0 I Environmental 

Protection Agency 

John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Scott J. Nally, Director 

FEB 2.9 ZOIZ 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA Region 5 

77 W. Jackson Blvd. 

Chicago, IL 60604 

Re: PM2_5 redesignation Request for the 1997 PM2_5 Annual Standard for the 

Parkersburg-Marietta Area 

Dear Administrator Hedman: 

I am writing to formally request a redesignation to attainment of the Ohio portion of the 

Parkersburg-Marietta area (Washington County, Ohio) with respect to the 1997 PM2_5 

annual standard. The enclosed submittal combines the redesignation request and the 

required maintenance plan for this area. 

Monitoring of existing air quality indicates that the 1997 National Ambient Air Quality 

Standard (NAAQS) for PM2.s has been attained throughout this area based on 2008-

2010 air quality data. Emissions projections indicate that current controls, existing State 

rules, existing federal rules, and Ohio's PSD program will be more than sufficient to 

maintain the NAAQS indefinitely into the future. These programs will, therefore, 

constitute the attainment and maintenance plan for the Parkersburg-Marietta area. 

The enclosed information, compiled by the Ohio Environmental Protection Agency (Ohio 

EPA) in cooperation with the Ohio Department of Transportation (Ohio DOT), the West 

Virginia Department of Environmental Protection (WVDEP), and the West Virginia 

Department of Transportation (WVDOT), shows significant emission reductions in point 

and mobile sources since ambient exceedances have occurred. A significant portion of 

the improved air quality can be attributed to federal programs for the mobile source 

sector, the regional reductions associated with the NOx Trading Program, and the 

Clean Air Interstate Rule (CAIR). 

Ohio EPA notified the public of the draft and the opportunity to provide comments on 

January 12, 2012. This notice was also published in a newspaper of general circulation 

in Marietta, Ohio on January 17, 2012. The public hearing for this package was held on 

50 West Town Street, Suite 700 

P.O. Box 1049 

Columbus, OH 43216-1049 

614 I 644 3020 

614 I 644 3184 (fax) 

www.epa.ohio.gov 
February 16, 2012 in Marietta, Ohio. No testimony was provided, nor were any 

comments received. 

If you have questions, please contact Jennifer Dines in our Division of Air Pollution 

Control at (614) 644-3696. 

Sincerely, 

r~ Scott J. Nally 

Director 

Cc: Bob Hodanbosi, Chief, Division of Air Pollution Control, Ohio EPA 

Enclosure 
 

REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR THE OHIO 

PORTION OF 

THE PARKERSBURG-MARIETTA, WV-OH 

ANNUAL PM2.5 

NONATTAINMENT AREA 

Washington County, Ohio 

Prepared by: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

February 2012
 

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 i 

TABLE OF CONTENTS 

Chapter One 

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

Geographical description and background ................................................................................... 2 

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

Chapter Two 

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

Chapter Three 

PM2.5 monitoring ............................................................................................................................ 8 

Annual PM2.5 NAAQS .................................................................................................................... 8 

Ambient data quality assured ........................................................................................................ 9 

Three complete years of data ....................................................................................................... 9 

Commitment to continue monitoring ........................................................................................... 12 

Chapter Four 

Emission inventory ...................................................................................................................... 13 

Base year inventory .................................................................................................................... 13 

Emission projections ................................................................................................................... 14 

Demonstration of maintenance ................................................................................................... 22 

Permanent and enforceable emissions reductions ..................................................................... 31 

Provisions for future update ........................................................................................................ 32 

Chapter Five 

Control measures and regulations .............................................................................................. 33 

Nonattainment areas to implement RACM and RACT ................................................................ 33 

Show Reasonable Further Progress (RFP) ................................................................................ 35 

Emission inventories ................................................................................................................... 35 

Implementation of past SIP revisions .......................................................................................... 36 

New source review provisions ................................................................................................... 38 

Assurance of continued controls ................................................................................................. 39 

Chapter Six 

Contingency measures ............................................................................................................... 40 

Commitment to revise plan ......................................................................................................... 40 

Commitment for contingency measures ..................................................................................... 40 

Potential contingency measures ................................................................................................. 41 

List of PM2.5, SO2, and NOx sources ........................................................................................... 42 

Chapter Seven 

Public participation ...................................................................................................................... 43 

Chapter Eight 

Conclusions ................................................................................................................................ 44 
 ii 

FIGURES 

Figure 1 Map of the Parkersburg-Marietta, WV-OH, nonattainment area and monitor 

locations ................................................................................................................... 9 

Figure 2 PM2.5 Annual Mean Trends LADCO States ............................................................ 11 

Figure 3 PM2.5 Annual Mean Trends Midwest States ........................................................... 11 

Figure 4 PM2.5 Annual Mean National Trends ..................................................................... 12 

TABLES 

Table 1 Monitoring Data for Parkersburg-Marietta, WV-OH area for 2008 – 2010 ............. 10 

Table 2 Washington County, Ohio Emission Estimations for On-road Mobile Sources ...... 19 

Table 3 Summary of Ohio Emissions Estimations for On-road Mobile Sources ................. 20 

Table 4 Wood County, West Virginia Emission Estimations for On-road Mobile 

 Sources ................................................................................................................. 20

Table 5 Pleasants County (partial only), West Virginia Emission Estimations for 

 On-road Mobile Sources ........................................................................................ 20 

Table 6 Summary of West Virginia Emission Estimations for On-Road Mobile Sources .... 20 

Table 7 Emission Estimations Totals for On-road Mobile Sources for the 

 Parkersburg-Marietta Area ..................................................................................... 20 

Table 8 Percent of Mobile Emissions for the Parkersburg-Marietta Area in 2015 and 

2022 – With Apportionment Analysis for partial nonattainment areas ........ 21

Table 9 Reductions in SO2 and NOx EGU Emissions Between 2008 and 2009. ................ 24 

Table 10 Reductions in SO2 and NOx EGU Emissions Between the First Half of 2008 

 and 2010.... ............................................................................................................ 24 

Table 11 Washington County, Ohio PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. .................. 26 

Table 12 Wood County, West Virginia PM2.5 Emission Inventory Totals for Base Year 

 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR. ......... 26 

Table 13 Pleasants County, West Virginia PM2.5 Emission Inventory Totals for Base Year 

 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .......... 27 

Table 14 Parkersburg-Marietta Area PM2.5 Emission Inventory Totals for Base Year 2005, 

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

With CSAPR (West Virginia). ................................................................................. 27 

Table 15 Washington County, Ohio NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ........................ 27 

Table 16 Wood County, West Virginia NOx Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .................... 28 

Table 17 Pleasants County, West Virginia NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .......... 28 

Table 18 Parkersburg-Marietta Area NOx Emission Inventory Totals for Base Year 2005, 

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

With CSAPR (West Virginia). ................................................................................. 28 

Table 19 Washington County, Ohio SO2 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ........................ 29 

Table 20 Wood County, West Virginia SO2 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .................... 29 

Table 21 Pleasants County, West Virginia SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CSAPR .......... 29 
 iii 

Table 22 Parkersburg-Marietta Area SO2 Emission Inventory Totals for Base Year 2005, 

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

With CSAPR (West Virginia) .................................................................................. 30 

Table 23 Parkersburg-Marietta Area Comparison of 2008 Attainment Year and 2015 and 

2022 Projected Emission Estimates (tpy) ............................................................... 30 

Table 24 Parkersburg-Marietta Area Combined Comparison of 2005 Base Year and 2008 

Attainment Year On-Road and EGU Reductions ................................................... 31 

APPENDICES 

A Air Quality System (AQS) Data 

B Ohio 2005 SIP Base Year Inventory Discussion 

C Mobile Source Emissions Inventory for the Parkersburg-Marietta PM2.5 Nonattainment 

Area

D LADCO Technical Support Documents 

E Analysis of Insignificance of Mobile Emissions 

F Public Participation Documentation 
 iv 

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REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO 

PORTION OF THE PARKERSBURG-MARIETTA 

ANNUAL PM2.5 NONATTAINMENT AREA 

Washington County, Ohio 

CHAPTER ONE 

Introduction 

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

meet the annual PM2.5

1

 National Ambient Air Quality Standard (NAAQS) to 

develop State Implementation Plans (SIPs) to expeditiously attain and maintain 

the standard. The United States Environmental Protection Agency (U.S. EPA) 

revised the NAAQS for particulate matter in July 1997. It replaced the existing 

PM10 standard with a health-based PM2.5 standard and retained the PM10

standard as a particulate standard protecting welfare. The standards include an 

annual standard set at 15.0 micrograms per cubic meter (μg/m3), based on the 

3-year average of annual mean PM2.5 concentrations and a 24-hour standard of 

65 μg/m3

, based on the 3-year average of the 98th percentile of 24-hour 

concentrations. 

The revised NAAQS was legally challenged in the U.S. Court of Appeals for the 

District of Columbia Circuit (the D.C. Circuit). On May 14, 1999, the D.C. Circuit 

remanded, without vacatur, the standard back to U.S. EPA. The remand did not 

question the level at which U.S. EPA set the standards but rather the 

constitutionality of the CAA provision that authorizes U.S. EPA to set national air 

quality standards. U.S. EPA requested a rehearing which the D.C. Circuit 

denied. Therefore, in December 1999, U.S. EPA appealed the D.C. Circuit 

decision to the U.S. Supreme Court. The U.S. Supreme Court issued a decision 

on February 27, 2001 that unanimously affirmed the constitutionality of the CAA 

provision but did remand several other issues back to the D.C. Circuit, including 

the issue of whether U.S. EPA acted arbitrarily and capriciously in establishing 

the specific levels of the standards. 

The D.C. Circuit heard arguments in this remanded case in December 2001, and 

issued its decision on March 26, 2002. The D.C. Circuit rejected the claims that 

the U.S. EPA had acted arbitrarily and capriciously in setting the levels of the 

standards. 

 

1 Particle pollution is a mixture of microscopic solids and liquid droplets suspended in air. This pollution, also 

known as particulate matter, is made up of a number of components, including acids (such as nitrates and 

sulfates), organic chemicals, metals, soil or dust particles, and allergens (such as fragments of pollen or 

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

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

secondarily in the atmosphere. 
 2 

On December 17, 2004, U.S. EPA promulgated the initial PM2.5 nonattainment 

areas designations for the PM2.5 standards across the country. Modifications to 

those designations were made and an effective date was set at April 5, 2005. 

Unlike Subpart 2 of the CAA Amendments of 1990 which defined five ozone 

nonattainment classifications for the areas that exceed the NAAQS based on the 

severity of the ozone levels, PM2.5 nonattainment designations are simply 

labeled “nonattainment.” The CAA Amendments require states with PM2.5

nonattainment areas to submit a plan within three years of the effective date of 

the designations (April 5, 2008) detailing how the PM2.5 standards will be 

attained by April 5, 2010. Ohio EPA submitted its attainment demonstration for 

the entire State of Ohio on July 16, 2008. 

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

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

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

nonattainment to attainment: 

• A determination that the area has attained the PM2.5 standard.

• An approved State Implementation Plan (SIP) for the area under 

Section 110(k).

• A determination that the improvement in air quality is due to 

permanent and enforceable reductions in emissions resulting 

from implementation of the SIP and other federal requirements.

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

• A determination that all Section 110 and Part D requirements 

have been met. 

This document addresses each of these requirements, and provides additional 

information to support continued compliance with the annual PM2.5 standard. 

 

Geographical Description and Background 

The current Parkersburg-Marietta nonattainment area is located in south-eastern 

Ohio and includes the following counties: Washington in Ohio; and Pleasants 

(partial nonattainment of Grant Tax district) and Wood in West Virginia. This area 

is shown in Figure 1 under Chapter Three. 

 The Parkersburg-Marietta area has not previously been subject to nonattainment 

area rulemakings for fine particles. 

As a result of the 2005 PM2.5 designations, U.S. EPA designated the 

Parkersburg-Marietta area nonattainment for the 15.0 μg/m3 annual standard2

, 

and Ohio EPA was required to develop a plan to reduce oxides of nitrogen 

(NOx), sulfur dioxide (SO2) and direct PM2.5 emissions and to demonstrate that 

 

2 There were no monitors in Ohio that violated the 1997 24-hour PM2.5 standard of 65μg/m3. 
 3 

the area will meet the federal annual air quality standard by April 5, 2010. Ohio’s 

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

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

demonstration analysis. Volatile organic compounds (VOCs) and ammonia 

(NH3) were not included in the analysis since they were not part of Ohio’s 

current attainment strategy for PM2.5 (although controls for VOCs have been 

implemented for ozone nonattainment). This is consistent with U.S. EPA’s “Clean 

Air Particle Implementation Rule” [74FR 20856] (hereafter referred to as 

“Implementation Rule”). In the Implementation Rule U.S. EPA presumes NH3 

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

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

demonstration that emissions of VOCs significantly contribute to nonattainment 

of the annual PM2.5 standard. 

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

Parkersburg-Marietta area be redesignated from nonattainment to attainment for 

the annual PM2.5 standard. In addition, the State of West Virginia may also 

submit a request for their respective portions of the Parkersburg-Marietta area. 

Status of Air Quality 

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

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

met the NAAQS for annual PM2.5 in this nonattainment area. The NAAQS 

attainment, accompanied by decreases in emission levels discussed in Chapter 

Four, supports a redesignation to attainment for the Parkersburg-Marietta area 

based on the requirements in Section 107(d)(3)(E) of the CAA as amended. 
 4 

CHAPTER TWO 

Requirements for Redesignation 

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

Processing Requests to Redesignate Areas to Attainment (redesignation 

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

redesignation request and maintenance plan are based on the redesignation 

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

EPA Region 5. 

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

Parkersburg-Marietta area. 

i.) Attainment of the standard (CAA Section 107(d)(3)(E)(i)) 

 There are two components involved in making this demonstration. 

 The first component relies on ambient air quality data. The data 

that are used to demonstrate attainment should be the product of 

ambient monitoring that is representative of the area of highest 

concentration. The data should be collected and quality-assured in 

accordance with 40 CFR 58 and recorded in the Air Quality 

System (AQS)in order for it to be available to the public for review. 

 The second component relies upon supplemental U.S. EPAapproved air quality modeling. While no modeling is required for 

redesignating nonattainment areas, the redesignation guidance 

states it is “generally necessary” for particulate matter 

redesignations. Appendix C and Appendix D contains the most 

recent modeling results showing future attainment and 

maintenance are provided. Chapter Three discusses this 

requirement in more detail and provides the attainment 

demonstration. 

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

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

 The state must be able to reasonably attribute the improvement in 

air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures that 

have been adopted and implemented by the state. 

It was not necessary for Ohio to adopt or implement control 

measures for these counties beyond the federal measures. 

Ohio EPA has adopted several rules recently that will have an 

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

• Clean Air Interstate Rule (CAIR) 

• NOx SIP Call Rules 

Ohio was also subject to a Federal Implementation Plan under the 

CAIR replacement rule, the Cross-State Air Pollution Rule 

(CSAPR) that could have resulted in even greater reductions than 

the CAIR program. However, on December 30, 2011, the D.C. 

Circuit Court stayed CSAPR and ordered U.S. EPA to continue 

administering CAIR pending the court’s resolution. 

In addition, since the initial designations were made federally 

enforceable consent decrees have resulted in reductions in 

emissions from utilities within Washington County and across the 

state, including this area. 

 Chapters Four and Five discuss this requirement in more detail. 

iii.) Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v)) 

 For purposes of redesignation, a state must meet all requirements 

of Section 110 and Part D that were applicable prior to submittal of 

the complete redesignation request. 

 Subpart 1 of Part D consists of general requirements applicable to 

all areas which are designated nonattainment based on a violation 

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

requirements applicable to particulate matter (specifically to 

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

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

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

implementing PM2.5.[72 FR 20589] 

Section 110(a) requirements 

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

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

implementation plan submitted by a state must have been 

adopted by the state after reasonable public notice and 

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

enforceable emission limitations and other control 

measures, means or techniques necessary to meet the 

requirements of the CAA; provide for establishment and 

operation of appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 

provide for implementation of a source permit program to 

regulate the modification and construction of any stationary 

source within the areas covered by the plan; include 

provisions for the implementation of Part C, prevention of 
 6 

significant deterioration (PSD) and Part D, NSR permit 

programs; include criteria for stationary source emission 

control measures, monitoring, and reporting; include 

provisions for air quality modeling; and provide for public 

and local agency participation in planning and emission 

control rule development. In Ohio’s December 5, 2007 and 

September 4, 2009 infrastructure SIP submissions, Ohio 

verified that the State fulfills the requirements of Section 

110(a)(2) of the Act. 

Section 110(a)(2)(D) also requires State plans to prohibit 

emissions from within the State which contribute 

significantly to nonattainment or maintenance areas in any 

other State, or which interfere with programs under Part C 

to prevent significant deterioration of air quality or to 

achieve reasonable progress toward the national visibility 

goal for Federal class I areas (national parks and 

wilderness areas). In order to assist States in addressing 

their obligations regarding regionally transported pollution, 

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

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

the requirements of the federal CAIR to reduce NOx and 

SO2 emissions contributing to downwind states. On 

February 1, 2008, U.S. EPA approved Ohio’s CAIR 

program, which can be found in Ohio Administrative Code 

(OAC) Chapter 3745-1093. On July 6, 2011, U.S. EPA 

finalized a replacement to the CAIR program, the CSAPR. 

CSAPR could further assist States in addressing their 

obligations regarding regionally transported pollution by 

providing reductions in NOx and SO2 emissions in 2012 and 

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

Court stayed CSAPR and ordered U.S. EPA to continue 

administering CAIR pending the court’s resolution. 

iv.) Section 172(c) requirements 

 This Section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for 

an emission inventory will be satisfied by the inventory requirements 

of the maintenance plan. Chapters Four and Five discuss this 

requirement in more detail. 

 

3 http://www.epa.ohio.gov/dapc/regs/regs.aspx#3745-109 
 7 

v.) Conformity 

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

are consistent with the Section 176(c)(4) conformity requirements. 

The redesignation request should include conformity procedures, if 

the state already has these procedures in place. If a state does not 

have conformity procedures in place at the time that it submits a 

redesignation request, the state must commit to follow U.S. EPA’s 

conformity regulation upon issuance, as applicable. 

vi.) Maintenance plans (CAA Section 107(d)(3)(E)(iv)) 

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

U.S. EPA must fully approve a maintenance plan that meets the 

requirements of Section 175(A). The maintenance plan will 

constitute a SIP revision and must provide for maintenance of the 

relevant NAAQS in the area for at least 10 years after redesignation. 

 Section 175 (A) further states that the plan shall contain such 

additional measures, if any, as may be necessary to ensure such 

maintenance. 

 In addition, the maintenance plan shall contain such contingency 

measures as the Administrator deems necessary to ensure prompt 

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

contingency measures must include a requirement that the state will 

implement all measures contained in the nonattainment SIP prior to 

redesignation. 

States seeking redesignation of a nonattainment area should 

consider the following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 Chapter Six discusses this requirement in more detail. 
 8 

CHAPTER THREE 

PM2.5 MONITORING 

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

Requirement 1 of 4 

A demonstration that the NAAQS for annual PM2.5, as published in 40 CFR 50.7, 

has been attained. 

Background

 There is one monitor measuring PM2.5 concentrations in this 

nonattainment area located in Wood County, West Virginia. This 

monitor is operated by the WVDAQ (West Virginia Division of Air 

Quality). A listing of the design values based on the three-year 

average of the annual mean concentrations from 2008 through 

2010 is shown in Table 1. The location of the monitoring site for 

this nonattainment area is shown on Figure 1. 
 9 

Demonstration

 

Figure 1 - Map of the Parkersburg-Marietta, WV-OH nonattainment area 

and monitor locations 

Requirement 2 of 4 

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

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

public view. 

Demonstration

West Virginia has quality assured all data shown in Appendix A in 

accordance with 40 CFR 58.10 and all other federal requirements. West 

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

data are available to the public. 

Requirement 3 of 4 

A showing that the three-year average of the annual mean values, based on 

data from the monitoring site in the area or its affected downwind environs, are 

below 15.0 μg/m3

. (This showing must rely on three complete, consecutive 

calendar years of quality assured data.) 
 10 

Background 

The following information is taken from U.S. EPA's "Guideline 

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

 In accordance with the CAA Amendments, three complete years of 

monitoring data are required to demonstrate attainment at a 

monitoring site. The annual PM2.5 primary and secondary ambient 

air quality standards are met at an ambient air quality monitoring 

site when the three-year average of the annual average is less 

than 15.0 μg/m3. While calculating design values, three significant 

digits must be carried in the computations, with final values 

rounded to the nearest 0.1 μg/m3. Decimals 0.05 or greater are 

rounded up, and those less than 0.05 are rounded down, so that 

15.049 μg/m3 is the largest concentration that is less than, or equal 

to 15.0 μg/m3

. Values at or below 15.0 μg/m3 meet the standard; 

values equal to or greater than 15.1 μg/m3 exceed the standard. 

An area is in compliance with the annual PM2.5 NAAQS only if 

every monitoring site in the area meets the NAAQS. An individual 

site's 3-year average of the annual average concentrations is also 

called the site's design value. The air quality design value for the 

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

Table 1 shows the monitoring data for 2008 – 2010 that were 

retrieved from the U.S. EPA AQS. 

Demonstration

Table 1 - Monitoring Data for the Parkersburg-Marietta, WV-OH 

area for 2008 – 2010 

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

The design value calculated for the Parkersburg-Marietta area 

demonstrates that the annual PM2.5 NAAQS has been attained. The 

area's design value has trended downward as emissions have declined 

due to such factors as cleaner automobiles and fuels, and controls for 

EGUs, at the national, regional and local level. 

National monitoring for PM2.5 began in 1999. With respect to each of the 

Average

2008 2009 2010 2008-2010

54-029-1002 Wood, WV 13.8 12.0 13.4 13.1

Less than 75% capture in at least one quarter

Annual Standard

Site County

Year
 11 

Lake Michigan Air Directors Consortium (LADCO) states, there has been 

a clear downward trend in design values: 

Figure 2 - PM2.5 Annual Mean Trends LADCO States 

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

The same trend can be seen within the Midwest States as a whole: 

Figure 3 - PM2.5 Annual Mean Trends Midwest States 

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

Design values have also trended downward nationally: 
 12 

Figure 4 - PM2.5 Annual Mean National Trends 

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

Requirement 4 of 4 

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

appropriate monitoring network to verify the maintenance of the attainment 

status. 

Demonstration

 Ohio EPA does not currently operate any monitors in this area. 

Ohio EPA will consult with U.S. EPA Region 5 prior to making 

changes to the existing monitoring network, should changes 

become necessary in the future. 
 13 

CHAPTER FOUR 

EMISSION INVENTORY

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

U.S. EPA’s redesignation guidance requires the submittal of a comprehensive 

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

matter, and elemental carbon), SO2 and NOx

4

) representative of the year when 

the area achieves attainment of the annual PM2.5 air quality standard. Ohio also 

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

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

permanent and enforceable emission reductions. Other emission inventory 

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

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

of emissions is sufficient to maintain the annual PM2.5 standard; and a 

commitment to provide future updates of the inventory to enable tracking of 

emission levels during the 10-year maintenance period. 

The emissions inventory development and emissions projection discussion 

below, with the exception of the mobile (on-road) emissions inventory and 

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

emissions from Ohio’s portion of the Parkersburg-Marietta area. Specific 

emissions data are provided for all counties, including those in Ohio and West 

Virginia. West Virginia emissions data were obtained though the West Virginia 

Department of Environmental Protection (WVDEP). All of these inventories and 

emissions projections were prepared using similar methodologies, unless 

otherwise noted. Mobile emissions inventories and projections for all counties 

were prepared by the Wood-Washington-Wirt Interstate Planning Commission 

(WWW) and the Ohio Department of Transportation (ODOT), with data provided 

by Ohio EPA, West Virginia Department of Transportation (WVDOT), and 

WVDEP. 

Requirement 1 of 5 

A comprehensive emission inventory of PM2.5, SO2 and NOx completed for the 

base year. 

Background

The 2005 periodic inventory has been identified as one of the 

preferred databases for SIP development and coincides with 

nonattainment air quality in the Parkersburg-Marietta area. 

Periodic inventories, which include emissions from all sectors are 

prepared every three years by Ohio EPA. Ohio’s 2005 emissions 

 

4 VOC and NH3 are not addressed. 
 14 

data for all sources (Electrical Generating Unit (EGU-Point); NonElectrical Generating Unit (Non-EGU); Non-road Mobile (Nonroad); Other Area (Area); and Marine; Aircraft; Rail (MAR)) are 

derived from this inventory. Ohio’s point source data derived from 

this periodic inventory is actual source reported emissions under 

Ohio's annual emissions reporting program. 

West Virginia’s point source data are taken from U.S. EPA’s 

CSAPR estimates (EGU) and actual reported data under West 

Virginia’s emissions reporting program (non-EGUs). West 

Virginia’s emissions data for MAR and Area is derived from the 

2005 National Emissions Inventory (NEI) while Non-road 

emissions are derived from NONROAD modeling conducted by 

WVDAQ.

Demonstration

Ohio’s 2005 inventory is used as the base year for the purpose of 

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

attainment demonstration SIP submitted on July 18, 2008 and 

revised on June 7, 2010. The detailed emission inventory 

information for Ohio’s portion of the Parkersburg-Marietta area is 

provided in Appendix B. Emissions of PM2.5, SO2 and NOx for 

2005 are identified under Requirement Three of this Chapter. 

Requirement 2 of 5 

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

redesignation. 

Background

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

Parkersburg-Marietta area including area, mobile, and point sources for 

PM2.5, SO2 and NOx for base year 2005. The 2005 inventory was 

submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM2.5

attainment demonstration SIP for this area. The information below 

describes the procedures Ohio EPA used to generate the 2005 base year 

inventory and to develop SIP-ready modeling inventories and future year 

projections (Pechan Report5) based on a 2005 base year inventory. The 

report by Pechan generated future year estimates of annual emissions for 

each source sector using accepted growth surrogates. These inventories 

were provided to the LADCO and have been processed to develop 

average daily emissions for use in the air quality analyses. These 

 

5 

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

trols%20Report_Final.pdf 
 15 

processed modeling inventories have been identified as the correct 

iteration of the inventory for use in the redesignation. In this document, 

references to LADCO include the Midwest Regional Planning 

Organization. Note, that the on-road mobile source sector was addressed 

by specific modeling as discussed below. 

• Area source and MAR emissions were taken from the Ohio 

2005 periodic inventory submitted to U.S. EPA. These 

projections were made from the U.S. Department of 

Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information. 

• Mobile source emissions were calculated from 

MOVES2010 produced emission factors. In Ohio’s July 6, 

2008 PM2.5 Attainment Demonstration SIP6

, Ohio found that 

the regional highway emissions of PM2.5, NOx, and SO2 

were insignificant contributors to the nonattainment 

problems and, therefore, none of the three pollutants 

necessitated emissions inventory analysis. As documented 

in Ohio EPA’s attainment demonstration SIP, Ohio EPA in 

consultation with U.S. EPA determined that the 

Parkersburg-Marietta nonattainment area is not significantly 

impacted by on-road mobile emissions as compared to 

other source emissions; in addition, mobile source 

emissions in the area were expected to decrease. Based 

on the results of mobile source emission projections 

prepared as a part of this redesignation and maintenance 

plan, Ohio EPA is again making a finding that the regional 

highway emissions of PM2.5, NOx, and SO2 continue to be 

insignificant contributor to the nonattainment problems in 

this area, as discussed below. 

• Point source information was compiled from Ohio EPA’s 

2005 annual emissions inventory database and the 2005 

U.S. EPA Air Markets acid rain database7. 

• Biogenic emissions are not included in these summaries. 

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

National Mobile Inventory Model (NMIM) 2002 application. 

To address concerns about the accuracy of some of the 

categories in U.S. EPA’s non-road emissions model, 

LADCO contracted with two (2) companies to review the 

base data and make recommendations. One of the 

contractors also estimated emissions for three (3) non-road 

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

Emissions were estimated for aircraft, commercial marine 

 

6 http://www.epa.ohio.gov/portals/27/SIP/Attain/PM2_5/PM25Doc.pdf 

7 http://www.epa.gov/airmarkets/acidrain 
 16 

vessels, and railroads. Recreational motorboat population 

and spatial surrogates (used to assign emissions to each 

county) were significantly updated. The populations for the 

construction equipment category were reviewed and 

updated based upon surveys completed in the Midwest, 

and the temporal allocation for agricultural sources also 

was updated. 

West Virginia emission projections were provided by the WVDAQ 

as summarized below: 

• Area source and MAR emissions were compiled from the 

2008 NEI and 2015 and 2022 projections were grown using 

Workforce data. 

• Mobile source emissions were calculated using the same 

methodology as described above for Ohio’s portion. 

• EGU point source information was compiled from U.S. 

EPA’s CSAPR inventories. 

• Non-EGU point source information was compiled from West 

Virginia’s 2008 actual emissions inventory and 2015 and 

2022 projections were grown using Workforce data. 

• Non-road emissions were generated are derived from 

NONROAD modeling conducted by WVDAQ. 

Demonstration

On-Road Emission Estimations 

The ODOT, Division of Transportation System DevelopmentModeling and Forecasting Section and the Wood-Washington-Wirt 

Interstate Planning Commission (WWW), defined the underlying 

planning assumptions for the annual PM2.5 on-road mobile source 

emission inventories for the Parkersburg-Marietta, OH-WV 

nonattainment area. The WWW Region is comprised of 

Washington County, Ohio, Wood County, West Virginia, and the 

Grant Tax district of Pleasant county, West Virginia. The Grant Tax 

district in Pleasant County, West Virginia (shown above and 

adjacent to Wood County) is considered a “doughnut area” for 

planning purposes. For the most part, roadways within this district 

are not included in the travel demand model network. The 

WVDOT provided WWW with the VMT on the roads in this district 

by federal functional class for the year 2004. Based upon the 

advice of the WVDAQ, the modeling area’s growth factor was used 

to calculate future year VMT within this Tax district by functional 

class. 
 17 

In coordination with the ODOT and WVDOT, WWW utilizes a 

regional travel demand forecast model to simulate traffic in the 

area and to forecast traffic flows for given growth expectations. 

The model is primarily used as a long range planning tool to 

evaluate the transportation system including determination of 

locations where additional travel capacity may be needed and to 

determine the infrastructure requirements necessary to meet that 

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

the total emissions of pollution caused by vehicles in the area. 

The travel demand forecasting model is used to predict traffic 

volumes vehicle miles traveled (VMT), travel speeds, and a U.S. 

EPA computer program called MOVES is used to calculate 

emissions per mile. The product of these is the total amount of 

pollution emitted by the on-road vehicles for the area. 

Overview 

U.S.EPA published a Federal Register notice8 of availability on 

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

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

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

approved motor vehicle emission factor model for estimating 

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

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

local agencies. MOVES is a computer program designed by the 

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

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

estimate exhaust and evaporative emissions as well as brake and 

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

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

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

measures vehicle emissions to make sure the Agency has the best 

possible understanding of mobile source emissions. This 

assessment, in turn, informs the development of U.S. EPA’s 

mobile source emission models. MOVES represents the Agency’s 

most up-to-date assessment of on-road mobile source emissions. 

MOVES also incorporates several changes to the U.S. EPA’s 

approach to mobile source emission modeling based upon 

recommendations made to the Agency by the National Academy 

of Sciences. 

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

and nitrogen dioxide SIP development as expeditiously as 

 

8 http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ab1f98 
 18 

possible. The CAA requires that SIP inventories and control 

measures be based on the most current information and applicable 

models that are available when a SIP is developed. Regarding 

transportation conformity, U.S. EPA and U.S. DOT intend to 

establish a two-year grace period before MOVES is required for 

new transportation conformity analyses. 

The MOVES more detailed approach (when compared with the 

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

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

sources, such as data from vehicle inspection and maintenance 

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

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

This approach also allows users to incorporate a variety of activity 

data to better estimate emission differences such as those 

resulting from changes to vehicle speed and acceleration patterns. 

MOVES has a graphical user interface which allows users to more 

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

design provides users much greater flexibility regarding output 

choices. Unlike earlier models which provided emission factors in 

grams-per-mile in fixed output formats, MOVES output can be 

expressed as total mass (in tons, pounds, kilograms, or grams) or 

as emission factors (grams-per-mile and in some cases grams-pervehicle). Output can be easily aggregated or disaggregated to 

examine emissions in a range of scales, from national emissions 

impacts down to the emissions impacts of individual transportation 

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

update emissions data incorporated in MOVES more easily and will 

allow users to incorporate a much wider array of activity data to 

improve estimation of local emissions. For example, the 

improvements in MOVES will allow project-level PM2.5 emissions 

to be estimated. 

The annual on-road inventory runs meet the latest planning 

assumption requirement, utilizing the latest population and land 

use data available. WWW’s utilized U.S.EPA’s emissions model 

MOVES to develop emissions factors for SO2, NOx and PM2.5. 

Further details on the use of MOVES are found on Appendix C. 

Travel analysis zones (376 in the 2-county area) and external 

roadway “stations” (34) are the basic geographic units for 

estimating travel patterns. Socioeconomic data used to forecast 

these patterns include household population, household vehicles, 

and employment by category and location. Sources for year 2000 

data include the 2000 Census and QCEW/ES202 employment data 

adjusted to Year 2005 county-level control totals. All data sources 

were geocoded to the zone level. Future year data for each 
 19 

variable were projected through various methods. The forecasted 

distribution of land use by industry and traffic zone was developed 

in 2003 by WWW staff working in conjunction with West Virginia 

University’s Regional Research Institute and a consulting firm, as 

documented in their 2002 Transportation Plan update 

A travel demand model (TDM) is the traditional tool used to 

examine potential changes in future travel patterns. The road 

networks within them include all planned federal-aid projects as 

well as any regionally significant projects found in the 

Transportation Improvement Program (TIP) and Long Range 

Transportation Plan (LRTP) expected to be open for traffic by the 

end of each respective analysis year. All projects identified in the 

LRTP having an impact on travel time and/or vehicle carrying 

capacity regardless of funding source were included in the air 

quality analysis. 

The WWW region area TDM network covers about 1000 miles of 

streets and highways in the 2-county area including all collector 

and arterial streets, and has been validated to observed traffic for 

year 2005. The hourly distribution of trips by trip purpose and 

direction are constrained to match the hourly distribution of traffic 

counts. Trip distribution also begins with a trip-length distribution 

by purpose borrowed from another urban area and adjusted to 

ensure modeled VMT matched HPMS estimates of VMT within 1% 

in the model base year of 2005. (Home-based work trips were 

separately constrained to a target average value based on the 

2000 Census.) 

On-Road Mobile Emission Estimations 

Tables 2 through 7 contain the results of the emissions analysis for the 

appropriate years. All emissions estimations are expressed in tons per 

year (tpy). 

Table 2 - Washington County, Ohio Emissions Estimations for OnRoad Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 90.45 75.52 41.68 25.22 

NOx (tpy) 2,687.09 2,247.41 1,200.52 572.25 

SO2 (tpy) 26.97 8.54 6.46 6.31 

Annual VMT 787,956,160 804,042,805 880,728,940 947,254,205 
 20 

Table 3 – Summary of Ohio Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 90.45 75.52 41.68 25.22 

NOx (tpy) 2,687.09 2,247.41 1,200.52 572.25 

SO2 (tpy) 26.97 8.54 6.46 6.31 

Annual VMT 787,956,160 804,042,805 880,728,940 947,254,205 

Table 4 – Wood County, West Virginia Emissions Estimations for 

On-Road Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 81.43 66.32 33.62 24.16 

NOx (tpy) 2,459.26 2,122.62 992.62 538.59 

SO2 (tpy) 31.13 10.37 7.88 7.70 

Annual VMT 878,434,550 987,566,995 1,089,633,405 1,175,437,970 

Table 5 – Pleasants County (partial only), West Virginia Emissions 

Estimations for On-Road Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 1.61 1.20 0.55 0.37 

NOx (tpy) 54.17 42.41 19.05 9.96 

SO2 (tpy) 0.69 0.22 0.18 0.15 

Annual VMT 22,094,910 22,362,455 22,984,415 23,568,050 

Table 6 – Summary of West Virginia Emissions Estimations for 

On-Road Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 83.04 67.52 34.17 24.53 

NOx (tpy) 2,513.43 2,165.03 1,011.67 548.55 

SO2 (tpy) 31.82 10.59 8.06 7.85 

Annual VMT 900,529,460 1,009,929,450 1,112,617,820 1,199,006,020 

Table 7 – Emissions Estimations Totals for On-Road Mobile 

Sources for the Parkersburg-Marietta Area 

 2005 2008 2015 2022 

PM2.5 (tpy) 173.49 143.04 75.85 49.75 

NOx (tpy) 5,200.52 4,412.44 2,212.19 1,120.80 

SO2 (tpy) 58.79 19.13 14.52 14.16 

Annual VMT 1,688,485,620 1,813,972,255 1,993,346,760 2,146,260,225 
 21 

The following table identifies the percentage of mobile emissions of all 

emissions, as identified under Appendix E, for each pollutant in the entire 

Parkersburg-Marietta area and Ohio’s portion of this area for 2015 and 

2022. 

Table 8 – Percent of Mobile Emissions for the Parkersburg-Marietta 

Area in 2015 and 2022 – With Apportionment Analysis for 

Partial Nonattainment Areas 

 

NOx SO2 PM2.5

2015 2022 2015 2022 2015 2022 

ParkersburgMarietta Area 

Total (tpy) 18,491.26 12,968.52 77,293.31 48,438.63 3,536.75 3,446.56

Mobile (tpy) 2,212.19 1,120.80 14.52 14.16 75.85 49.75

% Mobile 11.96% 8.64% 0.02% 0.03% 2.14% 1.44%

Ohio Portion 

Total (tpy) 11,439.41 6,417.53 67,625.84 37,351.17 1,198.61 1,181.01

Mobile (tpy) 1,200.52 572.25 6.46 6.31 41.68 25.22

% Mobile 10.49% 8.92% 0.01% 0.02% 3.48% 2.14%

SO2 constitutes less than one percent (<1%) of the area’s 

total SO2 emissions in the 2015 and 2022 horizon years. 

PM2.5 constitutes just over two percent (2.14%) of the area’s 

total PM2.5 emissions in the 2015 horizon year and less than 

two percent (1.44%) of the area’s total PM2.5 emissions in 

the 2022 horizon year. 

 

NOx emissions are just under twelve percent (11.96%) of 

the area’s total NOx emissions in the 2015 horizon year and 

less than nine percent (8.64%) in the 2022 horizon year. 

Therefore, the Ohio EPA is herein making a finding that the area’s 

highway emissions for PM2.5, NOx, and SO2 continue to be insignificant 

contributors to the nonattainment problem of the Parkersburg-Marietta 

area, as agreed upon as a part of the interagency consultation process. 

Because of this finding it is not necessary to establish mobile emission 

budgets for this area in the 2015 and 2022 horizon years. The 

nonattainment area meets the 40 CFR 93.109(m) criteria for PM2.5, NOx, 

and SO2. Throughout this document Ohio EPA demonstrates that it would 

be unreasonable to expect that the Parkersburg-Marietta area would 

experience enough motor vehicle emissions growth in PM2.5, NOx, and 

SO2 for a PM2.5 NAAQS violation to occur. Moreover, Ohio EPA 

demonstrates that 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, the absence of SIP motor vehicle control 

measures, and historical trends and future projections of the growth of 
 22 

motor vehicle emissions, are evidence enough to consider mobile source 

PM2.5, NOx, and SO2 insignificant contributors to fine particles. 

Requirement 3 of 5 

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

PM2.5 standard. 

Background

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

as the maintenance year for this redesignation request. This 

document contains projected emissions inventories for 2015 and 

2022. 

Emission projections for the Parkersburg-Marietta area were 

performed using the following approaches: 

• As performed by ODOT and WWW (for the entire 

nonattainment area), mobile source emission projections 

are based on the U.S. EPA MOVES model. The analysis is 

described in more detail in Appendix C. All projections were 

made in accordance with “Procedures for Preparing 

Emissions Projections” U.S. EPA-45/4-91-019. As 

discussed above, it was determined that the mobile 

emission contribution as a percent of the total emission 

inventory from the area is not significant. 

• Emissions inventories are required to be projected to future 

dates to assess the influence growth and future controls will 

have. LADCO has developed growth and control files for 

point, area, and non-road categories. These files were used 

to develop Ohio’s portion of this nonattainment area futureyear emissions estimates used in this document. This was 

done so the inventories used for redesignation are 

consistent with modeling performed in the future. Appendix 

D contains LADCO’s technical support document detailing 

the analysis used to project emissions (Base M9

). 

• For the 2008 attainment year emissions were grown from 

the 2005 LADCO modeling inventory, using LADCO’s 

growth factors, for all sectors except point sources 

(electrical generating units and non-electrical generating 

units). Point source emissions for 2008 were compiled 

from Ohio EPA’s 2008 annual emissions inventory 

 

9

 http://www.ladco.org/tech/emis/current/index.php 
 23 

database. The 2015 interim year emissions were estimated 

based on the 2009 and 2018 LADCO modeling inventory, 

using LADCO’s growth factors, for all sectors except nonEGU PM2.5. The 2022 maintenance year is based on 

emissions estimates from the 2018 LADCO modeling, for 

all sectors except non-EGU PM2.5. Non-EGU PM2.5 

emissions for 2015 and 2022 were grown from 2005 and 

2009 emissions estimates.

Ohio EPA is identifying emissions projections for 2015 and 2022 

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

raised concerns regarding the CAIR program and its remand. 

However, Ohio EPA believes these are the most appropriate and 

accurate future projections. Although CSAPR has been stayed by 

the D.C. Circuit Court (December 30, 2011), the Court has ordered 

U.S. EPA to continue administering CAIR pending the court’s 

resolution. It is believed that CSAPR will provide even greater 

reductions in emissions than the CAIR program once resolved; 

therefore, these emissions projections will be conservative. 

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

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

eastern states and the District of Columbia to significantly reduce 

emissions of NOx and SO2. CAIR replaced the NOx SIP Call for 

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

emissions to be cut from 4.5 million tons in 2004, to a cap of 1.5 

million tons by 2009, and 1.3 million tons in 2018 in 28 states. 

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

Ohio submitted a CAIR SIP which was approved by U.S. EPA on 

February 1, 2007. Revisions to the CAIR SIP were again 

submitted on July 15, 2009. The revised CAIR SIP was approved 

as a direct final action on September 25, 2009 (74 FR 48857). As 

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

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

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

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

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

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

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

23, 2008, U.S. EPA’s CAIR program was remanded without 

vacatur by the D.C. Circuit Court. 

As can be seen in Table 9 below, Ohio has seen a significant 

decline in the 264,000 tons of NOx and 1,373,000 tons of SO2

 

10 http://www.epa.gov/CAIR/oh.html 
 24 

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

and implementing control programs to address CAIR11 and 

consent decrees. 

Table 9 - Reductions in SO2 and NOx EGU Emissions Between 

2008 and 2009 

SO2 NOx

2008 2009 Change 2008 2009 Change 

Ohio 709,444 601,101 15% 235,018 96,351 59% 

LADCO States 2,019,036 1,620,071 20% 702,384 393,930 44% 

National 7,616,262 5,747,353 25% 2,996,287 1,990,385 34% 

Source: Clean Air Markets Quarterly Emissions Tracking12

Significant reductions also occurred regionally and nationally as 

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

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

implemented under CAIR: 

Table 10 – Reductions in SO2 and NOx EGU Emissions 

Between the First Half of 2008 and 2010 

SO2 NOx

2008 

 (1st half) 

2010 

(1st half) Change 2008 (1st half) 

2010 

(1st half) Change 

Ohio 373,798 279,854 25% 130,598 53,187 59% 

LADCO States 1,190,497 854,282 28% 419,114 220,907 47% 

National 3,895,472 2,502,965 36% 1,487,179 930,148 37% 

Source: Clean Air Markets Quarterly Emissions Tracking13

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

“Based on emissions monitoring data, EPA has observed 

substantial reductions in SO2 emissions from 2005 to 2009 and in 

the first two quarters of 2010 as companies installed more 

controls, electric demand declined, and low natural gas prices 

made combined-cycle gas-fired units more competitive in several 

parts of the country. Thus, even after CAIR's vacatur and 

subsequent remand in late 2008, the controls in place generally 

have continued to operate, helping to drive continued progress in 

reducing emissions.14” 

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

CAIR program is providing real reductions at this time, Ohio 

 

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

beginning in 2010.

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

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

14 http://www.epa.gov/airmarkets/background.htm
 25 

believes these reductions have assisted with PM2.5 attainment in 

this nonattainment area and throughout Ohio. 

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

program, the CSAPR. CSAPR would preserve those initial 

reductions achieved under CAIR and provide even greater 

reductions in NOx and SO2 emissions in 2012 and 2014, ahead of 

the 2015 CAIR Phase 2. As a result of CSAPR, U.S. EPA 

projected that in 2012 emissions of NOx will decrease to 90,842 

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

decrease to 304,022 tons per year in 2012 and 134,333 tons per 

year in 2014, within Ohio. In addition, U.S. EPA projections 

indicated that as a result of implementation of CSAPR, there will 

be no maintenance issues within this entire nonattainment area. 

Furthermore, modeling conducted as part of CSAPR projects the 

counties within this area will not have maintenance issues in 2012 

or 2014 even without CSAPR (or CAIR)15. However, on December 

30, 2011, the D.C. Circuit Court stayed CSAPR and ordered U.S. 

EPA to continue administering CAIR pending the court’s 

resolution. 

Therefore, it is Ohio EPA’s belief it is most appropriate to evaluate 

Ohio EPA’s demonstration that the projected level of emissions is 

sufficient to maintain the annual PM2.5 standard by assessing 

future year emissions that include the CAIR program. 

The detailed inventory information for the Ohio portion of the 

Parkersburg-Marietta area for 2005 is in Appendix B. Emission 

trends are an important gauge for continued compliance with the 

PM2.5 standard. Therefore, Ohio EPA performed an initial 

comparison of the inventories for the base year and maintenance 

years. Mobile source emission inventories are described in 

Appendix C. 

Sectors included in the following tables are: Electrical Generating 

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

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

Maintenance is demonstrated when the future-year (2022) 

projected emission totals are below the 2008 attainment year 

totals. 

 

15 See supplemental table “Impacts of the Proposed Transport Rule on Counties with Monitors 

Projected to have Ozone and/or Fine Particle Air Quality Problems.”
 26 

Demonstration

PM2.5

The 2005 and 2008 actual PM2.5 emissions data below generally contains 

particulate fraction emissions only and not the condensable fractions as 

Ohio EPA did not have a consistent reporting requirement during those 

years. U.S. EPA IPM modeling was used to generate future year EGU 

emissions with the CAIR program. The IPM modeling added additional 

PM2.5 condensable emissions into future years. Therefore, comparing 

base and attainment year emissions with the future year predictions is not 

accurate in the IPM CAIR modeling. This step leads to a false perception 

of significant PM2.5 emissions growth. Modeling performed by LADCO, 

without CAIR, did not incorporate added condensable fraction emissions. 

Although Ohio EPA has stated that it is most appropriate to evaluate 

future year emissions that include the CAIR program, because of this flaw 

it will be more accurate and appropriate for the purposes of PM2.5 to 

evaluate future year emissions without the CAIR program. 

Table 11 - Washington County, Ohio PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 384.81 392.62 407.19 418.67 -26.05 

Non-EGU 472.37 471.72 470.21 468.70 3.02 

Non-road 35.53 30.63 21.19 11.55 19.08 

Area 148.43 222.16 251.82 254.36 -32.20 

MAR 11.76 10.70 6.52 2.51 8.19 

On-road 90.45 75.52 41.68 25.22 50.30 

TOTAL 1,143.35 1,203.35 1,198.61 1,181.01 22.34 

Table 12 - Wood County, West Virginia PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CSAPR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 176.51 182.34 174.02 166.12 16.22 

Non-road 36.85 33.25 25.02 17.51 15.74 
 27 

Area 921.41 694.95 686.19 684.48 10.47 

MAR 46.05 25.56 25.72 25.88 -0.32 

On-road 81.43 66.32 33.62 24.16 42.16 

TOTAL 1,262.25 1,002.42 944.57 918.15 84.27 

Table 13 - Pleasants County, West Virginia PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenanc

e 

Safety 

Margin 

EGU Point 1,360.23 1,287.83 1,330.92 1,286.59 1.24 

Non-EGU 198.72 159.57 143.78 141.49 18.08 

Non-road 8.32 8.19 5.96 3.73 4.46 

Area 143.43 121.73 116.47 113.48 8.25 

MAR 28.83 12.30 12.38 12.45 -0.15 

On-road 1.61 1.20 0.55 0.37 0.83 

TOTAL 1,741.14 1,590.82 1,610.06 1,558.11 32.71 

Table 14 – Parkersburg-Marietta Area PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

projected 2015 and 2022 (tpy) – Without CAIR (Ohio) 

and With CSAPR (West Virginia) 

PM2.5 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

Washington 1,143.35 1,203.35 1,198.61 1,181.01 22.34 

Wood, WV 1,262.25 1002.42 944.57 918.15 84.27 

Pleasants, WV 1,741.14 1,590.82 1,610.06 1,558.11 32.71 

COMBINED 

PM2.5 TOTAL 4,146.74 3,796.59 3,753.24 3,657.27 139.32 

NOx 

Table 15 - Washington County, Ohio NOx Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2022 (tpy) – With CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 16,137.09 17,168.69 7,505.59 3,364.26 13,804.43 

Non-EGU 1,748.86 1,941.94 2,019.31 2,052.47 -110.53 

Non-road 425.97 356.74 224.17 88.88 267.86 

Area 168.44 178.66 183.96 191.01 -12.35 

MAR 500.78 472.52 305.86 148.66 323.86 

On-road 2,687.09 2,247.41 1,200.52 572.25 1,675.16 

TOTAL 21,668.23 22,365.96 11,439.41 6,417.53 15,948.43 
 28 

Table 16 - Wood County, West Virginia NOx Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 943.43 859.44 818.79 780.12 79.32

Non-road 406.22 361.87 231.95 168.36 193.51

Area 704.32 397.82 393.72 389.62 8.20

MAR 1,246.83 754.15 758.90 763.65 -9.50

On-road 2,459.26 2,122.62 992.62 538.59 1,584.03

TOTAL 5,760.06 4,495.90 3,195.98 2,640.34 1,855.56

Table 17 - Pleasants County, West Virginia NOx Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 12,318.14 8,251.74 3,733.99 3,798.80 4,452.94

Non-EGU 639.94 156.90 22.73 21.64 135.26

Non-road 38.49 37.72 31.31 26.65 11.07

Area 174.42 43.54 42.80 42.07 1.47

MAR 799.88 362.14 364.42 366.70 -4.56

On-road 54.17 42.41 19.05 9.96 32.45

TOTAL 14,025.04 8,894.45 4,214.30 4,265.82 4,628.63

Table 18 - Parkersburg-Marietta Area NOx Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2022 (tpy) – With CAIR (Ohio) and With CSAPR (West 

Virginia) 

NOx 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

Washington 21,668.23 22,365.96 11,439.41 6,417.53 15,948.43

Wood, WV 5,760.06 4,495.90 3,195.98 2,640.34 1,855.56

Pleasants, WV 14,025.04 8,894.45 4,214.30 4,265.82 4,628.63

COMBINED 

NOx TOTAL 41,453.33 35,756.31 18,849.69 13,323.69 22,432.62

SO2
 29 

Table 19 - Washington County, Ohio SO2 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2022 (tpy) – With CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 140,957.01 133,348.05 61,849.00 31,206.55 102,141.50

Non-EGU 5,200.90 5,372.72 5,744.96 6,122.46 -749.74

Non-road 41.04 15.08 2.47 0.49 14.59

Area 9.78 10.56 10.51 10.15 0.41

MAR 44.48 31.29 12.44 5.21 26.08

On-road 26.97 8.54 6.46 6.31 2.23

TOTAL 146,280.18 138,786.24 67,625.84 37,351.17 101,435.07

Table 20 - Wood County, West Virginia SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 5,231.51 3,175.37 3,018.61 2,869.59 305.78

Non-road 31.18 5.53 0.67 0.72 4.81

Area 715.82 521.01 493.53 466.05 54.96

MAR 58.80 39.60 39.85 40.09 -0.49

On-road 31.13 10.37 7.88 7.70 2.67

TOTAL 6,068.44 3,751.88 3,560.54 3,384.15 367.73

Table 21 - Pleasants County, West Virginia SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – With CSAPR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 52,295.78 15,803.98 6,090.44 7,687.48 8,116.50

Non-EGU 5,623.32 1,175.69 1.11 1.08 1,174.61

Non-road 2.42 0.47 0.12 0.13 0.34

Area 97.76 55.40 52.50 49.60 5.80

MAR 38.47 19.29 19.41 19.53 -0.24

On-road 0.69 0.22 0.18 0.15 0.07

TOTAL 58,058.44 17,055.05 6,163.76 7,757.97 9,297.08
 30 

Table 22 - Parkersburg-Marietta Area SO2 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2022 (tpy) – With CAIR (Ohio) and With CSAPR (West 

Virginia) 

SO2 2005 

Base 

2008 

Attainment 2015 Interim 2022 Maintenance 

Safety 

Margin 

Washington 146,280.18 138,786.24 67,625.84 37,351.17 101,435.07

Wood, WV 6,068.44 3,751.88 3,560.54 3,384.15 367.73

Pleasants, WV 58,058.44 17,055.05 6,163.76 7,757.97 9,297.08

COMBINED 

SO2 TOTAL 210,407.06 159,593.17 77,350.14 48,493.29 111,099.88

PM2.5, NOx, and SO2

Table 23 - Parkersburg-Marietta Area Comparison of 2008 

Attainment Year and 2015 and 2022 Projected 

Emission Estimates (tpy) 

 2008 

Attainment 2015 Interim 

2015 

Projected 

Decrease 

2022 

Maintenance 

2022 

Projected 

Decrease 

PM2.5 4,146.74 3,753.24 393.50 3,657.27 489.47

NOx 35,756.31 18,849.69 16,906.62 13,323.69 22,432.62

SO2 159,593.17 77,350.14 82,243.03 48,493.29 111,099.88

As shown in the table above (Table 23), PM2.5 emissions in the 

nonattainment area are projected to decrease by 393.50 tpy in 

2015 and 489.47 tpy in 2022. NOx emissions in the nonattainment 

area are projected to decrease by 16,906.62 tpy in 2015 and 

22,432.62 tpy in 2022. SO2 emissions in the nonattainment area 

are projected to decline by 82,243.03 tpy in 2015 and 111,099.88 

in 2022. 

In general, EGU source emissions show decreases due to the 

CAIR program. Cleaner vehicles and fuels are expected to be in 

place in 2009 and 2018, and the CSAPR will be implemented in 

2012 and 2014 and these programs should cause an overall drop 

in all three pollutants emissions. Decreases from U.S. EPA rules 

covering Tier 2 Motor Vehicle Emissions Standards and Gasoline 

Sulfur Control Requirements16, Highway Heavy-Duty Engine 

Rule17, and the Non-Road Diesel Engine Rule18 are factored into 

 

16 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 

17 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 
 31 

the changes. 

In addition to the above, additional reductions from Ohio’s utilities 

have been occurring: 

• Muskingum River AEP Station in Washington County has 

implemented important changes in 2008. Unit #5 (as required 

through a federally enforceable consent decree) began 

continuous operation of their advanced NOx control device. 

Unit #5 is the largest (600 MW) of five units at this facility. 

The remaining four units are 205 to 240 MWs (2 each). In 

addition, by the close of 2015, all units at the Muskingum 

River AEP Station are required to retire, repower or retrofit the 

unit (as required through a federally enforceable consent 

decree) and initial plans indicate AEP will install advanced 

SO2 controls (FGD scrubber) on unit #5. 

• R.H.Gorsuch AMP Station in Washington County permanently 

shut down at the end of 2010. This facility operated four 53 

MW units. 

Requirement 4 of 5 

A demonstration that improvement in air quality between the year violations 

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

enforceable emission reductions and not on temporary adverse economic 

conditions or unusually favorable meteorology. 

Background 

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

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

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

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

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

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

not cause a violation of the NAAQS.” 

Demonstration 

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

have contributed to the attainment of the annual PM2.5 standard. Some of 

these reductions were realized due to the application of tighter federal 

standards on new vehicles. Also Title IV of the CAA, the NOx SIP Call, 

CAIR, and federal consent decrees required the reductions of SO2 and 

NOx emissions from utility sources. Reductions achieved are discussed 

in greater detail under Chapter Five. 

 18 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 
 32 

Table 24 - Parkersburg-Marietta Area Comparison of 2005 base 

year and 2008 attainment year on-road and EGU 

reductions 

 2005 2008 

On-road PM2.5 173.49 143.04

On-road NOx 5,200.52 4,412.44

On-road SO2 58.79 19.13

EGU PM2.5 1,745.04 1,680.45

EGU NOx 28,455.23 25,420.43

EGU SO2 193,252.79 149,152.03

Requirement 5 of 5 

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

emission levels, including an annual emission statement from major sources. 

Demonstration

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

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

Consolidated Emissions Reporting Rule (CERR). Ohio EPA 

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

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

be prepared for future years as necessary to comply with the 

inventory reporting requirements established in the CFR. 

Emissions information will be compared to the 2005 base year and 

the 2022 projected maintenance year inventories to assess 

emission trends, as necessary, and to assure continued 

compliance with the annual PM2.5 standard. 
 33 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

CAA Section107 (d)(3)(E)(ii), 107(d)(3)(iv), and 107(d)(3)(E)(v) 

Requirement 1 of 6

Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with 

nonattainment areas to implement RACM and RACT. 

Background

Section 172(c)(1) of the 1990 Clean Air Act Amendments requires 

states with nonattainment areas to submit a SIP providing for 

implementation of all reasonably available control measures and 

as expeditiously as practicable (including such reductions in 

emissions from existing sources in the area as may be obtained 

through the adoption, at a minimum, of reasonable available 

control technology). 

U.S. EPA’s Implementation Rule interprets this requirement in 

great detail. Under U.S. EPA’s approach, RACT is determined as 

part of the broader RACM analysis and identification of all 

measures (for stationary, mobile, and area sources) that are 

technically and economically feasible, and that would collectively 

contribute to advancing the attainment date (i.e. by one year or 

more). States are required to use a combined approach to RACT 

and RACM, that (1) identifies potential measures that are 

reasonable, (2) uses modeling to identify the attainment date that 

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

RACT and RACM. 

The Implementation Rule also provides for a presumption that in 

States that fulfill their CAIR emission reduction requirements, EGU 

compliance with CAIR is equivalent to RACM/RACT. 

Demonstration

In 1972, 1980, and 1991, Ohio promulgated rules requiring 

reasonably available controls measures for particulate emissions 

from stationary sources. 

Statewide RACT rules have been applied to all new sources 

locating in Ohio since that time. RACT requirements are 

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio EPA 

also has an active enforcement program to address violations 
 34 

discovered by field office staff. The Ohio RACT rules for 

particulate matter are found in OAC Chapter 3745-1719. 

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

Chapter 3745-1420), CAIR (OAC Chapter 3745-10921), and NOx

Reasonably Available Control Technology rules (OAC Chapter 

3745-11022) over the past five years. Emissions from EGUs make 

up a significant contribution to Ohio’s inventory. Beginning in 2009, 

Ohio implemented CAIR which has, and will, provide for significant 

reductions in NOx, PM2.5, and SO2 until such time CSAPR is 

implemented. Then the CSAPR will provide for even greater 

reductions. 

As part of a larger initiative, LADCO, in consultation with two 

contractors, performed a series of studies exploring control 

measures for reducing both ozone precursors and PM2.5 

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

The first consultant, MACTEC, prepared a series of white papers23

researching different stationary source categories. The results 

were compiled into two reports24. The second consultant, Environ, 

investigated control options for mobile sources. The results were 

compiled into two reports25. The stationary and mobile source 

sectors (and associated control measures) were selected by the 

LADCO States based on several factors presented in the report 

(See Chapter 2). 

Photochemical modeling was then conducted (as part of LADCO 

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

candidate control measures and a modeling report was 

developed26. Based on the results, the LADCO project team felt it 

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

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

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

 

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

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

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

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

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

24 

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

ures_i_april_2005.pdf; 

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

ures_ii_june_2006.pdf 

25

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

rol_measures_february_2006.pdf; 

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

rol_measures_for_ladco_states_in_2009_and_2012_march_2007.pdf

26 http://www.ladco.org/reports/control/modeling/round4_modeling.pdf
 35 

attainment would be achieved in this area by 2009. Because of a 

projected 2009 attainment date, it would not have been reasonably 

possible or practicable for Ohio to develop RACT/RACM 

requirements, promulgate regulations and implement a control 

program prior to the projected attainment date. 

Requirement 2 of 6

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

demonstration SIPs for nonattainment areas to show reasonable further 

progress (RFP). 

Background

U.S. EPA’s Implementation Rule requires RFP only for any area 

which a State projects an attainment date beyond 2010. The RFP 

would provide emission reductions showing linear progress 

between 2002 and 2009. If a State demonstrates attainment will 

occur by 2010 or earlier, U.S. EPA considers the attainment 

demonstration to demonstrate achievement of RFP. 

Demonstration

In Ohio’s attainment demonstration submitted on July 18, 2008, 

Ohio demonstrated (using a weight of evidence approach) that 

attainment would be achieved in this area by 2009; and therefore, 

it was not necessary to submit a separate RFP plan. 

Requirement 3 of 6

Section 172(c)(3) requires states to submit a comprehensive inventory of actual 

emissions. 

Background

Section 172(c)(3) requires states to submit a comprehensive 

inventory of actual emissions in the area, including the 

requirement for periodic revisions as determined necessary. 40 

CFR 51.1008 requires such inventory to be submitted within three 

years of designation and requires a baseline emission inventory 

for calendar year 2002 or other suitable year to be used for 

attainment planning. 

Demonstration

The 2005 comprehensive inventory was submitted to U.S. EPA 

with Ohio’s PM2.5 attainment demonstration SIP submitted on July 

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

June 7, 2010. 
 36 

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

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

emissions statement SIP on March 18, 1994 which was approved 

by U.S. EPA on October 13, 1995 (59 FR 51863). As discussed in 

Chapter 4 (Requirement 4), Ohio EPA submits, and commits to 

submit, emission inventories (statements) every three years. 

Requirement 4 of 6

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

fully implemented. 

Background

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

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

result in significant emission reductions from large EGUs, 

industrial boilers, and cement kilns in the eastern United States. 

Ohio passed this rule in 2001. NOx SIP Call requirements are 

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio EPA 

also has an active enforcement program to address violations 

discovered by field office staff. Compliance is tracked through the 

Clean Air Markets data monitoring program. Beginning in 2004, 

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

NOx emissions statewide compared to previous uncontrolled 

years. The other 21 states also have adopted these rules. 

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

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

eastern states and the District of Columbia to significantly reduce 

emissions of NOx and SO2. CAIR replaced the NOx SIP Call for 

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

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

2018 in 28 states. States were required to submit a CAIR SIP as 

part of this effort. Ohio submitted a CAIR SIP which was approved 

by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were 

again submitted on July 15, 2009. The revised CAIR SIP was 

approved as a direct final action on September 25, 2009 (74 FR 

48857). 

Demonstration

Controls for EGUs under the NOx SIP Call formally commenced 

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

generally trending downward since 1998 with larger reductions 

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

Air Markets web site, quantify the gradual NOx reductions that 
 37 

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

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

developed the NOx Budget Trading Program rules in OAC Chapter 

3745-1427 in response to the SIP Call. OAC Chapter 3745-14 

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

program based on an 85 percent reduction of NOx emissions from 

EGUs and a 60 percent reduction of NOx emissions from nonEGUs, compared to historical levels. This cap was in place 

through 2008, at which time the CAIR program superseded it as 

discussed above. Requirement 3 of 5 under Chapter 4 above 

discussed the reductions Ohio has seen as a result of CAIR. 

On April 21, 2004, U.S. EPA published Phase II of the NOx SIP 

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

emissions) stationary internal combustion engines. Ohio EPA’s 

OAC rule 3745-14-12 addresses stationary internal combustion 

engines, all used in natural gas pipeline transmissions. U.S. EPA 

approved this revision to the SIP on April 4, 2008. An 82 percent 

NOx reduction from 1995 levels is anticipated. Completion of the 

compliance plan occurred by May 1, 2006, and the compliance 

demonstration began May 1, 2007. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur 

Standards 

In February 2000, U.S. EPA finalized a federal rule to significantly 

reduce emissions from cars and light trucks, including sport utility 

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

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

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

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

estimated that NOx emission reductions will be approximately 77 

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

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

SUVs, vans, and heavier trucks. The sulfur content of gasoline is 

estimated to be reduced by up to 90 percent. VOC emission 

reductions will be approximately 12 percent for passenger cars, 18 

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

percent for larger SUVs, vans, and heavier trucks. 

Heavy-Duty Diesel Engines 

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

Engines, a program which includes low-sulfur diesel fuel 

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

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

 

27 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 
 38 

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

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

inventory. It also estimated the level of sulfur in highway diesel fuel 

will be reduced by 97 percent by mid-2006. 

Clean Air Non-road Diesel Rule 

In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. 

 This rule applies to diesel engines used in industries such as 

construction, agriculture, and mining. It also contains a cleaner 

fuel standard similar to the highway diesel program. The new 

standards will cut emissions from non-road diesel engines by more 

than 90 percent. Non-road diesel equipment, as described in this 

rule, currently accounts for 47 percent of diesel particulate matter 

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

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

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

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

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

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

precursors. 

Requirement 5 of 6

Acceptable provisions to provide for new source review. 

Background

Ohio has a longstanding and fully implemented New Source 

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

3128. The Chapter includes provisions for the Prevention of 

Significant Deterioration (PSD) permitting program in OAC rules 

3745-31-01 to 3745-31-20. Ohio's PSD program was conditionally 

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

approval on January 22, 2003 (68FR 2909) by U.S. EPA as part of 

the SIP. 

Demonstration

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

the closing of which credit was taken in demonstrating attainment, 

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

without meeting all applicable NSR requirements. Once the area 

is redesignated, Ohio EPA will implement NSR through the PSD 

program. 

Requirement 6 of 6

 

28 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx 
 39 

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

unless the State demonstrates through modeling that the standard can be 

maintained without one or more control measures. 

Demonstration

Ohio commits to maintaining the aforementioned control measures 

after redesignation. Ohio hereby commits that any changes to its 

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

required for maintenance of the annual PM2.5 standard in the 

Parkersburg-Marietta area, will be submitted to U.S. EPA for 

approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal office, has the legal authority and 

necessary resources to actively enforce any violations of its rules 

or permit provisions. After redesignation, it intends to continue 

enforcing all rules that relate to the emission of PM2.5 precursors in 

the Parkersburg-Marietta area. 
 40 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4

A commitment to submit a revised plan eight years after redesignation. 

Demonstration

Ohio hereby commits to review its maintenance plan eight years 

after redesignation, as required by Section 175(A) of the CAA. 

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

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

Demonstration

Ohio hereby commits to adopt and expeditiously implement 

necessary corrective actions in the following circumstances: 

Warning Level Response: 

A warning level response shall be prompted whenever the PM2.5

average of the weighted annual mean of 15.5 μg/m3 occurs in a 

single calendar year within the maintenance area. A warning level 

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

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

emissions appear to be increasing. The study will evaluate 

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

measures necessary to reverse the trend taking into consideration 

ease and timing for implementation as well as economic and social 

considerations. Implementation of necessary controls in response 

to a warning level response trigger will take place as expeditiously 

as possible, but in no event later than 12 months from the 

conclusion of the most recent calendar year. 

Should it be determined through the warning level study that action 

is necessary to reverse the noted trend, the procedures for control 

selection and implementation outlined under “action level 

response” shall be followed. 

Action Level Response: 

An action level response shall be prompted whenever a two-year 

average of the weighted annual means of 15.0 μg/m3

 or greater 
 41 

occurs within the maintenance area. A violation of the standard 

(three-year average of the weighted annual means of 15.0 μg/m3

or greater) shall also prompt an action level response. In the 

event that the action level is triggered and is not found to be due to 

an exceptional event, malfunction, or noncompliance with a permit 

condition or rule requirement, Ohio EPA in conjunction with the 

metropolitan planning organization or regional council of 

governments, will determine additional control measures needed 

to assure future attainment of the NAAQS for annual PM2.5. In this 

case, measures that can be implemented in a short time will be 

selected in order to be in place within 18 months from the close of 

the calendar year that prompted the action level. Ohio EPA will 

also consider the timing of an action level trigger and determine if 

additional, significant new regulations not currently included as 

part of the maintenance provisions will be implemented in a timely 

manner and will constitute our response. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the 

necessary administrative and legal process. This process will 

include publication of notices, an opportunity for public hearing, 

and other measures required by Ohio law for rulemaking. 

If a new measure/control is already promulgated and scheduled to 

be implemented at the federal or State level, and that 

measure/control is determined to be sufficient to address the 

upward trend in air quality, additional local measures may be 

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

analysis to demonstrate the proposed measures are adequate to 

return the area to attainment. 

Requirement 3 of 4

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

event. 

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective 

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

be based on cost-effectiveness, emission reduction potential, 

economic and social considerations or other factors that Ohio EPA 

deems appropriate. Ohio EPA will solicit input from all interested 

and affected persons in the maintenance area prior to selecting 

appropriate contingency measures. Because it is not possible at 

this time to determine what control measures will be appropriate at 
 42 

an unspecified time in the future, the list of contingency measures 

outlined below is not exhaustive. 

1) Diesel reduction emission strategies. 

2) Alternative fuel (e.g., liquid propane and compressed natural 

gas) and diesel retrofit programs for fleet vehicle operations. 

3) Tighter PM2.5, SO2, and NOx emissions offsets for new and 

modified major sources. 

4) Impact crushers located at recycle scrap yards – upgrade wet 

suppression. 

5) Concrete manufacturing – upgrade wet suppression. 

6) Additional NOx RACT statewide. 

No contingency measure shall be implemented without providing 

the opportunity for full public participation during which the relative 

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

under consideration, can be fully evaluated. 

Requirement 4 of 4 

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

control requirements. 

Demonstration

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

subject to future controls. 

• ICI Boilers - SO2 and NOx controls; 

• EGUs; 

• process heaters; 

• internal combustion engines; 

• combustion turbines; 

• other sources greater than 100 tons per year; 

• fleet vehicles; 

• concrete manufacturers; 

• aggregate processing plants; 
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CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in the 

widely distributed county publications on January 17, 2012. 

The public hearing to receive comments on the redesignation request was held 

on February 16, 2012, at the Marietta Public Library, Marietta, Ohio. The public 

comment period closed on February 16, 2012. Appendix F includes a copy of 

the public notice, certification of publication, and the transcript from the public 

hearing. 
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CHAPTER EIGHT 

CONCLUSIONS

The Parkersburg-Marietta annual PM2.5 nonattainment area has attained the 

1997 annual NAAQS for PM2.5 and complied with the applicable provisions of the 

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

areas. Documentation to that effect is contained herein. Ohio EPA has prepared 

a redesignation request and maintenance plan that meet the requirements of 

Section 110 (a)(1) of the 1990 CAA. 

Based on this presentation, the Parkersburg-Marietta annual PM2.5 

nonattainment area meets the requirements for redesignation under the CAA 

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

quality improvements are due to permanent and enforceable measures. 

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

significant regional SO2 and NOx reductions will ensure continued compliance 

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

The State of Ohio hereby requests that the Parkersburg-Marietta annual PM2.5

nonattainment area be redesignated to attainment simultaneously with U.S. EPA 

approval of the maintenance plan provisions contained herein. 
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