The Kentucky Fine Particulate Matter (PM2.5) Attainment 

Demonstration 

for the Louisville, KY-IN, 

Cincinnati-Middletown, OH-KY-IN, and HuntingtonAshland, WV-KY-OH PM2.5 Nonattainment Areas 

Prepared by: 

Kentucky Division for Air Quality 

Submitted by 

Kentucky Energy and Environment Cabinet 

November 2008 

PREFACE 

This document contains Kentucky’s modeling demonstration that the three multi-state areas currently 

designated as not attaining the annual fine particle National Ambient Air Quality Standard will attain the 

standard by April, 2010. 

The three areas are: 

The Huntington-Ashland, WV-KY-OH annual PM2.5 nonattainment area is a multi-state nonattainment 

area, comprising: 

• Cabell, Wayne and a portion of Mason County, West Virginia; 

• Boyd County and a portion of Lawrence County, Kentucky; and 

• Lawrence, Scioto, and portions of Adams and Gallia Counties in Ohio. 

The Louisville, KY-IN annual PM2.5 nonattainment area is a multi-state nonattainment area, comprising: 

• Bullitt and Jefferson Counties, Kentucky, and 

• Clark and Floyd Counties and a portion of Jefferson County in Indiana. 

The Cincinnati-Middletown OH-KY-IN annual PM2.5 nonattainment area is a multi-state nonattainment 

area as well, comprising: 

• Butler, Clermont, Hamilton and Warren Counties, Ohio; 

• Boone, Campbell and Kenton Counties, Kentucky; and 

• A portion of Dearborn County in Indiana. 

VISTAS Background

When EPA promulgated regional haze regulations on July 1, 1999, it established requirements that states 

and tribes submit implementation plans to demonstrate reasonable progress towards the ultimate visibility 

goals of the rule. The first demonstration of reasonable progress is to be made for the year 2018 and state 

implementation plans were due December 2007. EPA also offered an optional approach that groups of 

states might collaborate in regional analyses of the haze problem. This option showed promise in 

allowing more cost-effective analyses and the southeastern states opted to follow this option. Southeastern 

States Air Resource Managers Inc. (SESARM) accepted responsibility for regional planning organization 

work tasks on behalf it its member agencies pursuant to this option. 

The member agencies of SESARM determined that it was appropriate to expand the collaborative effort 

for the regional haze program beyond their member boundaries and invited Virginia and West Virginia to 

join the group. A memorandum of agreement was arranged among the agencies and executed on August 

22, 2001. The effort was named the Visibility Improvement State and Tribal Association of the Southeast 

(VISTAS). Since that time, the agencies have worked together to organize their efforts, develop work 

task lists and schedules, procure professional services, and support administrative operations. Bylaws 

were developed and agreed upon by the participating members. An organizational structure was created 

including an oversight committee, an operations committee, and various work groups. This early 

planning has served the project well and much progress has been made. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, ii 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

ASIP Project Background 

On December 17, 2004, EPA made fine particle (PM2.5) nonattainment determinations for at least one 

area in seven of the states participating in the VISTAS regional haze project. They are Alabama, Georgia, 

North Carolina, Kentucky, Tennessee, Virginia, and West Virginia. In addition, South Carolina has one 

three-county area that was designated as unclassifiable in the same action. EPA’s Clean Air Interstate 

Rule (CAIR) modeling indicated that certain nonattainment areas may still be in nonattainment after full 

implementation of CAIR. These areas include Jefferson County, Alabama, and Clayton and Fulton 

Counties in Georgia. 

The PM2.5 compliance date is April 2010 unless a state demonstrates that more time is necessary in which 

case up to five additional years may be granted. The nonattainment designations triggered the 

requirement for development of state implementation plans (SIPs) that will be due in April 2008. The 

guidance from EPA indicates that a significant requirement of PM2.5 SIPs will be attainment 

demonstrations using, at least in part, modeling analyses to define effective emissions control strategies 

and confirm that attainment can be achieved after implementation of the strategies. 2009 is the modeling 

year for the PM2.5 attainment demonstration and also is an interim analysis year for the VISTAS regional 

haze demonstration. 

In April of 2004, EPA determined areas that were not meeting the 8-hour ozone standard. States having 

one or more 8-hour ozone nonattainment areas in the Southeast are Alabama, Georgia, Kentucky, North 

Carolina, South Carolina, Tennessee, Virginia, and West Virginia. EPA required attainment of the 8-hour 

ozone standard in basic nonattainment areas by June 15, 2009, and in moderate nonattainment areas by 

June 15, 2010. This required states with basic 8-hour ozone nonattainment areas to model 2008 as the 

SIP modeling demonstration year while moderate nonattainment areas will require 2009 as the modeling 

year. Given that North Carolina and Virginia have two-year SIP approval processes, there is an 

immediate need to complete an analysis of ozone attainment using air quality modeling. 

The states participating in the VISTAS project (the SESARM EPA Region 4 states plus Virginia and 

West Virginia from Region 3) concluded that a collaborative process was the most efficient approach for 

the collective states to develop information upon which to base the PM2.5 and 8-hour ozone attainment 

demonstrations. The local air regulatory agencies for Jefferson County, AL, Jefferson County, KY, 

Mecklenburg County, NC, Forsythe County, NC, Knox County, TN, and Shelby County, TN, also 

became signatory parties to this collaborative effort. SESARM coordinated activities among participating 

agencies and oversaw the performance of the inventory and modeling tasks in parallel with the VISTAS 

regional haze project tasks. 

The name of this collaborative effort is the Association for Southeastern Integrated Planning (ASIP). 

SESARM was awarded a grant from EPA on February 8, 2005, to conduct what was originally called the 

fine particle SIP development support project but has become known as ASIP. 

 The VISTAS-ASIP contact information is at www.vistas-sesarm.org. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, iii 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

EXECUTIVE SUMMARY 

INTRODUCTION

Fine particulate matter, also known as fine particles and PM2.5, refers to airborne particles less than or 

equal to 2.5 micrometers (μm) in diameter. Fine particles are treated as though they are a single pollutant, 

but they come from many different sources and are composed of many different compounds. PM2.5

exposure adversely affects human health, especially respiratory and cardiovascular systems. Individuals 

particularly sensitive to PM2.5 exposure include children, people with heart and lung disease, and older 

adults. 

A variety of meteorological and geographic factors influence the concentration levels of fine particles, 

including both the regional and local distribution of urbanized areas, primary and precursor emissions 

sources, and natural features such as oceans and forests. PM2.5 concentrations can also be high and 

exceed the national ambient air quality standards (NAAQS) for fine particulate matter at any time of the 

year. Therefore, the United States Environmental Protection Agency (USEPA) mandates the year round 

monitoring of PM2.5 concentrations throughout the country (40 CFR 58.App. D, 4.7). 

NATIONAL AMBIENT AIR QUALITY STANDARD

In 1997, the USEPA promulgated the primary (health) and secondary (welfare) NAAQS for PM2.5 (40 

CFR 50.7), setting the standard at a 15.0 micrograms per cubic meter (μg/m3) annual average and at a 65 

μg/m3 daily or 24-hour average. In 2006, the USEPA revised the daily standard from 65 μg/m3 to 35 

μg/m3

. A violation of the annual PM2.5 NAAQS occurs when the annual average PM2.5 concentration 

averaged over a three-consecutive-year period is equal to or greater than 15.1 μg/m3. A violation of the 

daily PM2.5 NAAQS occurs when the annual 98th percentile of daily PM2.5 concentration averaged over a 

three-consecutive-year period is equal to or greater than 36 μg/m3. The annual or daily PM2.5 design 

value for a nonattainment area is the highest monitor’s design value in that area. 

The USEPA designated areas as nonattainment for the annual PM2.5 NAAQSs based upon air quality 

monitoring data measured during 2001, 2002, and 2003. The effective date of nonattainment designations 

was April 5, 2005. USEPA is in the process of designating areas for the revised daily PM2.5 NAAQS 

which will occur in December 2008. This attainment demonstration does not address the 2006 24-hour 

average NAAQS. 

NATURE OF PROBLEM IN KENTUCKY

In Kentucky, there were three areas designated as nonattainment for violating the annual PM2.5 standard 

(Figure 1). All areas of Kentucky met the original daily PM2.5 standard. This PM2.5 attainment 

demonstration submittal covers the Louisville, KY-IN PM2.5 nonattainment area (Bullitt and Jefferson 

counties), the Cincinnati-Middletown, OH-KY-IN nonattainment area (Boone, Campbell, and Kenton 

counties), and the Huntington-Ashland PM2.5 nonattainment area (Boyd and a portion of Lawrence 

counties). This submittal covers only the Kentucky portion of these nonattainment areas for which 

Kentucky has jurisdiction. However, the appendices associated with this documentation include 

modeling results for all areas and the demonstrations for other states for their areas. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, iv 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Figure 1. Annual PM2.5 Nonattainment Counties for Kentucky (Louisville, KY-IN, area counties 

denoted by blue boxes, Cincinnati- Middletown, OH-KY-IN, area counties denoted by gray boxes, 

and Huntington-Ashland, WV-KY-OH, area counties denoted by green boxes.) 

The annual PM2.5 concentrations in these nonattainment areas are analyzed by the percentages of their 

individual component species. In Cincinnati- Middletown, OH-KY-IN, and Huntington-Ashland, WVKY-OH, the organic carbon (OC) and sulfate (SO4) components each account for approximately one-third 

of the total PM2.5 mass. The ammonium component makes up approximately ten percent of the total 

PM2.5 mass, and the remaining nitrate (NO3), elemental carbon, crustal material, and particle bound water 

components each contribute approximately five percent or less of the total PM2.5 mass. The percentages 

of species contribution fluctuate throughout the year with the most significant changes to SO4 and NO3. 

SO4 is more pronounced in the summertime or warm season months than during the wintertime. NO3
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, v 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

fluctuates from almost undetectable in the summertime to as much as ten percent contribution of the total 

PM2.5 mass during the coldest portion of the winter. 

In Louisville, KY-IN, the organic carbon (OC) and sulfate (SO4) components each account for 

approximately one-fourth of the total PM2.5 mass, the ammonium and the nitrate (NO3) components make 

up approximately ten percent of the total PM2.5 mass, and elemental carbon, crustal material, and particle 

bound water components each contribute approximately five percent or less of the total PM2.5 mass. The 

percentages of species contribution fluctuate throughout the year with the most significant changes to SO4

and NO3. SO4 is more pronounced in the summertime or warm season months than during the 

wintertime. NO3 fluctuates from under five percent in the summertime to as much as twenty-four percent 

contribution of the total PM2.5 mass during the coldest portion of the winter. 

The speciated analysis of the PM2.5 concentrations in the Louisville, KY-IN, the Cincinnati- Middletown, 

OH-KY-IN, and the Huntington-Ashland, WV-KY-OH, PM2.5 nonattainment areas demonstrates that the 

OC and SO4 components are the most important portions of the total PM2.5 mass throughout the year. OC 

contributors are predominately attributed to biogenic emissions sources. SO4 is associated with sulfur 

dioxide (SO2) emissions. When evaluated across Kentucky and also throughout all three nonattainment 

areas and surrounding regions, the SO2 is primarily from the point source sector. For this reason, SO2

emissions controls from point sources are believed to be the most appropriate strategy for addressing the 

PM2.5 nonattainment issues for these areas. 

CONTROLS APPLIED

Several control measures already in place or being implemented over the next few years will reduce 

stationary point, highway mobile, and nonroad mobile sources emissions. Expected federal and state 

control measures were modeled for the attainment year of 2009. 

The federal control measures that were modeled included the Tier 2 vehicle standards, the heavy-duty 

gasoline and diesel highway vehicle standards, low sulfur gasoline and diesel fuels, large nonroad diesel 

engines standards, the nonroad spark-ignition engines and recreational engines standard, and the Clean 

Air Interstate Rule (CAIR). 

The State control measures that were modeled are the NOx SIP Call Rule, which will reduce summertime 

NOx emissions from power plants and other industries, and also CAIR. Additional information is 

contained in Section 5 in the main narrative. 

ATTAINMENT TEST RESULTS

A modeling assessment was done to determine if the control strategies currently being implemented and 

proposed would lead to attainment of the annual PM2.5 NAAQS by the attainment year of 2009. The air 

quality modeling was applied in a relative sense, similar to the modeling assessment preformed for 8-hour 

ozone attainment demonstrations in previous years. Reviewing the modeling results of how PM2.5

concentrations decrease in future years, and in addition the geographic extent of these reductions, plays an 

important role for the State in determining if additional controls should be considered. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, vi 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

A modeled attainment test was applied to the air quality modeling results to determine if the annual PM2.5

NAAQS will be met by 2009. The baseline period for the air quality modeling was 2002, the midpoint of 

the three years used for nonattainment designations. The future year of 2009 was selected for the air 

quality modeling projections because it is the attainment year. 

The first step of the PM2.5 modeled attainment test breaks down baseline PM2.5 mass concentrations into 

the individual component species by calendar quarter for each federal reference monitor (FRM) site in the 

nonattainment area. The Speciated Modeled Attainment Test, commonly referred to as SMAT, was used 

to calculate future quarterly mean concentration estimates from the air quality modeling for each of these 

component species determined in step one. The future quarterly mean PM2.5 values were then averaged to 

produce a future year annual average PM2.5 concentration for each of the FRM sites. Finally, these future 

annual PM2.5 values were compared to the annual PM2.5 NAAQS (15.0 μg/m3) to determine if the 

modeling exercise predicted attainment of the standard. 

For all Kentucky FRM sites in the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and 

Huntington-Ashland, WV-KY-OH, PM2.5 nonattainment areas, the future annual PM2.5 concentrations 

derived from the modeled attainment test were ≤15.0 μg/m3

 (Table 1). 

During the comment period following the draft SIP submittal, it was noted by EPA that while the EPA’s 

Modeled Attainment Test Software (MATS) was not available during SIP development, the new tool is 

now available. In October, DAQ received MATS values from the VISTAS contractor and have added 

them to the table above. The MATS values were incorporated in the table above to compare SMAT with 

MATS; note that in all cases the design values are less than ≤15.0 μg/m3

. 

Therefore, the most recent modeling assessment tools available indicate that the Kentucky portions of all 

three nonattainment areas will attain the annual PM2.5 NAAQS by 2009. 

Section 6 in the narrative provides modeled 2009 design values for the entire nonattainment areas. In 

addition further discussion of both SMAT and MATS is presented. 

Table 1. Summary of Current and Future Predicted Annual PM2.5 Concentrations in 

VISTAS/ASIP Modeling 

AIRS ID State County 

2002 

Annual DVC

2009 12 km 

CONC of PM 

SMAT 

2009 12 km 

CONC of PM 

MATS 

21-019-0017 KY Boyd 14.9 12.8 12.6 

21-029-0006 KY Bullitt 14.9 13.1 13.0 

21-111-0044 KY Jefferson 16.6 14.8 14.5 

21-111-0048 KY Jefferson 16.1 14.2 14.0 

21-111-0051 KY Jefferson 15.4 13.6 13.4 

21-037-0003 KY Campbell 13.8 12.0 11.6 

21-117-0007 KY Kenton 14.9 12.7 12.6 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, vii 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

The Kentucky Division for Air Quality (KYDAQ) provides in this document a strong set of supplemental 

analyses further supporting that the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and 

Huntington-Ashland, WV-KY-OH, PM2.5 nonattainment areas will attain the annual PM2.5 NAAQS by 

2009. These analyses included investigating current air quality data trends along with the emission 

reductions that have recently occurred and still yet to occur by 2009, and considering air quality modeling 

results from other regional and national modeling exercises. 

The KYDAQ believes that the modeling attainment demonstration, in conjunction with the supplemental 

analyses, provides the necessary evidence that the Louisville, KY-IN, Cincinnati- Middletown, OH-KYIN, and Huntington-Ashland, WV-KY-OH, PM2.5 nonattainment areas will attain the annual PM2.5

NAAQS by the prescribed attainment date. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, viii 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, ix 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY iii

1.0 INTRODUCTION 1

1.1 What is fine particulate matter? ............................................................................................ 1 

1.2 What is the National Ambient Air Quality Standard? .......................................................... 2 

1.3 Nature of Problem in Kentucky ............................................................................................ 2 

1.4 Major Contributors to PM2.5 in the Kentucky Nonattainment Areas .................................... 6 

1.4.1 Conceptual Description of PM2.5 ................................................................................... 7 

1.5 Clean Air Act Requirements ................................................................................................. 9 

2.0 SIGNIFICANCE OF PM2.5 PRECURSOR POLLUTANTS 11

2.1 PM2.5 Component Species Analysis .................................................................................... 11 

2.2 Attribution of Emissions Sources ....................................................................................... 14

2.3 Clean Air Fine Particulate Implementation Rule Presumptions on Precursor Pollutants ... 17 

3.0 ATTAINMENT DEMONSTRATION METHODS AND INPUTS 18

3.1 Analysis Method ................................................................................................................. 18 

3.2 Model Selection .................................................................................................................. 19 

3.2.1 Selection of Air Quality Model .................................................................................... 19 

3.2.2 Selection of Meteorological Model .............................................................................. 20 

3.2.3 Selection of Emissions Processing System .................................................................. 21 

3.3 Selection of the Modeling Year .......................................................................................... 23 

3.4 Modeling Domains .............................................................................................................. 24 

3.4.1 Horizontal Modeling Domain ...................................................................................... 24 

3.4.2 Vertical Modeling Domain .......................................................................................... 25 

3.5 Baseline Emissions Inventory ............................................................................................. 25 

3.5.1 Stationary Point Sources .............................................................................................. 27 

3.5.2 Stationary Area Sources ............................................................................................... 28 

3.5.3 Off-Road Mobile Sources ............................................................................................ 29 

3.5.4 Highway Mobile Sources ............................................................................................. 30 

3.5.5 Biogenic Emission Sources .......................................................................................... 30 

4.0 MODEL PERFORMANCE EVALUATION 31

4.1 Modeling Performance Goals, and Criteria ........................................................................ 32 

4.1.2 Domain-Wide Model Performance .............................................................................. 33 

4.1.3 Nonattainment Area Model Performance .................................................................... 35 

4.1.4 Air Quality Model Performance Summary .................................................................. 35 

5.0 CONTROLS APPLIED 37

5.1 Federal Control Measures ................................................................................................... 37 

5.1.1 Tier 2 Vehicle Standards .............................................................................................. 37 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, x 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

5.1.2 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards ................................. 37 

5.1.3 Large Nonroad Diesel Engines Rule ............................................................................ 37 

5.1.4 Nonroad Spark-Ignition Engines and Recreational Engines Standard ........................ 38 

5.1.5 NOx SIP Call in Surrounding States ............................................................................ 38 

5.1.6 Clean Air Interstate Rule .............................................................................................. 39 

5.1.7 Industrial Boiler/Process Heater/RICE MACTs .......................................................... 44 

5.1.8 Combustion Turbine MACTs ...................................................................................... 48 

5.1.9 VOC 2-, 4-, 7-, and 10-year MACT Standards ............................................................ 48 

5.1.10 Consent Agreements .................................................................................................. 48

5.2 State Control Measures ....................................................................................................... 49 

5.2.1 NOx SIP Call Rule ....................................................................................................... 49 

5.2.2 Open Burning Bans ...................................................................................................... 50 

5.2.3 Clean Air Interstate Rule .............................................................................................. 50 

5.2.4 Fugitive Emissions ....................................................................................................... 50 

6.0 ATTAINMENT DEMONSTRATION 52

6.1 Attainment Test Introduction .............................................................................................. 52 

6.2 Attainment Test Results ...................................................................................................... 53 

6.3 Supplemental Analyses and Weight of Evidence ............................................................... 55 

6.3.1 Air Quality Modeling Metrics ...................................................................................... 55 

6.3.2 Other Modeling Results ............................................................................................... 58

6.4 Unmonitored Area Analysis ................................................................................................ 64 

6.5 Data Access ......................................................................................................................... 67 

7.0 CLEAN AIR ACT SECTION 172C REQUIREMENTS 69

7.1 Reasonably Available Control Measures (RACM) ............................................................ 69 

7.4 Reasonable Further Progress ............................................................................................... 71 

7.5 Actual Emissions Inventory ................................................................................................ 71 

7.6 Periodic Emissions Inventory ............................................................................................. 71 

7.7 Other Measures ................................................................................................................... 71 

7.8 Compliance with Section 110(a)(2) .................................................................................... 72 

7.9 Equivalent Techniques ........................................................................................................ 72 

7.10 Contingency Measures ...................................................................................................... 72 

8.0 MOTOR VEHICLE EMISSIONS BUDGETS 73

8.1 Transportation Conformity ................................................................................................. 73 

8.2 Pollutants to be Considered ................................................................................................. 73 

9.0 REFERENCES 86
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, xi 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

LIST OF APPENDICES 

Appendix A: Policy and Memorandums 

Appendix B: Stakeholders Correspondence Regarding Motor Vehicle Emissions Budgets 

Appendix C: Air Quality Data: 

Appendix C1 Ambient Air Data 

Appendix C2 Air Quality Data used for Modeling 

Attachment C1 Review & Assessment of Ambient Data to Support Model Performance Evaluation 

Appendix C3 AQS PM2.5 Data for all Kentucky sites 2000-2007

Appendix D: Modeling Protocol 

Appendix E: Emissions Inventory Summary used in the VISTAS-ASIP Modeling 

Appendix F: Emissions Inventory Documentation 

Appendix G: Emissions Inventory Quality Assurance Project Plan 

Appendix H: Emissions Modeling and Related 

Appendix I: Meteorological Development Documentation 

Appendix J: Model Performance Evaluation 

Appendix K: Modeling Results 

Appendix L: Attainment Test 

Appendix M: State and Local Control Measures 

Appendix N: Conceptual Description 

Appendix O: OH, IN, and WV Submittals 

Appendix P: Supporting Documentation from VISTAS and ASIP 

Appendix Q: Public Hearing and Related 

Appendix R: Statement of Consideration 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, xii 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 1 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

1.0 INTRODUCTION 

1.1 What is fine particulate matter? 

Fine particulate matter, also known as fine particles and PM2.5, refers to airborne particles less 

than or equal to 2.5 micrometers (μm) in diameter. Fine particles are treated as though they are a 

single pollutant, but they come from many different sources and are composed of many different 

compounds. PM2.5 exposure adversely affects human health, especially respiratory and 

cardiovascular systems. Individuals particularly sensitive to PM2.5 exposure include children, 

people with heart and lung disease, and older adults. 

PM2.5 can be liquid, solid, or can have a solid core surrounded by liquid. PM2.5 can include 

material produced by combustion, or photochemical reactions, and can contain salt from sea 

spray and soil-like particles. Particles are distinguished based on the method of formation. 

Primary particles are particles directly emitted into the atmosphere and retain the same chemical 

composition as when they were released. Secondary particles are those formed through chemical 

reactions involving atmospheric oxygen, water vapor, ammonia, hydroxyl radical, nitrates, sulfur 

dioxide (SO2), oxides of nitrogen (NOx), and organic gases from natural and anthropogenic 

sources. PM2.5 can therefore be composed of varying amounts of different species, including: 

• Sulfates 

• Nitrates (usually found in the form of ammonium nitrate) 

• Ammonium 

• Hydrogen ion 

• Particle bound water 

• Elemental carbon 

• Organic compounds 

o Primary organic species (cooking and combustion processses) 

o Secondary organic compounds 

• Crustal material (includes calcium, aluminum, silicon, magnesium, and iron) 

• Sea salt (generally only found at coastal monitoring sites) 

• Transitional metals 

• Potassium (generally from wood burning or cooking) 

The most significant sources of PM2.5 and its precursors are coal-fired power plants, industrial 

boilers, and other combustion sources. These emissions are often transported over large 

distances. Other sources of PM2.5 emissions include mobile sources, area sources, biogenic 

sources, fires, wind blown dust, and oceans. 

A variety of meteorological and geographic factors influence the concentration levels of fine 

particles, including both the regional and local distribution of urbanized areas, primary and 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 2 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

precursor emissions sources, and natural features such as oceans and forests. PM2.5

concentrations can also be high and exceed the national ambient air quality standards (NAAQS) 

for fine particulate matter at any time of the year. Therefore the United States Environmental 

Protection Agency (USEPA) mandates the year round monitoring of PM2.5 concentrations 

throughout the country (40 CFR 58.App. D, 4.7). 

1.2 What is the National Ambient Air Quality Standard? 

In 1997, the USEPA promulgated the primary (health) and secondary (welfare) NAAQS for 

PM2.5 (40 CFR 50.7), setting the standard at a 15.0 micrograms per cubic meter (μg/m3

) annual 

average and at a 65 μg/m3 daily or 24-hour average. In 2006, the USEPA revised the daily 

standard from 65 μg/m3 to 35 μg/m3. A violation of the annual PM2.5 NAAQS occurs when the 

annual average PM2.5 concentration averaged over a three-consecutive-year period is equal to or 

greater than 15.1 μg/m3. A violation of the daily PM2.5 NAAQS occurs when the annual 98th

percentile of daily PM2.5 concentration averaged over a three-consecutive-year period is equal to 

or greater than 36 μg/m3

. The annual or daily PM2.5 design value for a nonattainment area is the 

highest monitor’s design value in that area. 

Since the 1977 amendments to the Clean Air Act (CAA), areas of the country that violated the 

ambient standard for a particular pollutant were formally designated as nonattainment for that 

pollutant. This formal designation concept was retained in the 1990 Amendments (CAAA). 

With the implementation of the PM2.5 standard, areas not meeting the standard were designated 

under Section 172 of the CAAA (subpart 1) and have five years from designation to attain the 

standard. 

The USEPA designated areas as nonattainment for the annual PM2.5 NAAQSs based upon air 

quality monitoring data measured during 2001, 2002, and 2003. The effective date of 

nonattainment designations was April 5, 2005. USEPA is in the process of designating areas for 

the revised daily PM2.5 NAAQS, which will occur in December 2008. This attainment 

demonstration does not address the 2006 24-hour average NAAQS. 

1.3 Nature of Problem in Kentucky 

In Kentucky, there are three areas designated as nonattainment for the annual PM2.5 standard 

(Figure 1.3-1). All areas of Kentucky met the original daily PM2.5 standard. This PM2.5

attainment demonstration submittal covers the Louisville, KY-IN, PM2.5 nonattainment area 

(Bullitt and Jefferson counties), the Cincinnati- Middletown, OH-KY-IN, PM2.5 nonattainment 

area (Boone, Campbell, and Kenton counties), and the Huntington-Ashland, WV-KY-OH, PM2.5

nonattainment area (Boyd and a portion of Lawrence counties). The Indiana, Ohio, and West 

Virginia portions of the nonattainment areas are established in the appendices. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 3 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Figure 1.3-1. Annual PM2.5 Nonattainment Boundaries for Kentucky 

Figure 1.3-2 displays the distribution of the PM2.5 monitoring sites across Kentucky. A closer 

view of the PM2.5 federal reference method (FRM) monitoring sites in the Louisville, KY-IN, 

Cincinnati-Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM2.5

nonattainment areas is found in Figure 1.3-3. 

Figure 1.3-2. PM2.5 Monitoring Sites In Kentucky 

Jefferson County 

Bullitt County 

Boone County 

Kenton County 

Campbell County 

Boyd County 

Lawrence County (Portion) 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 4 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Figure 1.3-3. PM2.5 FRM Monitoring Sites in the Kentucky portion of the Louisville, KYIN, Cincinnati-Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, 

Nonattainment Areas 

Table 1.3-1 contains the quarterly and annual average PM2.5 concentrations for these FRM 

monitors in the PM2.5 nonattainment areas for the three-year period used in the nonattainment 

designation determinations. Table 1.3-1 also presents the 2002-2004 PM2.5 design value for the 

FRM monitors based on these quarterly and annual averages. The historic quarterly, yearly, and 

design value air quality data for the FRM monitors in the three PM2.5 nonattainment areas can be 

found in Appendix C. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 5 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Table 1.3-1. PM2.5 Concentrations and Design Values for the FRM monitors 

in the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and Huntington-Ashland, 

WV-KY-OH, PM2.5 Nonattainment Areas 

As mentioned in Section 1.1, PM2.5 is composed of many species from varying sources. Figure 

1.3-4 presents the Kentucky statewide averaged PM2.5 speciation data from the speciation trends 

network (STN) monitors for the year 2004. The figure presents sulfates (SO4) and organic 

carbons (OC) as the main contributors to PM2.5, sulfates with 29%, organic carbon with 25%; 

ammonium (NH4) contributes 11%; nitrates (NO3) contribute 10%; elemental carbon (EC) is 

approximately 4%; and crustal material is 3% of the total PM2.5 mass. The “other” portion of the 

PM2.5 that accounts for 18% of the mass can be attributed to water (H2O), and other trace 

materials captured with the STN monitors. 

County FRM 

Monitoring Site 

Year 1st Quarter 

(Q1) 

2nd Quarter 

(Q2) 

3rd Quarter 

(Q3) 

4th Quarter 

(Q4) 

Annual 

Average 

Design 

Value 

Bullitt 21-029-0006 

2002 11.57 15.45 20.66 11.09 14.69 

2003 12.92 13.74 20.30 10.53 14.37 14.2 

2004 11.61 13.66 18.10 11.12 13.62 

Jefferson 21-111-0043 

2002 12.0 16.4 26.4 13.9 17.2 

2003 14.6 16.3 20.9 12.0 16.0 15.9 

2004 12.5 14.5 18.0 13.0 14.5 

Jefferson 21-111-0044 

2002 12.14 17.63 26.47 13.57 17.45 

2003 14.70 15.05 20.17 11.59 15.38 15.6 

2004 12.43 13.50 17.77 12.50 14.05 

Jefferson 21-111-0048 

2002 10.93 16.00 25.31 13.46 16.43 

2003 13.93 14.63 21.27 12.30 15.53 15.2 

2004 10.84 13.85 18.21 11.95 13.71 

Jefferson 21-111-0051 

2002 11.08 17.88 20.94 13.00 15.73 

2003 13.48 14.87 20.85 10.48 14.92 14.4 

2004 11.05 12.19 16.71 10.59 12.64 

Campbell 21-037-0003 

2002 11.36 15.31 21.91 10.65 14.81 

2003 12.26 13.27 18.22 9.94 13.42 13.7 

2004 11.27 12.80 16.57 10.47 12.78 

Kenton 21-117-0007 

2002 10.83 14.95 22.18 12.29 15.06 

2003 13.69 14.06 18.94 10.50 14.30 14.3 

2004 11.79 13.26 17.86 10.77 13.42 

Boyd 21-019-0017 

2002 12.00 17.89 21.59 10.69 15.54 

2003 12.39 13.12 19.39 10.83 13.93 14.3 

2004 11.42 13.00 17.90 10.85 13.29 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 6 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Kentucky

 PM 2.5 Speciated Trends Network

 2004 Average Percentage Composition

Nitrate

10%

Sulfate

29%

Ammonium

11%

Organic carbon

25%

Elemental carbon

4%

Crustal component

3%

Other

18%

Figure 1.3-4. Kentucky PM2.5 Speciation for 2004 

1.4 Major Contributors to PM2.5 in the Kentucky Nonattainment Areas 

When the annual PM2.5 concentrations in Kentucky’s nonattainment areas are analyzed by the 

percentages of their individual component species, a similar distribution of components are 

found. The SO4 component accounts for approximately one-third of the total PM2.5 mass; the 

OC component accounts for approximately one-fourth of the total PM2.5 mass; NH4, NO3, and the 

remaining EC, crustal material, and particle bound water components each contribute 

approximately ten percent or less of the total PM2.5 mass. Individual plots of the speciated PM2.5

data (similar to Figure 1.3-4) from the PM2.5 monitoring locations in the nonattainment areas can 

be found in Appendix C. 

The percentages of species contribution fluctuate throughout the year with the most significant 

changes to SO4 and NO3. SO4 is more pronounced in the summertime or warm season months 

than during the wintertime. NO3 fluctuates from under five percent in the summertime to as 

much as twenty-four percent contribution of the total PM2.5 mass during the coldest portion of 

the winter. 

The speciated analysis of the PM2.5 concentrations in the Louisville, KY-IN, CincinnatiMiddletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM2.5 nonattainment areas 

demonstrates that the OC and SO4 components are the most important portions of the total PM2.5

mass throughout the year. OC is predominately attributed to biogenic emissions sources. SO4 is 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 7 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

associated with SO2 emissions. When evaluated across Kentucky and also throughout both 

nonattainment areas and surrounding regions, the SO2 is primarily from the point source sector. 

For this reason, SO2 emissions controls from point sources are believed to be the most 

appropriate strategy for addressing the PM2.5 nonattainment issues for Kentucky’s annual PM2.5

nonattainment areas. 

1.4.1 Conceptual Description of PM2.5

Further details on the nature of the PM2.5 problem in the PM2.5 nonattainment areas are discussed 

in Section 2 and can also be found in the “Conceptual Description of Fine Particulate Matter in 

Kentucky” section of Appendix N. 

1.4.1.1 Speciated PM2.5 in Kentucky nonattainment areas 

EPA’s Speciated Trend Network (STN) PM2.5 monitors collect filter-based 24-hr samples every 

third or sixth day; filters are analyzed to provide total PM2.5 mass and mass of individual. 

Sulfate (SO4) and particulate organic matter (POM, also called Organic Carbon, OC) are the 

dominant contributors to PM2.5 mass in these nonattainment areas. Sulfate peaks in the third 

quarter are primarily responsible for the peak PM2.5 values in the third quarter. Sulfate levels 

are highest in the third quarter and lowest in the first and fourth quarters, ranging spatially and 

seasonally from 3-10 μg/m3. 

In contrast, organic carbon levels are fairly constant across the quarters, varying spatially and 

seasonally from 3-7 μg/m3. Organic carbon speciation in urban areas suggests higher 

contributions from fuel combustion from mobile sources and primary carbon sources than in the 

Class I areas. 

Nitrate (NO3) has a significant contribution to PM2.5 in the KY nonattainment areas, 

particularly in the first quarter. Ammonium (NH4) is associated with sulfate or nitrate. Higher 

amounts of NO3 are present in the cooler months, with very low concentrations in the third 

quarter. NH4NO3 levels are higher in KY than in other nonattainment areas in the southeastern 

US, in part due to cooler winter time temperatures and in part due to closer proximity to the large 

source region for ammonia in the midwestern and central states. 

Secondary pollutants (SO4, NO3, and OC) are the major contributors to PM2.5. Primary 

components (EC, soil) are relatively minor contributors. Thus precursors of secondary 

components (e.g. SO2, NOx, biogenic VOC) are more important contributors to PM2.5 mass 

than primary PM2.5 sources. 

Collectively, these monitoring and modeling results confirm the conclusion that emissions 

control strategies to reduce emissions of SO2 contributing to sulfate would be most effective in 

reducing PM2.5 in Kentucky nonattainment areas. Reducing anthropogenic emissions of primary 

PM2.5 contributing to particulate organic matter and of nitrous oxides and ammonia contributing 

to ammonium nitrate would likely reduce PM2.5 concentrations more on winter days than 

summer days. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 8 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

1.4.1.2 Meteorological Contribution to Kentucky PM2.5

Across the southeastern US, days with elevated PM2.5 concentrations most frequently occurred 

on days with high temperatures, high relative humidity, low wind speeds, and elevated PM2.5 

mass on the previous day at upwind urban areas. 

1.4.1.3 Emissions Contributing to Kentucky PM2.5 

Point source (electric utility and industry) SO2 emissions are the predominant precursors for 

ammonium sulfate, accounting for 96-98% of the total SO2 emissions in 2002 in the Kentucky 

nonattainment areas. (See Appendix E, Emissions Inventory Summary Tables) Ground level and 

point sources of nitrogen oxides and agricultural emissions of ammonia are the primary 

precursors for ammonium nitrate. Fossil fuel combustion and wood burning are the most 

important contributors to elemental carbon. Fine soil might be from construction or agricultural 

activities or windblown dust. 

A combination of sources contribute to organic carbon mass, including wood burning, vegetative 

emissions, and fossil fuel combustion by industrial point sources, on road vehicles, and non road 

engines, and meat cooking. Carbon isotope studies indicated that modern sources of carbon, e.g. 

wood burning and vegetative emissions, are larger contributors to measured carbon than fossil 

(anthropogenic) sources of carbon (e.g. gasoline, diesel, coal). Elevated levels of carbon in the 

winter are likely due to wood burning (from forest fires, prescribed fires, land clearing, 

agricultural burning, or residential, commercial or industrial wood use). Elevated levels in 

summer are likely due to vegetative carbon emissions. Contributions from fossil fuel 

combustion (gasoline and diesel) are greater in urban areas than in rural areas. 

1.4.1.4 Emission Sensitivity Analyses 

To evaluate changes in PM2.5 mass loadings in response to changes in 2009 emissions from 

specific source and pollutant categories, emissions sensitivities were run using the CMAQ 

regional air quality model, the ASIP 2009 Base D inventory, and episodes selected in summer 

(Jun 1-Jul 10) and late fall (Nov 19-Dec 19) 2002. 

Emissions in 2009 for several combinations of pollutants and source sectors were reduced by 30 

percent in separate sensitivity runs for each state in the VISTAS region and for the other RPOs in 

the VISTAS 12 km modeling grid. 

The first observation from these data is that the responses to emissions reductions are larger in 

the summer than in the winter. The greatest reductions in PM2.5 mass would be accomplished 

by further reducing SO2 emissions from electric utilities and industrial point sources beyond 

2009 levels. 

For the Louisville and Cincinnati nonattainment areas, SO2 reductions from EGU in KY and the 

MRPO states would have the greatest benefits. For the Huntington-Ashland area, SO2 

reductions from KY, TN, and WV would have the greatest benefits. SO2 reductions from EGU 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 9 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

and non-EGU in other southeastern states would also be beneficial in reducing PM2.5 in the KY 

nonattainment areas. The largest response to SO2 emissions reductions in the winter is projected 

from SO2 emissions outside the ASIP 12 km modeling domain (Boundary Conditions). SO2 

emissions from outside the 12 km domain are a significant, but smaller contribution in the 

summer episode. This suggests that continental and/or intercontinental transport of SO2 

emissions can have impacts comparable to or greater than impacts from local sources of NOx or 

primary carbon. 

The model projects very little benefit to total PM2.5 of reducing emissions of nitrogen oxides 

from either ground or point sources in Kentucky in either winter or summer. In the Southeast, 

ammonium nitrate levels are generally limited by availability of ammonia, so reducing ammonia 

emissions would be a more effective strategy to reduce ammonium nitrate than reducing nitrogen 

oxide emissions. 

In both summer and winter the model projects some benefits from reducing local sources of 

primary carbon from ground (on road vehicles, off road engines, area sources) and point 

(industrial and electric utility) sources and from fire emissions. Ground sources of primary PM 

are more important in Louisville and Cincinnati than in Huntington-Ashland and more important 

than point sources in all areas. Because biogenic emissions dominate Volatile Organic Carbon 

(VOC) emissions, the model indicates little reduction in total PM2.5 in winter and no reduction 

in summer from reducing anthropogenic VOC emissions. 

In summary, SO2 reductions from electric utilities and industrial point sources are likely to be 

most effective in reducing PM2.5 in Kentucky nonattainment areas. From the mobile sector, 

reductions of primary carbon from local sources would be more effective than reductions of 

either VOC or NOx. 

1.4.1.5 General Summary of Conceptual Description 

In summary, sulfate and particulate organic matter are the most important contributors to PM2.5 

in the Kentucky nonattainment areas. PM2.5 composition and mass are similar across the 

monitoring sites. Sulfate and carbon can be elevated due to contributions from local sources. 

Emissions sensitivity results demonstrate the greatest benefits in reducing PM2.5 from further 

reducing SO2 emissions from electric utilities and industrial point sources. Benefits of reducing 

primary carbon emissions from ground sources are projected to be greater than reducing primary 

carbon from point sources; however this does not consider the difficulty in implementing 

controls for mobile versus point sources. Reducing regional emissions of ammonia is projected 

to reduce wintertime nitrate levels. 

The complete conceptual description with technical data analysis, exceptions to generalizations, 

and illustrative charts is located in Appendix N. 

1.5 Clean Air Act Requirements 

Section 172(c) as amended, contains the general requirements for nonattainment areas. These 

requirements are listed below and are discussed in more detail in Section 7. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 10 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Section 172(c) Nonattainment Plan Provisions

(1) Reasonably available control measures (RACM) 

(2) Reasonable further progress (RFP) 

(3) Actual emissions inventory and periodic emissions inventory 

(4) New source review (NSR) 

(5) Permit requirements for new and modified sources 

(6) Other measures as may be necessary to provide attainment by specified attainment date 

(7) Compliance with Section 110(a)(2) 

(8) Equivalent techniques 

(9) Contingency measures 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 11 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

2.0 SIGNIFICANCE OF PM2.5 PRECURSOR POLLUTANTS 

As suggested in Section 1.4, SO2 emissions are believed to be the most appropriate strategy for 

addressing the PM2.5 nonattainment issues for the Louisville, KY-IN, Cincinnati-Middletown, 

OH-KY-IN, and Huntington-Ashland, WV-KY-OH, nonattainment areas. This finding is based 

on several factors including: 

• An analysis of the percentage contribution of the PM2.5 component species annually 

and seasonally within the nonattainment areas 

• Attribution of emissions sources to these PM2.5 component species 

• Clean Air Fine Particulate Implementation Rule presumptions on precursor pollutants 

2.1 PM2.5 Component Species Analysis 

The Federal Reference Method (FRM) monitoring data is used for demonstrating compliance 

with the PM2.5 annual standard. Even though the Speciated Trend Network (STN) data provides 

speciation of PM2.5 components, the STN data are not directly comparable to the FRM data 

because slightly different monitoring and analytical methods are used in the two networks. 

Relative contributions from sulfate, nitrate, ammonium, organic carbon, elemental carbon, and 

soils (crustal) using the STN data were discussed in Section 1.4. The STN network provides a 

contribution assessment for specific components of PM2.5 but the data cannot be used to 

demonstrate compliance with the PM2.5 standard. 

To provide a means to relate the two data sets in order to assign specific concentrations of the 

components of PM2.5 to the FRM data, Neil Frank with the USEPA developed an approach to use 

the raw STN PM2.5 data to appropriately estimate the components of PM2.5 as measured by the 

FRM monitors. The approach is termed the “Sulfate, Adjusted Nitrate, Derived Water, Inferred 

Carbonaceous material balance approacH”, method or SANDWICH. 

The SANDWICH approach is discussed in greater detail in Appendix L

Using the SANDWICH approach, it is possible to analyze the percentage contribution of the 

individual PM2.5 component species relative to the total FRM PM2.5 mass. Figures 2.1-1 through 

2.1-3 present the speciated mass contributions of the component species at representative FRM 

monitors in the Louisville, KY-IN, Cincinnati, KY-OH, and Huntington-Ashland, KY-OH-WV, 

PM2.5 non attainment areas. The speciated mass contributions displayed in these figures are for 

the 2002 baseline year used throughout this attainment demonstration. These figures illustrate 

daily speciated mass contributions from left to right according to the calendar year with the 

farthest right bar of the charts representing the 2002 annual averaged speciated mass 

contributions. Trends for these three monitors are the same as for other monitors in the same 

nonattainment area. From each of the three 2002 PM2.5 speciated mass contribution plots, it is 

clear that SO4 and OC are the dominant PM2.5 components throughout the year. SO4 is most 

pronounced during the summertime, but remains a reasonably important component of the total 

PM2.5 mass in any of the seasons. NO3 contributions are important on several days in the first 

and fourth quarters and almost undetectable in the second and third quarters. NH4 and H2O are 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 12 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

less dominant than SO4 and OC but are reasonably consistent in each season. EC and crustal 

material are much less prevalent at any time of the year. 

Figure 2.1-1. 2002 PM2.5 Speciated Mass Contribution at Jefferson County, KY, (Louisville 

21-111-0048) using SANDWICH technique to speciate FRM mass 

2002 PM2.5 Speciated Mass Contributions at Jefferson Co. KY 

 (21-111-0048)

0

5

10

15

20

25

30

35

1/14/20021/26/2002

2/7/2002

2/19/2002

3/3/2002

3/15/20023/27/2002

4/8/2002

4/20/2002

5/2/2002

5/14/20025/26/20026/19/2002

7/1/2002

7/13/20027/25/2002

8/6/2002

8/18/20028/30/20029/11/20029/23/200210/5/2002

10/17/200210/29/200211/10/200211/22/2002

12/4/2002

12/16/2002

_

Avg.

Date

Mass (μg m-3)

Crustal

EC

OC

H2O

NH4

NO3

SO4
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 13 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Figure 2.1-2. 2002 PM2.5 Speciated Mass Contribution at Kenton Co, KY, (Cincinnati, OH, 

non attainment area) using SANDWICH technique to speciate FRM mass 

2002 PM2.5 Speciated Mass Contributions at Kenton Co., KY

21-117-007

0

5

10

15

20

25

30

35

40

1/14/20021/26/2002

2/7/2002

2/19/2002

3/9/2002

3/21/2002

4/2/2002

4/14/20024/26/20025/20/2002

6/1/2002

6/25/2002

7/7/2002

7/19/20027/31/20028/12/20028/24/2002

9/5/2002

9/17/20029/29/2002

10/11/200210/23/2002

11/4/2002

11/16/200211/28/200212/10/200212/28/2002

_

Avg.

Date

Mass (μg m-3)

Crusta

EC

OC

H2O

NH4

NO3

SO4
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 14 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Figure 2.1-3. 2002 PM2.5 Speciated Mass Contribution at Boyd County, KY, in the 

Huntington-Ashland, KY-OH-WV, non-attainment area using SANDWICH technique to 

speciate FRM mass 

2.2 Attribution of Emissions Sources 

Precursor pollutants to PM2.5 can be emitted directly, such as in smoke from a fire, or they can 

form from chemical reactions of gases such as SO2, nitrogen dioxide, and some organic gases. 

Sources of these precursor pollutants include power plants, gasoline and diesel engines, wood 

combustion, and high-temperature industrial processes such as smelters and steel mills. Other 

sources of the PM2.5 precursor pollutants include mobile sources, area sources, biogenics, fires, 

wind blown dust, and oceans. 

The speciated analysis of the PM2.5 concentrations in the Louisville, KY-IN, CincinnatiMiddletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH PM2.5 nonattainment areas 

presented above demonstrates that the OC and SO4 components are the most important portions 

of the total PM2.5 mass throughout the year at all monitoring locations. OC is predominately 

attributed to biogenic VOC emissions. SO4 is associated with SO2 emissions. NH4 can have a 

variety of sources including both industrial and natural processes. What little NO3 is present in 

the PM2.5 nonattainment areas throughout the year are attributed to NOx from combustion 

sources. Of all these components and associated emission sources, SO4 is the only significant 

PM2.5 component species found throughout the year that is attributed to a set of emissions source 

(SO2) that are controlled through regulatory actions by the Kentucky Division for Air Quality 

(KYDAQ). 

2002 PM2.5 Speciated Mass Contributions at Boyd County, KY 

 (21-019-0017)

0

5

10

15

20

25

30

35

40

45

50

1/14/2002

2/1/2002

2/13/20022/25/2002

3/9/2002

3/21/2002

4/2/2002

4/14/20024/26/2002

5/8/2002

5/20/2002

6/1/2002

6/13/20026/25/2002

7/7/2002

7/19/20027/31/20028/12/20028/24/2002

9/5/2002

9/17/20029/29/2002

10/11/200210/23/2002

11/4/2002

11/16/200211/28/200212/10/200212/28/2002

_

Avg.

Date

Mass (μg m-3)

Crusta

EC

OC

H2O

NH4

NO3

SO4
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 15 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

When evaluated throughout the nonattainment areas and across Kentucky, SO2 is primarily from 

the point source sector. Figures 2.2-1, 2.2-2, and 2.2-3 present the SO2 emissions from the 

various source sectors in the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and 

Huntington-Ashland, WV-KY-OH, PM2.5 nonattainment areas, respectively. The magnitude of 

the point source sector completely masks the SO2 emissions from all other source categories. 

When SO2 emissions by source category are evaluated across Kentucky (Figure 2.2-4), the 

vertical axis scale is significantly larger than the axis scale used for the nonattainment area SO2

emissions plots. Again, the magnitude of the point source sector completely masks the SO2

emissions from all other source sectors. 

Figure 2.2-1. Louisville, KY-IN, PM2.5 Nonattainment Area SO2 Emissions in 2002 

Louisville Area SO2 Emissions by Source Category

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

Point Area Mobile Nonroad

Emissions (TPY)
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 16 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Figure 2.2-2. Cincinnati-Middletown, OH-KY-IN, PM2.5 Nonattainment Area SO2

Emissions in 2002 

Figure 2.2-3. Huntington-Ashland, WV-KY-OH, PM2.5 Nonattainment Area SO2 Emissions 

in 2002 

NKY SO2 Emissions by Source Category

0

2000

4000

6000

8000

10000

12000

14000

16000

18000

Point Area Mobile Nonroad

Emissions (TPY)

Ashland Area SO2 Emissions by Source Category

0

10000

20000

30000

40000

50000

60000

70000

Point Area Mobile Nonroad

Emissions (TPY)
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 17 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Figure 2.2-4. Kentucky Total PM2.5 Nonattainment Area SO2 Emissions in 2002 

2.3 Clean Air Fine Particulate Implementation Rule Presumptions on Precursor Pollutants 

The USEPA’s Clean Air Fine Particulate Implementation Rule (72 FR 20586), commonly 

referred to as the PM2.5 Implementation Rule, guides States as they develop state implementation 

plans in response to annual and/or daily PM2.5 nonattainment. It establishes a hierarchy of 

precursor pollutants: SO2 is always considered a precursor, NOx is presumptively a precursor, 

and VOCs and ammonia are presumed not to be precursors. Kentucky considers SO2 and NOx to 

be pollutant precursors. 

The PM2.5 Implementation Rule allows states to exempt NOx by demonstrating that NOx 

emissions are not a significant contributor to an area's PM2.5 nonattainment problem and that the 

area is not a source of a PM2.5 transport problem. The PM2.5 precursor NOx, and direct PM2.5

have been deemed insignificant in the Huntington-Ashland, WV-KY-OH, nonattainment area for 

mobile budgets for conformity as discussed in a later section in this document. 

Kentucky Total SO2 Emissions by Source Category

0

20000

40000

60000

80000

100000

120000

140000

Point Area Mobile Nonroad

Emissions (TPY)
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 18 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

3.0 ATTAINMENT DEMONSTRATION METHODS AND INPUTS 

The attainment modeling for the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and 

Huntington-Ashland, WV-KY-OH, PM2.5 nonattainment areas was performed in conjunction 

with the regional haze modeling being done by the Southeast Regional Planning Organization 

(RPO), Visibility Improvement State and Tribal Association of the Southeast (VISTAS), and the 

PM2.5 and ozone (O3) modeling being done by the Association of Southeastern Integrated 

Planning (ASIP). VISTAS and ASIP are run by the ten Southeast states (Alabama, Florida, 

Georgia, Kentucky, Mississippi, Kentucky, South Carolina, Tennessee, Virginia and West 

Virginia). Since the regional haze and PM2.5 modeling use annual simulations and includes an 

intermediate year that is the attainment year required for the Louisville, KY-IN, CincinnatiMiddletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM2.5 nonattainment areas, the 

KYDAQ decided to use this modeling for its attainment demonstration. The sections below 

outline the methods and inputs used by VISTAS/ASIP for the regional modeling.

3.1 Analysis Method 

The modeling analysis is a complex technical evaluation that begins by selection of the modeling 

system. VISTAS decided to use the following modeling system: 

• Meteorological Model: The Pennsylvania State University/National Center for 

Atmospheric Research (PSU/NCAR) Mesoscale Meteorological Model (MM5) is a 

nonhydrostatic, prognostic meteorological model routinely used for urban- and regionalscale photochemical, fine particulate matter, and regional haze regulatory modeling 

studies. 

• Emissions Model: The Sparse Matrix Operator Kernel Emissions (SMOKE) modeling 

system is an emissions modeling system that generates hourly gridded speciated emission 

inputs of mobile, nonroad mobile, area, point, fire, and biogenic emission sources for 

photochemical grid models. 

• Air Quality Model: The USEPA’s Models-3/ Community Multiscale Air Quality 

(CMAQ) modeling system is a “One-Atmosphere” photochemical grid model capable of 

addressing O3, particulate matter, visibility, and acid deposition at regional scale for 

periods up to one year. 

Additionally, a historical year was selected to model that represented typical meteorological 

conditions in the Southeast when high ozone, high PM2.5, and poor visibility were observed 

throughout the region. Once the historical year is selected, meteorological inputs are developed 

using the meteorological model. Emission inventories are also developed for the historical year 

and processed through the emissions model. These inputs are used in the air quality model to 

predict ozone, PM2.5, and visibility, with the results compared to the historic data. The model 

performance is evaluated by comparing the modeled predicted data to the historic air quality 

data. 

Once model performance is deemed adequate, typical baseline and future year emissions are 

processed through the emissions model. For this demonstration, the baseline year was 2002, 

which corresponds with the same year as the historic meteorology used in the modeling. The 

attainment future year KYDAQ is using for this demonstration is 2009, since the mandatory 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 19 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

attainment date for the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and HuntingtonAshland, WV-KY-OH, PM2.5 nonattainment areas is April 5, 2010. The attainment date is set 

prior to the completion of the 2010 calendar year; therefore the attainment of the NAAQS would 

have to be met by the end of the 2009. These emissions are processed through the air quality 

model with the meteorological inputs. The air quality modeling results are used to determine a 

relative reduction in future ozone, which is used in the attainment demonstration. 

The complete modeling protocol used for this analysis can be found in Appendix D. 

3.2 Model Selection 

To ensure that a modeling study is defensible, care must be taken in the selection of the models 

to be used. The models selected must be scientifically appropriate for the intended application 

and be freely accessible to all stakeholders. Scientifically appropriate means that the models 

address important physical and chemical phenomena in sufficient detail, using peer-reviewed 

methods. Freely accessible means that model formulations and coding are freely available for 

review and that the models are available to stakeholders, and their consultants, for execution and 

verification at no or low cost. 

The following sections outline the criteria for selecting a modeling system that is both defensible 

and capable of meeting the study's goals. These criteria were used in selecting the modeling 

system used for this modeling attainment demonstration. 

3.2.1 Selection of Air Quality Model 

3.2.1.1 Criteria 

For an air quality model to qualify as a candidate for use in an attainment demonstration, a State 

needs to show that it meets several general criteria: 

• The model has received a scientific peer review. 

• The model can be demonstrated applicable to the problem on a theoretical basis. 

• Data bases needed to perform the analysis are available and adequate. 

• Available past appropriate performance evaluations have shown the model is not biased 

toward underestimates or overestimates. 

• A protocol on methods and procedures to be followed has been established. 

• The developer of the model must be willing to make the source code available to users 

for free or for a reasonable cost, and the model cannot otherwise be proprietary. 

3.2.1.2 Overview of CMAQ 

The air quality model selected for this study was CMAQ version 4.5, which was the most recent 

release at the point the attainment modeling exercise started. For more than a decade, the 

USEPA has been developing the Models-3 CMAQ modeling system with the overarching aim of 

producing a “One-Atmosphere” air quality modeling system capable of addressing ozone, fine 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 20 

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Final Kentucky Attainment Demonstration November 2008 

particulate matter, visibility, and acid deposition within a common platform. The original 

justification for the Models-3 development emerged from the challenges posed by the CAAA 

and the USEPA’s desire to develop an advanced modeling framework for “holistic” 

environmental modeling utilizing state-of-science representations of atmospheric processes in a 

high performance computing environment. The USEPA completed the initial stage of 

development with Models-3 and released the CMAQ model in mid 1999 as the initial operating 

science model under the Models-3 framework. 

Another reason for choosing CMAQ as the atmospheric model is the ability to do oneatmospheric modeling. Since KYDAQ will be using the same modeling exercise for the ozone 

and PM2.5 attainment demonstration state implementation plans (SIPs), as well as the regional 

haze SIP, having a model that can handle both ozone and particulate matter is essential. A 

number of features in CMAQ’s theoretical formulation and technical implementation make the 

model well suited for annual PM2.5 modeling. 

The configuration used for this modeling demonstration, as well as a more detailed description of 

the CMAQ model, can be found in Appendix D. 

3.2.2 Selection of Meteorological Model 

3.2.2.1 Criteria 

Meteorological models, either through objective, diagnostic, or prognostic analysis, extend 

available information about the state of the atmosphere to the grid upon which photochemical 

grid modeling is to be carried out. The criteria for selecting a meteorological model are based on 

both the models ability to accurately replicate important meteorological phenomena in the region 

of study, and the model's ability to interface with the rest of the modeling systems, particularly 

the air quality model. With these issues in mind, the following criteria were established for the 

meteorological model to be used in this study: 

• Non-Hydrostatic Formulation 

• Reasonably current, peer reviewed formulation 

• Simulates Cloud Physics 

• Publicly available at no or low cost 

• Output available in I/O API format 

• Supports Four Dimensional Data Assimilation 

• Enhanced treatment of Planetary Boundary Layer heights for AQ modeling 

3.2.2.2 Overview of MM5 

The non-hydrostatic MM5 model is a three-dimensional, limited-area, primitive equation, 

prognostic model that has been used widely in regional air quality model applications. The basic 

model has been under continuous development, improvement, testing, and open peer-review for 

more than 20 years and has been used worldwide by hundreds of scientists for a variety of 

mesoscale studies. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 21 

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Final Kentucky Attainment Demonstration November 2008 

MM5 uses a terrain-following non-dimensionalized pressure, or "sigma", vertical coordinate 

similar to that used in many operational and research models. In the non-hydrostatic MM5, the 

sigma levels are defined according to the initial hydrostatically balanced reference state so that 

the sigma levels are also time-invariant. The gridded meteorological fields produced by MM5 

are directly compatible with the input requirements of “one atmosphere” air-quality models using 

this coordinate. MM5 fields can be easily used in other regional air quality models with different 

coordinate systems by performing a vertical interpolation, followed by a mass-conservation 

readjustment. 

Distinct planetary boundary layer parameterizations are available for air-quality applications, 

both of which represent sub-grid-scale turbulent fluxes of heat, moisture and momentum. One 

scheme uses a first-order eddy diffusivity formulation for stable and neutral environments and a 

modified first-order scheme for unstable regimes. The other scheme uses a prognostic equation 

for the second-order turbulent kinetic energy, while diagnosing the other key boundary layer 

terms. 

Initial and lateral boundary conditions are specified for real-data cases from mesoscale threedimensional analyses performed at 12-hour intervals on the outermost grid mesh selected by the 

user. Surface fields are analyzed at three-hour intervals. A Cressman-based technique is used to 

analyze standard surface and radiosonde observations, using the National Meteorological 

Center's spectral analysis, as a first guess. The lateral boundary data are introduced using a 

relaxation technique applied in the outermost five rows and columns of the coarsest grid domain. 

Results of detailed performance evaluations of the MM5 modeling system in regulatory air 

quality application studies have been widely reported in the literature (e.g., Emery et al., 1999; 

Tesche et al., 2000, 2003) and many have involved comparisons with other prognostic models 

such as the Regional Atmospheric Modeling System (RAMS) and the Systems Application 

International Mesoscale Model. The MM5 enjoys a far richer application history in regulatory 

modeling studies compared with RAMS or other models. Furthermore, in evaluations of these 

models in over 60 recent regional scale air quality application studies since 1995, it has generally 

been found that the MM5 model tends to produce somewhat better photochemical model inputs 

than alternative models. 

The configuration used for this modeling demonstration, as well as a more detailed description of 

the MM5 model, can be found in Appendix I. 

3.2.3 Selection of Emissions Processing System 

3.2.3.1 Criteria 

The principal criterion for an emissions processing system is that it accurately prepares 

emissions files in a format suitable for the photochemical grid model being used. The following 

list includes clarification of this criterion and additional desirable criteria for effective use of the 

system. 

• File System Compatibility with the I/O API 

• File Portability 
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Final Kentucky Attainment Demonstration November 2008 

• Ability to grid emissions on a Lambert Conformal projection 

• Report Capability 

• Graphical Analysis Capability 

• MOBILE6 Mobile Source Emissions 

• Biogenic Emissions Inventory System version 2 (BEIS-3) 

• Ability to process emissions for the proposed domain in a reasonable amount of time. 

• Ability to process control strategies 

• No or low cost for acquisition and maintenance 

• Expandable to support other species and mechanisms 

3.2.3.2 Overview of SMOKE 

The Sparse Matrix Operator Kernel Emissions (SMOKE) Modeling System was originally 

developed at the Micro-computing Center of North Carolina. As with most emissions models, 

SMOKE is principally an emission processing system and not a true emissions modeling system

in which emissions estimates are simulated from “first principles”. This means that, with the 

exception of mobile and biogenic sources, its purpose is to provide an efficient, modern tool for 

converting emissions inventory data into the formatted emission files required by an air quality 

simulation model. For mobile sources, SMOKE actually simulates emissions rates based on 

input mobile-source activity data, emission factors and outputs from transportation traveldemand models. 

SMOKE was originally designed to allow emissions data processing methods to utilize emergent 

high-performance-computing as applied to sparse-matrix algorithms. Indeed, SMOKE is the 

fastest emissions processing tool currently available to the air quality modeling community. The 

sparse matrix approach utilized throughout SMOKE permits both rapid and flexible processing 

of emissions data. The processing is rapid because SMOKE utilizes a series of matrix 

calculations instead of less efficient algorithms used in previous systems. The processing is 

flexible because the processing steps of temporal projection, controls, chemical speciation, 

temporal allocation, and spatial allocation have been separated into independent operations 

wherever possible. The results from these steps are merged together at a final stage of 

processing. 

SMOKE contains a number of major features that make it an attractive component of the 

modeling system. The model supports a variety of input formats from other emissions 

processing systems and models. It supports both gridded and county total land use scheme for 

biogenic emissions modeling. SMOKE can accommodate emissions files from up to 10 

countries and any pollutant can be processed by the system. 

For additional information about the SMOKE model please refer to Appendix D. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 23 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

3.3 Selection of the Modeling Year 

A crucial step to SIP modeling is the selection of the period of time to model to represent current 

air quality conditions and to project changes in air quality in response to changes in emissions. 

The year 2002 was selected as the base year for several reasons. 

The USEPA’s April 2007 Guidance on the use of Models and Other Analyses for Demonstrating 

Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze (Attainment Modeling 

Guidance) identifies specific goals to consider when selecting one or more episodes for use in 

demonstrating reasonable progress in attaining the regional haze air quality goals. The USEPA 

recommends that episode selection derive from four principal criteria: 

• Simulate a variety of meteorological conditions 

• Model time periods in which observed concentrations are close to the appropriate 

baseline design value or visibility impairment 

• Model periods for which extensive air quality/meteorological data bases exist 

• Model a sufficient number of days so that the modeled attainment test applied at each 

monitor violating the NAAQS is based on multiple days 

VISTAS adopted a logical, stepwise approach in implementing the Attainment Modeling 

Guidance in order to identify the most preferable, representative modeling year. These steps 

include the following: 

• Representativeness of Meteorological Conditions: The VISTAS meteorological 

contractor (BAMS) identified important meteorological characteristics and data sets in 

the VISTAS region directly relevant to the evaluation of candidate annual modeling 

episodes. 

• Initial Episode Typing: At the time of selection in 2003, meteorological and air quality 

data were available for 2002 for model inputs and model performance evaluation. 

VISTAS used Classification and Regression Tree (CART) analyses to evaluate the 

candidate modeling years. The year 2002 was found to be representative of conditions in 

the other years. Subsequently, these analyses were repeated with the meteorological and 

air quality monitoring data for 2000 to 2004 to evaluate how well the 2002 modeling year 

represented the full 2000-2004 baseline period. This analysis confirmed that visibility 

and PM2.5 concentrations in 2002 were representative of the five-year baseline period. 

This analysis is discussed in more detail in the project report in Appendix I. 

• Data Availability: In parallel with the CART analysis, episode characterization analyses, 

collaborative investigations by VISTAS states (e.g., NCDAQ, Georgia DNR, FL DEP) 

intensively studied the availability of PM2.5, meteorological, and emissions data and 

representativeness of alternative baseline modeling periods from a regulatory standpoint. 

Additionally, 2002 was the year that the USEPA was requiring states to provide 

emissions inventory data for the Comprehensive Emissions Reporting Rule (CERR), it 

made sense to use 2002 as the modeling year to take advantage of the 2002 inventory. 

• Years to be used by other RPOs: VISTAS also considered what years other RPOs would 

be modeling, and several had already chosen calendar year 2002 as the modeling year. 
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• After a lengthy process of integrated studies, the episode selection process culminated in 

the selection of calendar year 2002 (1 January through 31 December) as the most current, 

representative, and pragmatic choice for modeling. All of the USEPA criteria for model 

year selection were directly considered in this process together with many other 

considerations (e.g., timing of new emissions or aerometric data deliveries by the USEPA 

or the states to the modeling teams). 

3.4 Modeling Domains 

3.4.1 Horizontal Modeling Domain 

The CMAQ model was run in one-way nested grid mode. This allowed the larger outer domains 

to feed concentration data to the inner nested domain. One-way nesting is believed to be 

appropriate for the generally stagnant conditions experienced during Kentucky ozone episodes. 

Two-way nesting was not considered due to numerical and computational uncertainty associated 

with the technique. 

The horizontal coarse grid modeling domain boundaries were determined through a national 

effort to develop a common grid projection and boundary. A smaller 12-km grid, modeling 

domain was selected in an attempt to balance location of areas of interest, such as ozone and fine 

particulate matter nonattainment areas. Processing time was also a factor in choosing a smaller 

12-km grid, modeling domain. 

The coarse 36-km horizontal grid domain covers the continental United States. This domain was 

used as the outer grid domain for MM5 modeling with the CMAQ domain nested within the 

MM5 domain. Figure 3.4.1-1 shows the MM5 horizontal domain as the outer most, blue grid 

with the CMAQ 36-km domain nested in the MM5 domain. 

Figure 3.4.1-1. The MM5 and CMAQ 36-km Horizontal Domains 
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Final Kentucky Attainment Demonstration November 2008 

To achieve finer spatial resolution in the VISTAS states, a one-way nested high resolution (12-

km grid resolution) was used. Figure 3.4.1-2 shows the 12-km grid, modeling domain for the 

VISTAS region. This is the modeling domain on which the attainment test results are based. 

Figure 3.4.1-2. VISTAS 12-km Modeling Domain 

3.4.2 Vertical Modeling Domain 

The vertical grid used in the MM5 modeling primarily defines the CMAQ vertical structure. The 

MM5 model employed a terrain following coordinate system defined by pressure, using 34 

layers that extend from the surface to the 100 mb. A layer-averaging scheme was used to 

generate 19 vertical layers for CMAQ to reduce the computational cost of the CMAQ 

simulations. The effects of layer averaging were evaluated in conjunction with the modeling 

effort and were found to have a relatively minor effect on the model performance metrics when 

both the 34 layer and a 19 layer CMAQ models were compared to ambient monitoring data. 

3.5 Baseline Emissions Inventory 

The CAAA revised many of the provisions of the CAA related to attainment of the NAAQS and 

the protection of visibility in mandatory Class I Federal areas (certain national parks and 

wilderness areas). These revisions established new emission inventory requirements applicable 

to certain areas that were designated nonattainment for certain pollutants. In the case of 

particulate matter, the emission inventory provisions are in the general provisions under Section

172(c)(3). An inventory was developed for the baseline year 2002 and projected to 2009. The 

pollutants inventoried include volatile organic compounds (VOC), NOx, PM2.5, coarse 

particulate (PM10), ammonia (NH3) and SO2. Table 3.5-1 show the typical annual emissions 

from the various source sectors for the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, 

and Huntington-Ashland, WV-KY-OH PM2.5 nonattainment areas respectively for 2002. The 

values for Lawrence County are for the entire county, not just the census block that U.S.EPA 

designated as nonattainment. The baseline emissions inventory for 2002 was developed for 
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Final Kentucky Attainment Demonstration November 2008 

Kentucky following the methods described in Appendix F. Comprehensive tables of emissions 

for all counties and all pollutants and all categories for the three nonattainment areas for 2002 

and 2009 is located in Appendix E 

Table 3.5-1. 2002 Annual Emission Summaries (in tons per year) 

County VOC NOx SOx PM NH3 

 Point Area Mobile 

Non 

road Point Area Mobile 

Non 

road Point Area Mobile 

Non 

road Point Area Mobile 

Nonroad Point Area Mobile Non

road 

Boone 884 3,136 2,306 1,621 6,703 1,893 4,088 3,973 15,769 1,048 150 557 140 1,174 68 303 34 124 153 1 

Campbell 186 1,882 1,313 519 55 532 1,979 1,989 1 467 78 277 85 474 33 88 0 93 84 0 

Kenton 264 3,448 2,368 832 20 1,585 3,682 2,832 18 1,190 155 310 11 972 60 131 2 94 155 1 

Bullitt 2,689 984 1,483 506 221 51 2,979 578 391 93 89 50 56 804 43 44 0 94 81 0 

Jefferson 4,959 3,205 14,567 4,171 25,915 234 25,864 10,989 41,483 0 917 1,429 830 1,083 369 720 42 166 816 4 

Boyd 3,083 780 991 312 7,046 40 1,213 3,319 9,711 542 54 482 1,256 712 21 131 336 38 44 0 

Lawrence 98 374 409 223 17,129 87 785 726 48,874 96 30 85 335 216 14 30 31 28 20 0 

There are five different emission inventory source classifications: stationary point and area 

sources, off-road and on-road mobile sources, and biogenic sources. Stationary point sources are 

those sources that emit greater than a specified tonnage per year, with data provided at the 

facility level. Electric generating utilities and industrial sources are the major categories for 

stationary point sources. Stationary area sources are those sources whose individual emissions 

are relatively small, but due to the large number of these sources, the collective emissions from 

the source category could be significant (i.e., dry cleaners, service stations, agricultural sources, 

fire emissions, etc.). These types of emissions are estimated on a countywide level. Biogenic 

sources are the natural sources like trees, crops, grasses, and natural decay of plants. The 

emissions from these sources are estimated on a countywide level. 

Non-road (or off-road) mobile sources are equipment that can have internal combustion engines 

but do not use the roadways, i.e., lawn mowers, construction equipment, railroad locomotives, 

aircraft, etc. The emissions from these sources, like stationary area sources, are estimated on a 

countywide level. On-road mobile sources are automobiles, buses, trucks, and motorcycles that 

use the roadway system. The emissions from these sources are estimated by vehicle type and 

road type, and are summed to the countywide level. 

In addition to the various source classifications, there are also various types of emission 

inventories. The first is the actual base year inventory. This inventory is the base year emissions 

that correspond to the meteorological data used, which for this modeling effort is data from 

2002. These emissions are used for evaluating the air quality model performance. 

The second type of inventory is the typical base year inventory. This inventory is similar to the 

actual base year inventory, except that for sources whose emissions change significantly from 

year to year, a more typical emission value is used. In this modeling effort, typical emissions 

were developed for the electric generating units (EGUs) and the wildland fire emissions. The air 

quality modeling runs using the typical base year inventory are used to calculate relative 

reduction factors used in the attainment demonstration test. 
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Final Kentucky Attainment Demonstration November 2008 

The future year base inventory is an inventory developed for some future year for which 

attainment of the PM2.5 standard is needed. For this modeling project, the future year inventory 

will be 2009, the first complete year for which the standard must be attained. It is the future base 

year inventory that control strategies and sensitivities are applied to determine what controls, 

beyond those measures already included in the future year base inventory, to which source 

classifications must be made in order to attain and maintain the annual PM2.5 standard. 

The detailed discussions of the emissions inventory development can be found in Appendix E, 

and emission summaries by county for the entire Louisville, KY-IN, Cincinnati-Middletown, 

OH-KY-IN, and Huntington-Ashland, WV-KY-OH, nonattainment areas are in Appendix F. 

In the sections that follow, a synopsis of the inventories used for each source classification is 

included. Below is an overview of the inventories used for each source classification. 

3.5.1 Stationary Point Sources 

Point source emissions are emissions from individual sources that are in a fixed location. 

Generally, these sources must have permits in order to construct and/or operate and their 

emissions are inventoried on an annual basis. All sources emitting VOC are inventoried in 

Marshall, Livingston, Edmonson, Daviess, Hancock, Jefferson, Fayette, Scott, Boyd, Greenup, 

Boone, Kenton, Campbell and Christian counties. In the remaining counties, sources emitting 

greater than or equal to 100 tons per year, or sources that have between 25 and 100 tons per year 

that have a federal regulation requirement are inventoried on an annual basis. Large NOx 

sources having minimum capacity to emit 100 tons per year (tpy) of a criteria pollutant, 10 tpy of 

a single hazardous air pollutant (HAP), or 25 tpy total of multiple HAPs are inventoried 

annually. Smaller sources have been inventoried less frequently. For the purposes of this 

modeling, point source emissions data can be grouped into EGU sources and other non-EGU 

sources. Appendix F.1 documents the point source modeling inventory development, including 

LMAPD inventory procedures, in more detail. 

3.5.1.1 Electric Generating Units 

The actual base year inventory for the EGU sources used 2002 continuous emissions monitoring 

(CEM) data reported to the USEPA’s Acid Rain program or 2002 hourly emissions data 

provided by stakeholders. These data provide hourly emissions profiles for SO2 and NOx that 

can be used in air quality modeling. Emissions profiles are used to estimate emissions of other 

pollutants (VOC, carbon monoxide, NH4, PM2.5, soil-based on measured emissions of SO2 and 

NOx. 

Emissions from EGUs vary daily and seasonally as a function of variability in energy demand 

and utilization and outage schedules. Since emissions from EGUs represent a significant portion 

of the emission inventory, a typical base year emissions inventory was developed to avoid 

anomalies in future-year emissions due to variability in meteorology, economic, and outage 

factors in 2002. This approach is consistent with the Attainment Modeling Guidance. To 

develop a typical year 2002 emissions inventory for EGU sources, each unit’s average CEM heat 

input for 2000 through 2004 was divided by the 2002 actual heat input to generate a unit specific 

normalizing factor. This normalizing factor was then multiplied by the 2002 actual emissions. 
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Final Kentucky Attainment Demonstration November 2008 

The heat inputs for the period 2000 through 2004 were used because the modeling current design 

values use monitored data from this same 5-year period. If a unit was shut down for an entire 

year during the 2000 through 2004 period, the average of the years the unit was operational was 

used. If a unit was shut down in 2002, but not permanently shutdown, the emissions and heat 

inputs from 2001 (or 2000) were used in the normalizing calculations. 

As part of the air quality modeling, VISTAS, in cooperation with the other eastern RPOs, 

contracted with ICF Resources, L.L.C., to generate future year emission inventories for the 

electric generating sector of the contiguous United States using the Integrated Planning Model 

(IPM). IPM is a dynamic linear optimization model that can be used to examine air pollution 

control policies for various pollutants throughout the contiguous United States for the entire 

electric power system. The dynamic nature of IPM enables projection of the behavior of the 

power system over a specified future period. Optimization logic in IPM determines the leastcost means of meeting electric generation and capacity requirements while complying with 

specified constraints including air pollution regulations, transmission bottlenecks, and plantspecific operational constraints. The versatility of IPM allows users to specify which constraints 

to exercise, and to populate IPM with their own datasets. 

The IPM modeling runs took into consideration the USEPA’s Clean Air Interstate Rule (CAIR) 

implementation. The EGU emissions were developed and documented in Appendix H and I of 

the “Documentation of the Base G2 and Best & Final 2002 Base Year, 2009 and 2018 Emission 

Inventories” provided by the contractor and that documentation is included in Appendix F of this 

SIP entitled “Emission Inventory Documentation”. 

3.5.1.2 Other Industrial Point Sources 

For the non-EGU sources, the same inventory is used for both the actual and typical base year 

emissions inventories. The non-EGU category uses annual emissions as reported under the 

CERR for the year 2002. These emissions are temporally allocated to month, day, and hour 

using source category code (SCC)-based allocation factors. 

The general approach for assembling future year data was to use recently updated growth and 

control data consistent with the USEPA’s CAIR analyses. This data was supplemented with 

state-specific growth factors and stakeholder input on growth assumptions. 

3.5.2 Stationary Area Sources 

Stationary area sources are sources whose individual emissions are relatively small, but due to 

the large number of these sources, the collective emissions could be significant (i.e., combustion 

of fuels for heating, structure fires, service stations, etc.). Emissions are estimated by 

multiplying an emission factor by some known indicator of collective activity, such as fuel 

usage, number of households, or population. Stationary area source emissions are estimated at 

the countywide level. 

A small portion of the 2002 area source base year inventory for ozone precursors in eleven 

Kentucky ozone nonattainment or maintenance areas was developed by the KYDAQ and 

provided to the VISTAS contractor. The VISTAS contractor calculated the remaining portion of 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 29 

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Final Kentucky Attainment Demonstration November 2008 

the area source inventory. The sources estimated by the contractor include emissions from 

animal husbandry, wildland fires, and particulate matter from paved and unpaved roads. For the 

other states or local air programs within the modeling domain, either state-supplied data or data 

reported under CERR for 2002 was used. 

The actual base year inventory will serve as the typical base year inventory for all area source 

categories except for wildland fires. For wildland fires, a typical year inventory was used to 

avoid anomalies in wildfire activity in 2002 compared to longer-term averages. Development of 

a typical year fire inventory provided the capability of using a comparable data set for both the 

base year and future years. Thus, fire emissions remain the same for air quality modeling in both 

the base and any future years. The VISTAS Fire Special Interest Work Group used State records 

to ratio the number of acres burned over a longer period (three or more years, as available from 

state records) to 2002. Based on these ratios, the 2002 acreage was then scaled up or down to 

develop a typical year inventory.

For categories other than wildland fires, the VISTAS/ASIP contractor generated the future base 

year emissions inventory used in the attainment demonstration modeling. Growth factors 

supplied from the states or the USEPA’s CAIR emission projections were applied to project the 

controlled emissions to the appropriate year. In some cases, the USEPA’s Economic Growth and 

Analysis System Version 5 growth factors were used if no growth factor was available from 

either the states or the CAIR growth factor files. Appendix F.2 provides a detailed discussion of 

the area source inventory. 

3.5.3 Off-Road Mobile Sources 

Off-road (or non-road) mobile sources are equipment that are motorized but do not use the 

roadways, such as construction equipment, aircraft, railroad locomotives, lawn and garden 

equipment, etc. For the majority of the non-road mobile sources, the emissions for 2002 were 

estimated using the USEPA’s NONROAD2005c model. For the three source categories not 

included in the NONROAD model, i.e., aircraft engines, railroad locomotives, and commercial 

marine, more traditional methods of estimating the emissions were used. The same inventory is 

used for both the actual and typical base year emissions inventories. 

For the source categories estimated using the USEPA’s NONROAD model, the model growth 

assumptions were used to create the 2009 future year inventory. The NONROAD model takes 

into consideration regulations affecting emissions from these source categories. For the three 

largest airports in Kentucky, the Federal Aviation Administration’s Terminal Area Forecast was 

used to project growth in aircraft emissions. For the commercial marine, railroad locomotives, 

and the remaining airport emissions, the VISTAS/ASIP contractor calculated the future growth 

in emissions using detailed inventory data (both before and after controls) for 1996 and 2010, 

obtained from the CAIR Technical Support Document. When available, state-specific growth 

factors were used. Appendix F.2 provides a detailed discussion of the nonroad mobile source 

inventory 
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Final Kentucky Attainment Demonstration November 2008 

3.5.4 Highway Mobile Sources 

For onroad vehicles, the newest version of the MOBILE model, MOBILE6.2, was used. Key 

inputs for MOBILE include information on the age of vehicles on the roads, the average speeds 

on the roads, the mix of vehicles on the roads, any programs in place in an area to reduce 

emissions for motor vehicles (such as emissions inspection programs), and temperature. 

The MOBILE model takes into consideration regulations that affect emissions from this source 

sector. The same MOBILE run is used to represent the actual and typical year emissions for 

onroad vehicles using input data reflective of 2002. The MOBILE model is then run for the 

2009 inventory using input data reflective of that year. The 2002 vehicle miles traveled (VMT), 

speeds, vehicle age, and vehicle mix data were obtained from the Kentucky Transportation 

Cabinet (KYTC). For several urban areas in Kentucky that run travel demand models (TDMs), 

VMT and speed data from TDMs was obtained by KYDAQ and Louisville APCD and provided 

to the VISTAS contractor. 

For a detailed discussion about the mobile source inventory development used in the attainment 

demonstration modeling, please refer to Appendix F.3. 

3.5.5 Biogenic Emission Sources 

Biogenic emissions were prepared with the SMOKE-BEIS3 (Biogenic Emission Inventory 

System 3 version 0.9) preprocessor. SMOKE-BEIS3 is a modified version of the Urban Airshed 

Model (UAM)-BEIS3 model. Modifications include use of MM5 data, gridded land use data, 

and improved emissions characterization. The emission factors that are used in SMOKE-BEIS3 

are the same as the emission factors as in UAM-BEIS3. The basis for the gridded land use data 

used by BEIS3 is the county land use data in the Biogenic Emissions Landcover Database 

version 3 (BELD3) provided by the USEPA. A separate land classification scheme, based upon 

satellite (AVHRR, 1 km spatial resolution) and census information aided in defining the forest, 

agriculture, and urban portions of each county. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 31 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

4.0 MODEL PERFORMANCE EVALUATION 

The initial modeling effort focused on evaluating previous regional air quality modeling 

applications and testing candidate model configurations for the SMOKE emissions and CMAQ 

model for the VISTAS 36-km and 12-km modeling domains. This effort resulted in a report 

recommending the model configuration for the annual emissions and air quality modeling, which 

is included as part of the VISTAS Emissions and Air Quality Modeling Protocol. The evaluation 

of the meteorological modeling configuration can be found in Appendix F.1, with a summary of 

the final meteorological and air quality modeling configuration in the modeling protocol 

contained in Appendix E and Appendix C, respectively. 

Air quality model performance for the 2002 modeling year was initially tested in 2004 using an 

early version of the VISTAS emissions inventory. In keeping with the one-atmosphere objective 

of the CMAQ modeling platform, model performance was evaluated based on measured ozone, 

fine particles, and acid deposition in the Air Quality System (AQS), IMPROVE, Speciated 

Trends Network (STN), Southeastern Aerosol Research and Characterization (SEARCH), 

National Acid Deposition Program (NADP) and Clean Air Status and Trends Network 

(CASTNet) monitoring networks (Figure 4.0-1). 

Figure 4.0.1: Monitoring Networks used for VISTAS 2002 model performance evaluation, 

and their location within the VISTAS 12km domain. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 32 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Overall, the KYDAQ believes that the meteorological model performance is adequate for this 

modeling exercise and should produce credible inputs for the air quality modeling for the 

attainment demonstration for the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and 

Huntington-Ashland, WV-KY-OH PM2.5 nonattainment areas. 

4.1 Modeling Performance Goals, and Criteria 

In 2004, VISTAS/ASIP established model performance goals and criteria for components of fine 

particle mass (Table 4.2.1-1) based on previous model performance for ozone and fine particles. 

The Attainment Modeling Guidance for fine particulate matter at the time noted that PM models 

might not be able to achieve the same level of performance as ozone models. VISTAS’ 

evaluation considered several statistical performance measures and displays. Fractional bias and 

mean fractional error were selected as the most appropriate metrics to summarize model 

performance; other metrics were also calculated and are included for FRM and STN monitors in 

the full model performance evaluation found in Appendix J. 

Table 4.1-1. Established Model Performance Goals and Criteria 

for the PM2.5 Component Species 

Fractional Bias Mean Fractional 

Error 

Comment 

<15 percent <35 percent Goal for PM2.5 model performance based on ozone 

model performance, considered excellent performance 

<30 percent <50 percent Goal for PM2.5 model performance, considered good 

performance 

<60 percent <75 percent Criteria for PM2.5 model performance, considered 

average performance. Exceeding this level of 

performance indicates fundamental concerns with the 

modeling system and triggers diagnostic evaluation. 

An additional way to evaluate model performance statistics is to visualize performance based on 

these fractional bias and mean fractional error goals via “soccer plots” and “bugle plots”. The 

soccer plot is so named because the dotted lines resemble a soccer goal. The soccer plot is useful 

as both bias and error are shown on a single plot. As bias and error approach zero, the points are 

plotted closer to or within the “goal”, represented here by the dashed boxes. 

The bugle plot, named for the shape formed by the criteria and goal lines. The bugle plots are 

shaped as such because the goal and criteria lines are adjusted based on the average 

concentration of the observed species. As the average concentration becomes smaller, the 

criteria and goal lines become larger to adjust for the model’s poor ability to predict at low 

concentrations. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 33 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

The analysis of bugle plots demonstrated that greater emphasis should be placed on performance 

of those components with the greatest contribution to PM2.5 mass (e.g. SO4 and OC) and that 

greater bias and error could be accepted for components with smaller contributions to total PM2.5

mass (e.g. EC, NO3, and soil). The soccer plots and bugle plots have been included as suggested 

model performance evaluation displays in the Attainment Modeling Guidance. 

4.1.2 Domain-Wide Model Performance 

As a summary of model performance, soccer and bugle plots for the all of the VISTAS STN and 

FRM monitors are included here. Plots have been developed for the average monthly 

concentrations and the performance statistics for all of the PM2.5 component species (SO4, NO3, 

NH4, OC, and EC) and reconstructed PM2.5 total mass from the STN monitoring sites (Figures 

4.2.2-1 and 4.2.2-2), as well as the total FRM PM2.5 mass (Figures 4.1.2-3 and 4.1.2-4). 

The soccer plots for monthly average component performance for all the VISTAS/ASIP STN 

sites shows generally good model performance for most species of PM2.5 and total PM2.5. The 

exception is the prediction of NO3 values, which most values fall outside the criteria goal (Figure 

4.1.2-1). There are a few months that fall on the criteria level goal, which is better seen in the 

zoomed view presented in the image on the right in Figure 4.1.2-1. However, when the very low 

concentration of NO3 is taken into consideration, as presented in the bugle plots (Figures 4.1.2-

2), NO3 performance largely falls within the criteria and goal model performance lines. One can 

still note a general tendency for under prediction in NO3, and other species in right hand image in 

Figure 4.1.2-2, which leads to a slight under prediction in total reconstructed PM2.5. 

Monthly total PM2.5 concentration performance at all the VISTAS/ASIP FRM monitors largely 

falls within goal level thresholds, with only two months falling just outside goal level 

performance (Figure 4.1.2-3). Figure 4.1.2-4 suggests a slight negative bias in PM2.5 prediction 

for most of the year, with mean fractional error values remaining within goal levels across the 

year. 

STN VISTAS Sites CMAQ 12km - 2002 Monthly

0.0

20.0

40.0

60.0

80.0

100.0

120.0

140.0

160.0

180.0

200.0

-180.0 -120.0 -60.0 0.0 60.0 120.0 180.0

Fractional Bias

Mean Fractional Error

Sulfate

Nitrate

Ammon.

Organics

EC

PM2.5

Criteria

Goal

STN VISTAS Sites CMAQ 12km - 2002 Monthly

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

90.0

100.0

-75.0 -25.0 25.0 75.0

Fractional Bias

Mean Fractional Error

Sulfate

Nitrate

Ammon.

Organics

EC

PM2.5

Criteria

Goal

Figure 4.1.2-1. VISTAS STN Soccer Plots 

The image on the left is a soccer plot depicting both the mean fractional error and fractional bias for 

component concentration for all VISTAS STN monitoring sites. The image on the right is a zoomed 

view of the soccer plot on the left to better depict the area inside the criteria/goal lines. Each point 

represents a monthly value as compared to the model performance criteria (red box) and modeling 

performance goals (green box). 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 34 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

STN VISTAS Sites CMAQ 12km - 2002 Monthly

-200.0

-150.0

-100.0

-50.0

0.0

50.0

100.0

150.0

200.0

0.0 4.0 8.0 12.0 16.0 20.0

Average Concentration (μg/m3)

Mean Fractional Bias

Sulfate

Nitrate

Ammon.

Organics

EC

PM2.5

(+) Criteria

(+) Goal

(-) Goal

(-) Criteria

STN VISTAS Sites CMAQ 12km - 2002 Monthly

0.0

50.0

100.0

150.0

200.0

0.0 4.0 8.0 12.0 16.0 20.0

Average Concentration (μg/m3)

Mean Fractional Error 

Sulfate

Nitrate

Ammon.

Organics

EC

PM2.5

Criteria

Goal

Figure 4.1.2-2. VISTAS STN Bugle Plots 

The image on the left is a bugle plot of the mean fraction bias for particulate matter and its 

component concentrations for all VISTAS STN monitoring sites. The image on the right is a bugle 

plot of mean fraction error for particulate matter and its component species for all VISTAS STN 

monitoring sites. Each point represents a monthly mean fraction bias value as compared to the 

model performance criteria (red lines) and modeling performance goals (green lines). 

FRM VISTAS Sites CMAQ 12km - 2002 Monthly

0.0

20.0

40.0

60.0

80.0

100.0

120.0

140.0

160.0

180.0

200.0

-180.0 -120.0 -60.0 0.0 60.0 120.0 180.0

Fractional Bias

Mean Fractional Error

PM2.5

Criteria

Goal

FRM VISTAS Sites CMAQ 12km - 2002 Monthly

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

90.0

100.0

-75.0 -25.0 25.0 75.0

Fractional Bias

Mean Fractional Error 

PM2.5

Criteria

Goal

Figure 4.1.2-3. VISTAS FRM Soccer Plots 

Soccer plots depicting both the mean fractional error and fractional bias for component 

concentration for all the VISTAS FRM Monitoring sites. The image on the right is a zoomed view of 

the soccer plot on the left to better depict the area inside the criteria/goal lines. Each point 

represents a monthly value as compared to the model performance criteria (red box) and modeling 

performance goals (green box). 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 35 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

FRM VISTAS Sites CMAQ 12km - 2002 Monthly

-200.0

-150.0

-100.0

-50.0

0.0

50.0

100.0

150.0

200.0

0.0 4.0 8.0 12.0 16.0 20.0

Average Concentration (μg/m3)

Mean Fractional Bias

PM2.5

(+) Criteria

(+) Goal

(-) Goal

(-) Criteria

FRM VISTAS Sites CMAQ 12km - 2002 Monthly

0.0

50.0

100.0

150.0

200.0

0.0 4.0 8.0 12.0 16.0 20.0

Average Concentration (μg/m3)

Mean Fractional Error 

PM2.5

Criteria

Goal

Figure 4.1.2-4. VISTAS FRM Bugle Plots 

The image on the left is a bugle plot of the mean fraction bias for particulate matter and its 

component species concentrations for all the VISTAS FRM Monitoring sites. The image on the right 

is a bugle plot of mean fraction error for particulate matter and its component species for all the 

VISTAS FRM Monitoring sites. Each point represents a monthly mean fraction bias value as 

compared to the model performance criteria (red lines) and modeling performance goals (green 

lines). 

Overall, the general tendency is for the model to have some difficulty in predicting NO3, as the 

monthly average values tend to fall outside the criteria goals for performance in the soccer plots. 

Part of this under prediction lies in the fact that NO3 are generally found in low concentrations 

across the southeast, and the model generally has difficulties representing any compound with 

low atmospheric concentrations. The bugle plots are more encouraging with NO3 performance, 

as these plots take into consideration the concentration of the component when evaluating 

performance. The bugle plots show all components and total PM2.5 falling within criteria levels, 

if not goal levels, of model performance. The weaker performance of NO3 accounts for the 

slight negative bias in both the total reconstructed PM2.5 mass from STN sites as well as FRM 

total PM2.5 data. 

4.1.3 Nonattainment Area Model Performance 

The statistical metrics were calculated for the Louisville, KY-IN, Cincinnati- Middletown, OHKY-IN, and Huntington-Ashland, WV-KY-OH, STN monitors to demonstrate model 

performance for the components of PM2.5 in and near the PM2.5 nonattainment areas. Model 

performance statistics for the STN sites were calculated on a component and total PM2.5 basis for 

the entire base year. Plots have been developed for the average monthly concentrations of PM2.5

and its component species at the STN sites, and for total PM2.5 from FRM monitors for all 

Kentucky STN sites collectively, and for other monitoring sites within the PM2.5 nonattainment 

areas, and are included in Appendix J. 

4.1.4 Air Quality Model Performance Summary 

Overall, the model performance for the entire nonattainment area, as well as the Kentucky 

portion, through the 2002 baseline modeling year is reasonably good. For the most part, mean 

normalized bias and mean normalized gross error are within the recommended limits for good 

model performance for most of component species as well as total PM2.5 mass. Overall 

performance was good for sulfate and organic carbon, which are the largest constituents of PM2.5

for Kentucky. Nitrate performance across the nonattainment areas was less than ideal, especially 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 36 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

during the summer months. This is likely due to the generally low atmospheric concentrations 

seen in the nonattainment areas, including Kentucky. When the performance is weighted by the 

concentration, as in the bugle plots, the performance metrics indicate better model performance. 

The model also does a good job capturing PM2.5 component and total concentrations through 

various episode-clean out cycles (see Appendix J). Overall, the KYDAQ believes that the model 

performance is well within the limits of acceptable performance established in the Attainment 

Modeling Guidance. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 37 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

5.0 CONTROLS APPLIED 

Several control measures already in place or being implemented over the next few years will 

reduce stationary point, highway mobile, and nonroad mobile source emissions. The federal and 

state control measures that have impacts on air quality in Kentucky were modeled for all of the 

future years and are discussed in the sections below. Although all the controls listed below may 

not directly reduce PM2.5 concentrations in Kentucky, the modeling assessment in this submittal 

was based on one atmosphere modeling completed for ozone and fine particulate matter 

attainment demonstrations and regional haze plans. 

5.1 Federal Control Measures 

5.1.1 Tier 2 Vehicle Standards 

Federal Tier 2 vehicle standards will require all passenger vehicles in a manufacturer’s fleet, 

including light-duty trucks and sport utility vehicles (SUVs), to meet an average standard of 0.07 

grams of NOx per mile. Implementation began in 2004, and should be completely phased in by 

2007. The Tier 2 standards will also cover passenger vehicles over 8,500 pounds gross vehicle 

weight rating (the larger pickup trucks and SUVs), which are not covered by the current Tier 1 

regulations. For these vehicles, the standards will be phased in beginning in 2008, with full 

compliance in 2009. The new standards require vehicles to be 77% to 95% cleaner than those on 

the road today. The Tier 2 rule also reduced the sulfur content of gasoline to 30 parts per million 

(ppm) starting in January of 2006. Most gasoline sold in Kentucky prior to January 2006 had a 

sulfur content of about 300 ppm. Sulfur occurs naturally in gasoline, but interferes with the 

operation of catalytic converters on vehicles, resulting in higher NOx emissions. Lower-sulfur 

gasoline is necessary to achieve the Tier 2 vehicle emission standards. 

5.1.2 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards 

New USEPA standards designed to reduce NOx and VOC emissions from heavy-duty gasoline 

and diesel highway vehicles began to take effect in 2004. A second phase of standards and 

testing procedures, which began in 2007, will reduce particulate matter from heavy-duty 

highway engines, and will also reduce highway diesel fuel sulfur content to 15 ppm because the 

sulfur damages emission control devices. The total program is expected to achieve a 90% 

reduction in particulate matter (PM) emissions and a 95% reduction in NOx emissions for these 

new engines using low sulfur diesel, compared to existing engines using higher-content sulfur 

diesel. 

5.1.3 Large Nonroad Diesel Engines Rule 

In May 2004, the USEPA promulgated new rules for large nonroad diesel engines, such as those 

used in construction, agricultural, and industrial equipment, to be phased in between 2008 and 

2014. The nonroad diesel rules also reduce the allowable sulfur in nonroad diesel fuel by over 

99%. Nonroad diesel fuel currently averages about 3,400 ppm sulfur. The rule limits nonroad 

diesel sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined engine and fuel 

rules would reduce NOx and PM emissions from large nonroad diesel engines by over 90%, 

compared to current nonroad engines using higher-content sulfur diesel.
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 38 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

5.1.4 Nonroad Spark-Ignition Engines and Recreational Engines Standard 

The new standard, effective in July 2003, regulates NOx, hydrocarbons (HC), and carbon 

monoxide (CO) for groups of previously unregulated nonroad engines. The new standard will 

apply to all new engines sold in the United States and imported after these standards began and 

apply to large spark-ignition engines (forklifts and airport ground service equipment), 

recreational vehicles (off-highway motorcycles and all-terrain-vehicles), and recreational marine 

diesel engines. The regulation varies based upon the type of engine or vehicle. 

The large spark-ignition engines contribute to ozone formation and ambient CO and PM levels in 

urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like 

the large spark-ignition engines, recreational vehicles contribute to ozone formation and ambient 

CO and PM levels. For the off-highway motorcycles and all-terrain-vehicles, model year 2006, 

the new exhaust emissions standard was phased-in by 50% and for model years 2007 and later at 

100%. Recreational marine diesel engines over 37 kilowatts are used in yachts, cruisers, and 

other types of pleasure craft. Recreational marine engines contribute to ozone formation and PM 

levels, especially in marinas. Depending on the size of the engine, the standard began phasing-in 

in 2006. 

When all of the nonroad spark-ignition engines and recreational engines standards are fully 

implemented, an overall 72% reduction in HC, 80% reduction in NOx, and 56% reduction in CO 

emissions are expected by 2020. These controls will help reduce ambient concentrations of 

ozone, CO, and fine PM. 

5.1.5 NOx SIP Call in Surrounding States 

In October 1998, the USEPA made a finding of significant contribution of NOx emissions from 

certain states and published a rule that set ozone season NOx budgets for the purpose of reducing 

regional transport of ozone (63 FR 57356). This rule, referred to as the NOx SIP Call, called for 

ozone season controls to be put on utility and industrial boilers, as well as internal combustion 

engines in 22 states in the Eastern United States. A NOx emissions budget was set for each state. 

A NOx trading program was established, allowing sources to buy credits to meet their NOx 

budget as opposed to actually installing controls. The emission budgets were to be met by the 

beginning of 2004. Even with the trading program, the amount of ozone season NOx emissions 

has decreased significantly in and around Kentucky. 

Implementation of the NOx SIP Call was projected by Integrated Planning Model (IPM). The 

MACTEC emissions inventory report describes the IPM methods, and in Table 2.1-5 of that 

report, the EGU NOx emissions by state in 2009. Link to MACTEC Emission Inventory Report: 

 http://www.vistas-sesarm.org/documents/VISTABF2003-20-2008.pdf 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 39 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

5.1.6 Clean Air Interstate Rule 

On May 12, 2005, the USEPA promulgated the “Rule To Reduce Interstate Transport of Fine 

Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to Acid Rain Program; 

Revisions to the NOX SIP Call”, referred to as CAIR. This rule established the requirement for 

States to adopt rules limiting the emissions of NOx and sulfur dioxide (SO2) and a model rule for 

the states to use in developing their rules. The purpose of the CAIR is to reduce interstate 

transport of precursors to fine particulate and ozone. 

CAIR applies to (1) any stationary, fossil-fuel-fired boiler or stationary, fossil-fuel-fired 

combustion turbine serving at any time, since the start-up of a unit’s combustion chamber, a 

generator with nameplate capacity of more than 25 Megawatt hours (MWh) producing electricity 

for sale and (2) for a unit that qualifies as a cogeneration unit during the 12-month period starting 

on the date that the unit first produces electricity and continues to qualify as a cogeneration unit, 

a cogeneration unit serving at any time a generator with nameplate capacity of more than 25 

MWh and supplying in any calendar year more than one-third of the unit’s potential electric 

output capacity or 219,000 MWh, whichever is greater, to any utility power distribution system 

for sale. 

This rule provides annual state caps for NOx and SO2 in two phases, with the Phase I caps for 

NOx and SO2 starting in 2009 and 2010, respectively. Phase II caps become effective in 2015. 

The USEPA is allowing the caps to be met through a cap and trade program if a state so chooses 

to participate in the program. When fully implemented, the CAIR will reduce SO2 emissions in 

the eastern United States by over 70 percent and NOx emissions by over 60 percent from 2003 

levels. 

The following is a discussion of CAIR Controls and implications of the vacatur of CAIR based 

on available emissions sensitivity data. 

On July 11, 2008, the DC Circuit Court vacated the Clean Air Interstate Rule that required large 

scale reductions of SO2 and NOx emissions from Electric Generating Units (EGU). The Court 

cited several reasons for vacating CAIR including the inability of the emission trading programs 

to assure that the states’ obligations under Section 110a2D of the Clean Air Act not to 

significantly contribute to nonattainment conditions in downwind states would be met. In 

September 2008 EPA petitioned the Court to rehear the case and in October 2008 the Court 

asked the original litigants to respond by November 6, 2008 whether the Court should vacate the 

rule in its entirety or remand portions of the rule to allow the initial control requirements to stand 

while EPA addressed the Court’s concerns. A decision by the Court is expected in December, 

2008. 

Kentucky’s 2009 modeling demonstration for the annual PM2.5 State Implementation Plan relied 

on emissions reductions required by CAIR in Kentucky and the eastern United States. If the 

Court were to uphold the CAIR vacatur, then not all the controls that were modeled in 

Kentucky’s SIP demonstration would be legally enforceable. In August 2008 the VISTAS states 

reviewed the emissions controls assumed under the 2009 Best and Final EGU inventory to 

determine which were controls were still legally enforceable if CAIR were to be vacated. 

Legally enforceable controls were defined as being subject to: 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 40 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

1. State rule 

2. Consent decree 

3. Permit condition 

VISTAS states provided legally enforceable controls and emissions for 2009, 2012, and 2018 for 

EGU in VISTAS states by early September 2008. We also asked the MRPO and MANE-VU 

states to provide the same information for their states. We anticipate receiving this information 

for the MRPO and MANE-VU states in mid November. At that point we will rerun the 2009 

SMOKE emissions and CMAQ air quality models using legally enforceable EGU emission 

controls to determine how the 2009 PM2.5 design values for PM2.5 nonattainment areas in the 

VISTAS states might change as a result of the CAIR vacatur. We do not expect to have those 

modeling results until January 2009. 

In the meantime, we can use emission sensitivity analyses performed using CMAQ, the 2009 

Base D inventory, and two month-long episodes in summer (Jun 1-Jul 10) and late fall (Nov 19-

Dec 19) 2002 to evaluate how emissions changes under the CAIR vacatur might affect PM2.5

concentrations in nonattainment areas. These emissions sensitivities were performed in 2006 by 

Georgia Institute of Technology and addressed changes in 2009 emissions for specific source 

categories and pollutant categories. The episode periods were selected using Classification and 

Regression Tree analyses to represent the annual 2002 base year conditions for PM2.5 in 

nonattainment areas in the southeastern US. Emissions in 2009 for several combinations of 

pollutants and source sectors were reduced by 30 percent in separate sensitivity runs for each 

state in the VISTAS region and for the other RPOs in the VISTAS 12 km modeling grid. The 

pollutant contributions that were evaluated were: 

• SO2 from Electric Generating Units (EGU) sources in each VISTAS state, other RPOs in 

the VISTAS 12 km grid, and Boundary Conditions from outside the 12 km domain. 

• SO2 from non-EGU point sources in each VISTAS state, other RPOs, and Boundary 

Conditions 

• NOx from ground level (on-road plus non-road plus area) sources in each VISTAS state 

and other RPOs 

• NOx from point (EGU plus non-EGU) sources in each VISTAS state and other RPOs 

• NH3 from all sources in VISTAS and other RPOs 

• Volatile Organic Compounds from anthropogenic and biogenic sources in the 12 km 

modeling domain 

• Primary Carbon from all ground level sources in each VISTAS state and other RPOs 

• Primary Carbon from all point sources in each VISTAS state and other RPOs 

• Primary Carbon from all fires in each VISTAS state and other RPOs 

Sensitivity results SO2 from EGU and NOx from point sources for the summer and winter 

episodes and for annual average PM2.5 (calculated as average of the summer and winter episode 

responses) provide a basis to interpret potential impacts of the CAIR vacatur for the three PM2.5

nonattainment areas in Kentucky. The discussion below focuses on SO2 because the emissions 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 41 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

sensitivity analyses show the greatest reductions in PM2.5 in nonattainment areas comes from 

reducing EGU SO2 emissions in Kentucky and eastern states. 

All three PM2.5 non-attainment areas in Kentucky are multi-state areas with counties and partial 

counties in more than one state as listed below:

Louisville, KY-IN: KY - Bullitt and Jefferson Counties; IN - Clark, Floyd, and Jefferson 

Counties 

Cincinnati-Hamilton, KY-IN-OH: OH- Butler, Clermont, Hamilton, and Warren Counties; IN 

- Dearborn County; KY - Boone, Campbell, and Kenton Counties

Huntington-Ashland, KY-OH-WV: WV - Cabell and Wayne Counties, and parts of Mason 

County; Ky - Boyd County and parts of Lawrence County; OH - Lawrence and Scioto Counties, 

and parts of Adams and Gallia County. 

The ASIP 2009 Best and Final modeling results delivered in spring 2008 demonstrated that all 

monitors in the Huntington-Ashland, KY-OH-WV would attain with only the Scioto County 

monitor in Ohio projected to be above 14.5 μg/m3

. In the Louisville, KY-IN nonattainment area, 

none of the monitors are projected to be above 14.5 μg/m3. All the Kentucky monitors in the 

Cincinnati, KY-IN-OH nonattainment area are projected to be below 13 μg/m3

 while the 

Hamilton County, OH monitors are closer to the standard. We expect that all monitors except 

Hamilton County, OH would continue to demonstrate attainment even if the CAIR vacatur 

resulted in increases in projected PM2.5 of 0.1-3 μg/m3

 in 2009. 

Table 1 details the emissions assumptions used to estimate the potential change in the 2009 

PM2.5 design value in the Kentucky nonattainment areas if CAIR were to be vacated. The ASIP 

Best and Final 2009 EGU SO2 inventories for Kentucky were 271,662 tons/yr under CAIR and 

310,840 tons/yr under the No CAIR (legally enforceable) scenario. This is a 39,178 tons/yr 

difference in SO2 emissions from KY or a 14.4% increase over the 2009 Best and Final EGU 

SO2 emissions. The ASIP Base D 2009 EGU SO2inventory for Kentucky was 342,678 tons/yr 

SO2 (higher emissions because Base D inventory was developed in 2005 prior to major utility 

consent decrees). The 30% 2009 Base D EGU SO2 emissions reduction modeled in the 

sensitivity was equal to 102,803 tons/yr. The difference between CAIR and No CAIR scenarios 

in the 2009 Best and Final EGU SO2 inventory is 38.1% of the reduction tested in the 2009 Base 

D EGU SO2 emissions sensitivity run. Therefore the response to the CAIR vacatur might be 

assumed to be 38.1% of the response to a 30% reduction in KY 2009 Base D EGU SO2

emissions. 

The CAIR vacatur would affect not only KY, but all eastern states. The 2009 Best and Final 

EGU SO2 emissions for the VISTAS states were 243,460 tons/yr greater for the No CAIR 

scenario (2,691,917 tons/yr) than the CAIR Best and Final EGU SO2 inventory (2,448,457 

tons/yr). This is a 9.9% increase in EGU SO2 emissions across the VISTAS states in the 2009 No 

CAIR scenario. In contrast, a 30% reduction in the 2009 Base D EGU SO2 inventory was 

690,169 tons/yr. So the change in the 2009 EGU SO2 emissions for the ten VISTAS states due 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 42 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

to the CAIR vacatur would be 35.3% of the SO2 emissions reductions tested for the 2009 Base D 

inventory. 

Table 1. 

2009 

No CAIR

Legally

Enforceable

2009 Best 

and Final

2009 

Difference 

No CAIR -

CAIR

2009 

Base D

2009 30% 

Reduction 

Base D

Ratio No 

CAIR to 

Base D 

emissions 

change 

AL 405,164 377,993 27,171 314,899

FL 339,645 287,633 52,013 206,851

GA 406,312 406,312 0 396,187

KY 310,840 271,662 39,178 342,678 102,803 0.381

MS 76,633 76,633 0 76,864

NC 227,433 227,433 0 139,499

SC 177,278 125,364 51,914 146,502

TN 255,141 255,141 0 280,189

VA 224,520 151,336 73,185 150,039

WV 268,950 268,950 0 246,853

VISTAS 2,691,917 2,448,457 243,461 2,300,563 690,169 0.353

EGU SO2 Emissions

Table 2 defines the projected change in 2009 PM2.5 concentration calculated for the No CAIR 

scenario based on the 2009 emissions sensitivity runs. 

Table 2. PM2.5 Response to EGU SO2 Emissions Changes 

2009 Response to 

Base D emissions 

(μ/m3) 

2009 Response to 

No CAIR emissions 

(μ/m3)

Louisville, KY-IN 

KY 0.143 0.054

VISTAS states 0.318 0.112

Cincinnati, OH-KY-IN 

KY 0.144 0.055

VISTAS states 0.291 0.103

Huntington-Ashland, WV-KY-OH 

KY 0.083 0.032

VISTAS states 0.315 0.111

 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 43 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

For the Louisville, KY-IN nonattainment area (monitor 21-111-0043), the response to a 30% 

reduction in KY 2009 Base D EGU SO2 emissions was 0.143 μg/m3 PM2.5. The response for 

Louisville, KY-IN to the CAIR vacatur for KY EGU might be assumed to be 0.381 times 0.143 

μg/m3

 or 0.054 μg/m3 PM2.5. The response for Louisville, KY-IN to a 30% reduction in 2009 

Base D EGU SO2 emissions for all the VISTAS states was 0.318 μg/m3. Thus the response to 

the CAIR vacatur for EGU in all the VISTAS states might be assumed to be 0.353 times 0.318 

μg/m3

 or 0.112 μg/m3 PM2.5 in Louisville, KY-IN. We do not know what emissions changes 

would result if CAIR were vacated from legally enforceable EGU controls for the CENRAP, 

MANE-VU, and MRPO states. 

For the Cincinnati, KY-IN-OH nonattainment area, using the difference in VISTAS SO2

emissions between the 2009 Best and Final CAIR EGU inventory and the NO CAIR scenario, 

the emission reduction tested in the 2009 Base D EGU SO2 sensitivity run as described above, 

and the PM2.5 responses to the 2009 EGU SO2 sensitivity run (0.291 μg/m3

), we would project a 

0.103 μg/m3 increase in PM2.5 in 2009 in the Cincinnati, KY-IN-OH) nonattainment area 

(monitor 21-117-0007) due to the CAIR vacatur for EGU sources in the VISTAS states. Of that 

amount, we calculate that 0.0548 μg/m3 would be attributable to CAIR vacatur for EGU sources 

in KY. Using similar logic, we would project a 0.111 μg/m3 increase in PM2.5 in 2009 in the 

Huntington-Ashland, KY-OH-WV nonattainment area (monitor 21-019-0017) due to the CAIR 

vacatur for EGU sources in the VISTAS states. Of that amount, we calculate that 0.0315 μg/m3 

might be attributable to the CAIR vacatur for EGU sources in Kentucky. West Virginia EGU are 

projected to retain the same SO2 controls under the NO CAIR scenario as the 2009 Best and 

Final CAIR scenario. 

While we do not know the emissions changes due to legally enforceable EGU controls in the 

CENRAP, MANE-VU, and MRPO states, if we assume that the increases in EGU SO2 in these 

regions were equivalent to the increases projected for the VISTAS states (10%), then we can 

estimate their combined impacts on the KY nonattainment areas. For Louisville, KY, the 

combined effect of a 30% change in EGU SO2 emissions from CENRAP, MANE-VU, and 

MRPO states resulted in a 0.273 μg/m3

 response in PM2.5. If we assume that the CAIR vacatur 

would increase SO2 emissions from these regions by 10 to 30%, then if CAIR were vacated, 

there might be an increase of 0.09 to 0.27 μg/m3 PM2.5 at the Louisville, KY monitor due to EGU 

in the CENRAP, MANE-VU, and MRPO states. For Huntington-Ashland, KY-OH-WV a 10 to 

30% increase in EGU SO2 emissions from CENRAP, MRPO, and MANE-VU states due to the 

CAIR vacatur might increase PM2.5 by 0.06 to 0.17 μg/m3. For Cincinnati, KY, a 10 to 30% 

increase in EGU SO2 emissions from CENRAP, MRPO, and MANE-VU states due to the CAIR 

vacatur might increase PM2.5 by 0.11 to 0.33 μg/m3

. SO2 emissions from outside the 12 km 

domain are a significant, but smaller contribution to PM2.5 in the KY nonattainment areas than 

contributions from within the 12 km domain. There is insufficient information to estimate how 

these boundary conditions would change if CAIR were vacated. 

If CAIR were vacated, summer-time nitrogen oxides (NOx) emissions controls would still be 

required under the NOx SIP call and the only emissions reductions that would not be legally 

enforceable would be year-round operation of already installed NOx control equipment. The 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 44 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

2009 NOx sensitivity runs projects very little benefit to total PM2.5 of reducing NOx emissions 

from either ground-level (primarily mobile) sources or point sources in Kentucky or the 

VISTAS states in either winter or summer. Ammonium nitrate is a very small component of 

total PM2.5 in the summer and roughly 5-10% of total PM2.5 in winter in the KY nonattainment 

areas. The 2009 emissions sensitivity results suggest that reducing ammonia emissions would be 

a more effective strategy to reduce wintertime ammonium nitrate than reducing nitrogen oxide 

emissions. 

These analyses combined suggest that Huntington-Ashland, KY-OH-WV and Louisville, KY-IN 

should continue to attain the annual PM2.5 standard even if CAIR is vacated. It is not clear if 

the Hamilton County, KY monitors would attain if CAIR were vacated. As stated above, 

VISTAS is preparing for a CMAQ run using legally enforceable EGU controls to resolve this 

question. 

5.1.7 Industrial Boiler/Process Heater/RICE MACTs 

EPA’s industrial boiler/process heater MACT (40 CFR 63 Subpart DDDDD) was vacated in 

June 2007, yet the final ASIP 2009 inventory and modeling demonstration for attainment of the 

PM2.5 annual standard included emissions reductions attributable to the vacated rule. For 

Kentucky a total of 259 tons/yr of SO2 and 156 tons/yr of primary PM2.5 were attributed to the 

vacated boiler MACT in the 2009 inventory. Total 2009 emissions for Kentucky are 428,733 

tons/yr for SO2 and 83,480 tons/yr primary PM2.5. Emission reductions attributed to the vacated 

boiler MACT compromise 0.06% of total state wide SO2 emissions and 0.19% of total state wide 

primary PM2.5. The emissions reductions attributable to the boiler MACT are insignificant 

fraction of total SO2 and primary PM2.5 emissions contributing to KY nonattainment areas, and 

including these reductions in the 2009 modeling demonstration does not change the attainment 

conclusions. 

Table 1 outlines the 2009 SO2 emissions in each county in the two PM2.5 nonattainment areas in 

Kentucky affected by boiler MACT assumptions; Table 2 outlines 2009 primary PM2.5 emissions 

in these two areas. The boiler MACT assumptions affect 2009 emissions in three Kentucky 

counties and one West Virginia county; no sources in Ohio or Indiana were affected. For the 

Huntington-Ashland, KY-OH-WV area, 40 tons/yr of SO2 from sources in Boyd County, KY 

and Wayne County, WV, or 0.025% of all SO2 emissions from point sources in the 

nonattainment area were attributed to the boiler MACT. For primary PM2.5, 23 tons/yr or 0.01% 

of total primary PM2.5 emissions from point sources in nonattainment area were attributed to the 

boiler MACT. For the Louisville, KY-IN nonattainment area, 51 tons/yr SO2 from sources in 

Bullitt and Jefferson, KY counties, or 0.11% of KY point source SO2 emissions and 0.06% of all 

point source SO2 emissions in the Louisville nonattainment area were attributed to the boiler 

MACT. For primary PM2.5, 23 tons/yr or 2.4% of KY primary PM2.5 point source emissions and 

0.7% of total primary PM2.5 point source emissions in the nonattainment area were attributed to 

the boiler MACT. No sources in the Cincinnati, KY-IN-OH nonattainment area were affected in 

2009 by the boiler MACT. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 45 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

ASIP emissions sensitivity analyses demonstrated the responses of PM2.5 in nonattainment areas 

to reductions in SO2 and primary PM2.5 emissions in 2009. These analyses indicate that a 30% 

reduction in 2009 SO2 non-EGU point source emissions in Kentucky (from 36, 418 SO2 tons /yr 

to 25,493 tons/yr) would reduce PM2.5 in Louisville, KY (monitor 21-111-0043) by 0.0212 

μg/m3

. The SO2 emissions reduction attributed to the boiler MACT amounted to 2.4% of the 

SO2 reduction modeled for the KY non-EGU point source emissions sensitivity. These SO2

emission reductions might underestimate the PM2.5 concentration in Lousiville, KY by 0.0005 

μg/m3. Further the PM2.5 non-EGU point emissions were reduced by 4.44% compared to the 

Kentucky non-EGU PM2.5 reduction tested in the emissions sensitivity, possibly underestimating 

the PM2.5 concentration in the Louisville, KY PM2.5 nonattainment area by an additional 0.002 

μg/m3. The combined SO2 and primary PM2.5 contribution to PM2.5 in the Louisville, KY 

nonattainment area that is attributable to the vacated boiler MACT is 0.0025 μg/m3. This 

concentration difference is less than model accuracy and does not change the conclusion that 

Louisville will attain the annual PM2.5 standard in 2009. 

Similarly, for the Huntington-Ashland, KY-OH-WV PM2.5 nonattainment area (monitor 21-019-

0017), the emissions sensitivity results indicate that the SO2 and primary PM2.5 emissions 

assumed under the vacated boiler MACT would result in an additional 0.006 μg/m3 PM2.5 from 

SO2 emissions and an additional 0.0003 μg/m3 from primary PM2.5 emissions, for a total increase 

of PM2.5 in the Huntington-Ashland nonattainment area of 0.0009 μg/m3 attributable to the 

vacated boiler MACT. These values are below the accuracy of the model and do not change the 

conclusion that the Huntington-Ashland area will attain the annual PM2.5 standard in 2009. 

Table 1. 2009 SO2 emissions in Louisville, KY-IN and Huntington-Ashland, KY-OH-WV PM2.5

nonattainment areas from the draft PM2.5 SIP and corrected SO2 emissions accounting for 

emissions that would not be controlled 2009 due to the vacatur of the boiler MACT. 

Louisville, KY-IN 

SOx 

Corrected 

Point 

Corrected 

Point Area Mobile Nonroad Total Total 

KENTUCKY 

Bullitt 401 97 14 8 520 410 529

Jefferson 43,688 14,585 112 921 59,306 43,730 59,348

KY Total 44,089 14,682 126 929 59,826 44,140 59,877

INDIANA 

Clark 3,459 687 17 49 4,212 

Floyd 28,295 659 11 14 28,979 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 46 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Jefferson 14,563 334 5 9 14,911 

IN Total 46,317 1,680 33 72 48,102 

Total Emissions 90,406 16,362 159 1,001 107,928 90,364 107,970

Huntington-Ashland, 

KY-OH-WV 

SOx 

Corrected 

Point 

Corrected 

Point Area Mobile Nonroad Total Total 

KENTUCKY 

Boyd 10,432 578 6 380 11,396 10,460 11,424

Lawrence 47,739 102 4 52 47,897 

KY Total 58,171 680 10 432 59,293 58,199 59,321

WEST VIRGINIA 

Cabell 123 1,528 13 19 1,682 

Mason 56,691 122 4 14 56,830 

Wayne 277 517 5 34 832 289 844

WV Total 57,091 2,167 21 66 59,345 57,103 59,357

OHIO 

Adams 22,422 55 4 8 22,489 

Gallia 21,807 50 4 8 21,869 

Lawrence 0 94 11 15 120 

Scioto 918 108 9 25 1,060 

OH Total 45,147 307 28 56 45,538 

Total Emissions 160,409 3,154 59 554 164,176 160,449 164,216
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 47 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Table 2. 2009 primary PM2.5 emissions in Louisville, KY-IN and Huntington-Ashland, KY-OHWV PM2.5 nonattainment areas from the draft PM2.5 SIP and corrected SO2 emissions accounting 

for emissions that would not be controlled 2009 due to the vacatur of the boiler MACT. 

Louisville, KY-IN 

PM2.5 

Corrected 

Point 

Corrected 

Point Area Mobile Nonroad Total Total 

KENTUCKY 

Bullitt 57 826 35 39 957 

Jefferson 899 4,365 241 649 6,154 922 6,177

KY Total 956 5,191 276 688 7,111 979 7,134

INDIANA 

Clark 641 939 41 96 1,717 

Floyd 419 731 28 42 1,220 

Jefferson 1,293 516 12 27 1,848 

IN Total 2,353 2,186 81 165 4,785 

Total Emissions 3,309 7,377 357 853 11,896 3,331 11,919

Huntington-Ashland, 

KY-OH-WV 

KENTUCKY 

Boyd 1,255 748 15 121 2,139 1,278 2,162

Lawrence 413 219 10 28 670 

KY Total 1,668 967 25 149 2,809 1,691 2,832

WEST VIRGINIA 

Cabell 339 857 31 74 1,301 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 48 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Mason 287 380 9 60 735 

Wayne 54 485 11 114 664 

WV Total 680 1,722 50 248 2,701 

OHIO 

Adams 3,696 323 12 20 4,051 

Gallia 3,905 230 11 19 4,165 

Lawrence 2 165 26 29 222 

Scioto 92 339 24 60 515 

OH Total 7,695 1,057 73 128 8,953 

Total Emissions 10,043 3,746 148 525 14,463 10,066 14,486

5.1.8 Combustion Turbine MACTs 

The projection inventories do not include the NOx co-benefit effects of the MACT regulations 

for Gas Turbines or stationary Reciprocating Internal Combustion Engines, which the USEPA 

estimates to be small compared to the overall inventory.

5.1.9 VOC 2-, 4-, 7-, and 10-year MACT Standards 

Various point source MACTs and associated emission reductions were implemented. 

Reductions occurring before 2002 were assumed to be accounted for in the 2002 base year 

inventory. 

5.1.10 Consent Agreements 

East Kentucky Power Cooperative (EKPC), a coal-fired electric utility, has agreed to spend 

approximately $650 million on pollution controls and pay a $750,000 penalty to resolve 

violations of the Clean Air Act at its three plants in Kentucky known as Spurlock, Dale, and 

Cooper. The agreement will reduce harmful air pollutants by more than 60,000 tons per year 

according to EPA. The company will install state-of-the-art pollution control equipment to 

reduce emissions of pollutants that cause acid rain and smog. The controls will reduce annual 

emissions of smog-forming nitrogen oxides by approximately 8,000 tons and sulfur dioxide by 

more than 54,000 tons per year from EKPC’s Spurlock, Dale, and Cooper plants when the 

controls are fully implemented. This consent decree will facilitate that SO2 scrubbers are 

installed for EKPC’s Spurlock Units 1 and 2 and Cooper Units 1 and 2 for BART. The SO2 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 49 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

scrubbers for EKPC Spurlock Units 1 and 2 have been included in this SIP’s PM2.5 modeling 

results for 2009. 

This consent decree will facilitate that a SO2 scrubber will be installed for AEP Big Sandy’s 

Unit 2 by December 31, 2015, per the consent decree. Although not reflected in the 2009 

modeling, the AEP Big Sandy Unit 2 scrubber will significantly reduce emissions of visibility 

impairing pollutants and assist in the maintenance of the PM2.5 NAAQS.

American Electric Power (AEP) has agreed to cut 813,000 tons of air pollutants annually 

(654,000 tons of SO2 and 159,000 tons of NOx) at an estimated cost of more than $4.6 billion, 

pay a $15 million penalty, and spend $60 million on projects to mitigate the adverse effects of its 

past excess emissions. The agreement imposes caps on emissions of pollutants from 16 plants 

located in five states. The facilities are located in Moundsville (2 facilities), St. Albans, Glasgow, 

and New Haven (2 facilities), West Virginia; Louisa, Kentucky; Glen Lyn and Carbo, Virginia.; 

Brilliant, Conesville, Cheshire, Lockburne, and Beverly, Ohio; and Rockport and Lawrenceburg, 

Indiana. AEP will install pollution control equipment to reduce and cap sulfur dioxide and 

nitrogen oxide emissions by more than 813,000 tons per year when fully implemented. By 

installing these pollution control measures, the plants will emit 79 percent less sulfur dioxide and 

69 percent less nitrogen oxides, as compared to 2006 emissions. 

5.2 State Control Measures 

5.2.1 NOx SIP Call Rule 

In response to the USEPA’s NOx SIP call, Kentucky adopted rules to control the emissions of 

NOx from large stationary combustion sources. These rules cover (1) fossil fuel-fired stationary 

boilers, combustion turbines, and combined cycle systems serving a generator with a nameplate 

capacity greater than 25 megawatts and selling any amount of electricity, (2) fossil fuel-fired 

stationary boilers, combustion turbines, and combined cycle systems having a maximum design 

heat input greater than 250 million British thermal units per hour, and (3) reciprocating 

stationary internal combustion engines rated at equal or greater than 2400 brake horsepower 

(3000 brake horsepower for diesel engines and 4400 brake horsepower for dual fuel engines). 

As part of the NOx SIP call, the USEPA rules established a NOx budget for sources in Kentucky 

and other states. 

Besides amending existing NOx rules and adopting new NOx rules specifically to address the 

USEPA NOx SIP call, the Kentucky rules also require new sources to control emissions of NOx. 

The objective of this requirement is (1) to aid in meeting the NOx budget for Kentucky for minor 

sources and (2) to aid in attaining and maintaining the ambient air quality standard for ozone in 

Kentucky. 

Kentucky’s NOx SIP Call rule was predicted to reduce summertime NOx emissions from power 

plants and other industries by 68% by 2006. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 50 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

KRS 224.10-100, Powers and duties of the cabinet, provides the Kentucky Energy and 

Environment Cabinet with the statutory authority to adopt and implement its NOx SIP Call 

program. A link to KRS 224.10-100 is as follows: http://www.lrc.ky.gov/KRS/224-10/100.PDF. 

5.2.2 Open Burning Bans 

In 2005 Kentucky revised the open burning regulation to prohibit most types of open burning in 

moderate ozone nonattainment areas within Kentucky during the period of May-September when 

ozone is most likely to form. LMAPCD also revised their open burning regulation in 2008. 

A copy of KYDAQ’s regulation is located at http://www.lrc.ky.gov/kar/401/063/005.htm

A copy of Louisville’s open burning regulation is located at 

http://www.louisvilleky.gov/NR/rdonlyres/94818773-D227-4F1B-A30D-1B3D2A0D8488/0/111FV10.pdf

5.2.3 Clean Air Interstate Rule 

In response to the USEPA’s CAIR, the KYDAQ developed rules to implement CAIR. Under the 

rule, Kentucky has caps as follows: 

• Annual NOx: 83,205 tons for 2009-2014 and 

69,337 tons for 2015 and each year thereafter; 

• Ozone season NOx: 36,109 tons for 2009-2014 and 

30,651 tons for 2015 and each year thereafter; 

• Annual SO2: 188,773 tons for 2010-2014 and 

 132,141 tons for 2015 and each year thereafter. 

The State’s NOx allocations have been distributed based on allocation methodologies in 401 

KAR 52:210 and 220. The USEPA will determine the SO2 allocations, which are based on the 

acid rain program. For the most part the rules follow the USEPA’s model rule. This rule does 

not preclude the DAQ from adopting additional emission reduction requirements for covered 

sources if necessary to attain or maintain an ambient air quality standard. 

The KYDAQ CAIR regulations became effective February 2, 2007, and was approved to 

Kentucky’s SIP published October 4, 2007, (72 FR 56623) and effective December 3, 2007. 

5.2.4 Fugitive Emissions

Both KYDAQ and LMAPCD have a fugitive emissions regulation. 

For Kentucky, 401 KAR 63:010. Fugitive emissions, provides for the control of fugitive 

emissions in Kentucky can be found at http://www.lrc.ky.gov/kar/401/063/010.htm
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 51 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

For LMAPCD, Regulation 1.14, Control of Fugitive Particulate Emissions can be found at 

http://www.louisvilleky.gov/NR/rdonlyres/BBE8C0CA-F988-4885-BB59-5775C7304B63/0/114fv2.pdf
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 52 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

6.0 ATTAINMENT DEMONSTRATION 

An attainment demonstration consists of (a) analyses that estimate whether selected emission 

reductions will result in ambient concentrations that meet the NAAQS, and (b) an identified set 

of control measures which will result in the required emission reductions. The necessary 

emission reductions for both of these attainment demonstration components may be determined 

by relying on results obtained with air quality models. 

Section 3.0 of the Attainment Modeling Guidance recommends applying both a modeled 

attainment test and a subsequent screening test (or unmonitored area analysis) to the air quality 

modeling results to determine if the annual PM2.5 NAAQS will be met. Additional technical or 

corroboratory analyses may also be used as part of a “supplemental analysis” or a more stringent 

“weight of evidence” determination to supplement the modeled attainment test and to further 

support a demonstration of attainment of the NAAQS. 

6.1 Attainment Test Introduction 

The purpose of this modeling assessment is to determine if control strategies currently being 

implemented (“on the books”) and proposed control strategies will lead to attainment of the 

NAAQS for PM2.5 by the attainment year of 2009. The modeling is applied in a relative sense, 

similar to the 8-hour ozone attainment test. However, the PM2.5 attainment test is more 

complicated and reflects the fact that PM2.5 is a mixture. In the test, ambient PM2.5 is divided 

into major components, with a separate relative response factor (RRF) and future design value 

(DVF) calculated for each of the PM2.5 components. Since the attainment test is calculated on a 

per species basis, the attainment test for PM2.5 is referred to as the Speciated Modeled 

Attainment Test (SMAT). In its entirety, SMAT consists of four basic steps. 

First, the observed quarterly mean PM2.5 and quarterly mean composition for each monitor is 

calculated. This is achieved by multiplying the monitored quarterly mean concentration of PM2.5

from FRM monitors by the monitored fractional composition of PM2.5 species for each quarter 

(e.g., (20% sulfate) x (15.0 μg/m3

 PM2.5 mass) = 3.0 μg/m3 sulfate mass). 

The monitored quarterly mean concentration of PM2.5 from FRM monitors are the 5-year 

baseline design values (DVB) that are the result of averaging the 3 current design values (DVC) 

that straddle the modeling base year. The fractional composition of PM2.5 species is derived 

from STN monitoring site data that has been processed by the “sulfate, adjusted nitrate, derived 

water, inferred carbonaceous material balance approach”, or SANDWICH method, so STN and 

FRM masses are equivalent. The mean composition derived from the SANWICH method 

includes the percent of PM2.5 that can be attributed to SO4, NO3, OC, EC, other primary 

inorganic particulates (or crustal materials), NH4, and particle bound water (PBW). 

The second step is to use model results to derive component specific RRF for each monitor for 

each quarter. The RRF is basically the ratio of the model’s future projections to the baseline 

current projections. For each component, the future year modeled quarterly mean concentration 

predicted near the monitoring site is divided by the base year modeled quarterly mean 

concentration predicted near the monitoring site. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 53 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

For the third step, the component-specific RRFs are applied to the observed air quality 

concentrations of the projected quarterly species estimate. For each quarter, the current quarterly 

mean component concentration (step 1) are multiplied by the component-specific RRF obtained 

in step 2. This leads to an estimated future quarterly mean concentration for each component. 

The fourth step sums the quarterly components to get a quarterly mean PM2.5 value. These 

quarterly mean values are then averaged to produce a future year annual average PM2.5 estimate, 

or future design value (DVF), for each FRM monitoring site. This final value is then compared 

to the NAAQS (15.0 μg/m3

) to determine if attainment is reached. For a more detailed 

discussion of SMAT and the data at each set for the monitors in the nonattainment areas, see 

Appendix L. 

6.2 Attainment Test Results 

The goal of the SMAT process is to sum the quarterly mean PM2.5 components to get annual 

mean for PM2.5 values. The table below displays the quarterly mean and annual mean PM2.5

estimates for 2009 the FRM sites in the Kentucky PM2.5 nonattainment areas. 

Table 6.2-1. Quarterly Mean and Annual Mean PM2.5 Mass Estimates for 2009 

AIRS ID County Site Name 

NonBlank 

Mass 

Q1 

NonBlank 

Mass 

Q2 

NonBlank 

Mass 

Q3 

NonBlank 

Mass 

Q4 

2009 

Annual 

DVF 

SMAT 

21-019-0017 Boyd Ashland 11.388 12.588 15.370 9.823 12.8 

21-029-0006 Bullitt Shepherdsville 3.034 3.155 3.807 2.569 13.1 

21-037-0003 Campbell NKU 2.907 2.883 3.315 2.380 12.0 

21-117-0007 Kenton Covington 3.006 2.916 3.650 2.613 12.7 

21-111-0044 Jefferson Beecher 12.094 13.761 18.124 12.240 14.8 

21-111-0048 Jefferson Barret 11.955 13.071 17.740 11.967 14.2 

21-111-0051 Jefferson Watson 11.726 13.659 15.530 11.560 13.6 

These 2009 annual DVFs are the final product of the SMAT process and are then compared to 

the NAAQS (15.0 μg/m3

) to determine if attainment goals will be reached. Values at all of the 

FRM sites in all the nonattainment areas that are < 15.0 μg/m3 have passed the attainment test 

portion of the attainment demonstration. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 54 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Kentucky sites are < 15.0 μg/m3

. The SMATS values for the counties in other states will be 

available in Appendix O Ohio, Indiana, and West Virginia Submittals when those documents 

become available. 

Recently, since the draft version of the Kentucky SIP, the MATS tool became available. The 

MATS software is primarily intended as a tool to implement the modeled attainment tests for 

particulate (PM2.5) and ozone (O3), and to perform the uniform rate of progress analysis for 

regional haze (visibility). The MATS tool incorporates updated procedures and information 

since the tool that was used in the CAIR modeling. As EPA recommended during the comment 

period, Kentucky has provided in the following table the MATS attainment test values for 2009 . 

MATS results have been provided by the ASIP contractor and are summarized in the table below 

and are available in Appendix L Attainment Test. 

Table 6.2-2. Summary of Predicted VISTAS-ASIP Design Values using MATS 

AIRS ID State County 2002 Annual 

DVC 

2009 VISTAS 

BaseG4 MATS 

21-019-0017 KY Boyd 14.9 12.6 

54-011-0006 WV Cabell 16.5 14.4 

39-087-0010 OH Lawrence 15.7 13.7 

39-145-0013 OH Scioto 17.1 14.7 

21-029-0006 KY Bullitt 14.9 13.0 

21-111-0044 KY Jefferson 16.6 14.5 

21-111-0048 KY Jefferson 16.1 14.0 

21-111-0051 KY Jefferson 15.4 13.6 

18-019-0006 IN Clark 16.3 14.3 

18-043-1004 IN Floyd 14.9 12.9 

21-037-0003 KY Campbell 13.8 11.6 

21-117-0007 KY Kenton 14.9 12.6 

39-017-0003 OH Butler 16.1 14.0 

39-017-0016 OH Butler 15.5 13.2 

39-017-0017 OH Butler 15.3 13.3 

39-061-0014 OH Hamilton 17.8 15.5 

39-061-0040 OH Hamilton 15.6 13.4 

39-061-0041 OH Hamilton 15.8 13.5 

39-061-0042 OH Hamilton 16.8 14.3 

39-061-0043 OH Hamilton 15.5 13.3 

39-061-7001 OH Hamilton 16.3 14.1 

39-061-8001 OH Hamilton 17.3 15.0 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 55 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

With MATS, it can be demonstrated that all counties in all three non-attainment areas, except 

one monitor in Hamilton County, Ohio, are < 15.0 μg/m3. However, as discussed Section 6.3-2 

to follow, the modeling completed by the Midwest Regional Planning Organization (MRPO), 

using a more recent base year (2005), supports Hamilton County (39-061-0014) attaining the 

annual PM2.5 standard. 

6.3 Supplemental Analyses and Weight of Evidence 

The Attainment Modeling Guidance asserts that all attainment demonstrations should be 

accompanied by supplemental analysis that further supports the modeling conclusions. This 

supplemental analysis can include additional analyses of air quality, emissions, and 

meteorological data, and consider modeling outputs other than the results of the attainment test. 

If the attainment test results fall short of the standard, the results of corroboratory analyses may 

be used in a weight of evidence determination (WOE) to show that attainment is likely despite 

modeled results, which may be inconclusive. 

The Attainment Modeling Guidance defines the guidelines for supplemental analysis/WOE for 

the annual PM2.5 standard as follows: 

- Sites with a DVF less than 14.5 μg/m3

 should submit basic supplemental analysis to 

confirm the outcome of the model attainment test. 

- Sites with a DVF between 14.5 and 15.5 μg/m3 should submit a weight of evidence 

demonstration to aggregate supplemental analysis to support the model attainment 

demonstration. 

- Sites with a DVF greater than or equal to 15.5 μg/m3 should consider additional control 

measure to ensure attainment, as more qualitative analysis is unlikely to demonstrate 

attainment. 

The Cincinnati- Middletown, OH-KY-IN, and Huntington-Ashland, WV-KY-OH, PM2.5

nonattainment areas have DVFs lower than 14.5μg/m3

. One monitor in the Louisville, KY-IN, 

PM2.5 nonattainment area has a DVF of 14.8μg/m3

. The following section will be an 

examination of supplemental analysis to corroborate modeling results. An additional WOE 

analysis section will follow to show attainment for the Louisville, KY-IN, PM2.5 nonattainment 

area. 

6.3.1 Air Quality Modeling Metrics 

Section 7.0 of the Attainment Modeling Guidance suggests several additional modeling exercises 

that can be performed as part of supplemental/WOE analysis. One of the metrics that can be 

considered as part of this type of additional analysis is the calculation of the percent change in 

number of grid cells ≥ 15 μg/m3

 within the nonattainment area. 

For the Louisville, KY-IN, Cincinnati-Middletown, OH-KY-IN, and Huntington-Ashland, WVKY-OH, nonattainment areas, the cell counts of modeling data were tallied from both the 2002 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 56 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

baseline and the 2009 attainment year modeling run for a subset of the highest day from the base 

year. This subset of days included all days with an 24-hour PM2.5 concentration greater than 30 

μg/m3

 at any of the monitoring sites in either nonattainment area, as well as the four days with 

the highest average daily values from each quarter. This selection process identified 28 days for 

presentation in this appendix, and coincides with the days used in the model performance 

evaluation (Appendix J) and in the model results section (Appendix K). A full listing of the 

days and the observed 24-hour PM2.5 concentrations from the monitors in the nonattainment 

areas can be found in both Appendix J and Appendix K. 

Data was extracted for only the grid cells that contained portions of either of the PM2.5 

nonattainment areas. Figure 6.3.1-1 highlights the 50 cells that encompass the Kentucky PM2.5

nonattainment areas. 

Louisville Area Northern Kentucky Huntington Ashland 

Figure 6.3.1-1. Areas for which the Air Quality Metrics were Applied 

The cell counts were binned based on concentration ranges of 15 μg/m3 intervals to help 

illuminate the change in severity on the days in Kentucky with the highest PM2.5 concentrations. 

Figure 6.3.1-2 presents the cell count results graphically. The graph clearly shows a striking 

increase in the number of days below 15 μg/m3

. By 2009, 70% of cells fall in the 0 –15 μg/m3

range, a substantial increase from the 60% in 2002. Raw cell counts show a total of 6729 cells 

shifted to the 0 – 15 μg/m3 range between 2002 and 2009 (Table 6.3.1-1). 

Figure 6.3.1-2 also shows a decrease in the number of cells in the 15 – 30 μg/m3 bin (5801 cell 

decrease) and the 30 - 45μg/m3

 bin (922 cell decrease). The number of cells in the 45 –60 range 

shows a decrease to zero from 2002 to 2009. A closer examination of the daily cell counts 

shows that all of the cells in the highest concentration category occur on the same day in both the 

2002 and 2009 modeling. Overall, the results from the air quality modeling metric are 

encouraging. The metric shows a substantial increase in the number of cells below 15 μg/m3

, 

and an increase in cells below 30μg/m3

. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 57 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

2002 2009

Modeling Year

Percentage of Nonattainment Area

45-60

30-45

15-30

0-15

Figure 6.3.1-2. Percentage of Cell in PM2.5 Nonattainment Areas within Concentration 

Categories for 2002 and 2009. 

Table 6.3.1-1. Number of Cells within Concentration Bins. Increases (decreases) in the 

Number of Cells within the Bins are Noted by Blue (Red) Coloration in the Last Column. 

Cincinnati 

Concentration 2002 2009 Difference 

<= 15 ug/m3 12523 15026 2503 

> 15 ug/m3 - <= 30 ug/m3 11502 9437 -2065 

> 30 ug/m3 - <= 45 ug/m3 795 357 -438 

> 45 ug/m3 - <= 60 ug/m3 0 0 0 

> 60 ug/m3 0 0 0 

Huntington/Ashland 

Concentration 2002 2009 Difference 

<= 15 ug/m3 21248 24116 2868 

> 15 ug/m3 - <= 30 ug/m3 8108 5409 -2699 

> 30 ug/m3 - <= 45 ug/m3 209 40 -169 

> 45 ug/m3 - <= 60 ug/m3 0 0 0 

> 60 ug/m3 0 0 0 

Louisville 

Concentration 2002 2009 Difference 

<= 15 ug/m3 6761 8119 1358 

> 15 ug/m3 - <= 30 ug/m3 5942 4905 -1037 

> 30 ug/m3 - <= 45 ug/m3 431 116 -315 

> 45 ug/m3 - <= 60 ug/m3 6 0 -6 

> 60 ug/m3 0 0 0 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 58 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

6.3.2 Other Modeling Results 

One way to acquire modeling sensitivity runs is to examine the modeling results from other 

RPOs or from USEPA modeling studies. Other modeling studies may use different physical and 

chemical modeling options for their meteorological and air quality modeling runs, which would 

provide a comparison or sensitivity based on these different options. 

An air quality modeling exercise that contained results for Kentucky PM2.5 nonattainment areas 

is the USEPA’s modeling for the CAIR. The Technical Support Document for the final CAIR, 

March 2005, provided modeling results with and without the implementation of CAIR. 

Differences between the USEPA’s modeling and the attainment demonstration are: 1) the 

meteorology was for 2001, 2) the DVB was the weighted design values the 1999-2003 period 

and 3) the modeling results were for 2010. 

The DVF was calculated using the CAIR SMAT tool, so methodologies between the CAIR DVF 

and the values presented in Section 6.4 are the same. These modeling results are listed in Table 

6.3.2-1 below. 

Table 6.3.2-1. USEPA’s CAIR SMAT Modeling Results 

Future Year Boyd Co Bullitt Co Jefferson Co Kenton Co 

2010 13.38 13.67 15.44 13.72 

2015 12.95 N/A 15.13 13.26 

The USEPA’s results were for the highest monitor in a county where more than one monitor is 

located. The USEPA’s modeling results predicts that the Kentucky nonattainment areas, except 

for Jefferson County, should be below the annual PM2.5 standard by 2010. 

Although 2010 is one year later than the attainment year for these areas, the USEPA’s 2010 

CAIR DVFs are approximately 0.5 μg/m3

 higher than what the KYDAQ is showing in the 

attainment demonstration, but still supports that the Kentucky nonattainment areas will attain the 

annual PM2.5 standard by the attainment year of 2009. 

The new MATS provided opportunity to use the updated speciation section of the tool as 

compared to the older CAIR SMAT tool. As DAQ has already noted previously in Section 6.2, 

Jefferson is below 15 μg/m3

 for both ASIP-VISTAS SMAT (14.8 μg/m3) and the more recent 

ASIP-VISTAS MATS (14.5μg/m3). 

And more significantly, the modeling completed by the Midwest Regional Planning 

Organization (MRPO), using a more recent base year (2005), also supports Jefferson County 

(12.8 μg/m3

) being well below 15 μg/m3, as discussed in the following section in more detail. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 59 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

The link to the website for the CAIR Modeling values for 2010 is: 

http://www.epa.gov/cair/pdfs/finaltech02.pdf

Ohio and Indiana Modeling 

Additional air quality modeling that encompassed the Kentucky nonattainment areas was 

performed by the Midwest Regional Planning Organization (MRPO) for both the Indiana and 

Ohio attainment demonstration submittals. The MRPO is made up of the five Midwest states 

(Illinois, Indiana, Michigan, Ohio and Wisconsin) and the Lake Michigan Air Directors 

Consortium (LADCO). 

The air quality model selected for this technical analysis was CAMx (version 4.30), an Eulerian 

photochemical grid model developed by ENVIRON and approved by US EPA for this use. 

CAMx allows for integrated “one-atmosphere” assessment of ozone and PM 2.5. More notable 

features of CAMx include flexi-nesting, which allows for reconfiguration of nested grids within 

the model, multiple gas phase chemistry mechanism options, Plume-in-Grid (PiG), and Ozone 

Source Apportionment Technology. CAMx modeling is performed on a Linux computing 

platform with a Portland Group (PGI) FORTRAN compiler to create executable files. 

After the 2005 base episodes were modeled and determined to be within accuracy parameters, 

several future-year exercises were performed such as projecting emissions to 2008 and 2009 and 

modeling the projected emission reductions from national, regional, and local control measures 

that are in effect or considered “on the books”. This includes the NOx SIP Call and Clean Air 

Interstate Rule (CAIR) as well as the latest gasoline and engine control measures. 

The table below summarizes the modeling results and illustrates that all monitored areas in the 

nonattainment areas will attain the NAAQS by 2009. 

Table 6.3.2-2. Summary of VISTAS MATS and LADCO 2009 Design Values 

AIRS ID State County 2002 Annual 

DVC 

VISTAS 

BaseG4 

MATS 

LADCO RPO 

2009 Value PM 

Round 5 

 

21-019-0017 KY Boyd 14.9 12.6 11.8 

54-011-0006 WV Cabell 16.5 14.4 13.4 

39-087-0010 OH Lawrence 15.7 13.7 12.7 

39-145-0013 OH Scioto 17.1 14.7 12.2 

21-029-0006 KY Bullitt 14.9 13.0 12.4 

21-111-0044 KY Jefferson 16.6 14.5 12.8 

21-111-0048 KY Jefferson 16.1 14.0 12.5 

21-111-0051 KY Jefferson 15.4 13.4 12.1 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 60 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

18-019-0006 IN Clark 16.8 14.9 13.6 

18-043-1004 IN Floyd 14.9 13.0 12.1 

21-037-0003 KY Campbell 13.8 11.6 11.6 

21-117-0007 KY Kenton 14.9 12.6 11.8 

39-017-0003 OH Butler 16.1 14.0 - 

39-017-0016 OH Butler 15.5 13.2 13.0 

39-017-0017 OH Butler 15.3 13.3 13.6 

39-061-0014 OH Hamilton 17.8 15.5 14.4 

39-061-0040 OH Hamilton 15.6 13.4 12.7 

39-061-0041 OH Hamilton 15.8 13.5 13.0 

39-061-0042 OH Hamilton 16.8 14.3 13.9 

39-061-0043 OH Hamilton 15.5 13.3 12.9 

39-061-7001 OH Hamilton 16.3 14.1 13.3 

39-061-8001 OH Hamilton 17.3 15.0 14.6 

The LADCO-RPO modeling shows attainment in 2009 for all counties in the nonattainment 

areas. The contradictory results (see table above) between the VISTAS-ASIP modeling and the 

LADCO-RPO modeling are due almost entirely to the separate and distinct base years used. The 

VISTAS-ASIP modeling relied on 2002 base year emissions. The LADCO-RPO modeling 

relied on the more recent 2005 base year emissions. Overall the LADCO-RPO modeling 

included more recent ambient data to predict future year design values. Additionally, LADCO 

used the CAMX model, while VISTAS used the CMAQ model. Areas that show nonattainment 

using the older base year also show attainment using the more recent updated data. 

6.3.3 Air Quality Trends and Additional Reductions in Emissions 

Since the annual PM2.5 designation in 2002, annual average concentrations of PM2.5 have 

decreased. Table 6.3.3-1 provides the annual average data. These values indicate the monitors 

are still trending towards the NAAQS. 

Table 6.3.3-1. Annual Average PM2.5 Concentrations in the NAAs for the Past 8 Years 

AIRS ID County Site Name 2000 2001 2002 2003 2004 2005 2006 2007

21‐019‐0017 Boyd Co., KY Ashland 15.7 15.3 15.5 13.9 13.3 16.0 13.8 14.3

54‐011‐0006

Cabell Co.,

WV Huntington 17.6 17.5 16.7 15.5 15.2 18.1 15.0 16.7

39‐087‐0010

Lawerence

Co., OH Ironton 17.4 17.7 15.5 14.3 13.7 17.0 14.4 15.0
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 61 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

39‐145‐0013

Scioto Co.,

OH New Boston 21.1 20.3 16.7 14.7 13.0 16.2 14.3 14.0

21‐029‐0006 Bullitt Shepherdsville 16.4 15.6 14.7 14.4 13.6 16.3 14.1 15.3

21‐037‐0003 Campbell NKU 15.1 13.4 14.8 13.4 12.8 14.8 11.5 14.4

21‐117‐0007 Kenton Covington 16.3 15.3 15.1 14.3 13.4 15.9 13.3 14.2

39‐017‐0003

Butler Co.,

OH Middletown 17.0 16.4 16.8 15.1 14.1 19.0 14.1 15.4

39‐017‐0016

Butler Co.,

OH Fairfield 18.9 15.9 15.3 15.8 14.7 17.9 14.0 14.9

39‐061‐0014

Hamilton

Co., OH Seymour 19.3 18.2 17.9 17.0 15.9 19.8 15.5 16.6

39‐061‐0040

Hamilton

Co., OH Howard Taft 16.7 15.9 15.3 15.5 14.6 17.5 13.6 15.1

39‐061‐0042

Hamilton

Co., OH W. 8th 20.6 17.6 16.8 16.7 16.0 19.1 14.9 15.9

39‐061‐0043

Hamilton

Co., OH Sharonville 19.1 16.1 15.4 15.7 14.9 16.9 14.5 14.9

39‐061‐7001

Hamilton

Co., OH Norwood 17.2 16.8 16.1 16.0 15.3 18.4 14.4 15.1

39‐061‐8001

Hamilton

Co., OH St. Bernard 19.3 17.0 17.0 17.3 16.4 20.0 15.9 16.1

21‐111‐0043 Jefferson 37th 17.3 n/a 17.2 16.0 14.5 16.7 15.0 15.1

21‐111‐0044 Jefferson Beecher 16.7 17.7 17.5 15.4 14.1 16.5 15.2 14.9

21‐111‐0048 Jefferson Barret 16.7 16.9 16.4 15.5 13.7 16.8 14.0 15.1

21‐111‐0051 Jefferson Watson 16.8 16.3 15.7 14.9 12.6 16.5 13.7 15.7

18‐019‐0006 Clark Co., IN Jeffersonville 18.6 16.9 16.0 n/a 15.1 18.5 14.9 16.5
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 62 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

18‐043‐1004 Floyd Co., IN New Albany 16.0 15.8 14.6 14.5 13.71 16.7 13.3 14.7

Annual average PM2.5 values are presented in micrograms per cubic meter (ug/m3).  Source: USEPA/AQS.

Bolded values represent annual average values that exceed the level of the annual PM2.5

National Ambient Air Quality Standard (i.e. greater than 15.0 ug/m3

).

   

n/a  ‐   The site moved mid‐year or did not meet 75% data recovery requiremen

       

Figure 6.3.3-1. Annual PM2.5 Average Concentrations for the FRM Monitors 

in the Kentucky portion of Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and 

Huntington-Ashland, WV-KY-OH, Nonattainment Areas 

The figure below provides a graphical representation of the Kentucky portion of the data. 

With the improvement in annual average PM2.5 values, there has also been an improvement in 

PM2.5 design values. When one takes into account the period of record, PM2.5 design values 

improved significantly over the last 8 years. 

Annual PM2.5 Averages for Kentucky

11.0

12.0

13.0

14.0

15.0

16.0

17.0

18.0

19.0

2000 2001 2002 2003 2004 2005 2006 2007

21-019-0017 Boyd 21-029-0006 Bullitt 21-037-0003 Campbell NKU

21-117-0007 Kenton 21-111-0043 Jefferson 21-111-0044 Jefferson

21-111-0048 Jefferson 21-111-0051 Jefferson
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 63 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Like with the annual averages, the three-year design values (Table 6.6.3-2) have also begun to 

hover near the level of the standard for the Louisville, IN-KY monitors in recent years. It is also 

important to note in the Cincinnati- Middletown, OH-KY-IN, and the Huntington-Ashland, WVKY-OH, monitors have also maintained design values that meet the NAAQS over the past 3 

design value periods (See Table 6.3.3-2). 

Table 6.3.3-2. Three-Year Design Values for the FRM Monitors 

in the Louisville, KY-IN, Cincinnati- Middletown, OH-KY-IN, and Huntington-Ashland, 

WV-KY-OH, PM2.5 Nonattainment Areas 

AIRS ID County Site Name

2000‐

2002

2001‐

2003

2002‐

2004

2003‐

2005

2004‐

2006

2005‐

2007

21‐019‐0017 Boyd Ashland 15.5 14.9 14.3 14.4 14.4 14.7

54‐011‐0006

Cabell Co.,

WV Huntington 17.3 16.6 15.8 16.3 16.1 16.6

39‐087‐0010

Lawerence

Co., OH Ironton 16.8 15.8 14.5 15.0 15.0 15.4

39‐145‐0013

Scioto Co.,

OH New Boston 19.4 17.2 14.8 14.6 14.5 14.9

21‐037‐0003 Campbell NKU 14.4 13.9 13.7 13.7 13.1 13.6

21‐117‐0007 Kenton Covington 15.5 14.9 14.3 14.5 14.2 14.5

39‐017‐0003

Butler Co.,

OH Middletown 16.7 16.1 15.3 16.1 15.7 16.2

39‐017‐0016

Butler Co.,

OH Fairfield 16.7 15.7 15.3 16.1 15.5 15.6

39‐061‐0014

Hamilton

Co., OH Seymour 18.4 17.7 16.9 17.5 17.1 17.3

39‐061‐0040

Hamilton

Co., OH Howard Taft 16.0 15.6 15.1 15.9 15.2 15.4

39‐061‐0042

Hamilton

Co., OH W. 8th 18.4 17.1 16.5 17.3 16.7 16.6

39‐061‐0043

Hamilton

Co., OH Sharonville 16.9 15.7 15.3 15.8 15.4 15.4
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 64 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

39‐061‐7001

Hamilton

Co., OH Norwood 16.7 16.3 15.8 16.6 16.0 15.9

39‐061‐8001

Hamilton

Co., OH St. Bernard 17.8 17.1 16.9 17.9 17.4 17.3

21‐029‐0006 Bullitt Shepherdsville 15.6 14.9 14.2 14.8 14.7 15.3

21‐111‐0043 Jefferson 37th n/a n/a 15.9 15.7 15.4 15.6

21‐111‐0044 Jefferson Beecher 17.3 16.9 15.6 15.3 15.2 15.5

21‐111‐0048 Jefferson Barret 16.7 16.3 15.2 15.3 14.8 15.3

21‐111‐0051 Jefferson Watson 16.3 15.6 14.4 14.7 14.3 15.3

18‐019‐0006

Clark Co.,

IN Jeffersonville 17.2 n/a n/a n/a 16.2 16.6

18‐043‐1004

Floyd Co.,

IN New Albany 15.5 15.0 14.3 15.0 14.6 14.9

PM2.5 design values are presented in micrograms per cubic meter  (ug/m3).

Source: USEPA/AQS

Bolded values represent annual average values that exceed the level of the annual PM2.5 National

Ambient Air Quality Standard (i.e. greater than 15.0 ug/m3

).

n/a – The site did not meet the 75% data recovery requirement.

Both KYDAQ and the Louisville Metro Air Pollution Control District have submitted 

exceptional events data exclusion packages for the years 2004-2007. Upon U.S. EPA approval, 

high monitoring days would be excluded from the calculations of the three-year averages 

demonstrating even lower design values than listed in the tables above. 

The Cabinet included, in Appendix O “Ohio, Indiana, and West Virginia Submittals”, the 

individual submittals for other states in the three nonattainment areas. Where the state has not 

currently submitted to their respective USEPA regional office, Kentucky will add the copy to the 

appendix as soon as one becomes available. 

6.4 Unmonitored Area Analysis 

Regarding the U.S. EPA guidance (Section 3) in “The Use of Models and Other Analyses for 

Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze” (April 

2007), the States are asked to review unmonitored areas in nonattainment areas. The test is 

called an “unmonitored test analysis”, and is necessary in nonattainment areas where the PM2.5

monitoring network just meets or minimally exceeds the size of the network required to report 

data to Air Quality System (AQS). The purpose of the analysis is to use a combination of model 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 65 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

output and ambient data to identify areas that might exceed the NAAQS if monitors were located 

there. 

This review is intended to ensure that a control strategy leads to reductions in PM2.5 at other 

locations which could have baseline (and future) design values exceeding the NAAQS were a 

monitor deployed there. The unmonitored area analysis should identify areas where future-year 

design values are predicted to be greater than the NAAQS. 

The unmonitored analysis area is intended to be the primary means for identifying high PM2.5

concentrations outside of traditionally monitored locations. The spatial resolution of the 

modeling that is the underlying basis of the unmonitored area analysis will determine how well it 

addresses primary PM hotspot issues. The finer the resolution of the grid model, the more likely 

that primary PM hotpots will be recognized. 

Based on the monitoring guidance, it is believed that an unmonitored area analysis conducted at 

12km or finer resolution is sufficient to address unmonitored PM2.5 for the annual NAAQS. 

The ASIP modeling provided current-year (DVC) and projected future-year (DVF) PM2.5 Design 

Values (ug/m3

) in Kentucky using the 2002 Typical and 2009 BaseG4 CMAQ 12 km modeling 

results. See Appendix P which contains various Technical Support Documents (TSD) from 

VISTAS and ASIP, “Chapter 4.0 PM2.5 Projections” from the Technical Support Document 

provided by ENVIRON, January, 2008, discusses the DVC and the DVF. 

As noted in the ENVIRON Technical Support Document, Chapter 4.0, “Section 4.7.6 

Kentucky”, of the 28 FRM monitoring sites in the state, four of them have current-year PM2.5

Design Values (DVCs) that exceed the annual PM2.5 NAAQS. Jefferson County was the second 

highest DVC of 16.6 μg/m3 which has a projected 2009 DVF of 14.8 μg/m3 using 12 km CMAQ 

results, which is below the NAAQS. 

The ASIP-VISTAS contractor provided maps to illustrate the MATS projections for the 

unmonitored areas. See Appendix L Attainment Test for September 18, 2008 document entitled 

“ASIP PM2.5 Projections for Unmonitored Areas”. 

All FRM monitoring sites in Kentucky are projected to be below the annual average PM2.5. 

See Figure 6.3.3-2 and Figure 6.3.3-3 below. And Table 6.3.3-3 that follows. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 66 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Figure 6.3.3-2

Kentucky 2002 Design Value (Left) and

2009 base G2 12km projected DVF (Middle) and

2009 base G2 36km projected DVF (Right)

0

2

4

6

8

10

12

14

16

18

Bell-0002

Boyd-0017

Bullitt-0006

Campbell-0003

Carter-0500

Christian-0006

Daviess-0014

Fayette-0012Fayette-0014

Franklin-0006

Hardin-0006

Henderson-0006Henderson-0014

Jefferson-0044Jefferson-0048Jefferson-0051

Kenton-0007

Madison-0003

McCracken-1004

Perry-0003

Pike-0002

Warren-0007

Kentucky

ug/m3

Sum of PBW

Sum of NH4

Sum of Crustal

Sum of EC

Sum of OC

Sum of NO3

Sum of SO4

Figure 6.3.3-3 

Kentucky 12km 2009 Projected DVF by G4a_EXCEL(Left) and

G4a_MATS (Middle) andG2a_EXCEL (Right)

0

2

4

6

8

10

12

14

16

Bell-0002

Boyd-0017

Bullitt-0006

Campbell-0003

Carter-0500

Christian-0006

Daviess-0014

Fayette-0012Fayette-0014

Franklin-0006

Hardin-0006

Henderson-0006Henderson-0014

Jefferson-0044Jefferson-0048Jefferson-0051

Kenton-0007

Madison-0003

McCracken-1004

Perry-0003

Pike-0002

Warren-0007

Kentucky

ug/m3

PBW

NH4

Crustal

EC

OC

NO3

SO4

blank
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 67 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Table 6.3.3-3 Current Year (DVC) and projected future-year (DVF) PM2.5 Design Values 

(ug/m3

) in Kentucky using the 2002 Typical and 2009 Base G4 CMAQ 12 km modeling results. 

 

2002 

Annual 

2009g4a 

Annual 

MATS 

20092g4a MATS 

minus 2002gt2a 

AIRS ID State County DVC DVF Difference 

21-013-0002 KY Bell 14.8 12.8 -2.0 

21-019-0017 KY Boyd 14.9 12.6 -2.3 

21-029-0006 KY Bullitt 14.9 13.0 -1.9 

21-037-0003 KY Campbell 13.8 11.6 -2.2 

21-043-0500 KY Carter 12.2 10.2 -2.0 

21-047-0006 KY Christian 13.5 11.9 -1.6 

21-059-0014 KY Daviess 14.4 12.8 -1.6 

21-067-0012 KY Fayette 14.9 12.5 -2.4 

21-067-0014 KY Fayette 15.6 13.2 -2.4 

21-073-0006 KY Franklin 13.7 11.5 -2.2 

21-093-0006 KY Hardin 14.0 12.1 -1.9 

21-101-0006 KY Henderson 14.5 13.0 -1.5 

21-111-0043 KY Jefferson 15.9 14.0 -2.0 

21-111-0044 KY Jefferson 16.6 14.5 -2.1 

21-111-0048 KY Jefferson 16.1 14.0 -2.0 

21-111-0051 KY Jefferson 15.4 13.4 -2.0 

21-117-0007 KY Kenton 14.9 12.6 -2.3 

21-125-0004 KY Laurel 12.2 10.5 -1.7 

21-145-1004 KY McCracken 13.1 11.8 -1.3 

21-151-0003 KY Madison 13.5 11.4 -2.1 

21-193-0003 KY Perry 13.2 11.2 -2.0 

21-195-0002 KY Pike 13.7 11.6 -2.1 

21-227-0007 KY Warren 13.8 12.1 -1.7 

*provided by VISTAS contractor, October 2008 

6.5 Data Access 

The modeling input and output files are very large and it would not be resource-efficient to 

submit all of these files with the SIP attainment demonstration. These include all files used to 

process the emissions, meteorology and air quality models and any other files used to develop 

the modeling. 

Here is the link to the VISTAS final work products some of which are relevant to the PM2.5 SIP 

attainment demonstration: 

http://www.vistas-sesarm.org/documents/FinalDocs.asp
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 68 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

The LADCO-Midwest RPO information the below link: 

http://www.ladco.org/

Here is the link the CAIR Modeling values for 2010: 

http://www.epa.gov/cair/pdfs/finaltech02.pdf
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 69 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

7.0 CLEAN AIR ACT SECTION 172C REQUIREMENTS 

Section 172(c) of the CAA, as amended, contains the general requirements for nonattainment 

areas. These requirements are listed below and are discussed in more detail in the following 

sections. 

Section 172(c) Nonattainment Plan Provisions

(1) Reasonably available control measures 

(2) Reasonable further progress 

(3) Actual emissions inventory and periodic emissions inventory 

(4) New source review 

(5) Permit requirements for new and modified sources 

(6) Other measures as may be necessary to provide attainment by specified attainment date 

(7) Compliance with Section 110(a)(2) 

(8) Equivalent techniques 

(9) Contingency measures 

7.1 Reasonably Available Control Measures (RACM) 

Section 172(c)(1) of the CAA requires SIPs to provide for the implementation of all RACM to 

demonstrate attainment as expeditiously as practicable. A subset of RACM is reasonably 

available control technology (RACT), which relates specifically to stationary point sources. 

The CAA requires a demonstration that the State has adopted all reasonable and available control 

measures to demonstrate attainment as expeditiously as practicable and that no additional 

measures that are reasonably available will advance the attainment date. 

Although regional photochemical modeling indicates that no additional control measures are 

necessary to achieve the annual fine particle standard by the attainment date, KYDAQ 

participates in the regional planning effort through the Southeast Regional Planning Organization 

(RPO), Visibility Improvement State and Tribal Association of the Southeast (VISTAS) and the 

Association of Southeastern Integrated Planning (ASIP) to evaluate potential control measures to 

attain the 8-hour ozone and fine particle standards and achieve regional haze goals. Candidate 

control measures were evaluated primarily for feasibility, cost effectiveness, and the ability to 

implement them in a relatively short time frame (i.e., January 1, 2009, for the 2009 monitoring 

year). Due mainly to lengthy rulemaking processes, many of the control strategies evaluated 

could not be implemented by the 2009 monitoring year and were not pursued since they were not 

needed to demonstrate attainment. 

However, notwithstanding the fact that regional modeling demonstrates compliance for the 

Louisville, KY-IN, nonattainment area without the implementation of additional local measures 

and that no additional, SIP-creditable, meaningful control measures could be adopted and 

implemented to advance the attainment date by one year, the Louisville Metro Mayor, Jerry 

Abramson, created the regional Fine Particle Air Quality Task Force (Task Force) to identify, 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 70 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

evaluate, and recommend strategies for reducing PM2.5 to achieve the annual PM2.5 standard. 

Part of the Task Force’s charge was to assess potential RACM/RACT opportunities. To focus on 

meaningful RACM/RACT opportunities, the Task Force reviewed stationary sources comprising 

at least 90% of the point source emissions of direct PM2.5, NOx, and SO2 and the non-road 

mobile sources comprising at least 90% of the nonroad mobile source emissions of direct PM2.5, 

NOx, and SO2, as well as mobile sources. 

With respect to RACT for stationary sources, the Task Force found that many of the larger 

stationary sources of direct PM2.5, NOx, or SO2 already employed RACT. It is noted that the 

EPA, in the preamble to its Clean Air Fine Particle Implementation Rule, indicates that the EPA 

presumes (with certain conditions) that electric utilities that comply with the Clean Air Interstate 

Rule (CAIR) have met the RACT requirement for NOx and SO2. Further, the Task Force did not 

identify any new control measures to be recommended for inclusion in the Louisville 

nonattainment area’s attainment demonstration. However, the Task Force noted that the 

following new control measures are in the process of being implemented: 

 1. Gallagher Station (Duke Energy), Floyd County, IN, is in the process of replacing 

electrostatic precipitators with more effective fabric filter collectors for all four units, to 

be completed by May 2008 

 2. General Electric, Jefferson County, KY, is replacing a backup coal-fired boiler with a 

landfill gas/natural gas boiler. 

 3. Süd-Chemie (a catalyst manufacturer), Jefferson County, KY, is installing high efficiency 

particulate air (HEPA) filters following existing fabric filter collectors to further reduce 

particulate emissions. 

 4. Kosmos (a cement kiln), Jefferson County, KY, since 2005, has replaced several fabric 

filter collectors and added measures to control fugitive dust. Kosmos is also in the 

process of modifying some of its existing fabric filter collectors to increase their control 

efficiencies. 

7.2 RACM Determination 

The Kentucky PM2.5 Nonattainment Areas will continue to implement the RACM measures 

already adopted and described in Section 5 of this document. The above analysis establishes that 

these measures contributed to the region being able to comply with the PM2.5 NAAQS (1997). 

Therefore, this analysis demonstrates that there are no additional measures that are necessary to 

demonstrate attainment as expeditiously as practicable and to meet any RFP requirements and 

that there are no potential measures that if considered collectively would advance the attainment 

year by one year or more. The above analysis meets the applicable statutory requirements set 

forth at Section 172(c)(1) of the Clean Air Act and the applicable regulatory requirements set 

forth at 40 C.F.R. Section 51.1010. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 71 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

7.3 RACT Applicability 

40 CFR 51.1010 notes that for each PM2.5 nonattainment area, a SIP revision must be submitted 

that demonstrates all RACM, including RACT for stationary sources, necessary to demonstrate 

attainment as expeditiously as practicable, have been adopted. The section of the implementation 

rule goes on to state that potential measures that are reasonably available considering technical 

and economic feasibility must be adopted as RACM if, considered collectively, they would 

advance the attainment date by one year or more. As discussed in Section 6.2.1, the states 

determined that there are no additional control measures that could be adopted by January 1, 

2008. Further, existing measures, and those planned for implementation by 2009, are expected to 

enable the region to continue to demonstrate compliance with the PM2.5 NAAQS (1997) through 

the 2009 attainment date. As such, no further actions on RACT are warranted. 

7.4 Reasonable Further Progress

In the PM2.5 Implementation Rule, the USEPA maintained that an area that demonstrates 

attainment by 2010 would be considered to have satisfied the RFP requirement and need not 

submit any additional material to satisfy this requirement. The USEPA will view an approved 

attainment demonstration as demonstrating that the area is making reasonable further progress 

toward attainment. 

7.5 Actual Emissions Inventory 

Section 172(c)(3) requires the development of a comprehensive, accurate, current inventory of 

actual emissions from all sources in the nonattainment area. Such inventory is due two years 

after the effective date of the PM2.5 nonattainment designations, i.e., April 5, 2007. The 

KYDAQ and the LMAPCD met this requirement through the submittal of the 2002 emission 

inventories under the CERR for the Kentucky counties in this nonattainment area. 

The KYDAQ submitted statewide emissions for area, nonroad mobile, and highway mobile 

sources. For stationary point sources, The KYDAQ submitted inventories for those counties 

without a local program. The final 2002 emission inventories used in the attainment 

demonstration will go through the public hearing process with the full attainment demonstration, 

which will include any updates or revisions that are necessary since the CERR submittal. 

7.6 Periodic Emissions Inventory 

Section 172(c)(3) requires periodic inventory submittals. The KYDAQ and the LMAPCD plan 

to meet this requirement through the CERR submittals. The KYDAQ and the LMAPCD 

submitted the 2005 emissions inventory in the summer of 2007. Similar to the 2002 CERR 

submittal, the 2005 CERR submittal included point sources for all but those counties with local 

programs, and statewide area, nonroad mobile, and highway mobile sources. 

7.7 Other Measures 

Section 1729(c)(6) requires the nonattainment SIPs to include enforceable limitations and other 

control measures, along with schedules for compliance as needed to demonstrate attainment. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 72 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Section 5.0 of this document discusses in detail the Federal and State measures that were 

modeled to show attainment. Appendix M contains the rules. 

7.8 Compliance with Section 110(a)(2) 

Section 172(c)(7) requires nonattainment SIPs to meet the applicable provisions of Section 

110(a)(2). On October 2, 2007, the USEPA provided guidance on SIP elements required under 

Section 110(a)(1) and (2) for the 8-hour ozone and PM2.5 NAAQSs. Regarding the PM2.5

NAAQSs, the only SIP element of concern is 110(a)(2)(G) which relates to emergency episodes. 

The USEPA has not yet taken regulatory action to provide the necessary numerical limits and 

concentration levels for emergency episode action plans for PM2.5. The states look to the 

USEPA to provide this information in order to adopt the necessary rules that will protect the 

public health. Once the USEPA has promulgated rules setting the emergency episode limits, the 

KYDAQ will start the rulemaking process to adopt these limits. 

The KYDAQ and the LMAPCD believe that with the exception of 110(a)(2)(G) prior rule 

submittals, along with this attainment demonstration plan, address the relevant requirements of 

Section 110(a)(2). 

7.9 Equivalent Techniques 

The KYDAQ believes that the procedures for modeling, emissions inventory and planning 

follow the USEPA guidance and is not requesting approval for equivalent techniques, as 

envisioned under Section 172(c)(8). 

7.10 Contingency Measures 

Section 172(c)(9) requires that the nonattainment SIPs contain specific measures that would take 

effect upon a State’s failure to attain the PM2.5 standard in a given area, without further action by 

the State or the USEPA. The contingency plan consists of Federal measures. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 73 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

8.0 MOTOR VEHICLE EMISSIONS BUDGETS 

8.1 Transportation Conformity 

The purpose of transportation conformity is to ensure that Federal transportation actions 

occurring in a nonattainment area do not hinder the area from attaining and/or maintaining the 

annual PM2.5 standard. This means that the level of emissions estimated by the KYTC or the 

metropolitan planning organizations for the Transportation Implementation Plan and Long Range 

Transportation Plan must not exceed the motor vehicle emission budgets (MVEBs) as 

determined in this attainment demonstration SIP. 

8.2 Pollutants to be Considered 

40 CFR 93.119(f)(7) through (10) identifies the pollutants for PM2.5 that regional emissions 

analysis needs to be performed for transportation conformity purposes. Only primary, or direct, 

PM2.5 tailpipe emissions must be considered for transportation conformity regional emissions 

analysis. The precursor pollutants NOx, VOC, SO2, and ammonia, as well as reentrained road 

dust only need to be considered if the KYDAQ and/or the USEPA has deemed the pollutant as a 

significant contributor to the overall PM2.5 nonattainment problem. The KYDAQ has determined 

that the precursor pollutants NOx, VOC, ammonia, and mobile source SO2, as well as 

reentrained road dust are insignificant contributors to the overall PM2.5 nonattainment problem in 

Kentucky. Therefore, the KYDAQ is not establishing MVEBs for these pollutants. 

The PM2.5 precursor SO2 could not be deemed insignificant to the overall PM2.5 nonattainment 

problem since sulfate is such a large fraction of the PM2.5 composition. However, the KYDAQ 

has determined that SO2 emitted by the mobile source sector is insignificant. The USEPA in its 

Federal Register notice for PM2.5 does not address the mobile sector in its listing of significant 

sources of SO2 emissions. Kentucky agrees with the following statements addressing SO2 from 

on-road mobile emissions as published in the May 6, 2005, Federal Register, 70 FR 24283: 

While speciated air quality data show that sulfate is a relatively significant component 

(e.g., ranging from nine to 40 percent) of PM2.5 mass in all regions of the country, 

emissions inventory data and projections show that on-road emissions of SOx constitute a 

‘‘de minimis’’ (i.e., extremely small) portion of total SOx emissions. Emissions inventory 

data for 1999 for the 372 potential PM2.5 nonattainment counties for PM2.5 (based on 

1999–2001 air quality data) show that on-road sources were responsible for only two 

percent of total SOx emissions. 

Furthermore, EPA has already adopted two regulations that will greatly reduce 

emissions of SOx from on-road sources by the time such regulations are both in full effect 

in 2009. .........This regulation will reduce the sulfur content of diesel fuel by 

approximately 97 percent nationally when fully effective. 

Although sulfate is a significant component of the PM2.5 nonattainment problem in Kentucky, the 

majority of the SO2 emissions in 2009 come from the stationary point source sector with the 

mobile source sector only contributing two tenths of one percent (0.2 %). This is consistent with 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 74 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

what the USEPA stated above. The discussion about the significance of mobile source SO2

emissions can be found in Appendix F.3. For the reasons discussed, the KYDAQ has determined 

that mobile source SO2 emissions are insignificant to the PM2.5 nonattainment problem. 

An affirmative insignificance finding from the USEPA only relieves the transportation partners 

from a regional emissions analysis for these pollutant emissions for these areas and does not 

relieve them of the other transportation conformity requirements. The transportation partners 

will need to note the insignificance finding for these pollutants (if found adequate and approved 

by the USEPA) in future conformity determinations. 

Louisville, KY-IN, PM2.5 Nonattainment Area 

As part of the consultation process on setting MVEBs, the KYDAQ participated in several 

conference calls with all of the transportation partners. The KYDAQ, Louisville Metro Air 

Pollution Control District (LMAPCD), Indiana Department of Environmental Management 

(IDEM), Kentuckiana Regional Planning and Development Agency (KIPDA), and other 

agencies involved in the transportation conformity process have agreed with continuing the 

previously utilized approach of maintaining regional mobile source emissions budgets. The 

following table shows the highway mobile NOx and PM2.5 emissions in tons per year for the 

Louisville, KY-IN area 

Table 8.2-1 Highway Mobile Source Emissions for the Louisville, KY-IN, PM2.5

Nonattainment Area 

2009 Tons/Year

NOx 21,575.40

PM 2.5 374.85

A reasonable buffer has been applied to the 2009 Budgets in the amount of 5%. Buffers are used 

to accommodate the wide array of assumptions that are factored into the calculation process. 

Since assumptions change over time, it is necessary to have a buffer that will accommodate the 

impact of refined assumptions in the process. With the buffer applied to the 2009 Budget, the 

2009 total PM2.5 and NOx emissions remain well below the 2002 base year emissions. 

Therefore, a MVEB (21,575.40 tons/year NOx, 374.85 tons/year PM2.5) is established for 

transportation conformity purposes for the Louisville, KY-IN, PM2.5 nonattainment area for 

2009. Upon USEPA’s affirmative adequacy finding for these MVEB’s, these MVEB’s will 

become the applicable MVEB’s. 

Cincinnati- Middletown, OH-KY-IN 

As part of the consultation process on setting MVEBs, the KYDAQ participated in several 

conference calls with all of the transportation partners. It was decided to have sub-area budgets 

for the Kentucky portion of the nonattainment area and a combined sub-area budget for the 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 75 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Indiana and Ohio portion of the nonattainment area. The MVEBs will be set for the attainment 

year 2009. 

Table 8.2-2 Highway Mobile Source Emissions for the Kentucky portion of the 

Cincinnati-Middletown, OH-KY-IN, PM2.5 nonattainment area 

2009 Tons/Year

NOx 7,186.77

PM 2.5 117.45

A reasonable buffer has been applied to the 2009 Budgets in the amount of 5%. Buffers are used 

to accommodate the wide array of assumptions that are factored into the calculation process. 

Since assumptions change over time, it is necessary to have a buffer that will accommodate the 

impact of refined assumptions in the process. With the buffer applied to the 2009 Budget, the 

2009 total PM2.5 and NOx emissions remain well below the 2002 base year emissions. 

Therefore, a MVEB (7,186.77 tons/year NOx, 117.45 tons/year PM2.5) is established for 

transportation conformity purposes for the Kentucky portion of the Cincinnati- Middletown, OHKY-IN, PM2.5 nonattainment area for 2009. Upon USEPA’s affirmative adequacy finding for 

these MVEB’s, these MVEB’s will become the applicable MVEB’s. 

Huntington-Ashland, WV-KY-OH 

For PM2.5, the pollutant itself and all its various precursors typically would require analysis. 

However, as noted in the implementation rule, ammonia and volatile organic compounds - while 

recognized as such precursors - are not considered as significant overall to the nonattainment 

problem. Therefore, they are not considered as an attainment plan precursors for SIP 

development purposes. Further, other pollutants/precursors may be considered significant 

overall but the highway contribution to those emissions may be insignificant. In that case, the 

federal Transportation Conformity rule allows such pollutant/precursors to be exempt from 

conformity analysis under certain circumstances. 

40CFR93.109(k) Areas with insignificant motor vehicle emissions. 

Notwithstanding the other paragraphs in this section, an area is not required to 

satisfy a regional emissions analysis for §93.118 and/or §93.119 for a given 

pollutant/precursor and NAAQS, if EPA finds through the adequacy or approval 

process that a SIP demonstrates that regional motor vehicle emissions are an 

insignificant contributor to the air quality problem for that pollutant/precursor and 

NAAQS. The SIP would have to demonstrate that it would be unreasonable to 

expect that such an area would experience enough motor vehicle emissions 

growth in that pollutant/precursor for a NAAQS violation to occur. Such a finding 

would be based on a number of factors, including the percentage of motor vehicle 

emissions in the context of the total SIP inventory, the current state of air quality 

as determined by monitoring data for that NAAQS, the absence of SIP motor 

vehicle control measures, and historical trends and future projections of the 

growth of motor vehicle emissions... (emphasis added) 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 76 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

For the reasons outlined below, the KYDAQ is herein making a finding that regional highway 

emissions of PM2.5, NOx and SO2 are insignificant contributors to the nonattainment problem for 

the Huntington-Ashland area. The finding will become final if EPA concurs and approves this 

SIP. First, the regional highway pollutant/precursor emissions constitute a relatively small 

fraction of the overall emissions as shown in the tables below. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 77 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Table 8.2-3 Huntington-Ashland 2002 and 2009 NOx Emissions Inventories (tons per year) 

 NOx 2002 NOx 2009 

 Point Area Mobile Nonroad Total Point Area Mobile Nonroad Total 

KENTUCKY 

Boyd 7,045.88 40.00 1,213.00 3,319.05 11,617.93 7,281 46 774 3,107 11,208 

Lawrence 17,129.00 87.00 785.00 726.43 18,727.43 5,730 93 528 664 7,015 

KY Total 24,174.88 127.00 1,998.00 4,045.48 30,345.36 13,011 139 1,302 3,771 18,223 

KY Mobile/KY 

Portion 6.6% 7.1% 

KY Mobile/Entire 

Nonattainment 1.0% 1.8% 

WEST VIRGINIA 

Cabell 246.54 716.32 2,987.76 1,957.64 5,908.26 250 737 1633 1849 4469 

Mason 26,815.10 349.19 701.14 1,544.77 29,410.20 15238 377 439 1454 17507 

Wayne 3,313.09 174.29 1,089.34 3,049.67 7,626.39 2683 180 581 2962 6406 

WV Total 30,374.73 1,239.79 4,778.24 6,552.08 42,944.84 18170 1294 2653 6265 28381 

OHIO 

Adams 54,917.00 112.00 917.00 494.00 56,440.00 7393 123 544 458 8518 

Gallia 68,963.00 112.00 864.00 538.00 70,477.00 9437 125 514 469 10545 

Lawrence 0.00 216.00 2,336.00 1,037.00 3,589.00 180 241 1352 846 2619 

Scioto 755.00 220.00 1,991.00 1,706.00 4,672.00 497 242 1177 1302 3218 

OH Total 124,635.00 660.00 6,108.00 3,775.00 135,178.00 17507 731 3587 3075 24900 

Total Emissions 179,184.61 2,026.79 12,884.24 14,372.56 208,468.20 48,688.40 2,163.65 7,541.65 13,110.60 71,504.30 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 78 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Table 8.2-4 Huntington-Ashland 2002 and 2009 SOx Emissions Inventories (tons per year) 

SOx 2002 SOx 2009 

 Point Area Mobile Nonroad Total Point Area Mobile Nonroad Total 

KENTUCKY 

Boyd 9,711 542 54 482 10,789 10,432.00 578 6 380 11,396 

Lawrence 48,874 96 30 85 49,085 47,739.00 102 4 52 47,897 

KY Total 58,585 638 84 567 59,874 58,171.00 680 10 432 59,293 

KY Mobile/KY Portion 0.1% 0.02% 

KY Mobile/Entire 

Nonattainment 0.0% 0.0% 

WEST VIRGINIA 

Cabell 124 1420 122 112 1778 123 1528 13 19 1682 

Mason 85418 119 32 83 85652 56691 122 4 14 56830 

Wayne 288 479 48 162 977 277 517 5 34 832 

WV Total 85830 2018 203 356 88407 57091 2167 21 66 59345 

OHIO 

Adams 137,241 43 44 45 137373 22422 55 4 8 22489 

Gallia 106,286 37 42 45 106410 21807 50 4 8 21869 

Lawrence 0 70 112 86 268 0 94 11 15 120 

Scioto 25 77 96 137 335 918 108 9 25 1060 

OH Total 243552 227 294 313 244386 45147 307 28 56 45538 

Total Emissions 387966.64 2883 580.98 1236.41 392666.91 160,408.62 3,153.50 59.25 554.36 164,175.72 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 79 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Table 8.2-5 Huntington-Ashland 2002 and 2009 PM Emissions Inventories (tons per year) 

PM 2002 PM 2009 

 Point Area Mobile Nonroad Total Point Area Mobile Nonroad Total 

KENTUCKY 

Boyd 1,256 712 21 131 2,120 1,255 748 15 121 2,139 

Lawrence 335 216 14 30 595 413 219 10 28 670 

KY Total 1,591 928 35 161 2,715 1,668 967 25 149 2,809 

KY Mobile/KY Anthro 1.3% 0.9% 

KY Mobile/Entire Non 0.4% 0.2% 

WEST VIRGINIA 

Cabell 319 865 48 82 1315 339 857 31 74 1301 

Mason 237 391 12 70 710 287 380 9 60 735 

Wayne 50 523 18 125 717 54 485 11 114 664 

WV Total 607 1779 79 277 2743 680 1722 50 248 2701 

OHIO 

Adams 952 315 17 25 1309 3696 323 12 20 4051 

Gallia 670 226 16 22 934 3905 230 11 19 4165 

Lawrence 0 163 38 36 237 2 165 26 29 222 

Scioto 30 337 36 71 474 92 339 24 60 515 

OH Total 1652 1041 107 154 2954 7695 1057 73 128 8953 

Total Emissions 3849.86 3748.46 221.06 592.19 8411.57 10,043.39 3,746.17 148.38 525.00 14,462.94 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 80 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

From the above, it can be readily determined that the maximum highway contribution to 

emissions of NOx is less than eight percent (8%) in the attainment year 2009. The highway 

contribution to direct PM is less than one percent (1%) and SO2 is two one-hundredths of one 

percent (0.02%). Therefore, the KYDAQ has determined that the regional highway emissions 

contribution as a percent of the total SIP inventory is insignificant. 

Second, the current air quality (CY 2007) is represented by a design value of 14.7 μg/m3

. This 

value is slightly higher than the 14.3 μg/m3 design value upon which the nonattainment 

designation is based. The graph below shows the level of PM2.5 concentrations from the year 

2001 to date. The values dropped from 15.5 μg/m3

 in 2002 to 14.9 and 14.3 in 2003 and 2004, 

respectively. This may be attributed to an overall decrease in sulfates from SO2 reductions 

mandated by the Acid Rain Program and preliminary implementation of controls from the Clean 

Air Interstate Rule. The design value then fluctuated from 14.4 to 14.7 during the 2005-2007 

period. This fluctuation is due to the year-to-year variability in PM2.5, and it is common to many 

monitoring sites. Overall, the PM concentrations have improved since the beginning of the 

decade. The area is designated as attainment for all other criteria pollutants. 

Given the relatively small contribution of the highway emissions to the total SIP inventory, 

highway emissions are not likely to contribute significantly to the local PM2.5 mass 

concentrations. Among other factors, this is largely due to the dominance of sulfates in the 

overall PM mass. 

Boyd PM2.5 Design Value

14

14.5

15

15.5

00-02 01-03 02-04 03-05 04-06 05-07
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 81 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Third, historically there have been no Huntington-Ashland area SIP requirements for motor 

vehicle control measures. Boyd County and a portion of Greenup in the area is subject to 

Transportation Conformity for the 8-hour ozone standard, with SIP-approved, seasonal budgets 

for NOx and Volatile Organic Compounds (VOC). Further, the entire nonattainment area 

currently is subject to Transportation Conformity for the PM2.5 standard. Emissions analysis has 

been mandatory for annual highway emissions of direct PM and NOx. However, upon a positive 

adequacy review or approval of this SIP submittal, no highway emissions analysis will be 

required under the annual PM2.5 standard. Highway analysis of seasonal ozone precursors would 

continue to be mandatory. And, PM2.5 hot-spot analyses would continue to apply for required 

projects under 40 CFR 93.116 and 93.123(b) of the Transportation Conformity rule. 

Fourth, Ashland Area Metropolitan Planning Organization (Ashland MPO) has extensively 

researched the area local historical trends and growth patterns to develop the LRTP and support 

transportation conformity evaluations. There is no reason to expect highway motor vehicle 

emissions growth that would lead to a PM2.5 NAAQS violation. The Ashland MPO has estimated 

emissions out, at least, to the calendar year 2030 confirming this. The transportation air quality 

conformity analysis for the Ashland MPO area took into account all the regional capacity 

projects, which are scheduled for implementation through the transportation plan horizon year 

and the four year TIP. Note that after comparative runs were made by the Kentucky Division for 

Air Quality, the interagency consultation team (IAC) determined that there was insignificant 

difference in emission calculations using monthly, quarterly, semi-annual, or annual runs. The 

IAC determined the region would use an annual run using July as the analysis month. The PM 

conformity tests were performed for calendar years 2002, 2009, 2015, 2020, and 2030, for July. 

For each of those analysis years, vehicle miles traveled (VMT) and Speed were developed by the 

Federal Functional Class (FC) codes within Boyd County and Lawrence County for July, The 

Boyd County data were derived from the regional traffic model assignments that are made for 

each of those years. Lawrence County is not covered by a travel demand model and VMT and 

Speed were determined by KYTC. Pursuant to the Transportation Conformity interim tests, 

NOx and direct PM were evaluated. 

The Ashland MPO study area includes Boyd and Greenup counties. According to the 2000 

census, these counties combine for a population of 86,643, of which 56,446 is in the urbanized 

area. The study area includes the urban areas of Ashland, Cannonsburg, and Catlettsburg. The 

transportation plan is a comprehensive examination of the future transportation needs for Boyd 

and Greenup counties [KY]. The study area is 506.2 square miles, with Boyd County 

representing 160.1 square miles, with Greenup County representing 346.1 square miles. 

The PM2.5 nonattainment area consists of Boyd County of the Ashland Area MPO and the donut 

area which is a portion of Lawrence County. 

VMT forecasts for the nonattainment portion of Lawrence County were determined in the 

following manner: First, using the latest traffic count data from the Kentucky Highway 

Information System (HIS), VMT was determined for the specific roadways in the designated 

portion of Lawrence County, Kentucky - U.S. census 2000 block group identifier number 21-

127-9901-6. This VMT was summarized by FC codes. (Local mileage and VMT were 

calculated from the KYTC Highway Information System (HIS) data base.) Future years VMT 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 82 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

were estimated by using the Lawrence County projected VMT annual growth rate (taken from 

KYTC’s County Level VMT forecasts). 

VMT forecasts for Boyd County were determined in the following manner: VMT were 

determined for all analysis years using the regional travel demand model detailed in the report by 

The Corradino Group, “Ashland Travel Model”, December 2002. This travel demand model was 

developed using TransCAD, a Geographic Information System (GIS)-based model package. The 

traffic analysis zone structure is described in detail in the model documentation. The model as 

written produced output for 2025, 2020, and 2030. Socioeconomic data for 2009 and 2015 were 

added to the travel demand model and the model was run to determine adjusted VMT for 2009 

and 2015. 

The model is calibrated to a 2000 base year, and the socioeconomic data and trip tables used in 

the travel demand model were developed using the latest planning and land-use assumptions. 

These assumptions include land-use, population, housing, and employment data derived from the 

Ashland Municipal Planning Commission, the Cabinet for Economic Development, the FIVCO 

Area Development District, and the Kentucky State Data Center. 

Model output included VMT by roadway functional classes. The travel demand model VMT 

output was then reconciled to 2000 HPMS data because the original calibration of the travel 

demand model was performed against 2000 HPMS data. The four major model development 

tasks are listed as follows: 

1. Developing Highway Network System and Related Attributes. 

2. Developing Traffic Analysis Zone [TAZ] System and Related Attributes. 

3. Deriving Internal-Internal, External-Internal, and External-External Trips. 

4. Model Calibration and Validation. 

The output by the regional travel demand model was input to the MOBILE6.2 emissions model 

for developing the roadway class-specific emission factors for the base year. These emissions 

factors were combined with the HPMS-adjusted VMT estimates to compute on-road emissions 

for each roadway class. The resulting emissions estimates were then summed to compute total 

regional emissions from on-road motor vehicles. 

For each future year of interest (i.e., analysis year), the regional travel model must first be used 

to develop roadway-class specific VMT estimates. These estimates are then compared to the base 

year VMT estimates output by the travel model, to develop roadway-class specific growth rates. 

The base year HPMS-adjusted VMT estimates above are then multiplied by these growth rates to 

compute future year HPMS-adjusted VMT estimates. 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 83 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Similar to the base year computation methodology, congested speeds output by the model were 

input to MOBILE to develop roadway class-specific emissions factors. The HPMS-adjusted 

VMT estimates for each roadway class were then multiplied by the emissions factors output by 

MOBILE, and the resulting emissions estimates summed across all roadway classes to compute 

total regional on-road emissions. The process was followed for each selected analysis year. The 

above example provides one approach to computing HPMS-adjusted VMT estimates for each 

analysis year and scenario. There are, however, a number of other variations that could be 

pursued depending on the robustness of the available data and desired level of analysis. 

Table 8.2-6 shows the Daily VMT (DVMT) for the model area for the years 2002, 2009, 2015, 

2020, and 2030. Appendix A [of the report] lists the VMT by facility type for all the above-listed 

years. 

Table 8.2-6. 

County Name Year 

Daily VMT 

(DVMT)

Boyd 2002 1,375,000 

Lawrence (partial) 2002 96,111 

2002 Total 1,471,111

 

Boyd 2009 1,598,133 

Lawrence (partial) 2009 108,730 

2009 Total 1,706,863

 

Boyd 2015 1,606,467 

Lawrence (partial) 2015 126,013 

2015 Total 1,732,480

 

Boyd 2020 1,918,593 

Lawrence (partial) 2020 136,851 

2020 Total 2,055,444

 

Boyd 2030 2,213,597 

Lawrence (partial) 2030 157,974 

2030 Total 2,371,571

In June 2005, EPA clarified how transportation conformity was determined in non-contiguous 

PM2.5 non-attainment areas. EPA’s clarification was as follows: 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 84 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

Noncontiguous PM2.5 nonattainment areas (NNAs) are areas that contain “satellite 

portions” that are not contiguous with the main portion of the nonattainment area. 

These satellite areas are designated as part of the overall nonattainment area 

because they have a point source which contributes, via transport, to the air 

quality problems of the main geographic portion of the PM2.5 nonattainment area. 

We believe that the satellite portions of NNAs best fit the definition of a donut 

area for transportation conformity purposes. Section 93.101 of the conformity rule 

defines “donut areas“ as “geographic areas outside a metropolitan planning area 

boundary, but inside the boundary of a nonattainment or maintenance area that 

contains any part of a metropolitan area(s). These areas are not isolated rural 

nonattainment and maintenance areas. 

The conformity guidance for “donut” areas was entitled Companion Guidance for the July 1, 

2004, Final Transportation Conformity Rule: Conformity Implementation in Multi-jurisdictional 

Nonattainment and Maintenance Areas for Existing and New Air Quality Standards. The partial 

county of Lawrence is thus considered a “donut area” for planning purposes. As part of the PM2.5 

Air Quality analysis, a small portion of Lawrence County [KY] was added to the Boyd County 

area as a “donut”. In this “donut” area there are roads with different classifications. The KYTC 

provided the Ashland Area MPO with the VMT on these roads [in the “donut area”] for the 

analysis years listed above as described in the methodology above. 

The donut area emissions were determined based on the Functional Class VMT and associated 

emission factors as determined from MOBILE 6.2. 

The socio-economic factors were accounted for in Boyd County in the travel demand model as 

described above. Forecasted population growth for the nonattainment portion of Lawrence was 

accounted for based on Kentucky Data Center (KDC) census forecasts. 

Input files were developed for modeling mobile emissions with the Mobile6.2 software by using 

the VMT split by functional class. The assumptions related to the derivation of model inputs 

were developed as part of an interagency consultation process involving the following agencies: 

• KYOVA Interstate Planning Commission. 

• Ashland Area MPO. 

• West Virginia Department of Transportation. 

• West Virginia Division of Air Quality 

• Kentucky Transportation Cabinet 

• Kentucky Division for Air Quality 

• Ohio Department of Transportation 

• Ohio EPA 

• Federal Highway Administration 

• Federal Transit Authority 

• U.S. EPA. 

 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 85 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

The results of the Mobile6.2 analysis yields mobile emission rates that can be used along with 

the DVMT by functional class of roadway to derive estimates of total mobile source emissions 

for nitrogen oxides (NOx) and PM2.5. The conformity results are represented in Table 8.2-7. The 

conformity rule required the region’s LRTP to conform to the SIP before FHWA approves the 

funding of future projects. The conformity evaluation is determined by the processes outlined in 

the conformity rule The Ashland Area PM2.5 non-attainment area, in conjunction with the entire 

Huntington-Ashland PM2.5 non-attainment area, has demonstrated conformity with the PM2.5 

transportation conformity rule using the base year interim emissions test. 

Table 8.2-7. 

Ashland PM2.5 Area Alone (Boyd and partial Lawrence) 

Year 

NOx 

(tpd) 

PM2.5 

(tpd) 

NOx 

(Annual) 

% Change 

from base 

PM2.5 

(Annual) 

% Change 

from base 

2002 4.066 0.083 1,484.09 na 30.295 na 

2009 2.609 0.057 952.29 -35.83% 20.805 -31.33% 

2015 1.398 0.037 510.27 -65.62% 13.505 -55.42% 

2020 1.142 0.038 416.83 -71.91% 13.870 -54.22% 

2030 0.905 0.040 330.33 -77.74% 14.600 -51.81% 

Entire Huntington-Ashland PM2.5 Area 

Year 

NOx 

(tpd) 

PM2.5 

(tpd) 

NOx 

(Annual) 

% Change 

from base 

PM2.5 

(Annual) 

% Change 

from base 

2002 5.456 1.753 1,991.44 na 639.845 na 

2009 3.929 1.057 1,434.09 -27.99% 385.805 -39.70% 

2015 2.228 0.697 813.22 -59.16% 254.405 -60.24% 

2020 1.512 0.448 551.88 -72.29% 163.520 -74.44% 

2030 1.215 0.420 443.48 -77.73% 153.300 -76.04% 
The Cincinnati-Middletown, OH-KY-IN, Huntington-Ashland, WV-KY-OH, 86 

and Louisville, KY-IN, PM2.5 

Final Kentucky Attainment Demonstration November 2008 

The forecasts clearly show that, despite any anticipated growth in the area, significant decreases 

in highway emissions are expected for all analysis years, for both NOx and direct PM. The 

interim conformity tests do not require evaluation of SO2. However, federal heavy duty diesel 

engine standards and low-sulfur fuel requirements are also expected to yield substantial emission 

decreases commensurate with those shown above. Therefore, the Kentucky DAQ reiterates its 

conclusion that highway emissions of PM2.5, NOx, and SO2 are insignificant contributors to the 

nonattainment problem for the Ashland area and are therefore exempt from transportation 

conformity evaluation under 40CFR93.109(k). 

9.0 REFERENCES 

Frank, N. H. Retained Nitrate, Hydrated Sulfates, and Carbonaceous Mass in Federal Reference 

Method Fine Particulate Matter for Six Eastern U.S. Cities. J. Air & Waste Manage. Assoc. 2006

56:500–511. 

Tesche, T.W., et al. Operational Evaluation of the MM5 Meteorological Model Over the 

Continental United States: Protocol for Annual and Episodic Evaluation. Office of Air Quality 

Planning and Standards. AG-TS-90/158. July 2002. 

USEPA Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of 

Air Quality Goals for Ozone, PM2.5, and Regional Haze. EPA -454/B-07-002. April 2007.