REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

THE CINCINNATI-HAMILTON, OH-KY-IN

8- HOUR OZONE

NONATTAINMENT AREA

Butler, Clermont, Clinton, Hamilton,

and Warren Counties, Ohio

Prepared by:

Ohio Environmental Protection Agency

Division of Air Pollution Control

December 2009

Revised July 2010

TABLE OF CONTENTS

Chapter One

Introduction 1

Background 1

Geographical description 2

Status of air quality 2

Chapter Two

Requirements for redesignation ,3

Chapter Three

Ozone monitoring 7

Ozone NAAQS 7

Ambient data quality assured 8

Three.complete years of data 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 for future updates 36

Chapter Five

Control measures and regulations 38

Marginal nonattainment areas to implement RACT 38

Emission inventories/statements 38

Implementation of past SIP revisions 39

New source review provisions 43

Assurance of continued controls 43

Chapter Six

Contingency measures 44

Commitment to revise plan 44

Commitment for contingency measures 44

Potential contingency measures 45

List of vac and NOx sources 47

Chapter Seven

Public participation 48

Chapter Eight

Conclusions 49
Figure 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 Nonattainment Area 8

TABLES

Monitoring Data for Cincinnati-Hamilton 2007 - 2009 10

Emission Estimations for On-road Mobile Sources for Butler Co., 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 for Warren Co., Ohio 18

Emission Estimations for On-road Mobile Sources for Dearborn Co., Indiana 19

Summary of Ohio 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 Butler Co, 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 Inventory Warren 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 Butler Co, Ohio 29

VOC Emission Inventory Clermont Co., Ohio 30

VOC Emission Inventory Clinton Co., Ohio 30

VOC Emission Inventory Hamilton Co., Ohio 31

VOC Emission Inventory Warren 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 Inventory Cincinnati-Hamilton, Total 34

Projected Emission Estimates 2008-2020 Cincinnati-Hamilton 34

Combined Comparison of 2005 and 2008 On-road and EGU Totals 36
APPENDICES

A Air Quality System (AQS) Data

B Ohio 2005 SIP Base Year Inventory Discussion

C "Mobile Source Emissions Inventory for the Cincinnati Ozone Nonattainment Area"

o LADCO Technical Support Document

E Public Participation Documentation
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REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE

CINCINNATI-HAMILTON, OHIO

OZONE NONATTAINMENT AREA

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

CHAPTER ONE

Introduction

The Clean Air Act (eM) requires areas failing to meet the 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-hour ozone standard set at 0.08 parts per million (ppm). The standard

was challenged legally and upheld by the U.S. Supreme Court in February of

2001.

On April 30, 2004, U.S. EPA designated 134 nonattainment areas for the

e.ight-hour ozone standard.· Section 107(d)(3)(E) of the CM allows states to

request nonattainment areas to be redesignated to attainment provided

certain criteria are met. The following are the criteria that must be met in order

for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has attained the eight-hour

ozone standard.

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

under Section 11 O(k). '-

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

permanent and enforceable reductions in emissions

resulting from implementation of the SIP and other federal

requirements.

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

v) A determination that all Section 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 of the 1990 CM Amendments re-evaluation, the following Counties

within the Cincinnati-Hamilton area were designated as moderate
nonattainment for the one-hour ozone standard pursuant to the CAA and,

therefore, were subject to nonattainment area rulemakings: Butler, Clermont,

Hamilton, and Warren Counties in Ohio and Boone, Campbell and Kenton

Counties in Kentucky. The Ohio portion of the Cincinnati-Hamilton area was

redesignated to attainment on 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 at those times.

As a result of the 2004 ozone designations, U.S. EPA designated the

Cincinnati-Hamilton area basic nonattainment for the eight-hour standard, and

Ohio EPA was required to develop a plan to reduce volatile organic

compounds (VOCs) and nitrogen oxides (NOx) emissions to meet the federal

eight-hour air quality standard for ozone by June 2009.

. .

This document is intended to support Ohio's request that the Ohio portions of

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 of the Cincinnati-Hamilton area. The Cincinnati-Hamilton area has

recorded three (3) years of complete quality-assured ambient air quality

monitoring data for the years 2007 - 2009 demonstrating attainment of the

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 Chapter Three.

Status of Air Quality

Ozone mon.itoring data for the most recent three (3) years, 2007 through

2009, 'demo'nstrate that the air quality has met the 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) of the eAA.
CHAPTER TWO

Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures

for Processing Requests to Redesignate Areas to Attainment (redesignation

guidance), issued September 4, 1992, to Regional Air Directors. The

redesignation request and maintenance plan are based on the redesignation

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

EPA Region V.

Below is a summary of each redesignation criterion as it applies to the

Cincinnati-Hamilton area.

L) Attainment of the standard

There are two components involved in making this

demonstration. The first component relies on ambient air

quality data. The data that are used to demonstrate attainment

should be the product of ambient monitoring that is

representative of the area of highest concentration. The data

should be collected and quality-assured in accordance with 40

CFR 58 and recorded in the Air Quality System (AQS) in order

for it to be available to the public for review.

The second component relies upon supplemental U.S. EPAapproved air quality modeling. 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 includes the CincinnatiHamilton area. Chapter Five discusses this requirement in

more detail.

iii.) Permanent and enforceable improvement in air quality

The state must be able to reasonably attribute the improvement

in air quality to emission reductions which are permanent and

enforceable. The state should estimate the percent reduction

achieved from federal measures as well as control measures

that have been adopted and implemented by the state.
The Ohio Counties portion of the Cincinnati-Hamilton area was

designated moderate nonattainment for ozone as part of the

1990 CAA Amendments re-evaluation. As a result, Ohio has

adopted and implemented control measures for these Counties

in that area beyond the federal measures and the initial

1979/1981 Statewiderules. In addition, Ohio EPA has adopted

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 Four and Five discuss this requirement in more detail.

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

prior to submittal of the complete redesignation request.

Part 0 consists of general requirements applicable to all areas

which are designated nonattainment based on a violation ofthe

NAAQS.

L) Section 11 O(a) requirements

Section 11 O(a) of Title I of the CAA contains the general

requirements for a SIP. Section 11 O(a)(2) provides that

the implementation plan submitted by a state 'must have

been adopted by the state after reason~ble public notice

and hearing, and that, among other things, it must

include enforceable emission limitations and other

control measures, means or techniques necessary to

meet the requirements of the CAA; provide for

establishment and operation of appropriate devices,

methods, systems and procedures necessary to monitor

ambient air quality; provide for implementation of a

source permit program to regulate the modification and

construction of any stationary source within the areas

covered by the plan; include provisions for the

implementation of Part C, prevention of significant

deterioration (PSD) and Part 0, NSR permit programs;

include criteria for stationary source emission control
measures, monitoring, and reporting; include provisions

for air quality modeling; 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, Ohio

verified that the State fulfills the requirements of Section

110(a)(2) of the 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 not apply for redesignations because they only have

meaning for areas not attaining the standard. The

requirements for an emission inventory will be satisfied

by the inventory requirements of the maintenance plan.

Chapters Four and Five discuss this requirement in more

detail.

ii.) Conformity

The state must work with U.S. EPA to show that its SIP

provisions are consistent with the Section 176(c)(4)

conformity requirements. The redesignation request

should include conformity procedures, if the state

already has these procedures in place. If a state does

not have conformity procedures in place at the time that

it submits a redesignation request, the state must

commit to follow U.S. EPA's conformity regulation upon

issuance, as applicable.

v.) Maintenance plans

Section 107(d)(3)(E) stipulates that for an area to be

redesignated, U.S. EPA must fully approve a maintenance plan

that meets the requirements of Section 175(A). The

maintenance plan must constitute a SIP revision and must

provide for maintenance of the relevant NAAQS in the area for

at least 10 years after redesignation. Section 175 (A) further

states that the plan shall contain such additional measures, if

any, as may be necessary to ensure such maintenance.

In addition, the maintenance plan shall contain such

contingency measures as the Administrator deems necessary

to ensure prompt correction of any violation of the NAAQS. At

a minimum, the contingency measures must include a
requirement that the state will implement all measures

contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should

consider the following provisions:

a.) attainment inventory;

b.) maintenance demonstration;

c.) monitoring n,etwork;

d.) verification of continued 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 of 4

A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, has

been attained.

Background

There are eleven monitors measuring ozone concentrations in

this nonattainment area. Eight of the 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 locations of the monitoring sites for this nonattainment area

are shown on Figure 1.

1 The draft version of this 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 of this document, prior to official submittal to U.S.

EPA. Ohio EPA does not believe the data as provided in this draft will change appreciably.
Demonstration

Figure 1 Map of the Cincinnati-Hamilton, OH nonattainment

area and monitor locations

Requirement 2 of 4

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

recorded in the U.S. EPA air quality system (AQS) database, and available for

public view. .

Demonstration

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 of 4

A showing that the three-year average of the fourth highest values, 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 calendar years 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 of ozone monitoring data are required to

demonstrate attainment at a monitoring site. The eight-hour

primary and secondary ozone ambient air quality standards are

met at an ambient air quality monitoring site when the threeyear average of the annual fourth-highest daily maximum eigh~­

hour average ozone concentrations is less than or equal to 0.08

ppm. When this occurs, the site is said to be in attainment.

Three significant digits must be carried in the computations.

Because the 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, for the purposes of this request, the eight-hour

standard is considered to be 0.085 ppm. Values

below 0.085 ppm meet the standard, values equal to or greater

than 0.085 ppm exceed the standard. These data handling.

procedures are applied on an individual basis at each monitor in

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 highest daily maximum eight-hour average ozone

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. EPA AQS. The air quality design value

for the area is the highest design value among all sites in the

area. Please note that the standard is measured in ppm while

the commonly used unit is ppb. For the remainder of this

document, ppb will be used.
Demonstration

Table 1 Monitoring Data for the Cincinnati-Hamilton, OH area

for 2007 - 2009

Data source: U.S~ EPA Air 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 80
1st 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

Highest Average 82 ppb

The area's design values have trended downward as emissions have

declined due to such factors as cleaner automobiles and fuels, and

controls for EGUs, both regionally and locally.

Requirement 4 of 4

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

appropriate monitoring network to verify the maintenance of the attainment

status.

Demonstration

Ohio EPA commits to continue monitoring ozone levels at the

Ohio sites indicated in Figure 1. Ohio EPA will consult with U.S.

EPA Region V prior to making changes to the existing

monitoring network, should changes become necessary in the

future. Ohio EPA will continue to quality assure the monitoring

data to meet the requirements of 40 CFR 58 and all other

federal requirements. Connection to a central station and
updates to the Ohio EPA web 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.

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

EMISSION INVENTORY

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

u.s. EPA's redesignation guidance requires the submittal of a comprehensive

inventory of ozone precursor emissions (VOC and NOx) representative of the

year when the area achieves attainment of the ozone air quality standard.

Ohio also must demonstrate that the improvement in air quality between the

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

based on permanent and enforceable emission reductions. Other emission

inventory related requirements include a projection of the emission inventory

to a year at least 10 years following redesignation; a demonstration that the

projected level of emissions is sufficient to maintain the ozone standard; and

a commitment to provide future updates of the inventory to enable tracking 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 emissions from 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.

Indiana and Kentucky emissions data were obtained directly from Indiana and

Kentucky, respectively. All of these inventories and emissions projections

were prepared using similar methodologies. Ohio recognizes that revisions to

the emissions data below may be necessary once Kentucky and Indiana

prepare a redesignation request and maintenance plan for their portion ofthe

nonattainment area. Mobile emissions inventories and projections for all

Counties were prepared by the Ohio, Kentucky, Indiana Council of

Governments (OKI).

Requirement 1 of 5

A comprehensive emission inventory qf the precursors of ozone completed

for the base year.

Background

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

reporting program. The 2005 periodic inventory has been

identified as one of the preferred databases for SIP

development and coincides with nonattainment air quality in the

Cincinnati-Hamilton area.

Periodic inventories, which include emissions from all sectors -

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

three years.
Demonstration

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

this submittal and was submitted to U.S. EPA on June 15,2007

along with the attainment demonstration for this area. The

detailed emission inventory information for the Ohio portion of

the Cincinnati-Hamilton area is provided in Appendix B.

Emissions of VOC and NOx for 2005 are identified under

Requirement Three of this Chapter.

Requirement 2 of 5

A projection of the emission inventory to a year at least 10. years following

redesignation.

Background

Ohio EPA prepared a comprehensive inventory'for the Ohio portion of

the Cincinnati-Hamilton area including area, mobile, and point sources

for precursors of ozone (VOCs and NOx) for base year 2005. The 2005

inventory was submitted to U.S. EPA on June 15, 2007 as part of the

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 year estimates of annual emissions for each source

sector using accepted growth surrogates. These inventories were

provided to the LADCO and have been processed to develop summerday emissions for use in the air quality analyses. These .processed

modeling inventories have been identified as the correct iteration ofthe

inventory for use in the redesignation. In this document, references to

LADCO include the Midwest Regional Planning Organization. Note,

the on-road mobile source sector was addressed by specific modeling

as discussed below.

• Area sources were taken from the Ohio 2005 periodic

inventory submitted to U.S. EPA. These projections

were made from the U.S. Department of Commerce

Bureau of Economic Analysis (BEA) growth factors,with

some updated local information.

• Mobile source emissions were calculated from

MOBILE6.2-produced emission factors.

3

http://www.ladco.org/tech/emis/r5/reports/LADCO%202005%20Base%20YrOA>2oGrowth%20and%

20Controls%20Report_Final.pdf
• Point source information was compiled from Ohio EPA's

2005 annual emissions inventory database and the 2005

U.S. EPA Air Markets acid rain database4.

• Biogenic emissions are not included in these summaries.

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

National Mobile Inventory Model (NMIM) 2002

application. To addr~ss concerns about the accuracy of

some of the categories in U.S. EPA's non-road

emissions model, LADCO contracted with two (2)

companies to review the base data and make

recommendations. One of the contractors also

estimated emissions for three (3) non-road categories

not included in U.S. EPA's non-road model. Emissions

were estimated for aircraft, commercial marine vessels,

and railroads. Recreational motorboat population and

spatial surrogates (used to assign emissions to each

county) were significantly updated. The populations for

the construction equipment category were reviewed and

updated based upon surveys completed in the midwest,

and the temporal allocation for agricultural sources also

was updated.

Demonstration

On-Road Emission Estimations

In coordination with the Ohio Department of Transportation

(Ohio DOT), OKI 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 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 determine the infrastructure requirements necessary to meet

that need. It is also used as a tool for air quality purposes to

estimate the total emissions of pollution caused by vehicles in

the area. The travel demand forecasting model is used to

predi.ct the total daily vehicle miles traveled (VMT), and a U.S.

EPA computer program called MOBILE6.2 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. Clinton

County is outside the area covered by the regional travel

demand model. The Ohio DOT uses traffic counts and local

traffic growth rates for the VMT estimates.

4 http://www.epa.gov/airmarkets/acidrain
Overview

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 uses the

loaded highway network to generate VMT by hour, VMT by

speed distribution, and VMT by facility type. 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 traffic volumes)

are estimated using techniques from the 1997 Highway

Capacity Manual. This permits the estimation of speeds as

conditions vary from hour to hour on the different facility types

throughout the region. The post-processing program performs

the appropriate summation by area and roadway type as well 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

traffic counting stations utilizing the average daily traffic monthly

conversion factors for June, 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 with the Ohio DOT and Ohio EPA, for temperature,

fuel programs and fuel characteristics. Low RVP (Reid Vapor

Pressure) gasoline is the summer fuel program in OKI's Ohio

counties. Low RVP fuel results in lower evaporative 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

appropriate calendar year (from 1952 to 2050). These emission

factors are then multiplied by VMT. The methodologies

incorporated into MOBILE6.2 for estimating emissions are

based on methods and research conducted by U.S.EPA. OKI's

development of MOBILE6.2 input values were guided by the
U.S.EPA's document "Technical Guidance on the Use of

MOBILE6 forEmission InventoryPreparation': January 2002.

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 factors than gasoline

vehicles, and higher average speeds have lower emission

factors except for diesel vehicles which have higher NOx at

higher speeds. MOBILE6.2 input and output files are provided

in Appendix C.

Best Available 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

available from OKI and most current Ohio DOT count data were

used by Ohio DOT for the 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" document dated October, 2009 (revised).

See Appendix C.

Analysis Years

Analysis years for this redesignation request include 2005, 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 for that year.

Local Road VMT

Most local roads such as subdivision streets are not explicitly

modeled in a travel demand model. These local roads are

represented as fictitious roadways called centroid connectors.

Local road VMT is included in the OKI post process by including

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 of the emissions analysis for

the appropriate years. All emissions estimations are expressed in

tons per summer day (TSD).

Table 2 - Butler County, 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 - Clermont County,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 of Ohio 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 for On-Road Mobile

Sources for the 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

Motor Vehicle Emission Budget

Table 14 and Table 15 contain the motor vehicle emissions

budgets for the Cincinnati-Hamilton area. For planning purposes,

budgets are established for the combined Ohio and Indiana

portions and for the separate .Kentucky portion.

Table 14 - Mobile Vehicle Emissions Budget for 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 of the mobile source emission estimates.
a e - ole e IC e missions B dU Igetfor KentUCk: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 budgets for the Ohio and Indiana portion ofthe area,

agre'ed upon as part of the 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 effort to accommodate future variations in travel demand

models and VMT forecast when no change to the network is

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

reasonable approach to address this variation. Based on this

discussion, a 15 percent margin of safety allocation was agreed

upon and has been added to the emissions estimates for the

Ohio and Indiana portions of this 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 as described above underthe expected

OKI 2030 Long Range Plan. All methodologies, the latest

planning assumptions, and the safety margins allocations were

determined through the interagency consultation process

described in the Transportation Conformity Memorandum of

Understanding (MOU) among OKI, 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 emissions due to expected

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

total decrease in emissions from all sources is sufficient to
accommodate this 15 percent allocation of safety margin to

mobile sources while still continuing to maintain the total

emissions in the Cincinnati-Hamilton area well below the 2006

attainment level of emissions.

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 of the 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

NOx for 2015; and

-An allocation of 6.76 TSD for VOC and 9.49 TSD for

NOx for 2020.

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

CFR 93.101 5

, discussed under "Requirement 3 of 5" below, it is

evident this allocation is significantly below the total safety

margin for this area (see Table 36).

The current one-hour budgets will no longer be applicable either after

the effective date of the approved redesignation or after the effective

date of any U.S. EPA action approving a finding that the eight-hour

conformity budget included in this submittal is adequate for

transportation conformity purposes, whichever date comes first.

Requirement 3 of 5

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

the ozone standard.

Background

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

2020 as the maintenance year for this redesignation request.

This document contains projected emissions inventories for

2015 and 2020.

5 "safety margin" means the amount by which the total projected emissions

from all sources of a given pollutant are less than the total emissions that

would satisfy the applicable requirement for reasonable further progress,

attainment, or maintenance.
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 )..

• For the Ohio portion of the 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 units and non-electrical generating

units). Point source emissions for 2008 were compiled

from Ohio EPA's 2008 annual emissions inventory

database. The 2015 interim year emissions were

estimated based on the 2009 and 2018 LADCO

modeling inventory, using LADCO's growth factors, for

all sectors. The 2020 maintenance year is based on

emissions estimates from the 2018 LADCO modeling.

The detailed inventory information for the Ohio portion of the

Cincinnati-Hamilton area for 2005 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 of Appendix B.

6 http://www.lade0 .org/tech/emis/current/index.php
Sectors 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- below the 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 2.95

NonEGU 12.03 10.53 13.29 13.22

Nonroad 7.76 6.55 4.06 3.01

Other 2.15 2.18 2.19 2.19

MAR 2.49 2.34 1.85 1.63

Onroad 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 Butler County, Ohio NOx Emissions Inventory to

incorporate the total emissions reduction credits available and used to offset the

allowed emissions of a major source modified within the maintenance area that will

begin operating during the maintenance period. The total emissions included for

this facility is 479.57 tons per year (assumed TSD =TPY/365). The emissions

increase does not significantly impact the safety margin for this area or prevent the

area from 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 51.49

NonEGU 0.15 0.18 0.16 0.16

Nonroad 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 0.00

NonEGU 0.00 0.00 0.00 0.00

Nonroad 2.21 1.96 1.34 1.07

Other 0.42 0.43 0.43 0.43

MAR 0.05 0.05 0.05 0.06

Onroad 5.07 3.87 2.02 1.41

TOTAL 7.75 6.31 3.84 2.97 3.34
Table 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 29.13

NonEGU 6.72 6.17 7.39 7.56

Nonroad 16.08 13.28 8.04 5.89

Other 5.19 5.27 5.30 5.30

MAR 4.49 3.93 3.14 2.84

Onroad 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 0.00

NonEGU 2.68 3.14 2.70 2.70

Nonroad 5.84 4.94 3.01 2.19

Other 1.15 1.17 1.17 1.17

MAR 0.26 0.25 0.'21 0.19

Onroad 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 26.03

NonEGU 5.09 3.21 5.12 5.19

Nonroad * 1.26 1.14 0.78 0.65

Other 0.26 0.26 0.27 0.27

Onroad 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

NonEGU 0.14 0.12 0.11 0.12

Nonroad * 12.96 11.02 9.77 9.48

Other 4.99 5.02 5.03 5.03

Onroad 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

Point

NonEGU 0.00 0.02 0.02 0.03

Nonroad* 6.33 5.34 4.57 4.34

Other 1.41 1.32 1.30 1.30

Onroad 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

Point

NonEGU 0.04 0.03 0.03 0.03

Nonroad* 8.43 7.33 6.15 5.75

Other 4.17 4.06 4.02 4.02

Onroad 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· emissions
Table 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 0.02

NonEGU 3.64 2.77 4.25 4.56

Nonroad 6.73 5.54 4.85 4.71

Other 11.96 10.31 9.76 9.76

MAR 0.15 0.14 0.10 0.09

Onroad 9.94 7.87 4.87 4.50

TOTAL 32.45 26.66 23.85 23.64 3.02
Table 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 0.53

NonEGU 0.24 0.09 0.26 0.27

Nonroad 4.31 3.66 3.11 2.95

Other 6.98 6.05 5.74 5.74

MAR 0.02 0.02 0.02 0.01

Onroad 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 0.00

NonEGU 0.00 0.00 0.00 0.00

Nonroad 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 0.06

Onroad 3.02 2.33 1.47 1.22

TOTAL 8.03 6.83 5.45 5.02 1.81
Table 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 0.31

NonEGU 2.66 2.85 2.97 3.12

Nonroad 17.25 14.47 12.55 12.06

Other 33.04 28.80 27.38 27.38

MAR 0.20 0.19 0.15 0.13

Onroad 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 0.00

NonEGU 0.53 0.82 0.57 0.57

Nonroad 4.78 4.09 3.38 3.14

Other 8.40 7.30 6.94 6.94

MAR 0.01 0.01 0.01 0.01

Onroad 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 0.46

NonEGU 2.91 3.23 3.51 3.69

Nonroad 0.82 0.74 0.62 0.60

Other 2.07 2.42 1.79 1.79

Onroad 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

Point

NonEGU 2.40 2.64 2.86 3.01

Nonroad* 1.71 5.07 4.55 4.36

Other 8.13 8.41 8.50 8.50

Onroad 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 emissions
Table 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 0.00

NonEGU 0.25 0.28 0.30 0.31

Nonroad* 1.76 1.51 1.29 1.22

Other 4.77 4.34 4.20 4.20

Onroad 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 0.00

NonEGU 1.20 1.17 1.31 1.42

Nonroad* 2.33 1.95 1.76 1.73

Other 8.53 7.88 7.66 7.66

Onroad 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 of 2008

attainment year and 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

nonattainment area are projected to decrease by 26.59 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, cleaner vehicles 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 by 28.01 TSD in 2015 and 45.69 TSD in 2020. Again,

area source emissions and, to a lesser extent, point sources

show a slight increase due to expectations that the population

will grow in this area. Decreases from U.S. EPA rules covering

Tier 2 MotorVehicle Emissions Standards and Gasoline Sulfur
Control 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 of consideration of reductions 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 of safety allocation is being requested for

mobile emissions. The mobile budget margin of safety

allocation translates into an additional 6.14 TSD for VOC and

9.39 TSD for NOx in the year 2015 and 6.76 TSD for VOC and

9.49 TSO for NOx in the year 2020. U.S. EPA's conformity

regulations allow for allocation, through a revision to the SIP, of

all or some portion of the overall area's safety margin (emission

reductions from 2008 to 2020) to the 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 separately between 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 of the 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 of the 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
Requirement 4 of 5

A demonstration that improvement in air quality between the year violations

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

enforceable emission reductions and not on temporary adverse economic

conditions or unusually favorable meteorology.

Background

Ambient air quality data from all monitoring sites indicate that air

quality met the NAAQS for ozone in 2007-2009. U.S. EPA's

redesignation guidance (p 9) states: "A state may generally

demonstrate maintenance of the NAAQS by either showing that

future emissions of a pollutant or its precursors will not exceed

the level of the attainment inventory, or by modeling to show

that the future mix of sources and emissions rates will not

cause a violation of the NAAQS."

Demonstration

Permanent and enforceable reductions of voe and NOx emissions

have contributed to the attainment of the eight-hour ozone standard.

Some of these reductions were due to the application of tighter federal

standards on new vehicles. Reductions achieved are discussed in

greater detail under Chapter Five.

Table 37 - Cincinnati-Hamilton Area Combined Comparison of

2005 base year and 2008 attainment year on-road

reductions

2005 2008

On-road voe 69.43 55.47

136.73 113.45

On-road NOx

Requirement 5 of 5

Provisions for future annual updates of the inventory to enable tracking of

the emission levels, including an annual emission statement from major

sources.

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 as
necessary to comply with the inventory reporting requirements

established in the CFR. Emissions information will be

compared to the 2005 base year and the 2020 projected

maintenance year inventories to assess emission trends, as

necessary, and to assure continued compliance with 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 of 5

Section 182(a) of the 1990 Clean Air Act Amendments requires states with

marginal nonattainment areas to implement RACT under Section 172(b).

Background

Section 182(b) of the 1990 Clean Air Act Amendments requires

states with moderate nonattainment areas to submit a SIP to

correct, or add, RACT requirements under Section 172(b) (as in

effect immediately before the enactment of the Clean Air Act

Amendments of 1990).

Demonstration

As required under the 1-hour ozone standard, Ohio EPA

submitted VOC RACT rules which U.S. EPA approved 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 necessary to ensure ongoing compliance. Ohio

EPA also has an active enforcement program to address

violations discovered by field office staff. The Ohio RACT rules

are found in OAC Chapter 3745-21 12.

Requirement 2 of 5

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 of the enactment of the Clean Air

Act Amendments and then every three years thereafter.

Demonstration

Ohio EPA submitted 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 EPA submits, and commits to submit, emission inventories

(statements) every three years.

12 http://www.epa.state.oh.us/dapc/regs/3745-21/3745_21.html
Requirement 3 of 5

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

reductions from large EGUs, industrial boilers, and cement kilns

in the eastern United States. Ohio passed this rule in 2001.

NOx SIP Call requirements are incorporated into permits along

with monitoring, recordkeeping, and reporting necessary to

ensure ongoing compliance. Ohio EPA also has an active

enforcement program to address violations discovered by field

office staff. Compliance is tracked through the Clean Air

Markets data monitoring program. Beginning in 2004, this rule

accounts for a reduction of approximately 31 percent of all NOx

emissions statewide compared to previous uncontrolled years.

The other 21 states also have adopted these rules.

On March 10, 2004, the U.S. EPA promulgated the CAIR.

Beginning in 2009, U.S. EPA's CAIR rule requires EGUs in 28

eastern states and the District of Columbia to significantly

reduce emissions of NOx. CAIR replaced the NOx SIP Call for

EGUs. National NOx emissions will be cut from 4.5 million tons

in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million

tons in 2018 in 28 states. States were required to submit a

CAIR SIP as part of this effort. Ohio submitted a CAIR SIP

which was approved by U.S. EPA on February 1, 2007.

Revisions to the CAIR SIP were again submitted on July 15,

2009. The revised CAIR SIP was approved as a direct final

action on September 25, 2009 (74 FR 48857). As a result of

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

decrease from a baseline of 264,000 tons per year to 91,000

tons per year within 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 are still in place. Ohio EPA is currently

in the process of revising these regulations to provide a "back

13 http://www.epa.gov/cair/pdfs/0053-2228.pdf
stop" for the reinstatement of the 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 gasoline vapor recovery systems for gasoline

dispensing stations in the area and section 182(b)(4) requires

motor vehicle inspection and maintenance programs.

Demonstration

u.s. EPA and Ohio EPA performed modeling that indicated this

area would attain the eight-hour ozone standard with the

implementation of the NOxSIP Call. Controls for EGUs formally

commenced May ,31 ,2004. Emissions covered by this program

have been generally trending downward since 1998 with larger

reductions occurring in 2002 and 2003. Data taken from the

U.S. EPA Clean Air Markets web site, quantify the gradual NOx

reductions that have occurred in Ohio as a result of Title IV of

the 1990 CM Amendments and the beginning of the NOxSIP

Call Rule. Ohio developed the NOxBudget Trading Program

rules in OAC Chapter 3745-1414 in response to the SIP Call.

OAC Chapter 3745-14 regulates EGUs and certain non-EGUs

under a cap and trade program based on an 85 percent

reduction of NOx emissions ·from EGUs and a 60 percent

reduction of NOx emissions from 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. EPA published Phase II of the NOxSIP

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

day emissions) stationary internal combustion" engines. Ohio

EPA's OAC rule 3745-14-12 addresses stationary internal

combustion engines, all used in natural gas pipeline

tran,smissions. U.S. EPA approved tris revision to the SIP on

April 4, 2008. An 82 percent NOx reduction from 1995 levels is

anticipated. Completion of the compliance plan occurred by

May 1, 2006, and the compliance demonstration began May 1,

2007. The 2007 controlled NOx emissions are 599 tons

statewide for the ozone season.

14 http://www.epa.state.oh.us/dapc/regs/3745-14/3745_14.html
Section 182(b)(3) requires states to submit Stage II vapor

recovery rules no later than November 15,1992. The U.S. EPA

partially approved and partially disapproved 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

of paragraph 3745-21-09 (000)(5), U.S. EPA considers 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 I and 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 a fully adopted 11M program by November

15, 1993. U.S. EPA approved Ohio's enhanced 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 request for replacement of the E-Check program 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 of the 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) - Vapor pressure limit for

cold cleaning degreasing operations. Approved July 28,

2009 (74 FR 37171)

• OAC rule 3745-21-18 - Mobile equipment refinishing

emission reduction via high transfer efficiency spray

guns. Approved July 28,2009 (74 FR 37171)

OAC Chapter 3745-72 - Low Reid Vapor Pressure

Fuels. Approved May 25, 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 cleaner cars, and refineries

will be required to make cleaner, lower sulfur gasoline. This

rule will apply nationwide. The federal rules will phase in

between 2004 and 2009. U.S. EPA has estimated that NOx

emission reductions will be approximately 77 percent for

passenger cars, 86 percent for smaller SUVs, light trucks, and

minivans, and 65 to 95 percent reductions for larger SUVs,

vans, and heavier trucks.VOC emission reductions will be

approximately 12 percent for passenger cars, 18 percent for

smaller SUVs, light trucks, and minivans, and 15 percent for

larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines

In July 2000, U.S. EPA issued a final rule for Highway Heavy

Duty Engines, a program which includes low-sulfur diesel fuel

standards, which will be phased in from 2004 through 2007.

This rule applies to heavy-duty gasoline and.diesel trucks and

buses. This rule will result in a 40 percent reduction in NOx

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

sources NOx 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. It also contains a

cleaner fuel standard similar to the highway diesel program.

The new standards will cut emissions from non-road diesel

engines by more than 90 percent. Non-road diesel equipment,

as described in this rule, currently accounts for 47 percent of

diesel particulate matter (PM) and 25 percent of NOx from

mobile sources nationwide. Sulfur levels will be reduced in nonroad diesel fuel by 99 percent from current levels, from

approximately 3,000 parts per million (ppm) now to 15 ppm in

2009. New engine standards take effect, based on engine

horsepower, starting in 2008.

Together, these rules will substantially reduce local and regional

sources of ozone precursors.
Requirement 4 of 5

Acceptable provisions to provide for new source review.

Background

Ohio has a longstanding and fully implemented New Source

Review ~NSR) program. This is addressed in GAC Chapter

3745-31 5. The Chapter includes provisions for the Prevention

of Significant Deterioration (PSD) permitting program in OAC

rules 3745-31-01 to 3745-31-20. Ohio'sPSD program was

conditionally approved on October 10, 2001 (66 FR 51570) and

received final approval on January 22, 2003 (68FR 2909) by

U.S. EPA as part of the SIP.

Demonstration

Any facility that is not listed in the 2005 emission inventory, or

for the closing of which credit was taken in demonstrating

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

reconstruct without meeting all applicable NSR requirements.

Once the area is redesignated, Ohio EPA will implement NSR

through the PSD program.

Requirement 5 of 5

Assure that all existing control measures will remain in effect after

redesignation unless the State demonstrates through 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

changes to its rules or emission limits applicable to VOC and/or

NOx sources, as required for maintenance of the ozone

standard in the Cincinnati-Hamilton area, will be submitted to

U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA's Legal section, has the legal authority

and necessary resources to actively enforce any violations of its

rules or permit provisions. After redesignation, it intends to

continue enforcing all rules that relate to the emission of ozone

precursors in the Cincinnati-Hamilton area.

15 http://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 of 4

A commitment to 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) of the

CAA.

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency

control measures in response to exceeding specified predetermined levels

(triggers) or'in the event that future violations of the ambient standard occur.

Demonstration

Ohio hereby commitS to adopt and expeditiously implement

necessary corrective actions in the following circumstances:

Warning Level Response:

A warning level response shall be prompted whenever an

annual (1-year) fourth high monitored value of 88 ppb occurs in

a single ozone season within the maintenance area. A warning

level response will consist of a study to determine whether the

ozone value indicates a trend toward higher ozone values or

whether emissions appear to be increasing. The study will

evaluate whether the trend, if any, is likely to continue and, if

so, the control measures necessary to reverse the trend taking

into consideration-ease and timing for implementation as well

as economic and social considerations. Implementation of

necessary controls in response to a warning level response

trigger will take place as expeditiously as possible, but in no

event later than 12 months from the conclusion of the most

recent ozone season (October 31).

Should it be determined through the warning level study that

action is necessary to reverse the noted trend, the procedures

for control selection and implementation outlined under "action

level response" shall be followed.
Action Level Response:

An action level response shall be prompted whenever a twoyear average fourth high monitored value of 85 parts per billion

(ppb) or greater occurs within the maintenance area. A

violation of the standard (three-year average fourth high value

of 85 ppb or greater) shall also prompt an action level response.

In the event that the action level is triggered and is not found to

be due to an exceptional event, malfunction, or noncompliance

with a permit condition or rule requirement, Ohio EPA in

conjunction with the metropolitan planning organization or.

regional council of governments, will determine additional

control measures needed to assure future attainment of the

NAAQS for ozone. In this case, measures that can be

implemented in a short time will be selected in order to be in

place within 18 months from the close of the 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 not currently included as part of the

maintenance provisions will be implemented in a timely manner

and will constitute our response.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the

necessary administrative and legal process. This process will

include publication of notices, an opportunity for public hearing,

and other measures required by Ohio law for rulemaking.

If a new measure/control is already promulgated and scheduled

to be implemented at the federal or State level, and that

measure/control is determined to be sufficient to address the

upward trend in air quality, additional local measures may be

unnecessary. Furthermore, Ohio will submit to U.S. EPA an

analysis to demonstrate the proposed measures are adequate

to return the area to attainment.

Requirement 3 of 4

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

an event.

Demonstration

Contingency measures to be considered will be selected from a

comprehensive list of measures deemed appropriate and

effective at the time the selection is made. The selection of

measures will be based on cost-effectiveness, emission
reduction potential, economic and social considerations orother

factors that Ohio EPA deems appropriate. Ohio EPA will solicit

input from all interested and affected persons in the

maintenance area prior to selecting appropriate contingency

measures. Because it is not possible at this time to determine

what control measures will be appropriate at an unspecified

time in the future, the list of contingency measures outlined

below is not exhaustive.

1) Implementation of an 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 after the 1990 CAA.

3) Apply vac RACT to smaller existing sources.

4) One or more transportation control measures sufficient to

achieve at least half a percent reduction in actual

areawide vac emissions. Transportation measures will

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) traffic flow and transit improvements; and

c) other new or innovative transportation 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 major sources.

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 of individual measures, at

the time they are under consideration, can be fully evaluated.

Requirement 4 of 4

A list of VOC and NOx sources potentially subject to future additional

control requirements.

Demonstration

The following is a list of VOC and NOx sources potentially subject to

future controls.

NOxRACT

• EGUs

• asphalt batching plants

• industrial/commercial and institutional boilers

• process heaters

• internal combustion engines

• combustion turbines

• other sources greater than 100 tons per year

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

• other sources greater than 50 tons per year
CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public

comment concerning the draft redesignation petition and maintenance plan in

the widely distributed 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 public comment period closed

on December 11 , 2009. No testimony was provided at the public hearing 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 of the 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) of the 1990 CAA.

Based on this presentation, the Cincinnati-Hamilton ozone nonattainment

area meets the requirements for redesignation under the CAA and U.S. EPA

guidance. Ohio has performed an analysis that shows the air quality

improvements are due to permanent and enforceable measures.

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

significant regional NOx reductions will ensure continued compliance

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

The State of Ohio hereby requests that the Cincinnati-Hamilton ozone

nonattainment area be redesignated to attainment simultaneously with 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 of CAA Section 175A (b), for subsequent plan revisions required

for areas redesignated for the one-hour ozone standard.
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