2,344.19 2,278.89 2,352.21 2,397.31

‐ 118.42

Montgomery 8,653.40 7,413.46 7,360.15 7,053.08 360.38

COMBINED
SO2 TOTAL 11,276.40 9,861.22 9,834.00 9,560.36 300.86

PM 2.5 , NO x , and SO 2

Table 22 - Dayton-Springfield Area Comparison of 2008 attainment year and 2015 and 2022 projected emission estimates (tpy)

2008
Base 2015
Interim 2015 Projected
Decrease 2022
Maintenance 2022 Projected
Decrease

PM 2.5 2,215.28 1,736.50 478.78 1,503.04 712.24

NO
x 37,118.96 23,775.79 13,343.17 15,857.31 21,261.65

SO 2 9,861.22 9,834.00 27.22 9,560.36 300.86

As shown in the t able above (Table 22), PM 2.5 emissions in the nonattainment area are projected to decrease by 478.78 tpy in 2015 and 712.24 tpy in 2022. NO x emissions in the nonattainment area are projected to decr ease by 13,343.17 tpy in 2015 and 21,261.65 tpy in 2022. SO 2 emissions in the nonattainment area are projected to decrease by 27.22 tpy in 2015 and 300.86 tpy in
2022.

In some cases, area source em issions and point sources show an 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 t he Transport Rule will be implemented in 2012 and 2014 and t hese programs should cause an overall drop in all three pollu tants emissions. Decreases from U.S. EPA rules covering Tier 2 Mo tor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 21 , Highway Heavy-Duty Engine Rule 22 , and the Non-Road Diesel Engine Rule 23 are factored into the changes.

21 http://www. epa.gov/fedrgstr/EPA-AIR/2000/ February/Day-10/a19a.htm 22 http://www. epa.gov/fedrgstr/EPA-AIR/1997 /October/Day-21/a27494.htm 23 http://www. epa.gov/fedrgstr/EPA-AIR/1998 /October/Day-23/a24836.htm33 All projections (PM 2.5 , SO 2 , and NO x ) do not take into account reductions expected from the CAIR. In many cases, Ohio utilities subject to CAIR have already, or will be installing controls and reducing NO x and SO 2 emissions beyond those projected for
EGU’s above.

As can be seen from the project ed decreases above, even in the
absence of consideration of reduc tions resulting from CAIR, and its future replacement, the Trans port Rule, the area will be able to
maintain the standard.

Requirement 4 of 5
A demonstration that improvement in air quality bet ween the year violations occurred and the year attainment wa s achieved is based on permanent and
enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

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

Demonstration
Permanent and enforceable reductions of PM 2.5 , NO x , and SO 2 emissions
have contributed to the attainment of the annual PM 2.5 standard. Some of these reductions were due to the applic ation of tighter federal standards on new vehicles. Also Title IV of the CAA, the NO x SIP Call, CAIR, and
federal consent decrees r equired the reductions of SO 2 and NO x emissions from utility sources. Reductions achieved are discussed in greater detail under Chapter Five.

Table 23 - Dayton-Springfield Area Comparison of 2005 base year and 2008 attainment year on-road and EGU reductions

2005 2008
On-road PM 2.5 871.08 724.75
On-road NO
x 28,056.27 22,653.69
On-road SO 2 423.66 131.47
EGU PM 2.5 173.19 173.28
EGU NO
x 2,835.31 1,870.13
EGU SO 2 5,914.75 5,069.9334 Requirement 5 of 5 Provisions for future annual updates of the inventory to enable tracking of the emission levels, including an annual emissi on statement from major sources.

Demonstration In Ohio, major point sources in a ll counties are required to submit air emissions information annually, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic inventory for all PM 2.5 precursor emission sectors every three years. These PM 2.5 precursor inventories will be prepared for future years as necessary to comply with the inventory reporting requirement s established in the CFR. Emissions information will be compared to the 2005 base year and the 2022 projected maintenance y ear inventories to assess emission trends, as necessary, and to assure continued compliance with the annual PM 2.5 standard.35 

### CHAPTER FIVE

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

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

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

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

The Implementation Rule also prov ides for a presumption that in
States that fulfill their CAIR em ission reduction requirements, EGU compliance with CAIR is equivalent to RACM/RACT.

Demonstration In 1972, 1980, and 1991, Ohio promulgated rules requiring reasonably available control 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 wit h monitoring, recordkeeping, and reporting necessary to ensur e ongoing compliance. Ohio EPA
also has an active enforcement program to address violations36 discovered by field office staff. The Ohio RACT rules are found in OAC Chapter 3745-17 24

.

In addition, Ohio EPA promulgated NO x SIP Call rules (OAC Chapter 3745-14 25 ), CAIR (OAC Chapter 3745-109 26 ), and NO x Reasonably Available Control Technology rules (OAC Chapter
3745-110 27 ) over the past five years. Emissions from EGUs make up a significant contribution to Ohio ’s inventory. Beginning in 2009, Ohio implemented CAIR which has, and will, provide for significant
reductions in NO x , PM 2.5 , and SO 2 until such time it is replaced by U.S. EPA’s proposed Transport Rule . Then the Transport Rule will provide for even greater reductions.

As part of a larger initiative , LADCO, in consultation with two contractors, performed a series of studies exploring control measures for reducing bot h ozone precursors and PM 2.5 precursors in Ohio, Illinois, I ndiana, Michigan, and Wisconsin area. The first consultant, MACTEC, pr epared a series of white papers 28 researching different stationary source categories. The results were compiled into two reports 29 . The second consultant, Environ, investigated control options for m obile sources. The results were compiled into two reports 30 . The stationary and mobile source sectors (and associated control m easures) were selected by the
LADCO States based on several fa ctors presented in the report (See Chapter 2).

Photochemical modeling was t hen conducted (as part of LADCO Round 4 modeling) to assess t he air quality benefit of the
candidate control measures and a modeling report was developed 31 . Based on the results, the LA DCO project team felt it would not be possible to advance the attainment date for PM 2.5

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

24 http://www. epa.ohio.gov/dapc/r egs/3745_17.aspx 25 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx
26 http://www. epa.ohio.gov/dapc/r egs/3745_109.aspx

27 http://www. epa.ohio.gov/dapc /regs/3745_110.aspx
28 http://www.ladco.org/r eports/control/white_papers
29 http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_i_april_2005.pdf; http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_ii_june_2006.pdf
30 http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_february_2006.pdf; http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_for_ladc o_states_in_2009_and_2012_march_2007.pdf
31 http://www.ladco.org/r eports/control/mode ling/round4_modeling.pdf37 attainment would be achieved in this area by 2009. Because of a projected 2009 attainment date, it would not have been reasonably possible or practicable for Ohio to develop RACT/RACM requirements, promulgate regulat ions and implement a control program prior to the proj ected attainment date.

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

Background U.S. EPA’s Implementation Rule requires RFP only for any area which a State projects an atta inment date beyond 2010. The RFP would provide emission reductions showing linear progress
between 2002 and 2009. If a State dem onstrates attainment will occur by 2010 or earlier, U.S. EPA considers the attainment
demonstration to demonstrat e achievement of RFP.

Demonstration
In Ohio’s attainment demonstrat ion submitted on July 18, 2008, Ohio demonstrated (using a weight of evidence approach) that
attainment would be achieved in this area by 2009; and therefore, it was not necessary to submit a separate RFP plan.

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

Background Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions in the area, including the requirement for periodic revisi ons as determined necessary. 40 CFR 51.1008 requires such inventor y to be submitted within three years of designation and requires a baseline emission inventory for calendar year 2002 or other suitable year to be used for attainment planning.

Demonstration The 2005 comprehensive inventory was submitted to U.S. EPA
with Ohio’s PM 2.5 attainment demonstrati on SIP submitted on July 18, 2008. It was then subsequently revised and resubmitted on June 7, 2010.38 Ohio also updates its inventor y in accordance with U.S. EPA’s CERR rule (i.e. emissions stat ements). Ohio EPA submitted its
emissions statement SIP on Ma rch 18, 1994 which was approved by U.S. EPA on October 13, 1995 ( 59 FR 51863). As discussed in Chapter 4 (Requirement 4), Ohio EPA submits, and commits to submit, emission inventories (sta tements) every three years.

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

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

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

Demonstration
Controls for EGUs under the NO x SIP Call formally commenced May 31, 2004. Emissions cover ed by this program have been generally trending downward since 1998 with larger reductions occurring in 2002 and 2003. Data ta ken from the U.S. EPA Clean Air Markets web site, quantify the gradual NO x reductions that39 have occurred in Ohio as a resu lt of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter
3745-14 32 in response to the SI P Call. OAC Chapter 3745-14 regulates EGUs and certain non-EGUs under a cap and trade program based on an 85 percent reduc tion of NOx emissions from EGUs and a 60 percent reduction of NO x emissions from nonEGUs, compared to historical le vels. This cap was in place through 2008, at which time the CAIR program superseded it as discussed above. Requirement 3 of 5 under Chapter 4 above
discussed the reductions Ohio has seen as a result of CAIR.

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

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

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoli ne and diesel trucks and buses.

32 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx40 This rule will result in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory. It also estima ted the level of sulfur in highway diesel fuel will be reduced by 97 percent by mid-2006.

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

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

Background Ohio has a longstanding and fu lly implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-
31 33 . The Chapter includes provis ions for the Prevention of Significant Deterioration (PSD) permitting program in OAC rules
3745-31-01 to 3745-31-20. Ohio's PSD program was conditionally approved on October 10, 2001 (66 FR 51570) and received final approval on January 22, 2003 (68FR 2909) by U.S. E PA as part of
the SIP.

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

program.

33 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx41 Requirement 6 of 6 Assure that all existing control measures will remain in effect after redesignation
unless the State demonstrates thr ough modeling that the standard can be
maintained without one or more control measures.

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

Ohio, through Ohio EPA’s Legal offi ce, has the legal authority and necessary resources to actively enf orce any violations of its rules or permit provisions. After redesi gnation, it intends to continue enforcing all rules that rela te to the emission of PM 2.5 precursors in the Dayton-Springfield area.42 

### CHAPTER SIX

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

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

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

.

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

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

Warning Level Response: A warning level response sha ll be prompted whenever the PM 2.5 average of the weighted annual mean of 15.5 μg/m 3 occurs in a single calendar year within the ma intenance area. A warning level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 values or whether emissions appear to be increas ing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse t he trend taking into consideration ease and timing for implementation as well as economic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expeditiously as possible, but in no event later than 12 months from the conclusion of the most recent calendar year.

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

Action Level Response: An action level response shall be prompted whenever a two-year43 average of the weighted annual means of 15.0 μg/m 3 or greater
occurs within the maintenance ar ea. A violation of the standard (three-year average of the we ighted annual means of 15.0 μg/m 3 or greater) shall also prompt an action level response. In the
event that the action level is tri ggered 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 organizati on or regional council of governments, will determine additi onal control measures needed
to assure future attainm ent of the NAAQS for annual PM 2.5 . In this case, measures that can be impl emented in a short time will be selected in order to be in place wit hin 18 months from the close of the calendar year that prompt ed the action level. Ohio EPA will also consider the timing of an ac tion level trigger and determine if additional, significant new regulations not currently included as part of the maintenance provisions will be implemented in a timely manner and will constitute our response.

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

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

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

event.

Demonstration Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appropriate and effective
at the time the selection is m ade. The selection of measures will be based on cost-effectiveness, em ission reduction potential,
economic and social cons iderations or other factors that Ohio EPA deems appropriate. Ohio EPA will solic it input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Because it is not possible at44 this time to determine what cont rol measures will be appropriate at an unspecified time in the future, the list of contingency measures
outlined below is not exhaustive.

1) Diesel reduction emission strategies. 2) Alternative fuel (e.g., li quid propane and compressed natural gas) and diesel retrofit programs for fleet vehicle operations. 3) Tighter PM 2.5 , SO 2 , and NO x emissions offsets for new and modified major sources. 4) Impact crushers located at recycle scrap yards – upgrade wet suppression. 5) Concrete manufacturing – upgrade wet suppression. 6) Additional NO x RACT statewide.

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

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

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

• ICI Boilers - SO 2 and NO x controls;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• other sources greater than 100 tons per year;

• fleet vehicles;

• concrete manufacturers;

• aggregate processing plants;45 

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesignat ion petition and maintenance plan in the widely distributed county publicat ions on April 1, 2011.

The public hearing to receive comment s on the redesignation request was held on May 3, 2011, at Ohio EPA’s Southwest District Office located at 401 E. Fifth Street in Dayton, Ohio. The public comment period closed on May 3, 2011Appendix F includes a copy of the public notice, certificati on of publication, and the transcript from the public hearing.46 

### CHAPTER EIGHT

CONCLUSIONS

The Dayton-Springfield annual PM 2.5 nonattainment area has attained the 1997 annual NAAQS for PM 2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of PM 2.5 nonattainment areas.
Documentation to that effect is contained herein. Oh io 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 Dayton-Springfield annual PM 2.5 nonattainment area meets the requirements for redes ignation under the CAA and U.S. EPA guidance. Ohio has performed an anal ysis that shows the air quality improvements are due to permanent and enforceable measures. Furthermore, because this area is subject to signific ant transport of pollu tants, significant regional SO 2 and NO x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of Ohio hereby reques ts that the Dayton-Springfield annual PM 2.5 nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenance plan provisions contained herein.This page left intentionally blank