# REDESIGNATION REQUESTAND MAINTENANCE PLAN FOR THE CINCINNATI-HAMILTON, OH-KY-IN 8- HOUR OZONE NONATTAINMENTAREA

Butler, Clermont, Clinton, Hamilton, and Warren Counties, Ohio

Prepared by: Ohio Environmental Protection Agency Division ofAir Pollution Control

December2009

Revised July2010

### TABLE OF CONTENTS

Chapter One Introduction 1 Background 1 Geographical description 2 Status ofairquality 2
ChapterTwo Requirements for redesignation ,3
ChapterThree Ozone monitoring 7 Ozone NAAQS 7 Ambient data qualityassured 8 Three.complete years ofdata 9 Commitment to continue monitoring 11
Chapter Four Emission inventory 13 Base year inventory 13 Emission projections 14 Demonstration of maintenance 22 Permanent and enforceable emissions reductions 36 Provisions forfuture updates 36
Chapter Five Control measures and regulations 38 Marginal nonattainment areas to implement RACT 38 Emission inventories/statements 38 Implementation ofpast SIP revisions 39 Newsource review provisions 43 Assurance ofcontinued controls 43
ChapterSix Contingency measures 44 Commitment to revise plan 44 Commitmentfor contingency measures 44 Potential contingency measures 45 List of

### vac and NOxsources 47
ChapterSeven Public participation 48
Chapter Eight Conclusions 49Figure 1

Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Table 7 Table 8

Table 9 Table 10 Table 11 Table 12 Table 13 Table 14 Table 15 Table 16 Table 17 Table 18 Table 19 Table 20 Table 21 Table 22 Table 23 Table 24 Table 25 Table 26 Table 27 Table 28 Table 29 Table 30 Table 31 Table 32 Table 33 Table 34 Table 35 Table 36 Table 37 FIGURES

Cincinnati-Hamilton Basic NonattainmentArea 8

TABLES
Monitoring Data for Cincinnati-Hamilton 2007

- 2009 10 Emission Estimations for On-road Mobile Sources for ButlerCo., Ohio 18 Emission Estimations for On-road Mobile Sources for Clermont Co., Ohio 18 Emission Estimations for On-road Mobile Sources for Clinton Co., Ohio 18 Emission Estimations for On-road Mobile Sources for Hamilton Co., Ohio 18 Emission Estimations for On-road Mobile Sources forWarren Co., Ohio 18 Emission Estimations for On-road Mobile Sources for Dearborn Co., Indiana 19 Summary ofOhio and Indiana Emission Estimations for On-Road Mobile Sources 19 Emission Estimations for On-road Mobile Sources for Boone Co., Kentucky 19 Emission Estimations for On-road Mobile Sources for Campbell Co., Kentucky. 19 Emission Estimations for On-road Mobile Sources for Kenton Co., Kentucky 19 Summary of Kentucky Emission Estimations for On-Road Mobile Sources 20 Emission Estimations for On-road Total Cincinnati-Hamilton Sources 20 Mobile Vehicle Emission Budget for Ohio and Indiana 20 Mobile Vehicle Emission Budget for Kentucky 21 NOx Emission Inventory ButlerCo, Ohio 24 NOx Emission Inventory Clermont Co., Ohio 25 NOx Emission Inventory Clinton Co'., Ohio 25 NOx Emission Inventory Hamilton Co., Ohio
, 26 NOx Emission InventoryWarren Co., Ohio 26 NOx Emission Inventory Dearborn Co., Indiana 27 NOx Emission Inventory Boone Co., Kentucky 27 NOx Emission Inventory Campbell Co., Kentucky 28 NOx Emission Inventory Kenton'Co., Kentucky 28 NOx Emission Inventory Cincinnati-Hamilton, Total. 29 VOC Emission Inventory ButlerCo, Ohio 29 VOC Emission Inventory Clermont Co., Ohio 30 VOC Emission InventoryClinton Co., Ohio 30 VOC Emission Inventory Hamilton Co., Ohio 31 VOC Emission InventoryWarren Co., Ohio 31 VOC Emission Inventory Dearborn Twp., Indiana 32 VOC Emission Inventory Boone Co., Kentucky 32 VOC Emission Inventory Campbell Co., Kentucky 33 VOC Emission Inventory Kenton Co., Kentucky 33 VOC Emission InventoryCincinnati-Hamilton, Total 34 Projected Emission Estimates 2008-2020 Cincinnati-Hamilton 34 Combined Comparison of2005 and 2008 On-road and EGU Totals 36APPENDICES

A Air QualitySystem (AQS) Data B Ohio 2005 SIP Base Year Inventory Discussion C "Mobile Source Emissions Inventoryforthe Cincinnati Ozone NonattainmentArea" 

## o LADCO Technical Support Document E Public Participation DocumentationThis page left intentionally blankREDESIGNATION REQUESTAND MAINTENANCE PLAN FOR THE CINCINNATI-HAMILTON, OHIO OZONE NONATTAINMENTAREA


### Butler, Clermont, Clinton, Hamilton, and Warren Counties, Ohio



### CHAPTER ONE

Introduction The Clean AirAct (eM) requires areas failing to meetthe National Ambient Air Quality Standard (NMQS) for ozone to develop State Implementation Plans (SIP's) to expeditiously attain and maintain the standard. In 1997, the United States Environmental Protection Agency (U.S. EPA) revised the air quality standard for ozone replacing the 1979 one-hour standard with an eight-hourozone standard set at 0.08 parts per million (ppm). The standard
was challenged legallyand upheld bythe U.S. Supreme Court in Februaryof 2001.

On April 30, 2004, U.S. EPA designated 134 nonattainment areas for the e.ight-hourozone standard.· Section 107(d)(3)(E) ofthe CM allows statesto request nonattainment areas to be redesignated to attainment provided certain criteria are met. Thefollowing arethe criteriathatmustbe metin order for an area to be redesignated from nonattainment to attainment:
i) A determination that the area has attained the eight-hour
ozone standard. ii) An approved State Implementation Plan (SIP) forthe area under Section 11 O(k). '- iii) A determination thatthe improvement in airquality is dueto permanent and enforceable reductions in emissions resulting from implementation ofthe SIP and otherfederal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 11 0 and Part 0 requirements have been met.
Background The current Cincinnati-Hamilton nonattainment area includes the following Counties: Butler, Clermont, Clinton, Hamilton, and Warren in Ohio; Dearborn (partial nonattainment of Lawrenceburg Township only) in Indiana; and Boone, Campbell, and Kenton in Kentucky.

As part ofthe 1990 CM Amendments re-evaluation, the following Counties within the Cincinnati-Hamilton area were designated as moderatenonattainment for the one-hour ozone standard pursuant to the CAA and, therefore, were subjectto nonattainmentarea rulemakings: Butler, Clermont, Hamilton, and Warren Counties in Ohio and Boone, Campbell and Kenton Counties in Kentucky. The Ohio portion ofthe Cincinnati-Hamilton areawas redesignated to attainmenton June 19, 2000 (65 FR 37879). Clinton County, Ohio was designated as a·transitional nonattainment area. Clinton County
was redesignated to attainm'ent on March 21, 1996 (61 FR 11560). A maintenance plan was approved atthose times.

As a result of the 2004 ozone designations, U.S. EPA designated the Cincinnati-Hamilton area basicnonattainmentforthe eight-hourstandard, and Ohio EPA was required to develop a plan to reduce volatile organic compounds (VOCs) and nitrogen oxides (NOx ) emissionsto meetthefederal eight-hourairqualitystandard for ozone byJune 2009.

. . This document is intended to support Ohio's requestthatthe Ohio portionsof the Cincinnati-Hamilton area be redesignated from nonattainment to attainment for the eight-hour ozone standard. In addition, the States of Kentucky and Indiana also intend to submit requests for their respective portions ofthe Cincinnati-Hamilton area. The Cincinnati-Hamilton area has recorded three (3) years of complete quality-assured ambient air quality monitoring data forthe years 2007

- 2009 demonstrating attainment ofthe eight-hour ozone standard.
Geographical Description The Cincinnati-Hamilton eight-hour ozone nonattainment area is located in southwest Ohio and includes the following Counties of: Butler, Clermont, Clinton, Hamilton, and Warren in Ohio; Dearborn (partial nonattainment of Lawrenceburg Township only) in Indiana; and Boone, Campbell, and Kenton in Kentucky. This area is shown in Figure 1 under ChapterThree.

Status ofAir Quality Ozone mon.itoring data for the most recent three (3) years, 2007 through 2009, 'demo'nstrate that the air quality has metthe NAAQS for ozone in this basic nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter Four, supports a redesignation to attainment for the Cincinnati-Hamilton area based on the requirements in Section 107(d)(3)(E) ofthe eAA.

### CHAPTER TWO
Requirements for Redesignation U.S. EPAhas published detailed guidance in adocumententitled Procedures forProcessingRequests to RedesignateAreas toAttainment(redesignation guidance), issued September 4, 1992, to Regional Air Directors. The redesignation requestand maintenance plan are based on the redesignation guidance, supplemented with additional guidance received from staffofU.S: EPA Region V.

Below is a summary ofeach redesignation criterion as it applies to the Cincinnati-Hamilton area. L) Attainment ofthe standard There are two components involved in making this demonstration. The first component relies on ambient air qualitydata. The datathatare used to demonstrateattainment should be the product of ambient monitoring that is representative ofthe area of highest concentration. The data should be collected and quality-assured in accordance with 40 CFR 58 and recorded in theAir Quality System (AQS) in order for itto be available to the publicfor review.

The second component relies upon supplemental U.S. EPAapproved airquality modeling. The supplemental modeling is not required for ozone nonattainment areas seeking redesignation; however, in Appendix C and Appendix D the most recent modeling results showing future attainment and maintenance are provided. Chapter Three discusses this requirement in more detail and provides the attainment demonstration.
ii.) SIP approval The SIP for the area must be fully approved under Section 110(k) and must satisfy all the requirements that apply to the
area. Ohio's SIP was approved on May 9, 1994 (59FR23799) and March 23, 1995 (60FR15235) and includesthe CincinnatiHamilton area. Chapter Five discusses this requirement in
more detail.
iii.) Permanent and enforceable improvement in airquality The state mustbe ableto reasonablyattributethe improvement in air qualityto emission reductions which are permanent and enforceable. The state should estimate the percent reduction achieved from federal measures as well as control measures that have been adopted and implemented bythe state.The Ohio Counties portion ofthe Cincinnati-Hamilton areawas designated moderate nonattainment for ozone as part of the 

### 1990 CAA Amendments re-evaluation. As a result, Ohio has adopted and implemented control measuresforthese Counties in that area beyond the federal measures and the initial 

### 1979/1981 Statewiderules. In addition, Ohio EPAhasadopted several rules recently that will have an impact Statewide on ozone emissions in the future:

• Portable Fuel Containers requirements

• Architectural and Industrial·Maintenance (AIM) Coatings rules

• Consumer Products rules
•. Clean Air Interstate Rule (CAIR)

• NOx Sip Call Rules
Chapters Fourand Fivediscussthis requirement in moredetail.
iv.) Section 

### 110 and Part 0 requirements For purposes of redesignation, a state must meet all requirements of Section 

### 110 and Part 0 that were applicable priorto submittal ofthe complete redesignation request.

Part 0 consists ofgeneral requirements applicable to all areas which aredesignated nonattainmentbased on aviolation ofthe NAAQS.
L) Section 

### 11O(a) requirements Section 

### 11O(a) ofTitle I ofthe CAAcontainsthe general requirements fora SIP. Section 

### 11O(a)(2) providesthat the implementation plan submitted byastate'must have been adopted bythe state after**reason~ble** publicnotice and hearing, and that, among other things, it must include enforceable emission limitations and other control measures, means or techniques necessary to meet the requirements of the CAA; provide for establishment and operation of appropriate devices, methods, systems and procedures necessaryto monitor ambient air quality; provide for implementation of a source permit program to regulate the modification and construction of any stationary source within the areas covered by the plan; include provisions for the implementation of Part C, prevention of significant deterioration (PSD) and Part 0, NSR permit programs; include criteria for stationary source emission controlmeasures, monitoring, and reporting; include provisions forairqualitymodeling; and providesforpublicand local agency participation in planning and emission control rule development. In Ohio's December 5, 2007 and September4, 2009 infrastructure SIPsubmissions, Ohio verified thatthe Statefulfillsthe requirements ofSection 110(a)(2) ofthe Act.
ii.) Section 172(c) requirements This Section contains general requirements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for attainment will notapplyfor redesignations becausetheyonly have meaning for areas not attaining the standard. The requirements for an emission inventorywill be satisfied bythe inventory requirements ofthe maintenance plan. Chapters Fourand Five discussthis requirement in more detail.
ii.) Conformity The state mustworkwith U.S. EPAto showthat 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. Ifa state does not have conformity procedures in place atthe time that it submits a redesignation request, the state must committo follow U.S. EPA's conformity regulation upon issuance, as applicable.
v.) Maintenance plans Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPAmustfullyapprove amaintenance plan that meets the requirements of Section 175(A). The maintenance plan must constitute a SIP revision and must provide for maintenance ofthe relevant NAAQS in the areafor at least 10 years after redesignation. Section 175 (A) further states that the plan shall contain such additional measures, if any, as may be necessaryto ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures as the Administratordeems necessary to ensure prompt correction ofanyviolation ofthe NAAQS. At
a minimum, the contingency measures must include arequirement that the state will implement all measures contained in the nonattainment SIP priorto redesignation.

States seeking redesignation of a nonattainment area should considerthe following provisions:
a.) attainment inventory; b.) maintenance demonstration; c.) monitoring n,etwork; d.) verification ofcontinued attainment; and e.) contingency plan. Chapter Six discusses this requirement in more detail.

### CHAPTER THREE

OZONE MONITORING1 CAA Section1 07 (d)(3)(E)(i)
Requirement 1 of4 Ademonstration thatthe NAAQSforozone, as published in40 CFR50.4, has been attained.
Background There are eleven monitors measuring ozone concentrations in this nonattainment area. Eight ofthe eleven monitors, located in Ohio, are operated by Ohio EPA Division of Air Pollution Control, Southwest District Office and the Hamilton County Division of Environmental Services. A listing of the design values based on the three-year average of the annual fourth highest daily maximum eight-hour average ozone concentrations from 2007 through 2009 is shown in Table 1. The locationsofthe monitoring sitesforthis nonattainmentarea are shown on Figure 1.

1The draftversion ofthis redesignation request primarily contains data through the end of August and has not been fully quality assured. However, all data will be incorporated and quality assured, as described in the text ofthis document, priorto official submittal to U.S. EPA. Ohio EPA does not believe the data as provided in this draftwill change appreciably.

### Demonstration

Figure 1 Map ofthe Cincinnati-Hamilton, OH nonattainment
area and monitor locations

Requirement 2 of4 Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in the U.S. EPAairqualitysystem (AQS) database, and availablefor publicview.

.


### Demonstration The Ohio Environmental -Protection Agency (Ohio EPA) has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and the Ohio Quality Assurance Manual. Ohio EPA has recorded the data in the AQS database and, therefore, the data are available to the public.

.Requirement 3 of4 A showing thatthe three-yearaverage ofthe fourth highestvalues, based on data from all monitoring sites in the area or its affected downwind environs,
are below 85 parts per billion (ppb). (This showing must rely on three complete, consecutive calendaryears of quality assured data.)
Background The following information is taken from U.S. EPA's "Guideline
on Data Handling Conventions for the eight-hour ozone National Ambient Air Quality Standard (NAAQS)," U.S. EPA454/R-98-017, December 1998.

Three complete years ofozone monitoring data are required to demonstrate attainment at a monitoring site. The eight-hour primaryand secondaryozone ambientairqualitystandards are met at an ambient air quality monitoring site when the threeyearaverage ofthe annual fourth-highestdailymaximum**eigh~­** houraverage ozone concentrations is lessthan orequalto 0.08 ppm. When this occurs, the site is said to be in attainment. Three significant digits must be carried in the computations. Becausethe third decimal digit, in ppm, is rounded, 0.084 ppm is the largest concentration that is less than or equal to 0.08 ppm. Therefore, forthe purposes ofthis request, theeight-hour standard is considered to be 0.085 ppm. Values below 0.085 ppm meetthe standard, values equal to orgreater than 0.085 ppm exceed the standard. These data handling. procedures are applied on an individual basis ateach monitorin the area. An area is in compliance with the eight-hour ozone NAAQS if, and only if, every monitoring site in the area meets the NAAQS. An individual site's three-year average of the annual fourth highestdailymaximum eight-houraverageozone concentrations is also called the site's design value.

Table 1 shows the monitoring data for 2007

- 2009 that were retrieved from the U.S. EPAAQS. The airqualitydesign value for the area is the highest design value among all sites in the
area. 

### Please note thatthe standardis measuredinppm while the commonly used unit is ppb. For the remainder ofthis document, ppb willbe used.Demonstration

Table 1 Monitoring Data forthe Cincinnati-Hamilton, OH area for 2007

- 2009

Data source:**U.S~** EPAAir Quality System (AQS) http://www.epa.gov/ttn/airs/airsags/index.htm

1st 2nd 3rd 4th**~2007-2009** SITE COUNTY ADDRESS YEAR %08S 8-HR 8-HR 8-HR 8-HR AVERAGE

10 39-017-

0004 Butler Hamilton 2007 100 97 96 91 91 78 39-017-

0004 Butler, Hamilton 2008 99 89 75 72 71 39-017-

0004 Butler Hamilton 2009 98 79 78 74 73 39-017- "

1004 Butler Middletown 2007 100 104 97 95 91 82 39-017-

1004 Butler Middletown 2008 96 91 87 82 79 39-017-

1004 Butler Middletown 2009 100 78 76 76 76 39-025-

0022 Clermont Batavia 2007 98 93 92 90 86 75 39-025-

0022 Clermont Batavia 2008 97 72 71 71 71 39-025-

0022 Clermont Batavia 2009 99 71 71 69 69 39-027-

1002 Clinton Wilmington 2007 99 91 89 85 82 76 39-027-

1002 Clinton Wilmington 2008 96 87 80 77 76 39-027-

1002 Clinton Wilmington 2009 96 73 72 71 70 39-061-

0006 Hamilton Cincinnati 2007 96 100 92 91 89 82 39-061-

0006 Hamilton Cincinnati 2008 96 93 89 87 86 39-061-

0006 Hamilton Cincinnati 2009 98 80 76 75 72 39-061-

0010 Hamilton Cleves 2007 99 93 91 88 86' 76 39-061-

0010 Hamilton Cleves 2008 96 85 79 78 77 39-061-

0010 Hamilton Cleves 2009 80 69 66 65 65 39-061-

0040 Hamilton Cincinnati 2007 99 97 93 88 86 80 39-061- ,0040 Hamilton Cincinnati 2008 100 86 83 81 801st 2nd 3rd 4tn 2007-2009
SITE COUNTY ADDRESS YEAR %085 8-HR 8-HR 8-HR 8-HR AVERAGE

10 39-061-

0040 Hamilton Cincinnati 2009 99 77 76 74 74 39-165-

0007 Warren Lebanon 2007 100 103 89 88 88 82 39-165-

0007 Warren Lebanon 2008 95 92 87 84 82 39-165-



### OOO? Warren Lebanon 2009 100 80 80 78 77 21-015-

0003 Boone Not in City 2007 100 81 79 78 78 68 21-015-

0003 Boone Not in City 2008 98 65 64 64 64 21-015-

0003 Boone Not in City 2009 98 69 67 65 64 21-037- Highland

3002 Campbell Heights 2007 100 95 92 88 86 76 21-037- Highland

3002 Campbell Heights 2008 99 84 83 75 75 21-037- Highland

3002 Campbell Heights 2009 100 75 72 70 68**21-117~** 0007 Kenton Covington 2007 100 93 89 85 85 77 21-117-

0007 Kenton Covington 2008 99 80 77 74 73 21-117-

0007 Kenton Covington 2009 99 76 75 75 74 HighestAverage 82 ppb

The area's design values havetrended downward as emissions have declined due to such factors as cleaner automobiles and fuels, and controls for EGUs, both regionally and locally.
Requirement 4 of4 A commitment that once redesignated, the state will continue to operate an appropriate monitoring network to verify the maintenance ofthe attainment status.

Demonstration Ohio EPA commits to continue monitoring ozone levels atthe Ohio sites indicated in Figure 1. Ohio EPAwill consultwith U.S. EPA Region V prior to making changes to the existing monitoring network, should changes become necessary in the future. Ohio EPAwill continue to qualityassurethe monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. Connection to a central station andupdates to the Ohio EPA web site2 will provide real time availability of the data and knowledge of any exceedances. Ohio EPA will enter all data into AQS on a timely basis in accordance with federal guidelines.

2www.epa.state.oh.us/dapc/

### CHAPTER FOUR

EMISSION INVENTORY CAA Section107 (d)(3)(E)(iii)



## u.s. EPA's redesignation guidance requiresthesubmittal ofacomprehensive inventoryofozone precursoremissions (VOC and NOx ) representative ofthe year when the area achieves attainment of the ozone air quality standard. Ohio also must demonstrate thatthe improvement in airquality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions. Other emission inventory related requirements include a projection ofthe emission inventory to a year at least 10years following redesignation; a demonstration thatthe projected level ofemissions is sufficientto maintain the ozone standard; and
acommitmentto providefuture updates ofthe inventoryto enabletracking of emission levels during the 1O-year maintenance period.

The emissions inventory development and emissions projection discussion below, with the exception of the mobile (on-road) emissions inventory and projections, identifies procedures used by Ohio EPA and the Lake Michigan Air Directors Consortium (LADCO) regarding emissionsfrom Ohio's portion of the Counties in the Cincinnati-Hamilton area. Specific emissions data are provided for all Counties, including those in Ohio, Kentucky and Indiana. Indianaand Kentuckyemissions datawere obtained directlyfrom Indianaand Kentucky, respectively. All of these inventories and emissions projections
were prepared using similarmethodologies. Ohio recognizesthat revisionsto the emissions data below may be necessary once Kentucky and Indiana prepare a redesignation requestand maintenance plan fortheirportion ofthe nonattainment area. Mobile emissions inventories and projections for all Counties were prepared by the Ohio, Kentucky, Indiana Council of Governments (OKI).


### Requirement 1 of5 A comprehensive emission inventory qfthe precursors of ozone completed forthe base year. 

### Background The point source data are taken from Ohio's annual emissions reporting program. The 2005 periodic inventory has been identified as one of the preferred databases for SIP developmentand coincideswith nonattainmentairqualityin the Cincinnati-Hamilton area.

Periodic inventories, which include emissionsfrom all sectors

- mobile, area, non-road, and pointsources
-are prepared every three years.

### Demonstration The 2005 inventory'is used asthe base yearforthe purpose of this submittal and was submitted to U.S. EPAon June 15,2007 along with the attainment demonstration for this area. The detailed emission inventory information forthe Ohio portion of the Cincinnati-Hamilton area is provided in Appendix B. Emissions of VOC and NOx for 2005 are identified under Requirement Three ofthis Chapter.



### Requirement 2 of5 A projection of the emission inventory to a year at least 10.years following redesignation.


### Background Ohio EPAprepared acomprehensive inventory'forthe Ohio portion of the Cincinnati-Hamilton area including area, mobile, and pointsources forprecursors ofozone (VOCs 

### andNOx ) forbaseyear2005. The2005 inventorywas submitted to U.S. EPAon June 15, 2007 as part ofthe attainment demonstration for this area. The information below describes the procedures Ohio EPA used to generate the 2005 base 

### year inventory and to develop**SIP-read~** 

### modeling inventories and future year projections (Pechan Report). The report by Pechan generated future yearestimates ofannual emissions foreach source sector using accepted growth surrogates. These inventories were provided tothe LADCO and have been processedtodevelopsummerday emissions for use in the air quality analyses. These

.processed modeling inventories have been identified asthe correctiteration ofthe inventoryfor use in the redesignation. In this document, referencesto LADCO include the Midwest Regional Planning Organization. Note, the on-road mobilesourcesectorwas addressed byspecificmodeling
as discussed below.

• Area sources were taken from the Ohio 2005 periodic inventory submitted to U.S. EPA. These projections
were made from the U.S. Department of Commerce Bureau of EconomicAnalysis (BEA) growth factors,with
some updated local information.

• Mobile source emissions were calculated from MOBILE6.2-produced emission factors.

3 http://www.ladco.org/tech/emis/r5/reports/LADCO%202005%20Base%20Y rOA>2oGrowth%20and% 20Controls%20Report _Final.pdf• Pointsource information was compiled from Ohio EPA's 2005 annual emissions inventorydatabaseand the2005 U.S. EPAAir Markets acid rain database4

.
• Biogenicemissionsare notincluded inthesesummaries.

• Non-road emissions were generated using U.S. EPA's National Mobile Inventory Model (NMIM) 2002 application. To**addr~ss** concerns aboutthe accuracyof
some of the categories in U.S. EPA's non-road emissions model, LADCO contracted with two (2) companies to review the base data and make recommendations. One of the contractors also estimated emissions for three (3) non-road categories not included in U.S. EPA's non-road model. Emissions
were estimated foraircraft, commercial marinevessels, and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipmentcategorywere reviewed and updated based upon surveys completed in the midwest, and the temporal allocation foragricultural sources also
was updated.

Demonstration

On-Road Emission Estimations In coordination with the Ohio Department of Transportation (Ohio DOT), OKI utilizes a regional travel demand forecast model to simulatetraffic in the area and toforecasttrafficflows forgiven growth expectations. The model has been validated to observed traffic volumes for the model base year 2005. The model is primarily used as a long range planning tool to evaluate the transportation system including determination of locations where additional travel capacity may be needed and to determinethe infrastructure requirements necessaryto meet that need. It is also used as a tool for air quality purposes to estimate the total emissions of pollution caused byvehicles in the area. The travel demand forecasting model is used to predi.ctthe total dailyvehicle miles traveled (VMT)
, and a U.S. EPAcomputerprogram called MOBILE6.2 is used to calculate emissions permile. The product ofthese isthe total amountof pollution emitted bythe on-road vehicles forthe area. Clinton County is outside the area covered by the regional travel demand model. The Ohio DOT uses traffic counts and local traffic growth rates forthe VMT estimates.

4http://www.epa.gov/airmarkets/acidrainOverview OKI incorporates a variety of sources of local data to both improve and confirm the accuracy of VMT, as well as other travel-related parameters. Free flow speeds used on the highway and transit networks are based on travel time studies performed locally. An OKlpost-processing program usesthe loaded highway network to generate VMT by hour, VMT by speed distribution, and VMT byfacilitytype. These tables are then included as input into MOBILE6.2. The VMT by hour tables utilize hourly traffic distribution and directional split factors for different roadway types as developed by OKI. The main source of the data was the permanent traffic counting stations located throughout the OKI region. These data were supplemented with data collected at coverage count stations (locations with counts taken on only one-two days). The stations were classified by area type(urban and rural) and functional classification (freeway, arterial and collector). Speeds representing various "loaded" conditions (with trafficvolumes)
are estimated using techniques from the 1997 Highway Capacity Manual. This permits the estimation of speeds as conditions varyfrom hourto houron the differentfacilitytypes throughoutthe region. The post-processing program performs the appropriatesummation byareaand roadwaytypeaswell as regional totals. OKI has also developed seasonal conversion factors to adjust traffic volumes to summer conditions. The factors were derived from local data collected at permanent trafficcounting stations utilizingtheaveragedailytrafficmonthly conversion factors forJune, July and August.

OKI's utilized U.S.EPA's emissions model MOBILE6.2 to develop emission factorsforVOC's and NOx. The MOBILE6.2 input file contains local parameters, developed through consultation withthe Ohio DOTand Ohio EPA, fortemperature, fuel programs and fuel characteristics. Low RVP (Reid Vapor Pressure) gasoline is the summerfuel program in OKI's Ohio counties. Low RVP fuel results in lowerevaporative emissions and is a key component of the region's strategy for ozone attainment. The local parameters are combined with the VMT tables from the OKI Travel Demand Model to produce one set of emission factors measured in grams per mile for the appropriatecalendaryear(from 1952to2050). Theseemission factors are then multiplied by VMT. The methodologies incorporated into MOBILE6.2 for estimating emissions are based on methodsand research conducted byU.S.EPA. OKI's development of MOBILE6.2 input values were guided by theU.S.EPA's document "Technical Guidance on the Use of MOBILE6forEmission InventoryPreparation': January2002.

Some of the assumptions built into MOBILE6.2 include the following: older vehicles have much higher emission factors than newer vehicles, diesel vehicles have much higher NOx emission factors and lowerVOC emission factorsthan gasoline vehicles, and higher average speeds have lower emission factors except for diesel vehicles which have higher NOx at higherspeeds. MOBILE6.2 inputand outputfiles are provided in Appendix C.

BestAvailable Data Most current vehicle age distribution data, temperature data, and fuel properties data provided by Ohio EPA were used by OKI and the Ohio DOT· for generating emission factors. Likewise, the most current transportation planning data availablefrom OKI and mostcurrentOhio DOTcountdatawere used by Ohio DOTforthe emissions estimates. Details about each data set and how it was used is documented in OKI's "Mobile Source Emissions Inventory for the Cincinnati Ozone NonattainmentArea" documentdated October, 2009 (revised). See Appendix C.
Analysis Years Analysisyearsforthis redesignation request include2005, 2008 (attainment year), 2015 (interim year), and 2020 to meet the requirements specified by the CAA and U.S. EPA. The travel demand model presents the transportation system conditions for each of these years. Model runs for each future analysis year contain the road network OKI and Ohio DOT expect to exist in July of that year with corresponding socioeconomic forecasts forthatyear.

Local Road VMT Most local roads such as subdivision streets are not explicitly modeled in a travel demand model. These local roads are represented asfictitious roadways called centroid connectors. Local road VMT is included in the OKI postprocess byincluding the traffic loaded on centroid connectors. In addition, some local road traffic is captured as intra-zonal trips which travel demand models usually do not assign to roadway segments. The OKI post process includes these trips as local road VMT.On-Road Mobile Emission Estimations Tables 2 through 13 contain the results ofthe emissions analysis for the appropriate years. All emissions estimations are expressed in tons persummerday (TSD).



### Table 2 - ButlerCounty, Ohio Emission Estimations for On-Road Mobile··Sources
2005 2008 2015 2020


### voe (TSD) 9.94 7.87 4.87 4.50
NOx (TSD) 18.88 16.05 7.55 5.37
VMT (miles/day) 7,804,476 8,133,554 8,869,806 9,520,999



### Table 3 - ClermontCounty,Ohio Emission Estimations for On-Road Mobile Sources
2005 2008 2015 2020


### voe (TSD) 6.86 5.42 3.29 3.04
NOx (TSD) 13.04 11.05 5.10 3.63
VMT (miles/day) 5,391,578 5,599,530 5,995,538 6,434,554



### Table 4 - Clinton County, Ohio Emission Estimations for On-Road Mobile Sources
2005 2008 2015 2020


### voe (TSD) 3.02 2.33 1.47 1.22
NOx (TSD) 5.07 3.87 2.02 1.41
VMT (miles/day) 1,809,600 1,793,580 2,049,496 2,172,899

- .- 

### Table 5 - Hamilton County, Ohio Emission Estimations for On-Road Mobile Sources
2005 2008 2015 2020


### vae (TSD) 29.47 22.70 13.44 12.00
NOx (TSD) 56.51 46.80 21.11 14.44
VMT (miles/day) 23,170,766 23,481,421 24,516,538 25,407,972



### Table 6 -Warren County, Ohio Emission Estimations for On-Road Mobile Sources
2005 2008 2015 2020


### voe (TSD) 7.97 6.26 4.02 3.88
NOx (TSD) 15.15 12.76 6.23 4.63
VMT (miles/day) 6,263,010 6,464,217 7,324,104 8,209,236

### Table 7 - Dearborn County, Indiana Emission Estimations for On-Road Mobile Sources
2005 2008 2015 2020


### voe (TSD) 1.00 0.75 0.50 0.42
NOx (TSD) 1.44 1.14 0.60 0.42
VMT (miles/day) 599,761 613,027 673,632 715,923



### Table 8 - Summary ofOhio and Indiana Emission Estimations for On-Road Mobile Sources
2005 2008 2015 2020


### voe (TSD) 58.26 45.33 27.59 25.06
NOx (TSD) 110.09 91.67 42.61 29.90 VMT,(miles/day) 45,039,191 46,085,329 49,429,114 52,461,583



### Table 9 - Boone County, Kentucky Emission Estimations for On-Road Mobile Sources
2005 2008 2015 2020


### voe (TSD) 4.33 -4.00 3.17 2.96
NOx (TSD) 10.27 8.53 4.63 3.45
VMT (miles/day) 4,186,006 4,355,527 5,133,456 5,790,231



### Table 10

- Campbell County, Kentucky Emission Estimations for On-Road Mobile Sources
2005 2008 2015 2020


### voe (TSD) 2.52 2.29 1.74 1.55
NOx (TSD) 5.98 4.88 2.54 1.81
VMT (miles/day) 2,437,698 2,495,174 2,809,926 3,039,274



### Table 11

- Kenton County, Kentucky Emission Estimations for On-Road Mobile Sources
2005 2008 2015 2020


### voe (TSD) 4.32 3.85 2.85 2.56
NOx (TSD) 10.39 8.37 4.23 3.01
VMT (miles/day) 4,182,042 4,197,027 4,623,038 4,998,184

### Table 12

- Summary of Kentucky Emission Estimations for OnRoad Mobile Sources
2005 2008 2015 2020


### voe (TSD) 11.17 10.14 7.76 7.07
NOx (TSD) 26.64 21.78 11.40 8.27
VMT (miles/day) 10,805,746 11,047,728 12,566,420 13,827,689



### Table 13

- Emission Estimation Totals forOn-Road Mobile Sources forthe Cincinnati-Hamilton Area
2005 2008 2015 2020


### voe (TSD) 69.43 55.47 35.35 32.14
NOx (TSD) 136.73 113.45 54.01 38.17
VMT (miles/day) 55,844,937 57,133,057 61,995,534 66,289,272



### MotorVehicle Emission Budget

Table 14 and Table 15 contain the motor vehicle emissions budgetsforthe Cincinnati-Hamilton area. Forplanning purposes, budgets are established for the combined Ohio and Indiana portions and forthe separate

.Kentucky portion.

Table 14

- Mobile Vehicle Emissions Budgetfor Ohio and Indiana 2015 2015 2015 2020 2020 2020 Estimated Mobile Total Estimated Mobile Total Emissions Safety Mobile Emissions Safety Mobile .Margin Budget Margin Budget Allocation* Allocation* 

### voe (TSD) 2'7.59 4.14 31.73 25.06 3.76 28.82 NOx (TSD) 42.61 6.39 49.00 29.90 4.49 34.39 VMT 56,843,481 60,330,820 (miles/day) 

## - - 

## - - *The 15 percent margin of safety was calculated by taking 15 percent ofthe mobile source emission estimates.

### B d tf K 

### t k 

### a e 

# - ole e IC 

### e missions U 

### Ige or en UC 

### :y 2015 2015 2020. 2020 Mobile Total Mobile Total 2015 Safety Mobile 2020 Safety Mobile Estimated Margin Budget Estimated Margin Budget Emissions Allocation Emissions Allocation 

### voe (TSD) 7.76 2.00 9.76 7.07 3.00 10.07 NOx (TSD) 11.40 3.00 14.40 8.27 5.00 13.27 VMT 14,451,383 15,901,842 (miles/day) 

### - - - -

The above budgetsforthe Ohio and Indiana portion ofthearea, agre'ed upon as part ofthe interagency consultation process, include the emission estimates calculated for 2015 and 2020 (from Table 8) with an additional 15 percent margin of safety allocated to those estimates.

In an effortto accommodate future variations in travel demand models and VMT forecast when no change to the network is planned, Ohio EPA consulted with U.S. EPA to determine a reasonable approach to address this variation. Based on this discussion, a 15 percentmargin ofsafetyallocationwasagreed upon and has been added to the emissions estimates for the Ohio and Indiana portions ofthis nonattainment area.

The above budget for the Kentucky portion of the area was provided directly by Kentucky as part of the consultation process and also includes a margin of safety allocated to the emission estimates calculated for 2015 and 2020 (from Table 12).

The emission estimates are derived from the travel demand model and MOBILE6.2 asdescribed above undertheexpected OKI 2030 Long Range Plan. All methodologies, the latest planning assumptions, and the safetymargins allocationswere determined through the interagency consultation process described in the Transportation Conformity Memorandum of Understanding (MOU) among OKI, Ohio DOT, and Ohio EPA.

A 15 percent margin ofsafety is appropriate because: 1)there is an acknowledged potential variation in VMT forecast and potential estimated mobile source emissions due to expected modificationstoTDM and mobileemissions models; and 2) the total decrease in emissions from all sources is sufficient toaccommodate this 15 percent allocation of safety margin to mobile sources while still continuing to maintain the total emissions in the Cincinnati-Hamilton area well belowthe 2006 attainment level ofemissions.

The 15 percent margin of safety was calculated by taking 15 percent of the mobile source emission 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 ofthe total emission reduction from all sources as can be seen from Table 36.

In summary, for all three states combined, the mobile budget safety margin allocation translates into:

--An allocation of 6.14 TSD for

## vac and 9.39 TSD for NOxfor2015; and -An allocation of 6.76 TSD for VOC and 9.49 TSD for NOxfor2020.

When compared to the overall safety margin, as defined in 40 CFR 93.101 5

, discussed under"Requirement3of5" below, it is evident this allocation is significantly below the total safety margin forthis area (see Table 36).

The current one-hourbudgetswill no longerbe applicable eitherafter the effective date ofthe approved redesignation orafterthe effective date of any U.S. EPA action approving a finding that the eight-hour conformity budget included in this submittal is adequate for transportation conformity purposes, whicheverdate comes first.


### Requirement3 of5 Ademonstration thatthe projected level ofemissions issufficientto maintain the ozone standard.


### Background In consultation with U.S. EPA,Ohio EPA selected the year 2020 as the maintenance yearforthis redesignation request. This document contains projected emissions inventories for 2015 and 2020.

5"safety margin" means the amount bywhich the total projected emissions from all sources ofa given pollutant are less than the total emissions that would satisfythe applicable requirement for reasonable further progress, attainment, or maintenance.

### Emission projections for the Cincinnati-Hamilton area were performed using the following approaches:

• As performed by OKI, mobile source emission projections are based on the U.S. EPA MOBILE6.2 model. The analysis is described in more detail in Appendix C. All projections were made in accordance with "Procedures for Preparing Emissions Projections" U.S. EPA-45/4-91-019.

• Emissions inventories are required to be projected to future dates to assess the influence growth and future controls will have. LADCO has developed growth and control files for point, area, and non-road categories. These files were used to develop the future-year emissions estimates used in this document. This was done so the inventories used for redesignation are consistent with modeling performed in the future. Appendix D contains LADCO's technical support document**detailin~** 

### the analysis used to project emissions (Base M )

..

• Forthe Ohio portion ofthe Cincinnati-Hamilton area, for the 2008 attainment year, emissions were grown from the 2005 LADCO modeling inventory, using LADCO's growth factors, for all sectors except point sources (electrical generating unitsand non-electrical generating units). Point source emissions for2008 were compiled from Ohio EPA's 2008 annual emissions inventory database. The 2015 interim year emissions were estimated based on the 2009 and 2018 LADCO modeling inventory, using LADCO's growth factors, for all sectors. The 2020 maintenance year is based on emissions estimates from the 2018 LADCO modeling.

The detailed inventory information for the Ohio portion ofthe Cincinnati-Hamilton area for2005 is in Appendix B. Emission trends are an important gauge for continued compliance with the ozone 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 ofAppendix B.

6http://www.lade0 .org/tech/emis/current/index.phpSectors included in the following tables are: Electrical Generating Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Non-road Mobile (Non-road); Other Area (Other); Marine; Aircraft; Rail (MAR); and On-road Mobile (On-road).

Maintenance is demonstrated when the future-year (2020) projected emission--totals-are-belowthe 2008 attainment yeartotals.

The emissions data in the tables below are based on the following data sources:



### Demonstration

Totals (T5D) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin

EGU Point 3.88 2.87 2.86 2.95NonEGU 12.03 10.53 13.29 13.22Nonroad 7.76 6.55 4.06 3.01 Other 2.15 2.18 2.19 2.19 MAR 2.49 2.34 1.85 1.63Onroad 18.88 16.05 7.55 5.37 TOTAL 47.19 40.52 31.80 28.37 12.15 Table 16

- Butler**Coun~,** Ohio N0.l!O Emission Inventory

7 Ohio EPA has revised the ButlerCounty, Ohio NOx Emissions Inventoryto incorporate the total emissions reduction credits available and used to offsetthe allowed emissions ofa majorsource modified within the maintenance area thatwill begin operating during the maintenance period. The total emissions included for this facility is 479.57 tons peryear (assumed TSD

## = TPY/365). The emissions increase does notsignificantly impactthe safety margin forthis area or preventthe
areafrom maintaining the standard in future years.Table 17

- Clermont County, Ohio**NO~** Emission Inventory Totals (T50) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 42.96 22.61 50.07 51.49Non

### EGU 0.15 0.18 0.16 0.16Nonroad 4.07 3.48 2.21 1.67 Other 1.65 1.67 1.67 1.67 MAR 0.96 0.74 0.55 0.50 On-road 13.04 11.05 5.10 3.63 TOTAL 62.83 39.73 59.76 59.12 -19.39

Table 18

- Clinton County, Ohio**NO~** Emission Inventory Totals (T50) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 0.00 0.00 0.00 0.00Non

### EGU 0.00 0.00 0.00 0.00Nonroad 2.21 1.96 1.34 1.07 Other 0.42 0.43 0.43 0.43 MAR 0.05 0.05 0.05 0.06Onroad 5.07 3.87 2.02 1.41 TOTAL 7.75 6.31 3.84 2.97 3.34Table 19

- Hamilton County, Ohio**NO~** Emission Inventory Totals (T50) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 15.23 12.92 28.32 29.13Non

### EGU 6.72 6.17 7.39 7.56Nonroad 16.08 13.28 8.04 5.89 Other 5.19 5.27 5.30 5.30 MAR 4.49 3.93 3.14 2.84Onroad 56.51 46.80 21.11 14.44 TOTAL 104.22 88.37 73.30 65.16 23.21

Table 

### 20

-Warren County, Ohio**NO~** Emission Inventory Totals (T50) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 0.00 0.00 0.00 0.00Non

### EGU 2.68 3.14 2.70 2.70Nonroad 5.84 4.94 3.01 2.19 Other 1.15 1.17 1.17 1.17 MAR 0.26 0.25 0.'21 0.19Onroad 15.15 12.76 6.23 4.63 TOTAL 25.08 22.26 13.32 10.88 11.38

### Table 21

- Dearborn County, Indiana NO! Emission Inventory .TSD) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 25.31 27.34 25.30 26.03Non

### EGU 5.09 3.21 5.12 5.19Nonroad * 1.26 1.14 0.78 0.65 Other 0.26 0.26 0.27 0.27Onroad 1.44 1.14 0.60 0.42 TOTAL 33.36 33.09 32.07 32.56 0.41 *MAR emissions are included in the Non-road emissions



### Table 22

- Boone County, Kentucky NO! Emission Inventory Totals (TSD) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 23.80 23.15 24.97 26.35

Non

### EGU 0.14 0.12 0.11 0.12Nonroad * 12.96 11.02 9.77 9.48 Other 4.99 5.02 5.03 5.03Onroad 10.27 8.53 4.63 3.45 TOTAL 52.16 47.84 44.51 44.43 3.41 *MAR emissions are included in the Non-road emissions

### Table 23

- Campbell County, Kentucky**NO~** 

### Emission Inventory Total 'T50) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU 0.00 0.00 0.00 0.00 PointNon

### EGU 0.00 0.02 0.02 0.03Nonroad* 6.33 5.34 4.57 4.34 Other 1.41 1.32 1.30 1.30Onroad 5.98 4.88 2.54 1.81 TOTAL 13.72 11.56 8.43 7.48 4.08 *MAR emissions are included in the Non-road emissions



### Table 24

- Kenton County, Kentucky**NO~** 

### Emission Inventory Totals (T50) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU 0.00 0.00 0.00 0.00 PointNon

### EGU 0.04 0.03 0.03 0.03Nonroad* 8.43 7.33 6.15 5.75 Other 4.17 4.06 4.02 4.02Onroad 10.39 8.37 4.23 3.01 TOTAL 23.03 19.79 14.43 12.81 6.98 *MAR emissions are included in the Non-road·emissionsTable 25

- Cincinnati-Hamilton Area NO! Emission Inventory Totals (TSO) NOx 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin

Butler 47.19 40.52 31.80 28.37 Clermont 62.83 39.73 59.76 59.12 Clinton 7.75 6.31 3.84 2.97 Hamilton 104.22 88.37 73.30 65.16 Warren 25.08 22.26 13.32 10.88 Dearborn 33.36 33.09 32.07 32.56 Boone 52.16 47.84 44.51 44.43 Campbell 13.72 11.56 8.43 7.48 Kenton 23.03 19.79 14.43 12.81 COMBINED NOx TOTAL 369.34 309.47 281.46 263.78 45.69

Table 26

- Butler County, Ohio VOC Emission Inventory Totals (TSO) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin

EGU Point 0.03 0.03 0.02 0.02NonEGU 3.64 2.77 4.25 4.56Nonroad 6.73 5.54 4.85 4.71 Other 11.96 10.31 9.76 9.76 MAR 0.15 0.14 0.10 0.09Onroad 9.94 7.87 4.87 4.50 TOTAL 32.45 26.66 23.85 23.64 3.02Table 27

- Clermont County, Ohio VOC Emission Inventory Totals (T50) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 0.49 0.27 0.52 0.53Non

### EGU 0.24 0.09 0.26 0.27Nonroad 4.31 3.66 3.11 2.95 Other 6.98 6.05 5.74 5.74 MAR 0.02 0.02 0.02 0.01Onroad 6.86 5.42 3.29 3.04 TOTAL 18.90 15.51 12.94 12.54 2.97

Table 28

- Clinton County, Ohio VOC Emission Inventory Totals (T50) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 0.00 0.00 0.00 0.00Non

### EGU 0.00 0.00 0.00 0.00Nonroad 1.73 1.60 1.20 1.02 Other 3.24 2.85 2.72 2.72 MAR 0.04 0.05 0.0.6 0.06Onroad 3.02 2.33 1.47 1.22 TOTAL 8.03 6.83 5.45 5.02 1.81Table 29

- Hamilton County, Ohio VOC Emission Inventory Totals (TSD) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 0.28 0.24 0.31 0.31Non

### EGU 2.66 2.85 2.97 3.12Nonroad 17.25 14.47 12.55 12.06 Other 33.04 28.80 27.38 27.38 MAR 0.20 0.19 0.15 0.13Onroad 29.47 22.70 13.44 12.00 TOTAL 82.90 69.25 56.80 55.00 14.25

Table 30

-Warren County, Ohio VOC Emission Inventory Totals (TSD) Sector 2005 2008 2015 2020 ' Safety Base Attainment Interim Maintenance Margin


### EGU Point 0.00 0.00 0.00 0.00Non

### EGU 0.53 0.82 0.57 0.57Nonroad 4.78 4.09 3.38 3.14 Other 8.40 7.30 6.94 6.94 MAR 0.01 0.01 0.01 0.01Onroad 7.97 6.26 4.02 3.88 TOTAL 21.69 18.48 14.92 14.54 3.94

### Table 31

- Dearborn County, Indiana

## vee Emission Inventory Totals (TSD) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 0.33 0.35 0.44 0.46Non

### EGU 2.91 3.23 3.51 3.69Nonroad 0.82 0.74 0.62 0.60 Other 2.07 2.42 1.79 1.79Onroad 1.00 0.75 0.50 0.42 TOTAL 7.13 7.49 6.86 6.96 0.53 *MAR emissions are included in the Non-road emissions



### Table 32

- Boone County, Kentucky

## vee Emission Inventory Totals (TSD) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU 0.17 0.17 0.18 0.19 PointNon

### EGU 2.40 2.64 2.86 3.01Nonroad* 1.71 5.07 4.55 4.36 Other 8.13 8.41 8.50 8.50Onroad 4.33 4.00 3.17 2.96 TOTAL 16.74 20.29 19.26 19.02 1.27 *MAR emissions are included in the Non-road emissionsTable 33

- Campbell County, Kentucky

## vec Emission Inventory Totals (TSO) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 0.00 0.00 0.00 0.00Non

### EGU 0.25 0.28 0.30 0.31Nonroad* 1.76 1.51 1.29 1.22 Other 4.77 4.34 4.20 4.20Onroad 2.52 2.29 1.74 1.55 TOTAL 9.30 8.42, 7.53 7.28 1.14 *MAR emissions are included in the Non-road emissions

Table 34

- Kenton County, Kentucky

## vec Emission Inventory Totals (TSO) Sector 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin


### EGU Point 0.00 0.00 0.00 0.00Non

### EGU 1.20 1.17 1.31 1.42Nonroad* 2.33 1.95 1.76 1.73 Other 8.53 7.88 7.66 7.66Onroad 4.32 3.85 2.85 2.56 TOTAL 16.38 14.85 13.58 13.37 1.48 *MAR emissions are included in the Non-road emissions

### Table.35

- Cincinnati-Hamilton Area VOC Emission Inventory Totals (T80)

VOC 2005 2008 2015 2020 Safety Base Attainment Interim Maintenance Margin Butler 32.45 26.66 23.85 23.64 Clermont 18.90 15.51 12.94 12.54 Clinton 8.03 6.83 5.45 5.02 Hamilton 82.90 69.25 56.80 55.00 Warren 21.69 18.48 14.92 14.54 Dearborn 7.13 7.49 6.86 6.96 Boone 16.74 20.29 19.26 19.02 Campbell 9.30 8.42 7.53 7.28 Kenton 16.38 14.85 13.58 13.37 COMBINED VOC TOTAL 213.52 187.78 161.19 157.37 30.41



### VOCand NOx

Table 36

- Cincinnati-Hamilton Area Comparison of2008 

### attainmentyearand projected emission estimates (T80)

2008 2015 2015 2020 2020 Projected Projected Decrease Decrease 

### voe 187.78 161.19 26.59 157.37 30.41 NOx 309.47 281.46 28.01 263.78 45.69

As shown in the table**abov~,** 

## vae emissions in the nonattainmentarea are projected to decrease by26.59 TSD in 2015 and 30.41 TSD in 2020. Point sources in the Kentucky
area show a slight increase due to expectations that the population will grow in this area; however, cleanervehicles and fuels are expected to be in place in 2009 and 2018, and they
cause an overall drop in

## vae emissions. 

## Nax emissions in the nonattainment area are projected to decrease by28.01 TSD in 2015 and 45.69TSD in 2020. Again,
area source emissions and, to a lesser extent, point sources showa slight increase due to expectations thatthe population will growin this area. Decreasesfrom U.S. EPA rules covering Tier2 MotorVehicle Emissions Standards and Gasoline SulfurControl Requirements8

, Highway

### Hea~-Duty Engine RUle9

, and the Non-Road Diesel Engine Rule1 are factored into the changes.

All projections do not take into account reductions expected from the Clean Air Interstate Rule11. In many cases, Ohio utilities subject to CAIR have already, or will be installing controls and reducing NOx emissions beyond those projected for EGU's above.

As can be seen from the projected decreases above, even in the absence ofconsideration ofreductions resulting from CAIR, the area will be able to maintain the standard.

As identified in Table 14 and Table 15 above, an additional mobile budget margin ofsafetyallocation is being requested for mobile emissions. The mobile budget margin of safety allocation translates into an additional 6.14 TSD forVOC and 9.39 TSD for NOx in the year2015 and 6.76 TSD forVOC and 9.49 TSO for NOx in the year 2020. U.S. EPA's conformity regulations allowforallocation, through a revision tothe SIP, of all orsome portion ofthe overall area'ssafetymargin (emission reductionsfrom 2008to 2020) tothe mobile emissions budgets for future conformity. As identified in Table 14 and Table 15 above, the mobile budget margin of safety allocation and the total budget is distributed separatelybetween Kentucky (alone) and Ohio/Indiana (combined). For the entire area, Ohio, Indiana and Kentucky chose to allocate:

In 2015: 6.14 TSO of the 26.59 TSD safety margin for VOC and 9.39 TSD ofthe 28.01 TSO safety margin for NOx as a mobile emissions budget safety margin.

In 2020: 6.76 TSO of the 30.41 TSD safety margin for VOC and 9.49 TSD ofthe 45.69 TSO safety margin for NOx asa mobile emissions budget safety margin.

8 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 9 http://www.epa.gov/fedrgstr/EPA-AIR/1997/0ctober/Day-21/a27494.htm 10 http://www.epa.gov/fedrgstr/EPA-AIR/1998/0ctober/Day-23/a24836.htm

11 http://www.epa.gov/fedrgstr/EPA-AIR/2005/May/Day-12/a5723a.pdf

### Requirement4 of5 A demonstration that improvement in airquality between the yearviolations occurred and the yearattainmentwas achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusuallyfavorable meteorology.


### Background Ambientairqualitydatafrom all monitoring sites indicatethatair quality met the NAAQS for ozone in 2007-2009. U.S. EPA's redesignation guidance (p 9) states: "A state may generally demonstrate maintenanceofthe NAAQS byeithershowingthat future emissions ofa pollutantorits precursorswill notexceed the level of the attainment inventory, or by modeling to show that the future mix of sources and emissions rates will not
cause aviolation ofthe NAAQS."



### Demonstration Permanent and enforceable reductions of

## voe and NOx emissions have contributed to the attainment ofthe eight-hourozone standard. Someofthese reductionswere duetothe application oftighterfederal standards on new vehicles. Reductions achieved are discussed in greaterdetail underChapter Five.



### Table 37

- Cincinnati-Hamilton Area Combined Comparison of 2005 base yearand 2008 attainmentyearon-road reductions

2005 2008

On-road 

### voe 69.43 55.47
136.73 113.45 On-road NOx



### Requirement5 of5 Provisions forfuture annual updates ofthe inventoryto enable tracking of the emission levels, including an annual emission statementfrom major
sources.



### Demonstration In Ohio, major point sources in all counties are required to submit air emissions information annually, in accordance with U.S. EPA's Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic inventory for all ozone precursor emission sectors every three years. These ozone precursor inventories will be prepared for future years asnecessaryto complywith the inventory reporting requirements established in the CFR. Emissions information will be compared to the 2005 base year and the 2020 projected maintenance year inventories to assess emission trends, as necessary, and to assure continued compliancewith the ozone standard.

### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS CM Section107 (d)(3)(E)(ii), 107(d)(3)(iv) & 107(d)(3)(E)(v)


### Requirement 1 of5 Section 182(a) ofthe 1990 Clean AirAct Amendments requires states with marginal nonattainment areas to implement RACT under Section 172(b).


### Background Section 182(b) ofthe 1990Clean AirActAmendments requires states with moderate nonattainment areas to submit a SIP to correct, oradd, RACT requirements underSection 172(b) (as in effect immediately before the enactment of the Clean AirAct Amendments of 1990).



### Demonstration As required under the 1-hour ozone standard, Ohio EPA submitted VOC RACT rules which U.S. EPAapproved on April 25, 1996 (61 FR 18255) and September 7, 1994 (59 FR 46182).

Statewide RACT rules have been applied to all new sources locating in Ohio since that time. RACT requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessaryto ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violationsdiscovered byfield office staff. The Ohio RACT rules
are found in OAC Chapter 3745-21 12

. 

### Requirement 2 of5 Section 182(a)(3)(8) requires states to submit emissions statements.


### Background Section 182(a)(3)(8) requires states to submit emissions statements within two years ofthe enactment ofthe Clean Air ActAmendments and then everythree years thereafter.



### Demonstration Ohio EPAsubmitted its emissions statement SIP on March 18, 1994 which was approved by U.S. EPA on October 13, 1995 (59 FR 51863). As discussed in Chapter 4 (Requirement 4), Ohio EPAsubmits, and commitstosubmit, emission inventories (statements) everythree years.

12http://www.epa.state.oh.us/dapc/regs/3745-21/3745_21.html

### Requirement 3 of5 Evidence that control measures required in past ozone SIP revisions have been fully implemented.
Background In addition to the historic RACT requirements and those mentioned above, the U.S. EPA NOx 

### SIP Call required 22 states to pass rules that would result in significant emission reductionsfrom large EGUs, industrial boilers, and cementkilns in the eastern United States. Ohio passed this rule in 2001. NOxSIP Call requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to
ensure ongoing compliance. Ohio EPA also has an active enforcement program to addressviolations discovered byfield office staff. Compliance is tracked through the Clean Air Markets data monitoring program. Beginning in 2004, this rule accountsfora reduction ofapproximately31 percentofall NOx 

### emissions statewide compared to previous uncontrolled years. The other21 states also have adopted these rules.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA's CAIR rule requires EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of NOx. CAIR replaced the NOxSIP Call for EGUs. National NOx

### emissionswill be cutfrom 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were required to submit a CAIR SIP as part of this effort. Ohio submitted a CAIR SIP which was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final action on September 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA projects that in 2009 emissions of NOx will decrease from a baseline of 264,000 tons peryearto 91,000 tons peryearwithin Ohio13.



### On December 23, 2008, U.S. EPA's CAIR program was remanded without vacatur by the D.C. Circuit Court. As mentioned above, Ohio EPA has not incorporated these expected CAIR reductions into this redesignation request. It should also be noted that Ohio's SIP-approved NOx SIP Call program and regulations arestill in place. Ohio EPAiscurrently in the process of revising these regulations to provide a "back

13http://www.epa.gov/cair/pdfs/0053-2228.pdfstop" forthe reinstatement ofthe NOx SIP Call program in the event the CAIR program, or an equivalent, is no longer implemented by U.S. EPA.

Section 182(b) contains additional provisions applicable to moderate nonattainment areas, for which the CincinnatiHamilton area was under the one-hour standard. Section 182(b)(3) requires gasolinevaporrecoverysystemsforgasoline dispensing stations in the area and section 182(b)(4) requires motorvehicle inspection and maintenance programs.

Demonstration



## u.s. EPAand Ohio EPAperformed modelingthatindicatedthis
area would attain the eight-hour ozone standard with the implementation ofthe NOxSIP Call. ControlsforEGUsformally commenced May,31 ,2004. Emissionscovered bythis program have been generallytrending downward since 1998with larger reductions occurring in 2002 and 2003. Data taken from the U.S. EPAClean AirMarketsweb site, quantifythe gradual NOx reductions that have occurred in Ohio as a result ofTitle IV of the 1990 CM Amendments and the beginning ofthe NOxSIP Call Rule. Ohio developed the NOxBudget Trading Program rules in OAC Chapter 3745-1414 in response to the SIP Call. OAC Chapter3745-14 regulates EGUs and certain non-EGUs under a cap and trade program based on an 85 percent reduction of NOx emissions ·from EGUs and a 60 percent reduction of NOx emissions from non-EGUs, compared to historical levels. This cap will stay in place through 2008, at which time the CAIR program will supersede it as discussed above.

On April 21 ,2004, U.S. EPApublished Phase II ofthe NOxSIP Call that establishes a budgetfor large (greaterthan 1 ton per day emissions) stationary internal combustion" engines. Ohio EPA's OAC rule 3745-14-12 addresses stationary internal combustion engines, all used in natural gas pipeline tran,smissions. U.S. EPA approved tris revision to the SIP on April 4, 2008. An 82 percent NOxreduction from 1995 levels is anticipated. Completion of the compliance plan occurred by May 1, 2006, and the compliance demonstration began May 1, 2007. The 2007 controlled NOx emissions are 599 tons statewide forthe ozone season.

14http://www.epa.state.oh.us/dapc/regs/3745-14/3745_14.htmlSection 182(b)(3) requires states to submit Stage II vapor recovery rules no laterthan November 15,1992. The U.S. EPA partiallyapproved and partiallydisapproved Ohio's SIP revision for implementation of Stage II on October, 20, 1994 (59 FR 52911). As stated in that rulemaking action, with the exception ofparagraph 3745-21-09 (000)(5), U.S. EPAconsiders Ohio's Stage II program to fully satisfy the criteria set forth in the September 17, 1993, U.S. EPA guidance document for such programs entitled "Enforcement Guidance for Stage II Vehicle Refueling Control Programs." Furthermore, the September 17, 1993, guidance memorandum states that once onboard vapor recovery regulations are promulgated, the Stage II regulations
are no longer applicable for moderate ozone nonattainment
areas. The U.S. EPA promulgated onboard vapor recovery rules in February 1994. Therefore, pursuant to Section 202(a)(6) of the CAA, Stage II would no longer be required. Stage Iand Stage II requirements are still being implemented in the original one-hour attainment area (excludes Clinton County).

The U.S. EPA's final 11M regulations in 40 CFRPart 85 require the states to submit afully adopted 11M program by November 15, 1993. U.S. EPAapproved Ohio'senhanced 11M program (ECheck), on April 4, 1995 (60 FR 16989) and January 6, 1997 (62 FR 646). The E-check program is no longer being implemented in this area. On November 3, 2005, Ohio EPA submitted a requestfor replacementofthe E-Checkprogram in this area. In order to transfer the E-Check program from the active maintenance plan to a contingency plan, alternative emission reduction programs were adopted to replace the benefits associated with the E-Check program in the one-hour maintenance plan approved at that time. The following programs were implemented in place ofthe E-Check program and are still being implemented today in the original one-hour attainment area (excludes Clinton County):

• OAC rule 3745-21-09(O)(2)(e)

-Vaporpressure limitfor cold cleaning degreasing operations. Approved July28, 2009 (74 FR 37171)

• OAC rule 3745-21-18

- Mobile equipment refinishing emission reduction via high transfer efficiency spray guns. Approved July28,2009 (74 FR 37171) OAC Chapter 3745-72

- Low Reid Vapor Pressure Fuels. Approved May25, 2007 (72 FR 29269) OAC rule 3745-21-17

- Portable Fuel Containers. Approved October 14,2009 (74 FR 52691)

### Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleanercars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NOx 

### emission reductions will be approximately 77 percent for passengercars, 86 percentforsmallerSUVs, lighttrucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks.VOC emission reductions will be approximately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for largerSUVs, vans, and heaviertrucks.
Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low-sulfurdiesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoline and.diesel trucks and buses. This rule will result in a 40 percent reduction in NOx 

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

### inventory.

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. Italsocontainsa cleaner fuel standard similar to the highway diesel program. The new standards will cut emissions from non-road diesel engines bymorethan 90 percent. Non-road diesel equipment,
as described in this rule, currently accounts for 47 percent of diesel particulate matter (PM) and 25 percent of NOx 

### from mobilesources nationwide. Sulfurlevelswill be reduced in nonroad diesel fuel by 99 percent from current levels, from approximately 3,000 parts per million (ppm) nowto 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starting in 2008. Together, these ruleswill substantiallyreduce local and regional
sources ofozone precursors.Requirement 4 of5 Acceptable provisions to provide for newsource review.
Background Ohio has a longstanding and fully implemented New Source 

### Review**~NSR)** 

### program. This is addressed in GAC Chapter 3745-31 5. The Chapterincludes provisionsforthe Prevention of Significant Deterioration (PSD) permitting program in OAC rules 3745-31-01 to 3745-31-20. Ohio'sPSD program was conditionallyapproved on October 10, 2001 (66 FR51570) and received final approval on January 22, 2003 (68FR 2909) by U.S. EPA as part ofthe SIP.

Demonstration Any facility that is not listed in the 2005 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable NSR requirements. Once the area is redesignated, Ohio EPAwill implement NSR through the PSD program.
Requirement 5 of5 Assure that all existing control measures will remain in effect after redesignation unlessthe Statedemonstratesthrough photochemical modeling that the standard can be maintained without one (1) or more control
measures.

Demonstration Ohio commits to maintaining the aforementioned control
measures after redesignation. Ohio hereby commits that any changesto its rules oremission limits applicabletoVOC and/or NOx sources, as required for maintenance of the ozone standard in the Cincinnati-Hamilton area, will be submitted to U.S. EPAfor approval as a SIP revision.
Ohio, through Ohio EPA's Legal section, hasthe legal authority and necessary resourcesto activelyenforceanyviolations ofits rules or permit provisions. After redesignation, it intends to continue enforcing all rulesthat relate tothe emission ofozone precursors in the Cincinnati-Hamilton area.

15http://www.epa.state.oh.us/dapc/regs/3745-31/3745_31.html

### CHAPTER SIX

CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v)
Requirement 1 of4 A commitmentto submit a revised p·lan eight(8) years after redesignation.

Demonstration Ohio hereby commits to review its maintenance plan eight (8) years after redesignation, as required by Section 175(A) ofthe CAA.
Requirement 2 of4 A commitmentto expeditiouslyenact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or'in the eventthatfuture violations ofthe ambientstandard occur.

Demonstration Ohio hereby commitS to adopt and expeditiously implement necessary corrective actions in the following circumstances:
Warning Level Response:

A warning level response shall be prompted whenever an annual (1-year) fourth high monitored value of88 ppb occurs in
a single ozone season within the maintenance area. Awarning level response will consist ofa studyto determinewhetherthe
ozone value indicates a trend toward higher ozone values or whether emissions appear to be increasing. The study will evaluate whetherthe trend, if any, is likely to continue and, if so, the control measures necessaryto reversethetrend 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 ozone season (October31).

Should it be determined through the warning level study that action is necessaryto reverse the noted trend, the procedures forcontrol selection and implementation outlined under"action level response" shall be followed.Action Level Response:

An action level response shall be prompted whenever a twoyearaveragefourth high monitored value of85 parts perbillion (ppb) or greater occurs within the maintenance area. A violation ofthe standard (three-yearaverage fourth high value of85 ppb orgreater) shall also promptan action level response.

In the eventthatthe action level istriggered and is notfound to be dueto an exceptional event, malfunction, ornoncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropolitan planning organization or. regional council of governments, will determine additional control measures needed to assure future attainment of the NAAQS for ozone. In this case, measures that can be implemented in a short time will be selected in order to be in placewithin 18 monthsfrom the close ofthe ozone season that prompted the action level. Ohio EPA will also consider the timing of an action level trigger and determine if additional, significant new regulations notcurrently included as partofthe maintenance provisionswill be implemented in atimelymanner and will constitute our response.

Control Measure Selection and Implementation
Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication ofnotices, an opportunityforpublichearing, and other measures required by Ohio lawfor rulemaking.

Ifa newmeasure/control is alreadypromulgated 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 demonstratethe proposed measures are adequate to return the area to attainment.
Requirement 3 of4 A list of potential contingency measures thatwould be implemented in such
an event.

Demonstration Contingency measuresto be considered will beselected from a comprehensive list of measures deemed appropriate and effective at the time the selection is made. The selection of
measures will be based on cost-effectiveness, emission

### reduction potential, economicand social considerationsorother factorsthatOhio EPAdeems appropriate. Ohio EPAwill solicit input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency
measures. Because it is not possible atthis time to determine what control measures will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not exhaustive.
1) Implementation ofan enhanced 11M program (E-Check) in Butler, Clermont, Hamilton and Warren Counties.
2) Tighten or adopt VOCRACT on existing sources covered by U.S. EPA Control Technique Guidelines issued afterthe 1990 CAA.
3) Apply

## vac RACTto smallerexisting sources. 4) Oneormoretransportation control measuressufficientto achieve at least half a percent reduction in actual areawide

## vac emissions. Transportation measureswill be selected from the following, based upon the factors listed above after consultation with affected local governments:

a) 

### trip reduction programs, including, but not limited to, employer-based

. transportation management plans, areawide rideshare programs, work schedule changes, and telecommuting;

b) 

### trafficflow and transit improvements; and

c) 

### other newor innovativetransportation measures not yet in widespread use that affected local governments deem appropriate.
5) Alternative fuel and diesel retrofit programs for fleet vehicle operations.
6) Require VOC or NOx 

### emission offsets for new and modified majorsources. 7) Increase the ratio of emission offsets required for new sources.8) Require VOC or NOx controls on new minor sources (less than 100 tons).
9) Adopt NOx RACT for existing combustion sources.

No contingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits ofindividual measures, at the time they are under consideration, can be fully evaluated.
Requirement 4 of4 A list ofVOC and NOxsources potentially subjectto future additional control requirements.

Demonstration The following is a list ofVOC and NOxsources potentially subjectto future controls.

NOxRACT

• EGUs

• asphalt batching plants

• industrial/commercial and institutional boilers

• process heaters

• internal combustion engines

• combustion turbines

• othersources greaterthan 100 tons peryear

VOC RACT

• synthetic organic compound manufacturing

• organic compound batch processes

• wood manufacturing

• industrial wastewater

• aerospace industry

• bakeries

• plastic parts coating

•**volatil~** organic liquid storage

• industrial solvent cleaning

• offset lithography

• industrial surface coating

• othersources greaterthan 50 tons peryear

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public commentconcerning the draft redesignation petition and maintenance plan in the widely distributed countypublicatibns-on November4,-2009.

The public hearing to receive comments on the redesignation request was held on December 9, 2009, at the Hamilton County Department of Environmental Services, Cincinnati, Ohio. The publiccommentperiod closed
on December 11
,2009. Notestimonywas provided atthe publichearing and
no comments were received during the public comment period. Appendix E includes a copy of the public notice from the public hearing and .comment period.

### CHAPTER EIGHT

CONCLUSIONS

The Cincinnati-Hamilton ozone nonattainment area has attained the 1997 NAAQS for ozone and complied with the applicable provisions ofthe 1990 Amendments to the CAA regarding redesignations of ozone nonattainment
areas. Documentation to that effect is contained herein. Ohio EPA has prepared a redesignation request and maintenance plan that meet the requirements of Section 110 (a)(1) ofthe 1990 CAA.

Based on this presentation, the Cincinnati-Hamilton ozone nonattainment
area meetsthe requirementsfor redesignation underthe CAAand U.S. EPA guidance. Ohio has performed an analysis that shows the air quality improvements are due to permanent and enforceable measures. Furthermore, becausethis area issubjecttosignificanttransportofpollutants, significant regional NOx reductions will ensure continued compliance (maintenance) with the standard with an increasing margin ofsafety.

The State of Ohio hereby requests that the Cincinnati-Hamilton ozone nonattainment area be redesignated to attainment simultaneouslywith U.S. EPA approval of the maintenance plan provisions contained herein. In addition, the State of Ohio requests that this maintenance plan satisfy the requirements ofCAASection 175A(b), forsubsequentplan revisions required for areas redesignated forthe one-hour ozone standard.This page left intentionally blank