Ohio Environmental 

Protect ion Agency 

Governor 

Lt. Governor 

Director 

JUN 18 2012 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA Region 5 

77 W. Jackson Blvd. 

Chicago, IL 60604 

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Re: PM2.s Redesignation Request for the 1997 Annual and 2006 24-Hour 

Standards for the Canton-Massillon Area 

Dear Administrator Hedman: 

I am writing to formally request a redesignation to attainment of the Canton-Massillon 

area (Stark County, Ohio) with respect to the 1997 annual and 2006 24-hour PM2.5 

standards. The enclosed submittal combines the redesignation request and the required 

maintenance plan for this area. Ohio EPA is also requesting U.S. EPA make a clean 

data determination to ensure the requirement to submit an attainment demonstration 

SIP for the 24-hour standard will not be applicable in the event the redesignation 

request and maintenance plan is not approved prior to the attainment demonstration 

SIP submittal deadline of December 14, 2012. 

Monitoring of existing air quality indicates that the 1997 and 2006 National Ambient Air 

Quality Standard (NAAQS) for PM2.5 has been attained throughout this area based on 

2009-2011 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 Canton-Massillon area. 

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

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

Division of Transportation System Development-Modeling and Forecasting Section and 

the Stark County Area Transportation Study (SCATS) 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). 

50 West Town street, Suite 700 

P.O. Box 1049 

Columbus, OH 43216-1049 

614 1 644 3020 

614 1 644 3184 (fax) 

www.epa.ohio.gov 
Ohio EPA notified the public of the draft and the opportunity to provide comments on 

April 27, 2012. This notice was also published in a newspaper of general circulation in 

Canton, Ohio. The public hearing for this package was held on June 6, 2012 in 

Magnolia, Ohio. Testimony was provided and one set of comments were received; both 

in support of our request. 

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

Control at (614) 644-3696. 

Sincerely, 

/C~ Scott J. Nail~ Director 

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

Enclosure 
 

REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR 

THE CANTON-MASSILLON, OH 

ANNUAL AND 24-HOUR PM2.5 

NONATTAINMENT AREA 

Stark County, Ohio 

Prepared by: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

June 2012 
 

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 ii 

TABLE OF CONTENTS 

Chapter One 

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

Geographical description and background ................................................................................... 3 

Status of air quality ....................................................................................................................... 4 

Chapter Two 

Requirements for redesignation .................................................................................................... 5 

Chapter Three 

PM2.5 monitoring .......................................................................................................................... 10 

Annual and 24-Hour PM2.5 NAAQS ............................................................................................. 10 

Ambient data quality assured ...................................................................................................... 11 

Three complete years of data ..................................................................................................... 11 

Commitment to continue monitoring ........................................................................................... 18 

Chapter Four 

Emission inventory ...................................................................................................................... 19 

Base year inventory .................................................................................................................... 19 

Emission projections ................................................................................................................... 20 

Demonstration of maintenance ................................................................................................... 26 

Permanent and enforceable emissions reductions ..................................................................... 33 

Provisions for future update ........................................................................................................ 34 

Chapter Five 

Control measures and regulations .............................................................................................. 35 

Marginal nonattainment areas to implement RACM and RACT .................................................. 35 

Show Reasonable Further Progress (RFP) ................................................................................ 37 

Emission inventories ................................................................................................................... 37 

Implementation of past SIP revisions .......................................................................................... 38 

New source review provisions ................................................................................................... 40 

Assurance of continued controls ................................................................................................. 41 

Chapter Six 

Contingency measures ............................................................................................................... 42 

Commitment to revise plan ......................................................................................................... 42 

Commitment for contingency measures ..................................................................................... 42 

Potential contingency measures ................................................................................................. 43 

List of PM2.5, SO2, and NOx sources ........................................................................................... 44 

Chapter Seven 

Public participation ...................................................................................................................... 45 

Chapter Eight 

Conclusions ................................................................................................................................ 46 
 iii 

FIGURES 

Figure 1 Canton-Massillon 24-hour PM2.5 Exceedances ................................................... 9 

Figure 2 Map of the Canton-Massillon nonattainment area and monitor locations............ 11 

Figure 3 Canton-Massillon Area (Stark County) Highest 98th Percentile Value in the Year 

for the County ...................................................................................................... 15 

Figure 4 Ohio 24-Hour PM2.5: Design Values 1999-2001 Through 2008-2010 ................ 16 

Figure 5 PM2.5 Annual Mean Trends LADCO States ......................................................... 17 

Figure 6 PM2.5 Annual Mean Trends Midwest States ........................................................ 17 

Figure 7 PM2.5 Annual Mean National Trends ................................................................... 18 

TABLES 

Table 1 Monitoring Data for the Canton-Massillon area for 2009 – 2011 ......................... 13 

Table 2 Annual Standard Comparison Between Original and Imputed Values for Monitor 

39-151-0017 from 2003 to 2011 .......................................................................... 14 

Table 3 24-Hour Standard Comparison Between Original and Imputed Values for Monitor 

39-151-0017 from 2003 to 2011 .......................................................................... 14 

Table 4 Canton-Massillon Area (Stark County), Total Emissions Estimations for On-Road 

Mobile Sources .................................................................................................... 24 

Table 5 Mobile Vehicle Emissions Budget ....................................................................... 25 

Table 6 Reductions in SO2 and NOx EGU Emissions Between 2008 and 2009 ............. 29 

Table 7 Reductions in SO2 and NOx EGU Emissions Between the First Half of 2008 and 

2010..... ............................................................................................................... 29 

Table 8 Canton-Massillon Area (Stark County), Ohio PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) – Without 

CAIR.... ............................................................................................................... 31 

Table 9 Canton-Massillon Area (Stark County), Ohio NOx Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) - Without 

CAIR ....... ........................................................................................................... 31 

Table 10 Canton-Massillon Area (Stark County), Ohio SO2 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 2025 (tpy) - Without 

CAIR......... .......................................................................................................... 32 

Table 11 Canton-Massillon Area Comparison of 2008 attainment year and 2015 and 

2025 projected emission estimates (tpy). ...................................................... 32 

Table 12 Canton-Massillon Area Comparison of 2005 base year and 2008 

attainment year on-road and non-road reductions. ...................................... 34 
 iv 

APPENDICES 

A Air Quality System (AQS) Data 

B Ohio 2005 SIP Base Year Inventory Discussion 

C Mobile Source Emissions Inventory for the Canton-Massillon PM2.5 Nonattainment Area 

D LADCO Technical Support Document 

E Incomplete Monitoring Data Substitution Analysis 

F Public Participation Documentation 
 v 

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 1 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 

CANTON-MASSILLON 

ANNUAL AND 24-HOUR PM2.5 NONATTAINMENT AREA 

Stark County, Ohio 

CHAPTER ONE 

Introduction 

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

meet the annual and/or 24-hour PM2.5

1

 National Ambient Air Quality Standards 

(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. Then in 2006, U.S. EPA revised the NAAQS for particulate 

matter again, strengthening the primary 24-hour PM2.5 NAAQS from 65 μg/m3 to 

35 μg/m3, but retained the current primary annual PM2.5 NAAQS at 15.0 μg/m3. 

The revised 24-hour PM2.5 standard was published on October 17, 2006 (71 FR 

61144) and became effective on December 18, 2006. The revised 24-hour 

NAAQS is also based on the 3-year average of the 98th percentile of 24-hour 

concentrations. 

The 1997 revision of the 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 

 

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 

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. 

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

areas designations for the 1997 PM2.5 standards across the country. 

Modifications to those designations were made and an effective date was set at 

April 5, 2005. Subsequently, on November 13, 2009, U.S. EPA promulgated the 

initial PM2.5 nonattainment areas designations for the 2006 revised 24-hour PM2.5

standard across the country (effective December 14, 2009). 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. For the 1997 standards, this was due on April 5, 2008 and 

detailed how the PM2.5 standards will be attained by April 5, 2010. Ohio EPA 

submitted its attainment demonstration for the entire State of Ohio for the 1997 

standards on July 16, 2008. For the 2006 revised standard, attainment 

demonstration plans are due by December 14, 2012, detailing how the standard 

will be attained by December 14, 2014. However, areas that attain before the 

required date for submitting a plan may be exempt from certain otherwise 

applicable requirements. 

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: 

i) A determination that the area has attained the PM2.5 standard.

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

under Section 110(k).

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

permanent and enforceable reductions in emissions resulting 

from implementation of the SIP and other federal requirements.

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

v) A determination that all Section 110 and Part D requirements 

have been met. 
 3 

This document addresses each of these requirements, and provides additional 

information to support continued compliance with the 1997 annual and 2006 24-

hour PM2.5 standards 

The Canton-Massillon area has not previously been subject to nonattainment 

area rulemakings for fine particles. 

 

Geographical Description and Background 

The current Canton-Massillon nonattainment area is located in northeast Ohio 

and includes Stark County. This area is shown in Figure 2 under Chapter Three. 

As a result of the 2005 PM2.5 designations, U.S. EPA designated the CantonMassillon area nonattainment for the 1997 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 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 for the 1997 annual PM2.5 NAAQS submitted to U.S. EPA 

on July 16, 2008. 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” [74 FR 20856] (hereafter referred to as “1997 

Implementation Rule”). In the 1997 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 technical 

demonstration that emissions of VOCs significantly contribute to nonattainment 

of the annual PM2.5 standard. This is also consistent with U.S. EPA’s 

“Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National 

Ambient Air Quality Standards (NAAQS)” memorandum issued on March 2, 

2012 (hereafter referred to as “2006 Implementation Memo”). In this 

memorandum, U.S. EPA recommends that “the projected attainment inventory 

for the nonattainment area includes direct PM2.5, SO2, presumptively NOx, as 

well as other precursors that have been determined to be significant through the 

area’s SIP development process.” Furthermore, the 2006 Implementation Memo 

indicates that U.S. EPA believes the overall framework and policy approach of 

the 1997 Implementation Rule “continues to provide effective and appropriate 

guidance on the EPA’s interpretation of the general statutory requirements that 

states should address in their SIPs” and that they are “relevant to the statutory 

requirements” for the 2006 24-hour PM2.5 standard. 

 

2 There were no monitors in Ohio that violated the 1997 24-hour PM2.5 standard of 65μg/m3. 
 4 

As a result of the 2009 PM2.5 designations, U.S. EPA designated the CantonMassillon area nonattainment for the 35 μg/m3 24-hour standard. An attainment 

plan demonstration is not due until December 14, 2014. 

This document is intended to support Ohio’s request that the Canton-Massillon 

area be redesignated from nonattainment to attainment for the 1997 annual and 

2006 24-hour PM2.5 standards. 

Status of Air Quality 

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

recent three (3) years, 2009 through 2011, demonstrate that the air quality has 

met the NAAQS for annual and 24-hour PM2.5 standards in this nonattainment 

area. The NAAQS attainment, accompanied by decreases in emission levels 

discussed in Chapter Four, supports a redesignation to attainment for the 

Canton-Massillon area based on the requirements in Section 107(d)(3)(E) of the 

CAA as amended. 
 5 

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 

Canton-Massillon 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: 
 6 

• 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 across the state. 

 Chapters Four and Five discuss this requirement in more detail. 

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

 For purposes of redesignation, a 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 

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

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

implementing PM2.5.[72 FR 20589] 

 i.) Section 110(a) requirements 

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

requirements for a SIP. 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 

significant deterioration (PSD) and Part D, NSR permit 
 7 

programs; include criteria for stationary source emission 

control measures, monitoring, and reporting; include 

provisions for air quality modeling; and provides for public 

and local agency participation in planning and emission 

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

September 4, 2009 infrastructure SIP submissions, Ohio 

verified that the State fulfills the requirements of Section 

110(a)(2) of the Act. 

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. 

 ii.) Section 172(c) requirements 

 This Section contains general requirements for 

nonattainment plans. The requirements for reasonable 

further progress, identification of certain emissions 

increases, and other measures needed for attainment will 

not apply for redesignations because they only have 

meaning for areas not attaining the standards. 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 
 8 

 iii.) Conformity 

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

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

conformity requirements. The redesignation request should 

include conformity procedures, if the state already has 

these procedures in place. If a state does not have 

conformity procedures in place at the time that it submits a 

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

EPA’s conformity regulation upon issuance, as applicable. 

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

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

U.S. EPA must fully approve a 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. 

 U.S. EPA’s 2006 Implementation Memo states: 

As mentioned earlier in this memorandum, statewide annual 

emission inventories are required under 40 CFR Part 51, Subpart 

A. We expect that for many nonattainment areas, these annual 

inventories will serve as an appropriate starting point for the 

emission inventories used for SIP development. In contrast with 

the 1997 annual PM2.5 NAAQS, where states rely only on annual 

inventories in the implementation process, the 2006 24-hour PM2.5 

NAAQS is designed to protect against peak exposures. Thus, for 
 9 

the 2006 24-hour PM2.5 NAAQS, there are some circumstances in 

which EPA believes that seasonal inventories may be useful for 

SIP planning purposes. For example, we have observed that in 

some nonattainment areas, all of the highest fine particle 

concentrations over the course of a year occur in one season. 

If exceedances occur during only one season for each of the years 

on which the nonattainment designation is based, and this is the 

case for all subsequent years, we recommend that states develop 

a seasonal inventory and that they use this inventory for SIP 

planning purposes.... 

Ohio EPA analyzed the PM2.5 monitoring data for the Canton-Massillon 

area to determine whether the exceedances occurred in only one season. 

 As can be seen in Figure 1 below, exceedances between 2006 and 

2008, the years on which the nonattainment designation is based, 

occurred in the second and third quarters. During subsequent years, 

2009 through 2011, exceedances have occurred in the first, third and 

fourth quarters. Based on this analysis and in consultation with U.S. 

EPA, it was determined that an annual inventory would be sufficient for 

SIP planning, and that a seasonal inventory would not be required. 

Figure 1 – Canton-Massillon 24-hour PM2.5 Exceedances 

 Chapter Six discusses this requirement in more detail. 
 10 

CHAPTER THREE 

PM2.5 MONITORING 

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

Requirement 1 of 4 

A demonstration that the NAAQS for the annual and 24-hour PM2.5 standards as 

published in 40 CFR 50.7, have been attained. 

Background

 There are two monitors measuring PM2.5 concentrations in this 

nonattainment area. These monitors are operated by The Air 

Pollution Control Division of the Canton City Health Department4

. 

A listing of the design values based on the three-year average 

from 2009 through 2011 of the annual mean concentrations and of 

the 98th percentile 24-hour concentrations are shown in Table 1. 

The locations of the monitoring sites for this nonattainment area 

are shown on Figure 2. 

 

4 The Air Pollution Control Division of the Canton City Health Department is a Local Air Agency 

that contracts with Ohio EPA and receives grants from U.S. EPA to enforce state and local air pollution 

control regulations in the single-county region (Stark). 
 11 

Demonstration

 

Figure 2 - Map of the Canton-Massillon 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

Ohio EPA has quality assured all data shown in Appendix A in 

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

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

are available to the public. 

Requirement 3 of 4 

Based on data from all monitoring sites in the area or its affected downwind 

environs, a showing that the three-year average of the annual mean values are 

below 15.0 μg/m3

and a showing that the three-year average of the 98th

percentile of 24-hour concentrations are below 35 μg/m3

. (These showings must 

rely on three complete, consecutive calendar years of quality assured data.) 
 12 

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. 

 The 24-hour 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 24-hour 98th percentile values are 

less than or equal to 35 μg/m3. While calculating design values, 

one decimal place must be carried in the computations, with final 

values rounded to the nearest 1 μg/m3

. Decimals 0.5 or greater 

are rounded up, and those less than 0.5 are rounded down, so that 

35.49 μg/m3

 is the largest concentration that is less than, or equal 

to 35 μg/m3. Values at or below 35 μg/m3 meet the standard; 

values greater than 35 μg/m3

 exceed the standard. An area is in 

compliance with the 24-hour PM2.5 NAAQS only if every monitoring 

site in the area meets the NAAQS. An individual site's 3-year 

average of the 24-hour 98th percentile 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 2009 - 2011 that were 

retrieved from the U.S. EPA AQS. 
 13 

Demonstration

Table 1 - Monitoring Data for the Canton-Massillon area for 2009 – 

2011 

Site County

Annual Standard 24‐Hour Standard

Year Average

2009‐

2011

Year Average

2009‐

2009 2010 2011 2009 2010 2011 2011

39‐151‐

0017 Stark 13.1 14.4 12.8 13.4 30.0 33.0 28.1 30

39‐151‐

0020 Stark 11.9 13.8 11.3 12.3 27.5 32.2 23.1 28

   Less than 75% capture in at least one quarter

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

The design values calculated for the Canton-Massillon area shows that 

the annua land 24-hour PM2.5 NAAQS have been attained. However, one 

monitor site in Stark County (site 39-151-0017) did not meet the 75% data 

capture requirement in 2009. Specifically, the first quarter of 2009 

achieved only 67% capture due to operator error in setting the computer 

parameters for downloading the data which caused loss of some data in 

February and early March of 2009. 

Under 40 CFR Part 50, Appendix N, the use of less than complete data 

may be approved by U.S. EPA considering such factors as monitoring 

site closures/moves, monitoring diligence, and nearby concentrations in 

determining whether to use such data. With the exception of this 

occurrence, since 2009, this site and a second site in Stark County, have 

always met the 75% data capture requirement. 

However, in order to further demonstrate that this monitor has attained 

the standard, Ohio EPA prepared a statistical analysis of the annual and 

24-hour standards using multiple imputations. Ohio EPA has imputed 

missing values for this site and then performed an ordinary analysis as if 

the imputed values were real measurements. Multiple imputations use 

random draws from the conditional distribution of the target variable given 

the other variables. When a regression model is used for imputation, the 

process involves adding a random residual to the “best guess” for missing 

values, to yield the same conditional variance as the original variable. 

Appendix E describes, and includes, the full statistical analyses 

performed to show that the three-year average (2009 to 2011) of the 

annual mean values, based on missing data imputations, is 13.5 μg/m3

, 

below the 15.0 μg/m3

 annual standard. 
 14 

Table 2 shows site 39-151-0017 before and after the imputation of 

missing data. Also the “new” site (with imputed values) shows a passing 

annual design value for 2009 to 2011 of 13.5 μg/m3

. 

Table 2 – Annual Standard Comparison Between Original and 

Imputed Values for Monitor 39-151-0017 from 2003 to 2011 

Site ID County 2003 2004 2005 2006 2007 2008 2009 2010 2011 '03-'05 '04-'06 '05-'07 '06-'08 07-'09 '08-'10 '09-'11

OLD 39-151-0017 Stark 16.8 15.5 17.8 14.6 15.9 13.9 13.1 14.4 12.8 16.7 16.0 16.1 14.8 14.3 13.8 13.4

NEW 39-151-0017 Stark 16.8 15.2 17.8 14.6 15.4 14.2 13.2 14.4 12.8 16.6 15.9 15.9 14.7 14.3 13.9 13.5

Incomple data (quarter with <75% data capture)

Year Annual Design Value

With respect to the 24-hour standard, the same imputed data set from 

which the 2009 to 2011 annual design value was determined was also 

used to calculate a new 24-hour design value. From this revised data set, 

an updated, valid 24-hour design value for the 2009 to 2011period of 30 

μg/m3

 was determined, demonstrating that the monitor is below the 35 

μg/m3

 24-hour standard (see Appendix E for full statistical analyses). 

Table 3 shows site 39-151-0017 before and after the imputation of 

missing data. Also the “new” site (with imputed values) shows a passing 

24-hour design value for 2009 to 2011 of 30 μg/m3. 

Table 3 – 24-Hour Standard Comparison Between Original and 

Imputed Values for Monitor 39-151-0017 from 2003 to 2011 

39‐151‐17OLD 2003 2004 2005 2006 2007 2008 2009 2010 2011

Creditable Samples 111 106 111 111 89 67 320 111 336 2003‐2005 2004‐2006 2005‐2007 2006‐2008 2007‐2009 2008‐2010 2009‐2011

98th Percentile 34.2 36.3 47.6 32.2 33.4 37.9 30 33 28.1 39 39 38 35 34 34 30

39‐151‐17NEW 2003 2004 2005 2006 2007 2008 2009 2010 2011

Creditable Samples 111 122 111 111 113 119 334 111 336 2003‐2005 2004‐2006 2005‐2007 2006‐2008 2007‐2009 2008‐2010 2009‐2011

98th Percentile 34.2 36.3 47.6 32.2 33.4 38.1 30.3 33 28.1 39 39 38 35 34 34 30

<75% data capture in a least one quarter

Year includes one or more quarters with imputed values

Year

24‐hour Design Value

24‐hour Design Value

 

With the data imputation analysis and results, Requirement 3 of 4 has 

been met. 

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

declined due to cleaner automobiles and fuels, and controls for EGUs. 

National monitoring for PM2.5 began in 1999. With respect to CantonMassillon area, there has been a clear downward trend in monitored 

values: 
 15 

Figure 3 – Canton-Massillon Area (Stark County) Highest 98th

Percentile Value in the Year for the County 

The same trend is seen with respect to all Ohio monitors. 
 16 

Figure 4 - Ohio 24-Hour PM2.5: Design Values 1999-2001 Through 

2008-2010 

Source: WVDEP: http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: 

PM25dv20082010Final.xls 

The same trend is seen with respect to each of the Lake Michigan Air 

Directors Consortium (LADCO) states: 
 17 

Figure 5 - 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 6 - PM2.5 Annual Mean Trends Midwest States 

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

Design values have also trended downward nationally: 
 18 

Figure 7 - 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 commits to continue monitoring PM2.5 levels at the Ohio 

sites indicated in Figure 2 and Table 1. 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. Ohio EPA will continue to quality assure the monitoring 

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

requirements. Connection to a central station and updates to the 

Ohio EPA web site5

 will provide real time availability of the data 

and knowledge of any exceedances. Ohio EPA will enter all data 

into AQS on a timely basis in accordance with federal guidelines. 

 

5 www.epa.ohio.gov/dapc 
 19 

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

6

) representative of the year when 

the area achieves attainment of the annual and 24-hour PM2.5 air quality 

standards. 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 and 24-

hour PM2.5 standards; 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 of Stark County in the Canton-Massillon area. All of these inventories 

and emissions projections were prepared using similar methodologies. Mobile 

emissions inventories and projections for all counties were prepared by the Ohio 

Department of Transportation (ODOT) and the Stark County Regional Planning 

Commission (SCATS). 

Requirement 1 of 5 

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

base year. 

Background

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

reporting program. The 2005 periodic inventory has been identified 

as one of the preferred databases for SIP development and 

coincides with nonattainment air quality in the Canton-Massillon 

area. 

Periodic inventories, which include emissions from all sectors - 

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

three years. 

 

6 VOC and NH3 are not addressed. 
 20 

Demonstration

The 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 the Canton-Massillon 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 Canton-Massillon 

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 Report7

) 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 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, 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. Only PM2.5 and 

NOx necessitate an emissions inventory analysis. As 

documented in Ohio EPA’s attainment demonstration SIP, 

Ohio EPA in consultation with U.S. EPA determined mobile 

 

7 

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

trols%20Report_Final.pdf 
 21 

sources are insignificant contributors for SO2. Consistent 

with Ohio EPA’s attainment demonstration, Ohio EPA 

continues to consider mobile source SO2 to be an 

insignificant contributor to fine particles for this 

nonattainment area. Based on the demonstration below, 

SO2 constitutes less than sixteen percent (<16%) of the 

area’s total SO2 emissions in 2005 (15.8%), 2008 (5.1%), 

2015 (2.6%) and 2025 (2.4%). 

• Point source information was compiled from Ohio EPA’s 

2005 annual emissions inventory database and the 2005 

U.S. EPA Air Markets acid rain database8

. 

• 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 

vessels, and railroads. Recreational motorboat population 

and spatial surrogates (used to assign emissions to each 

county) were significantly updated. The populations for the 

construction equipment category were reviewed and 

updated based upon surveys completed in the Midwest, 

and the temporal allocation for agricultural sources also 

was updated. 

 

Demonstration 

On-Road Emission Estimations 

In coordination with the ODOT, SCATS utilizes a regional travel 

demand forecast model to simulate traffic in the area and to 

forecast traffic flows for given growth expectations. The model has 

been validated to observed traffic volumes for the model base year 

2000 (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), vehicle trips, and a U.S. EPA 

 

8 http://www.epa.gov/airmarkets/acidrain 
 22 

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 notice9 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 

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 

 

9 http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ab1f98
 23 

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 gramsper-vehicle). Output can be easily aggregated or disaggregated to 

examine emissions in a range of scales, from national emissions 

impacts down to the emissions 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. 

SCATS maintains a regional travel demand forecasting model for 

use in the urban transportation planning process. The model 

employs the traditional four-step modeling process to project 

existing and future traffic volumes and travel patterns on the 

regional transportation network. The four-step process consists of 

trip generation, trip distribution, modal split, and route assignment. 

Output from the urban models is link-by-link directional 24-hour 

traffic volumes. 

In 2000 SCATS, in cooperation with the Ohio Department of 

Transportation (ODOT), updated its travel demand model. The 

new model includes changes to the model interface to Cube 

Voyager, and improves model functionality. The changes primarily 

affected trip generation distribution functions in the SCATS region. 

Traffic analysis zones are the basic geographic units for estimating 

travel in Stark County. A variety of socio-economic data items are 

used in the SCATS transportation planning process. These data 

are used primarily to forecast future travel patterns by serving as 

independent variables in the Stark County trip generation 

equations. 

The principal data requirements of the SCATS travel demand 
 24 

forecasting model are population and employment, from these 

variables other characteristics including household, labor force, 

and personal vehicles may be derived. 

SCATS’s socioeconomic model variables reflect the current and 

expected future regional land uses. Independent variables are 

available for 4 analysis years (2005, 2008, 2015, and 2025), and it 

is possible to interpolate data for any year between available data 

sets. A summary of SCATS’s socio-economic data is available in 

Table 2. From that Table, population and households are expected 

to slightly increase over the planning period with employment 

making modest gains through 2025. Both population and 

employment are expected to decline in the older urban areas of 

the region as the trend to develop in the suburban fringes and rural 

areas continues. 

The SCATS network encompasses the entire PM2.5 nonattainment 

area. The modeling network includes all of Stark County, and 

portions of Mahoning, Columbiana, and Carroll counties. Traffic 

volumes on parts of the network outside of Stark County are 

excluded from the emissions analyses. 

Total emissions (post processing) were computed with the aid of 

several custom programs by ODOT. The process uses data on 

daily and directional traffic distributions as well as more up-to-date 

volume/delay functions from the 2000 Highway Capacity Manual 

(HCM). This process also uses rewritten code able to handle the 

newer model network formats and MOVES generated emission 

factors

On-Road Mobile Emission Estimations 

Table 3 contains the results of the emissions analysis for the appropriate 

years. All emissions estimations are expressed in tons per year (tpy). 

Table 4 - Canton-Massillon Area (Stark County), Total Emissions 

Estimations for On-Road Mobile Sources 

 2005 2008 2015 2025 

PM2.5 (tpy) 433.47 285.36 177.68 88.26

NOx (tpy) 14,004.65 10,947.26 6,767.79 4,064.20

SO2 (tpy) 191.33 45.99 20.84 19.24

VMT 2,876,507,695 2,670,278,315 2,801,480,485 3,010,820,030
 25 

Motor Vehicle Emission Budget 

Table 4 contains the motor vehicle emissions budgets for the 

Canton-Massillon area. 

Table 5 - Mobile Vehicle Emissions Budget 

 2015 

Estimated 

Emissions 

2015 Mobile 

Safety Margin 

Allocation* 

2015 Total 

Mobile 

Budget 

2025 

Estimated 

Emissions 

2025 Mobile 

Safety Margin 

Allocation* 

2025 Total 

Mobile 

Budget 

PM2.5 (tpy) 177.68 26.65 204.33 88.26 13.24 101.50

NOx (tpy) 6,767.79 1,015.15 7,782.84 4,064.20 609.63 4,673.83

*The 15 percent margin of safety was calculated by taking 15 percent of the mobile source emission 

estimates. 

The above budgets for the Canton-Massillon area, agreed upon as 

part of the interagency consultation process, include the emission 

estimates calculated for 2015 and 2025 (from Table 3) with an 

additional 15 percent margin of safety allocated to PM2.5 and NOx

in 2015 and 2025. 

In an effort to accommodate future variations in travel demand 

models and VMT forecast when no change to the network is 

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

reasonable approach to address this variation. Based on this 

discussion, a 15 percent margin of safety allocation was agreed 

upon and has been added to the emissions estimates for this 

nonattainment area. 

All methodologies, the latest planning assumptions, and the safety 

margins allocations were determined through the interagency 

consultation process described in the Transportation Conformity 

Memorandum of Understanding (MOU) among SCATS, Ohio 

DOT, and Ohio EPA. 

A 15 percent margin of safety is appropriate because: 1) there is 

an acknowledged potential variation in VMT forecast and potential 

estimated mobile source emissions due to expected modifications 

to TDM and mobile emissions models; and 2) the total decrease in 

emissions from all sources is sufficient to accommodate this 15 

percent allocation of safety margin (as defined in 40 CFR 

93.10110) to mobile sources while still continuing to maintain the 

total emissions in the Canton-Massillon area well below the 2008 

attainment level of emissions. 

 

 

10 "Safety margin" means the amount by which the total projected emissions from all sources of a given 

pollutant are less than the total emissions that would satisfy the applicable requirement for reasonable 

further progress, attainment, or maintenance.
 26 

The 15 percent margin of safety was calculated by taking 15 

percent of the mobile source emission estimates. Safety margin, 

as defined by the conformity rule, looks at the total emissions from 

all sources in the nonattainment area. The actual allocation is less 

than 15 percent of the total emission reduction from all sources as 

can be seen from Table 10. 

In summary, the mobile budget safety margin allocation translates 

into an additional 26.65 tpy for PM2.5 and 1,015.15 tpy for NOx for 

2015 and an additional 13.24 tpy for PM2.5 and 609.63 tpy for NOx

for 2025. 

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

93.101, discussed under “Requirement 3 of 5” below, it is evident 

this allocation is significantly below the total safety margin for this 

area. 

The current PM2.5 and NOx mobile budgets for the fine particle 

NAAQS will no longer be applicable either after the effective date 

of the approved redesignation or after the effective date of any 

U.S. EPA action approving a finding that the PM2.5 and NOx 

conformity budgets included in this submittal are adequate for 

transportation conformity purposes, whichever date comes first. 

Finally, it is important to underline that all motor vehicle emission 

budgets in this redesignation submittal, which are based on 

MOVES2010, will replace previous motor vehicle emission 

budgets on Attainment Demonstration submittals based on 

MOBILE6.2. 

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 2025 

as the maintenance year for this redesignation request. This 

document contains projected emissions inventories for 2015 and 

2025. 

Emission projections for the Canton-Massillon area were 

performed using the following approaches: 

• As performed by ODOT and SCATS mobile source 

emission projections are based on the U.S. EPA MOVES 

model. The analysis is described in more detail in Appendix 
 27 

C. All projections were made in accordance with 

“Procedures for Preparing Emissions Projections” U.S. 

EPA-45/4-91-019. 

• Emissions inventories are required to be projected to future 

dates to assess the influence growth and future controls will 

have. LADCO has developed growth and control files for 

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

to develop the future-year emissions estimates used in this 

document. This was done so the inventories used for 

redesignation are consistent with modeling performed in the 

future. Appendix D contains LADCO’s technical support 

document detailing the analysis used to project emissions 

(Base M11). 

• For the 2008 attainment year, emissions were grown from 

the 2005 LADCO modeling inventory, using LADCO’s 

growth factors, for all sectors except point sources 

(electrical generating units and non-electrical generating 

units). Point source emissions for 2008 were compiled from 

Ohio EPA’s 2008 annual emissions inventory database. 

The 2015 interim year emissions were estimated based on 

the 2005, 2009 and 2018 LADCO modeling inventory, using 

LADCO’s growth factors, for all sectors. The 2025 

maintenance year is based on emissions estimates from 

the 2018 LADCO modeling. 

The detailed inventory information for Canton-Massillon 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 Section 5 of 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 (Other); Marine; Aircraft; Rail 

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

Ohio EPA is identifying emissions projections for 2015 and 2025 

for EGUs without the implementation of the CAIR program. U.S. 

EPA has raised concerns regarding the CAIR program and its 

remand. Although CSAPR has been stayed by the D.C. Circuit 

Court (December 30, 2011), the Court has ordered U.S. EPA to 

 

11 http://www.ladco.org/tech/emis/current/index.php 
 28 

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. 

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 Ohio12. 

On December 23, 2008, U.S. EPA’s CAIR program was remanded 

without vacatur by the D.C. Circuit Court. As mentioned above, 

Ohio EPA has not incorporated these expected CAIR reductions 

into this redesignation request. It should also be noted that Ohio’s 

SIP-approved NOx SIP Call program and regulations are still in 

place. Ohio EPA is currently in the process of revising these 

regulations to provide a “back stop” for the reinstatement of the 

NOx SIP Call program in the event the CAIR program, or an 

equivalent, is no longer implemented by U.S. EPA. 

As can be seen in Table 5 below, Ohio has seen a significant 

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

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

and implementing control programs to address CAIR13 and 

consent decrees. 

 

12 http://www.epa.gov/CAIR/oh.html 

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

beginning in 2010.
 29 

Table 6 - 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 Tracking14

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 7 – 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 Tracking15 

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.”16 

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

CAIR program is providing real reductions at this time, Ohio 

believes these reductions have assisted with PM2.5 attainment 

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 

 

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

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

16 http://www.epa.gov/airmarkets/background.htm
 30 

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 Stark 

County will not have maintenance issues in 2014 even without 

CSAPR (or CAIR)17. 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. 

The detailed inventory information for the Canton-Massillon 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 (2025) 

projected emission totals are below the 2008 attainment year 

totals. 

Demonstration

 

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

Projected to have Ozone and/or Fine Particle Air Quality Problems.” 
 31 

PM2.5

Table 8 - Canton-Massillon Area (Stark County), Ohio PM2.5

Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2025 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 380.10 378.14 373.57 362.61 15.53 

Non-road 231.64 203.73 156.01 85.22 118.51 

Area 370.87 376.97 373.34 370.83 6.14 

MAR 14.58 12.91 8.12 6.00 6.91 

On-road 433.47 285.36 177.68 88.26 197.10 

TOTAL 1,430.66 1,257.11 1,088.72 912.92 344.19 

NOx

Table 9 - Canton-Massillon Area (Stark County), Ohio NOx

Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2025 (tpy) - 

Without CAIR 

Sector 2005 Base 2008 

Attainment 2015 Interim 

2025 

Maintenan

ce 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 1,129.41 1,118.36 1,092.56 1,045.93 72.43 

Non-road 2,801.96 2,322.49 1,449.53 1,092.96 1,229.53 

Area 1,313.88 1,328.46 1,335.60 1,336.73 -8.27

MAR 537.27 510.69 355.84 282.85 227.84 

On-road 14,004.65 10,947.26 6,767.79 4,064.20 6,883.06 

TOTAL 19,787.17 16,227.26 11,001.32 7,822.67 8,404.59 

SO2
 32 

Table 10 - Canton-Massillon Area (Stark County), Ohio SO2

Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2025 (tpy) - 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2025 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 553.14 564.92 592.40 604.18 -39.26

Non-road 261.01 95.96 16.06 3.61 92.35 

Area 163.72 162.13 153.53 141.99 20.14 

MAR 38.35 37.79 30.06 26.28 11.51 

On-road 191.33 45.99 20.84 19.24 26.75 

TOTAL 1,207.55 906.79 812.89 795.30 111.49 

PM2.5, NOx, and SO2

Table 11 - Canton-Massillon Area Comparison of 2008 attainment year 

and 2015 and 2025 projected emission estimates (tpy) 

 

2008 Base 2015 

Interim 

2015 Projected 

Decrease 

2025 

Maintena

nce 

2025 Projected 

Decrease 

PM2.5 1,257.11 1,088.72 168.39 912.92 344.19

NOx 16,227.26 11,001.32 5,225.94 7,822.67 8,404.59

SO2 906.79 812.89 93.90 795.30 111.49

 

As shown in the table above (Table 10), PM2.5 emissions in the 

nonattainment area are projected to decrease by 168.39 tpy in 

2015 and 344.19 tpy in 2025. NOx emissions in the nonattainment 

area are projected to decrease by 5,225.94 tpy in 2015 and 

8,404.59 tpy in 2025. SO2 emissions in the nonattainment area are 

projected to decrease by 93.90 tpy in 2015 and 111.49 tpy in 

2025. 

In some cases, non-EGU point sources show an increase due to 

expectations that the population will grow in this area; however, 

cleaner vehicles and fuels are expected to be in place in 2009 and 

2018, and 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 

Requirements18, Highway Heavy-Duty Engine Rule19, and the 

 

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

19 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 
 33 

Non-Road Diesel Engine Rule20 are factored into the changes. 

All projections (PM2.5, SO2, and NOx) do not take into account 

reductions expected from the CAIR. In many cases, Ohio utilities 

subject to CAIR have already, or will be installing controls and 

reducing NOx and SO2 emissions beyond those projected for 

EGU’s above. 

As can be seen from the projected decreases above, even in the 

absence of consideration of reductions resulting from CAIR or 

CSAPR, the area will be able to maintain the standard.

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 2009-2011. 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 and 24-hour PM2.5

standards. Some of these reductions were due to the application of 

tighter federal standards on new vehicles and application of tighter federal 

standards on non-road diesel vehicles (Clean Air Non-road Diesel Rule). 

Reductions achieved are discussed in greater detail under Chapter Five. 

Table 12 - Canton-Massillon Area Comparison of 2005 base year 

and 2008 attainment year on-road and non-road 

reductions 

2005 2008 

On-road PM2.5 433.47 285.36 

On-road NOx 14,004.65 10,947.26 

 

20 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 
 34 

On-road SO2 191.33 45.99 

Non-road PM2.5 231.64 203.73 

Non-road NOx 2,801.96 2,322.49 

Non-road SO2 261.01 95.96 

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 and 24-hour PM2.5 standards. 
 35 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 6

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

nonattainment areas to implement RACM and RACT. 

Background

Section 172(c)(1) of the 1990 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 1997 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 1997 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 control measures for particulate emissions 

from stationary sources. 

Statewide RACT rules have been applied to all new sources 

locating in Ohio since that time. RACT requirements are 

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio EPA 
 36 

also has an active enforcement program to address violations 

discovered by field office staff. The Ohio RACT rules for 

particulate matter are found in OAC Chapter 3745-1721. 

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

Chapter 3745-1422), CAIR (OAC Chapter 3745-10923), and NOx

Reasonably Available Control Technology rules (OAC Chapter 

3745-11024) 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 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 papers25

researching different stationary source categories. The results 

were compiled into two reports26. The second consultant, Environ, 

investigated control options for mobile sources. The results were 

compiled into two reports27. 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 

developed28. 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, 

 

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

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

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

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

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

26 

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 

27

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

28 http://www.ladco.org/reports/control/modeling/round4_modeling.pdf
 37 

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

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 1997 Implementation Rule requires RFP only for any 

area which a State projects an attainment date beyond 2010 for 

the annual standard and beyond 2014 for the 24-hour standard. If 

a State demonstrates attainment will occur by 2010 (annual 

standard) or 2014 (24-hour standard) or earlier, U.S. EPA 

considers the attainment demonstration to demonstrate 

achievement of RFP. However, if a State attains the standard 

prior to the requirement to submit an attainment demonstration 

(2012 in the case of the 24-hour standard), an attainment 

demonstration is not required. 

Demonstration

In Ohio’s attainment demonstration for the annual standard was 

submitted on July 18, 2008. Ohio demonstrated (using a weight of 

evidence approach) that attainment of the annual standard would 

be achieved in this area by 2009; and therefore, it was not 

necessary to submit a separate RFP plan under the annual 

standard. 

With respect to the 24-hour standard, this area attained the 

standard prior to the deadline for submitting an attainment 

demonstration; 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
 38 

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. 

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 
 39 

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 

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 

3745-1429 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 

 

29 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 
 40 

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. 

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-

3130. The Chapter includes provisions for the Prevention of 

Significant Deterioration (PSD) permitting program in OAC rules 

 

30 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx 
 41 

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

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 and 24-hour PM2.5

standards in the Canton-Massillon 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 Canton-Massillon area. 
 42 

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 or whenever a 98th percentile 24-hour PM2.5

concentration of 35.5 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. 
 43 

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 

occurs or whenever a two-year average of the 98th percentile 24-

hour PM2.5 concentration of 35.0 μg/m3 or greater 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 or 

three-year average of the 98th percentile 24-hour PM2.5 

concentration of 35.0 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 

both annual and 24-hour 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 
 44 

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 

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; 

• process heaters; 

• internal combustion engines; 

• combustion turbines; 

• other sources greater than 100 tons per year; 

• fleet vehicles; 

• concrete manufacturers; 

• aggregate processing plants; 
 45 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in the 

widely distributed county publications. 

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

on June 6, 2012, at Stark Co Library, Sandy Valley Branch, 9754 Cleveland 

Avenue SE Magnolia, Ohio. The public comment period closed on June 6, 2012. 

 Appendix F includes a copy of the public notice, certification of publication, 

comments received and the transcript from the public hearing. 
 46 

CHAPTER EIGHT 

CONCLUSIONS

The Canton-Massillon annual and 24-hour PM2.5 nonattainment area has 

attained the 1997 annual and 2006 24-hour 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 Canton-Massillon annual and 24-hour 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 Canton-Massillon annual and 24-

hour 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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