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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 S IP for the 24-hour standard w i ll not be applicable in the event the redesignation request and maintenance p la n 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. Emiss io ns projections ind ica te that current controls, existing State rules, existing federal ru les, 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
reduct ions in point and mobile sources since ambient exceedances have occurred. A significant port i on of the improved air quality can be attributed to federal programs for
the mobile source sector, the regional reductions associated with the NOx Trad i ng Program, and the Clean Ai r Interstate Rule (CAIR).

50 West T own street, Suite 700 P.O. Box 1049 Columbus, OH 43216-1049 614 1 644 3020 614 1 644 3184 (fax)

www .epa.ohio .govOhio 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 PM 2.5 

# NONATTAINMENT AREA

Stark County, Ohio

Prepared by: Ohio Environmental Protection Agency Division of Air Pollution Control

June 2012This page left intentionally blankii 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
PM 2.5 monitoring ................................................................................................................... ....... 10 Annual and 24-Hour PM 2.5 NAAQS ............................................................................................. 10 Ambient data quality assured ...................................................................................................... 11 Three complete years of data .................................................................................................. ... 11 Commitment to continue monitoring ........................................................................................... 1 8

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 PM 2.5 , SO 2 , and NO
x sources ........................................................................................... 44

Chapter Seven Public participation .......................................................................................................... ............ 45

Chapter Eight Conclusions ................................................................................................................... ............. 46iii 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 PM 2.5 Annual Mean Trends LADCO States ......................................................... 17 Figure 6 PM 2.5 Annual Mean Trends Midwest States ........................................................ 17 Figure 7 PM 2.5 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 . ...................................... 34iv APPENDICES

A Air Quality System (AQS) Data B Ohio 2005 SIP Base Year Inventory Discussion C Mobile Source Emissions Inventory for the Canton-Massillon PM 2.5 Nonattainment Area D LADCO Technical Support Document E Incomplete Monitoring Data Substitution Analysis F Public Participation Documentationv This page left intentionally blank1 REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE CANTON-MASSILLON
ANNUAL AND 24-HOUR PM 2.5 NONATTAINMENT AREA

Stark County, Ohio



### CHAPTER ONE

Introduction The Clean Air Act (CAA), as amended, requi res each State with areas failing to meet the annual and/or 24-hour PM 2.5 1 National Ambient Air Quality Standards (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard. The United St ates Environmental Protection Agency (U.S. EPA) revised the NAAQS for particula te matter in July 1997. It replaced the existing PM 10 standard with a health-based PM 2.5 standard and retained the PM 10 standard as a particulate standard protecting welfare. The stan dards include an annual standard set at 15.0 microgr ams per cubic meter (μg/m 3 ), based on the 3-year average of annual mean PM 2.5 concentrations, and a 24-hour standard of 65 μg/m 3 , based on the 3-year average of the 98 th percentile of 24-hour concentrations. Then in 2006, U.S. EPA revised the NAAQS for particulate matter again, strengthening the primary 24-hour PM 2.5 NAAQS from 65 μ g/m 3 to 35 μ g/m 3 , but retained the cu rrent primary annual PM 2.5 NAAQS at 15.0 μ g/m 3

. The revised 24-hour PM 2.5 standard was published on October 17, 2006 (71 FR 61144) and became effective on Decem ber 18, 2006. The revised 24-hour NAAQS is also based on the 3-year average of the 98 th percentile of 24-hour concentrations.

The 1997 revision of the NAAQS was lega lly challenged in the U.S. Court of Appeals for the District of Columbia Circu it (the D.C. Circuit ). On May 14, 1999, the D.C. Circuit remanded, without vacatu r, 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 wh ich 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 affi rmed 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 acid s (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 PM 2.5 describes particulate matter that is 2. 5 micrometers in diameter and smaller - 1/30 th the diameter of a human hair. Fine particle pollution can be emitt ed directly or formed secondarily in the atmosphere.2 provision but did remand several other iss ues back to the D.C. Circuit, including the issue of whether U.S. EPA acted arbitrarily and capric iously 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 arbitr arily and capriciously in setting the levels of the standards.

On December 17, 2004, U.S. EPA promulgated the initial PM 2.5 nonattainment areas designations for the 1997 PM 2.5 standards across the country. Modifications to those designations we re made and an effective date was set at April 5, 2005. Subsequently, on Novem ber 13, 2009, U.S. EPA promulgated the initial PM 2.5 nonattainment areas designations for the 2006 revised 24-hour PM 2.5 standard across the country (effective Dece mber 14, 2009). Unli ke Subpart 2 of the CAA Amendments of 1990 which defined five ozone nonattainment classifications for the areas that exceed the NAAQS based on th e severity of the ozone levels, PM 2.5 nonattainment designations are simply labeled “nonattainment.” The CAA Amendm ents require states with PM 2.5 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 PM 2.5 standards will be attained by April 5, 2010. Ohio EPA submitted its attainment demonstration fo r the entire State of Ohio for the 1997 standards on July 16, 2008. For t he 2006 revised standard, attainment demonstration plans are due by December 14, 2012, detailing how the standard will be attained by December 14, 2014. Howe ver, areas that attain before the required date for submitting a plan ma y be exempt from certain otherwise applicable requirements.

Section 107(d)(3)(E) of the CAA allows st ates to request nonattainment areas to be redesignated to attainment provided cert ain criteria are met. The following are the criteria that must be met in or der for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has attained the PM 2.5 standard. ii) An approved State Im plementation Plan (SIP) for the area under Section 110(k). iii) A determination that the improv ement 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 Sect ion 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 PM 2.5 standards

The Canton-Massillon area has not prev iously 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. Th is area is shown in Figur e 2 under Chapter Three.

As a result of the 2005 PM 2.5 designations, U.S. EPA designated the CantonMassillon area nonattainment for the 1997 15.0 μg/m 3 annual standard 2 , and Ohio EPA was required to develop a plan to reduce oxides of nitrogen (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and to demonstrate that the area will meet the federal annual air quality standard by April 5, 2010. Ohio’s main
PM 2.5 components are primary particles (or ganic carbon, crustal material, and elemental carbon), SO 2 and NO x , which were included in the attainment demonstration analysis for the 1997 annual PM 2.5 NAAQS submitted to U.S. EPA on July 16, 2008. Volatile organic compounds (VOCs) and ammonia (NH 3 ) were not included in the analysis since they were not part of Ohio’s current attainment strategy for PM 2.5 (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 Impl ementation Rule U. S. EPA presumes NH3 emissions are not a PM 2.5 attainment plan precurso r and that States are not required to address VOC unless the State or U.S. EPA makes technical demonstration that emissions of VOCs si gnificantly contribute to nonattainment of the annual PM 2.5 standard. This is also consistent with U.S. EPA’s “Implementation Guidance for t he 2006 24-Hour Fine Particle (PM 2.5 ) National Ambient Air Quality Standards (NAAQ S)” memorandum issued on March 2, 2012 (hereafter referred to as “2006 Im plementation Memo”). In this memorandum, U.S. EPA recomm ends that “the projected attainment inventory for the nonattainment area includes direct PM 2.5 , SO 2 , presumptively NO x , as well as other precursors that have been determined to be significant through the area’s SIP development process.” Furt hermore, the 2006 Implementation Memo indicates that U.S. EPA believes the ov erall framework and policy approach of the 1997 Implementation Rule “continues to provide effective and appropriate guidance on the EPA’s interpretation of t he general statutory requirements that states should address in their SIPs” and that they are “relevant to the statutory requirements” for the 2006 24-hour PM 2.5 standard.

2 There were no monitors in Ohio that violated the 1997 24-hour PM 2.5 standard of 65μg/m 3

.4 As a result of the 2009 PM 2.5 designations, U.S. EPA designated the CantonMassillon area nonattainment for the 35 μg/m 3 24-hour standard. An attainment plan demonstration is not due until December 14, 2014.

This document is intended to support Oh io’s request that the Canton-Massillon area be redesignated from nonattainment to attainment for the 1997 annual and 2006 24-hour PM 2.5 standards.

Status of Air Quality
PM 2.5 complete quality-assured ambient ai r 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 PM 2.5 standards in this nonattainment area. The NAAQS attainment, accompani ed by decreases in emission levels discussed in Chapter Four, supports a redesignation to attainment for the Canton-Massillon area based on the requirem ents in Section 107(d)(3)(E) of the CAA as amended.5 

### CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed gui dance 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 pl an are based on the redesignation guidance, supplemented with additional guidanc e received from staff of U.S. EPA Region 5.

Below is a summary of each redesignat ion 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 am bient air quality data. The data that are used to demonstrate atta inment should be the product of ambient monitoring that is repr esentative of t he 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 avail able to the public for review.

The second component relie s 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 A ppendix D contains the most recent modeling results sho wing future attainment and maintenance are provided. C hapter Three discusses this requirement in more detail and provides the attainment demonstration.

ii.) Permanent and enforceable improvem ent in air quality (CAA Section 107(d)(3)(E)(iii)) The state must be able to reasonabl y attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should es timate the percent reduction achieved from federal m easures as well as control measures that have been adopted and implement ed 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 rule s recently that will have an impact on statewide PM 2.5 emissions in the future:6 • Clean Air Interstate Rule (CAIR)

• NO x SIP Call Rules

Ohio was also subject to a F ederal Implementati on Plan under the CAIR replacement rule, the Cr oss-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 hav e 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 st ate 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 nonat tainment based on a violation of the NAAQS. Subpart 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 ). However, for the pur pose of implementing the
PM 2.5 standards, U.S. EPA’s 1997 Impl ementation Rule stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 .[72 FR 20589]

i.) Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Secti on 110(a)(2) provides that the implementation plan submitt ed 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 limitat ions and other control measures, means or techniques necessary to meet the requirements of the CAA; pr ovide for establishment and operation of appropriate dev ices, methods, systems and procedures necessary to m onitor ambient air quality; provide for implementation of a source permit program to regulate the modification and cons truction of any stationary source within the areas co vered by the plan; include provisions for the implementati on of Part C, prevention of significant deterioration (PSD) and Part D, NSR permit7 programs; include criteria fo r stationary source emission control measures, monito ring, and reporting; include provisions for air quality mode ling; 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 requi res State plans to prohibit emissions from within t he State which contribute significantly to nonattainment or maintenance areas in any other State, or which interf ere with programs under Part C to prevent significant deterio ration of air quality or to achieve reasonable progress towa rd the national visibility goal for Federal class I areas (national parks and wilderness areas). In order to assist States in addressing their obligations regarding r egionally transported pollution, U.S. EPA finalized CAIR to reduce SO 2 and NO x emissions from large electric generating units (EGU). Ohio has met the requirements of the f ederal CAIR to reduce NO x and SO 2 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 3745-109 3 . On July 6, 2011, U.S. EPA finalized a replacement to t he CAIR program, the CSAPR. CSAPR could further assist States in addressing their obligations regarding regiona lly transported pollution by providing reductions in NO x and SO 2 emissions in 2012 and 2014. However, on December 30, 2011, the D.C. Circuit Court stayed CSAPR and order ed 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 r equirements for reasonable further progress, identificat ion of certain emissions increases, and other measur es needed for attainment will not apply for redesignations because they only have meaning for areas not atta ining the standards. The requirements for an emission in ventory 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#3745-1098 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 ma intenance 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) furt her 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 d eems necessary to ensure prompt correction of any violation of t he NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all meas ures 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 requir ed under 40 CFR Part 51, Subpart A. We expect that for many nonattainment areas, these annual inventories will serve as an appropr iate starting point for the emission inventories used for SIP development. In contrast with the 1997 annual PM 2.5 NAAQS, where states rely only on annual inventories in the implementati on process, the 2006 24-hour PM 2.5 NAAQS is designed to protect against peak exposures. Thus, for9 the 2006 24-hour PM 2.5 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 dur ing only one season for each of the years on which the nonattainment designat ion 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 PM 2.5 monitoring data for the Canton-Massillon area to determine whether the exceedanc es occurred in only one season. As can be seen in Figure 1 below, exceedances between 2006 and 2008, the years on which the nonatta inment designation is based, occurred in the second and third quar ters. During subsequent years, 2009 through 2011, exceedances have o ccurred 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 in ventory would not be required.

Figure 1 – Canton-Massillon 24-hour PM 2.5 Exceedances

Chapter Six discusses this requirement in more detail.10 

### CHAPTER THREE

PM 2.5 MONITORING CAA Section 107(d)(3)(E)(i)

Requirement 1 of 4 A demonstration that the NAAQ S for the annual and 24-hour PM 2.5 standards as published in 40 CFR 50.7, have been attained.

Background There are two monitors measuring PM 2.5 concentrations in this nonattainment area. These monitors are operated by The Air Pollution Control Division of the Canton City Health Department 4

. A listing of the design values based on the three-year average from 2009 through 2011 of the annual mean concentrations and of the 98 th percentile 24-hour concentrati ons 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 fr om 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 assur ed in accordance with 40 CFR 58.10, recorded in the U.S. EPA air quality syst em (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 ot her federal requirements. Ohio EPA has recorded the data in the AQ S 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 t he three-year average of the annual mean values are below 15.0 μg/m 3 and a showing that the thr ee-year average of the 98 th percentile of 24-hour concent rations are below 35 μg/m 3 . (These showings must rely on three complete, consecutive ca lendar years of quality assured data.)12 Background The following information is taken from U.S. EPA's "Guidelineon Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999.

In accordance with the CAA Amendm ents, three comp lete years of monitoring data are required to demonstrate attainment at a monitoring site.

The annual PM 2.5 primary and secondary ambient air quality standards are met at an ambient ai r quality monitoring site when the three-year average of t he annual average is less than 15.0 μg/m 3 . While calculating design values, three significant digits must be carried in the computati ons, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, and those less than 0.05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than, or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard; values equal to or great er than 15.1 μg/m 3 exceed the standard. An area is in compliance with the annual PM 2.5 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 PM 2.5 primary and secondary ambient air quality standards are met at an ambient ai r quality monitoring site when the three-year average of the 24-hour 98th per centile values are less than or equal to 35 μg/m 3 . While calculating design values, one decimal place must be carried in the computations, with final values rounded to the nearest 1 μg/m 3 . Decimals 0.5 or greater are rounded up, and those less than 0.5 are rounded down, so that 35.49 μg/m 3 is the largest concentration that is less than, or equal to 35 μg/m 3 . Values at or below 35 μg/m 3 meet the standard; values greater than 35 μg/m 3 exceed the standard. An area is in compliance with the 24-hour PM 2.5 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. T he 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

‐ 2011 2009 2010 2011 2009 2010 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 t he Canton-Massillon area shows that the annua land 24-hour PM 2.5 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. Spec ifically, the first quarter of 2009 achieved only 67% capture due to operator error in setting the computer parameters for downloading the data whic h caused loss of some data in February and early March of 2009.

Under 40 CFR Part 50, Appendix N, t he use of less than complete data may be approved by U.S. EPA consider ing such factors as monitoring site closures/moves, monitoring d iligence, 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 demonstr ate that this monitor has attained the standard, Ohio EPA prepared a st atistical 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 measur ements. Multiple imputations use random draws from the conditional distri bution 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/m 3

, below the 15.0 μg/m 3 annual standard.14 Table 2 shows site 39-151-0017 befor e 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/m 3

.

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) Annual Design Value Year

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 va lue. From this revised data set, an updated, valid 24-hour design val ue for the 2009 to 2011period of 30 μg/m 3 was determined, demonstrating that the monitor is below the 35 μg/m 3 24-hour standard (see Appendix E for full statistical analyses).

Table 3 shows site 39-151-0017 befor e 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/m 3

.

Table 3 – 24-Hour Standard Comparison Between Original and Imputed Values for Monitor 39-151-0017 from 2003 to 2011

39

‐ 151

‐ 17 OLD 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

‐ 17 NEW 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 re sults, 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 PM 2.5 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 98 th 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 PM 2.5 : 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 - PM 2.5 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 - PM 2.5 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 - PM 2.5 Annual Mean National Trends

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

Requirement 4 of 4 A commitment that once redesignated, the state will cont inue to operate an appropriate monitoring network to verify the maintenance of the attainment

status.

Demonstration Ohio EPA commits to continue monitoring PM 2.5 levels at the Ohio sites indicated in Figure 2 and T able 1. Ohio EPA will consult with U.S. EPA Region 5 prior to ma king 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 c entral station and updates to the Ohio EPA web site 5 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 a ccordance with federal guidelines.

5 www. epa.ohio.gov/dapc19 

### 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 PM 2.5 precursor emissions (primary par ticles (organic carbon, crustal matter, and elemental carbon), SO 2 and NO x 6 ) representative of the year when the area achieves attainm ent of the annual and 24-hour PM 2.5 air quality standards. Ohio also must demonstrate t hat the improvement in air quality between the year that violations occu rred and the year that attainment was achieved is based on permanent and enfor ceable emission reductions. Other emission inventory related requirements include a projection of the emission inventory to a year at least 10 year s following redesignati on; a demonstration that the projected level of emissions is sufficient to maintain the annual and 24- hour PM 2.5 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 mob ile (on-road) emi ssions inventory and projections, identifies procedures us ed 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 a ll 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 PM 2.5 , SO 2 and NO x completed for the base year.

Background The point source data are tak en from Ohio's annual emissions reporting program. The 2005 periodi c inventory has been identified as one of the preferred databas es for SIP development and coincides with nonattainment air quality in the Canton-Massillon

area.

Periodic inventories, which incl ude emissions from all sectors - mobile, area, non-road, and point sources - are prepared every three years.

6 VOC and NH 3 are not addressed.20 Demonstration The 2005 inventory is used as t he base year for the purpose of this submittal and was submitt ed to U.S. EPA with Ohio’s PM 2.5 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 PM 2.5, SO 2 and NO x 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 in ventory for the Canton-Massillon area including area, mobile, and point sources for PM 2.5 , SO 2 and NO x for base year 2005. The 2005 inventory wa s submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM 2.5 attainment demonstration SIP for this area. The information below describes the procedures Ohio EPA used to generate the 2005 base year invent ory and to develop SIP-ready modeling inventories and future y ear projections (Pechan Report 7 ) 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 in ventories were provided to the LADCO and have been processed to develop average daily emissions for use in the air quality analyses. Thes e processed modeling inventories have been identified as the correct iterat ion of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organizati on. 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 submi tted 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 PM 2.5 and NO x necessitate an emissions inventory analysis. As documented in Ohio EPA’s atta inment demonstration SIP, Ohio EPA in consultation with U.S. EPA determined mobile

7 http://www.ladco.org/tech/emis/r5/r eports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con trols%20Report_Final.pdf21 sources are insignificant contributors for SO 2 . Consistent with Ohio EPA’s attainment demonstration, Ohio EPA continues to consider mobile source SO 2 to be an insignificant contributor to fine particles for this nonattainment area. Based on the demonstration below, SO 2 constitutes less than sixt een percent (<16%) of the area’s total SO 2 emissions in 2005 (15.8%), 2008 (5.1%), 2015 (2.6%) and 2025 (2.4%).

• Point source information wa s compiled from Ohio EPA’s 2005 annual emissions inv entory database and the 2005 U.S. EPA Air Markets acid rain database 8

.

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generated using U.S. EPA’s National Mobile Inventory M odel (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 emi ssions for three (3) non-road categories not included in U.S. EPA’s non-road model. Emissions were estimated fo r aircraft, commercial marine vessels, and railroads. Recreat ional motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment cat egory were reviewed and updated based upon surveys completed in the Midwest, and the temporal allocation fo r agricultural sources also was updated.

Demonstration

On-Road Emission Estimations In coordination with the ODOT, SC ATS 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 trav el capacity may be needed and to determine the infrastructure require ments necessary to meet that need. It is also used as a tool fo r air quality purposes to estimate the total emissions of pollution caus ed 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/acidrain22 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 notice 9 of availability on March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions Simulator), hereafter referred to as MOVES. Upon publication of the Federal Register notic e, MOVES became U.S. EPA’s approved motor vehicle emission factor model for estimating VOCs, NO x , CO, PM 10 and PM 2.5 and other pollutants and precursors from cars, trucks, mo torcycles, and buses by state and local agencies. MOVES is a com puter program designed by the U.S. EPA to estimate air pollution emissions from mobile sources. MOVES replaces U.S. EPA’s prev ious emissions model for onroad mobile sources, MOBI LE6.2. MOVES can be used to estimate exhaust and evaporative em issions as well as brake and tire wear emissions from all types of on-road vehicles.

The CAA requires U.S. EPA to regul arly update its mobile source emission models. U.S. EPA c ontinuously collects data and measures vehicle emissions to ma ke 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 seve ral changes to the U.S. EPA’s approach to mobile source emission modeling based upon recommendations made to the A gency by the National Academy of Sciences.

U.S. EPA believes that MOVES s hould 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 ava ilable when a SIP is developed.

Regarding transportation confo rmity, 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 appr oach (when compared with the previous MOBILE model) to mode ling allows U.S. EPA to easily incorporate large amount s of in-use data from a wide variety of

9 http://www.r egulations.gov/search/Regs/hom e.html#document Detail?R=0900006480ab1f9823 sources, such as data from v ehicle inspection and maintenance (I/M) programs, remote sensing dev ice (RSD) testing, certification testing, portable emission meas urement systems (PEMS), etc. This approach also allows users to incorporate a variety of activity data to better estimate emissi on differences such as those resulting from changes to vehicle speed and acceleration patterns. MOVES has a graphical user interfac e which allows users to more easily set up and run the m odel. MOVES database-centered design provides users much gr eater flexibility regarding output choices. Unlike earlier models whic h 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-pe r-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 impac ts of individual transportation projects. The database-centered des ign also allows U.S. EPA to update emissions data incorporat ed in MOVES more easily and will allow users to incorporate a mu ch wider array of activity data to improve estimation of loca l emissions. For example, the improvements in MOVES will allow project-level PM 2.5 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-st ep modeling process to project existing and future traffic volu mes 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 wit h the Ohio Department of Transportation (ODOT), updated it s travel demand model. The new model includes changes to the model interface to Cube Voyager, and improves model func tionality. The changes primarily affected trip generation di stribution functions in the SCATS region.

Traffic analysis zones are the basic geographic units for estimating travel in Stark County. A variet y of socio-economic data items are used in the SCATS transportati on planning process. These data are used primarily to forecast futu re travel patterns by serving as independent variables in the St ark County trip generation equations.

The principal data requirement s of the SCATS travel demand24 forecasting model are populati on 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 fo r any year between available data sets. A summary of SCATS’s soci o-economic data is available in Table 2. From that Table, population and households are expected to slightly increase over t he planning period with employment making modest gains through 2025. Both population and employment are expected to decli ne 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 PM 2.5 nonattainment area. The modeling network incl udes 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 OD OT. The process uses data on daily and directional traffic distributi ons 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 t he emissions analysis for the appropriate years. All emissions estimations are expressed in tons per year (tpy).

Table 4 - Canton-Massillon Area (S tark County), Total Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2025

PM 2.5 (tpy) 433.47 285.36 177.68 88.26

NO x (tpy) 14,004.65 10,947.26 6,767.79 4,064.20
SO 2 (tpy) 191.33 45.99 20.84 19.24
VMT 2,876,507,695 2,670,278,315 2,801,480,485 3,010,820,03025 Motor Vehicle Emission Budget

Table 4 contains the motor v ehicle 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 consultati on process, include the emission estimates calculated for 2015 and 2025 (from Table 3) with an additional 15 percent margin of safety allocated to PM 2.5 and NO x 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 wit h 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 planni ng 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 emissi ons due to expected modifications to TDM and mobile emissions model s; and 2) the to tal decrease in emissions from all sources is su fficient to accommodate this 15 percent allocation of safety margin (as defined in 40 CFR
93.101 10 ) 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 t he amount by which the total projected em issions from all sources of a given pollutant are less than the total em issions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance.26 The 15 percent margin of safe ty was calculated by taking 15 percent of the mobile source emi ssion 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 emissi on 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 PM 2.5 and 1,015.15 tpy for NO x for 2015 and an additional 13.24 tpy for PM 2.5 and 609.63 tpy for NO x 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 PM 2.5 and NO x mobile budgets for the fine particle NAAQS will no longer be applicable eit her after the effective date of the approved redesignat ion or after the effective date of any U.S. EPA action approving a finding that the PM 2.5 and NO x conformity budgets included in th is 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 s ubmittal, which are based on MOVES2010, will replace previous motor vehicle emission budgets on Attainment Demonstr ation submittals based on MOBILE6.2.

Requirement 3 of 5 A demonstration that the projec ted level of emissions is sufficient to maintain the
PM 2.5 standard.

Background In consultation with U.S. EPA, Ohio EPA selected the year 2025 as the maintenance year for th is redesignation request. This document contains projected em issions inventories for 2015 and
2025.

Emission projections for t he 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 Appendix27 C. All projections were made in accordance with “Procedures for Preparing Em issions Projections” U.S. EPA-45/4-91-019.

• Emissions inventories are requi red to be projected to future dates to assess the influence growth and future controls will have. LADCO has developed grow th and control files for point, area, and non-road categorie s. 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 M 11 ).

• For the 2008 attainment year, emissions were grown from the 2005 LADCO modeling inv entory, using LADCO’s growth factors, for all se ctors except point sources (electrical generating units and non-electrical generating units). Point source emissions for 2008 were compiled from Ohio EPA’s 2008 annual emissi ons inventory database. The 2015 interim year emissions were estimated based on the 2005, 2009 and 2018 LADCO mode ling 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 informati on for Canton-Massillon area for 2005 is in Appendix B. Emissi on trends are an important gauge for continued compliance with the PM 2.5 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 tabl es are: Electrical Generating Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Ar ea (Other); Marine; Aircraft; Rail (MAR); and On-road Mobile (On-road).

Ohio EPA is identifying emissi ons projections for 2015 and 2025 for EGUs without the implementati on of the CAIR program. U.S. EPA has raised concerns regardi ng the CAIR program and its remand. Although CSAPR has been st ayed by the D.C. Circuit Court (December 30, 2011), the C ourt has ordered U.S. EPA to

11 http://www.ladco.org/tech/emis/current/i ndex.php28 continue administering CAIR pending the court’s resolution. It is believed that CSAPR will provi de 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 NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. The intent of the CAIR program is for national NO x emissions to be cut from 4.5 milli on 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 CA IR SIP as part of this effort. Ohio submitted a CAIR SIP wh ich 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 Sept ember 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA projec ts that in 2009 emissions of NO x will decrease from a baseline of 264,000 tons per year to 93,000 tons per year while in 2010 emissions of SO 2 will decrease from a baseline of 1,373,000 tons per y ear to 298,000 tons per year, within Ohio. And by 2015 U.S. EPA projects emissions of NO x will decrease to 83,000 tons per y ear while emissions of SO 2 will decrease to 208,000 tons per year, within Ohio 12

.

On December 23, 2008, U.S. EPA’ s CAIR program was remanded without vacatur by the D.C. Circu it Court. As mentioned above, Ohio EPA has not incorporated t hese expected CAIR reductions into this redesignation request. It should also be noted that Ohio’s SIP-approved NOx SIP Ca ll program and regulat ions are still in place. Ohio EPA is currently in the process of revising these regulations to provide a “back st op” for the reinst atement 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 NO x and 1,373,000 tons of SO 2 emitted in 2005. In 2008 and 2009 facilities began preparing for and implementing control programs to address CAIR 13 and consent decrees.

12 http://www. epa.gov/CAIR/oh.html 13 Under CAIR, NOx reductions are to occur begi nning in 2009 while SO2 reductions are to occur beginning in 2010.29 Table 6 - Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2009

SO 2 NO x 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 Tracking 14

Significant reductions also occu rred regionally and nationally as can be seen from the above table. Data is also available for the first two quarters of 2010, the year SO 2 reductions are to be implemented under CAIR:

Table 7 – Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010

SO 2 NO x 2008 (1 st half) 2010 (1 st half) Change 2008 (1 st half) 2010 (1 st 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 Tracking 15

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

“Based on emissions monitoring data, EPA has observed substantial reductions in SO 2 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 t he analysis by U.S. EPA that the CAIR program is providing real reductions at this time, Ohio believes these reductions have assisted with PM 2.5 attainment throughout Ohio.

On July 6, 2011, U.S. EPA finaliz ed a replacement to the CAIR program, the CSAPR. CSAPR woul d preserve those initial reductions achieved under CAIR and provide even greater reductions in NO x and SO 2 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.htm30 the 2015 CAIR Phase 2. As a result of CSAPR, U.S. EPA projected that in 2012 emissions of NO x will decrease to 90,842 tons per year and in 2014 to 85,744 tons per year while SO 2 will decrease to 304,022 tons per y ear 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 th is 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 informati on for the Canton-Massillon area for 2005 is in Appendix B. Emissi on trends are an important gauge for continued compliance with the PM 2.5 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 tabl es are: Electrical Generating Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Ar ea (Area); Marine, Aircraft, Rail (MAR); and On-road Mobile (On-road).

Maintenance is demonstrated w hen the future-year (2025) projected emission totals are below the 2008 attainment year totals.

Demonstration

17 See supplemental table “Impac ts of the Proposed Transport Rule on Counties with Monitors Projected to have Ozone and/or Fine Particle Air Quality Problems.”31 PM 2.5

Table 8 - Canton-Massillon Area (Stark County), Ohio PM 2.5 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

NO x

Table 9 - Canton-Massillon Area (Stark County), Ohio NO x 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

SO 232 Table 10 - Canton-Massillon Area (Stark County), Ohio SO 2 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

PM 2.5 , NO x , and SO 2

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

PM 2.5 1,257.11 1,088.72 168.39 912.92 344.19

NO x 16,227.26 11,001.32 5,225.94 7,822.67 8,404.59

SO 2 906.79 812.89 93.90 795.30 111.49

As shown in the t able above (Table 10), PM 2.5 emissions in the nonattainment area are projected to decrease by 168.39 tpy in 2015 and 344.19 tpy in 2025. NO x emissions in the nonattainment area are projected to decr ease by 5,225.94 tpy in 2015 and 8,404.59 tpy in 2025. SO 2 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 s ources show an increase due to expectations that the population will grow in this area; however, cleaner vehicles and fuels are expec ted to be in place in 2009 and 2018, and the CSAPR will be im plemented 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 Requirements 18 , Highway Heavy-Duty Engine Rule 19 , 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.htm33 Non-Road Diesel Engine Rule 20 are factored into the changes.

All projections (PM 2.5 , SO 2 , and NO x ) 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 NO x and SO 2 emissions beyond those projected for EGU’s above.

As can be seen from the project ed decreases above, even in the absence of considerati on 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 bet ween the year violations occurred and the year attainment wa s 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 monito ring sites indicate that air quality met the NAAQS for PM 2.5 in 2009-2011. U.S. EPA’s redesignation guidance (p 9) states: “A state ma y generally demonstrate maintenance of the NAAQS by either showing that fu ture 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 PM 2.5 , NO x , and SO 2 emissions have contributed to the attainm ent of the annual and 24-hour PM 2.5 standards. Some of these reductions were due to the application of tighter federal standards on new vehicl es 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 PM 2.5 433.47 285.36
On-road NO
x 14,004.65 10,947.26

20 http://www. epa.gov/fedrgstr/EPA-AIR/1998 /October/Day-23/a24836.htm34 On-road SO 2 191.33 45.99

Non-road PM 2.5 231.64 203.73 Non-road NO
x 2,801.96 2,322.49 Non-road SO 2 261.01 95.96

Requirement 5 of 5 Provisions for future annual updates of the inventory to enable tracking of the emission levels, including an annual emissi on statement from major sources.

Demonstration In Ohio, major point sources in a ll 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 PM 2.5 precursor emission sectors every three years. These PM 2.5 precursor inventories will be prepared for future years as necessary to comply with the inventory reporting requirement s established in the CFR. Emissions information will be compared to the 2005 base year and the 2022 projected maintenance y ear inventories to assess emission trends, as necessary, and to assure continued compliance with the annual and 24-hour PM 2.5 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 Cl ean Air Act Amendments requires states with nonattainment areas to submit a SIP providing for implementation of all reasonably av ailable 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 mini mum, 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, mob ile, and area sources) that are technically and economically feasib le, and that would collectively contribute to advancing the attain ment 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 i dentify the attainment date that is as expeditious as practicabl e, and (3) selects the appropriate RACT and RACM.

The 1997 Implementation Rule also provides for a presumption that in States t hat fulfill their CAIR emission reduction requirements, EGU compliance with CAIR is equivalent to RACM/RACT.

Demonstration In 1972, 1980, and 1991, Ohio pr omulgated 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 wit h monitoring, recordkeeping, and reporting necessary to ensur e ongoing compliance. Ohio EPA36 also has an active enforcement program to address violations discovered by field office sta ff. The Ohio RACT rules for particulate matter are found in OAC Chapter 3745-17 21

.
In addition, Ohio EPA promulgated NO x SIP Call rules (OAC Chapter 3745-14 22 ), CAIR (OAC Chapter 3745-109 23 ), and NO x Reasonably Available Control Technology rules (OAC Chapter
3745-110 24 ) over the past five years. Emissions from EGUs make up a significant contribution to Oh io’s inventory. Beginning in 2009, Ohio implemented CAIR which has, and will, provide for significant reductions in NO x , PM 2.5 , and SO 2 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 bot h ozone precursors and PM 2.5 precursors in Ohio, Illinois, I ndiana, Michigan, and Wisconsin area. The first consultant, MACTEC, pr epared a series of white papers 25 researching different stationary source categories. The results were compiled into two reports 26 . The second consultant, Environ, investigated control options for m obile sources. The results were compiled into two reports 27 . The stationary and mobile source sectors (and associated control m easures) were selected by the LADCO States based on several fa ctors presented in the report (See Chapter 2).

Photochemical modeling was t hen conducted (as part of LADCO Round 4 modeling) to assess t he air quality benefit of the candidate control measures and a modeling report was developed 28 . Based on the results, the LA DCO project team felt it would not be possible to advance the attainment date for PM 2.5

. Ohio EPA, in its attainment dem onstration submitted on July 18,

21 http://www. epa.ohio.gov/dapc/r egs/3745_17.aspx 22 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx
23 http://www. epa.ohio.gov/dapc/r egs/3745_109.aspx
24 http://www. epa.ohio.gov/dapc /regs/3745_110.aspx
25 http://www.ladco.org/r eports/control/white_papers
26 http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_i_april_2005.pdf; http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_ii_june_2006.pdf
27 http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_february_2006.pdf; http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_for_ladc o_states_in_2009_and_2012_march_2007.pdf
28 http://www.ladco.org/r eports/control/mode ling/round4_modeling.pdf37 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 regulat ions and implement a control program prior to the proj ected 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 fo r the 24-hour standard. If a State demonstrates attain ment will occur by 2010 (annual standard) or 2014 (24-hour standar d) or earlier, U.S. EPA considers the attainment demonstration to demonstrate achievement of RFP. However, if a State a ttains the standard prior to the requirement to s ubmit an attainment demonstration (2012 in the case of the 24- hour standard), an attainment demonstration is not required.

Demonstration In Ohio’s attainment demonstr ation for the annual standard was submitted on July 18, 2008. Ohio demonstrated (using a weight of evidence approach) that attainm ent of the annual standard would be achieved in this area by 2009; and therefore, it was not necessary to submit a s eparate RFP plan under the annual standard.

With respect to the 24-hour st andard, this area attained the standard prior to the deadline fo r submitting an attainment demonstration; and theref ore, it was not necessary to submit a separate RFP plan.

Requirement 3 of 6 Section 172(c)(3) requires states to subm it a comprehensive inventory of actual emissions.

Background38 Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions in the area, including the requirement for periodic revisi ons as determined necessary. 40 CFR 51.1008 requires such inventor y 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 PM 2.5 attainment demonstrati on SIP submitted on July 18, 2008. It was then subsequently revised and resubmitted on June 7, 2010.

Ohio also updates its inventor y in accordance with U.S. EPA’s CERR rule (i.e. emissions stat ements). Ohio EPA submitted its emissions statement SIP on Ma rch 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 (sta tements) every three years.

Requirement 4 of 6 Evidence that control meas ures required in past PM 2.5 SIP revisions have been fully implemented.

Background In addition to the historic RACT requirements for PM, the U.S. EPA NO x SIP Call required 22 states to pass rules that would result in significant emissi on reductions from large EGUs, industrial boilers, and cement kiln s in the eastern United States. Ohio passed this rule in 2001. NOx SIP Call requirements are incorporated into permits along wit h monitoring, recordkeeping, and reporting necessary to ensur e 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 monitori ng program. Beginning in 2004, this rule accounts for a reduction of approximately 31 percent of all NO x emissions statewide compar ed to previous uncontrolled years. The other 21 states al so 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 NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. National NO x emissions will be cut from 4.5 million tons in39 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were requi red to submit a CAIR SIP as part of this effort. Ohio submi tted 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 acti on on September 25, 2009 (74 FR 48857).

Demonstration Controls for EGUs under the NO x SIP Call formally commenced May 31, 2004. Emissions cover ed by this program have been generally trending downward since 1998 with larger reductions occurring in 2002 and 2003. Data ta ken from the U.S. EPA Clean Air Markets web site, quantify the gradual NO x reductions that have occurred in Ohio as a resu lt of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter
3745-14 29 in response to the SI P Call. OAC Chapter 3745-14 regulates EGUs and certain non-EGUs under a cap and trade program based on an 85 percent reduc tion of NOx emissions from EGUs and a 60 percent reduction of NO x emissions from nonEGUs, compared to historical le vels. 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 NO x SIP Call that establishes a budget for la rge (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio EPA’s OAC rule 3745-14-12 addresses stat ionary 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 NO x reduction from 1995 levels is ant icipated. 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 li ght trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refiner ies will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in bet ween 2004 and 2009. U.S. EPA has

29 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx40 estimated that NO x emission reductions will be approximately 77 percent for passenger cars, 86 per cent 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 approxim ately 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 gasoli ne and diesel trucks and buses. This rule will result in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory. It also estima ted 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 hi ghway 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 perc ent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwide. Sulfur levels will be reduced in non -road diesel fuel by 99 percent from current levels, from appr oximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starti ng in 2008. Together, these rules will substantially reduce lo cal and regional sources of PM 2.5 precursors.

Requirement 5 of 6 Acceptable provisions to provide for new source review.

Background Ohio has a longstanding and fu lly implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-
31 30 . The Chapter includes provis ions for the Prevention of Significant Deterioration (PSD) permitting program in OAC rules

30 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx41 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. E PA 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 ta ken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable NSR r equirements. Once the area is redesignated, Ohio EPA will impl ement 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 t he aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicable to PM 2.5 , SO 2 , and NO x as required for maintenance of the annual and 24-hour PM 2.5 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 offi ce, has the legal authority and necessary resources to actively enf orce any violations of its rules or permit provisions. After redesi gnation, it intends to continue enforcing all rules that rela te to the emission of PM 2.5 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 pl an 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 ex ceeding specified predetermined levels (triggers) or in the event that future vi olations 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 sha ll be prompted whenever the PM 2.5 average of the weighted annual mean of 15.5 μg/m 3 occurs in a single calendar year or whenever a 98 th percentile 24-hour PM 2.5 concentration of 35.5 μg/m 3 occurs in a single calendar year, within the maintenance area. A wa rning level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 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 c onsideration ease and timing for implementation as well as econom ic and social considerations. Implementation of necessary cont rols in response to a warning level response trigger will take plac e as expeditiously as possible, but in no event later than 12 mont hs from the conclusion of the most recent calendar year.

Should it be determined through the wa rning level study that action is necessary to reverse the noted trend, the procedur es 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/m 3 or greater occurs or whenever a tw o-year average of the 98 th percentile 24- hour PM 2.5 concentration of 35.0 μg/m 3 or greater occurs, within the maintenance area. A violati on of the standard (three-year average of the weighted annual means of 15.0 μg/m 3 or greater or three-year average of the 98 th percentile 24-hour PM 2.5 concentration of 35.0 μg/m 3 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 except ional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metr opolitan 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 PM 2.5 . In this case, measures that can be implemented in a short time will be se lected 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 det ermine if additional, significant new regulations not currently in cluded as part of the maintenance provisions will be implemented in a timely manner and will constitute our response.

Control Measure Sele ction 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 alr eady 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 propos ed measures are adequate to return the area to attainment.

Requirement 3 of 4 A list of potential contingen cy measures that would be implemented in such an

event.

Demonstration Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appropriate and effective44 at the time the selection is m ade. The selection of measures will be based on cost-effectiveness, emission reduction potential, economic and social cons iderations or other factors that Ohio EPA deems appropriate. Ohio EPA will solic it 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 cont rol 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., li quid propane and compressed natural gas) and diesel retrofit programs for fleet vehicle operations. 3) Tighter PM 2.5 , SO 2 , and NO x 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 NO x RACT statewide.

No contingency measure shall be implemented without providing the opportunity for full public partici pation during which the relative costs and benefits of individual meas ures, at the time they are under consideration, can be fully evaluated.

Requirement 4 of 4 A list of PM 2.5 , SO 2 , and NO x sources potentially subject to future additional control requirements.

Demonstration The following is a list of PM 2.5 , SO 2 , and NO x sources potentially subject to future controls.

• ICI Boilers - SO 2 and NO x 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 redesignat ion petition and maintenance plan in the widely distributed county publications.

The public hearing to receive comment s 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, certificati on of publication, comments received and the transcr ipt from the public hearing.46 

### CHAPTER EIGHT

CONCLUSIONS

The Canton-Massillon annual and 24-hour PM 2.5 nonattainment area has attained the 1997 annual and 2006 24-hour NAAQS for PM 2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of PM 2.5 nonattainment areas. Documentat ion to that effect is contained herein. Ohio EPA has prepared a redesignation request and maintenance plan that meet the require ments of Section 110 (a)(1) of the 1990 CAA.

Based on this presentation, t he Canton-Massillon annual and 24-hour PM 2.5 nonattainment area meets the requirem ents for redesignation under the CAA and U.S. EPA guidance. Ohio has perfo rmed an analysis that shows the air quality improvements ar e due to permanent and enf orceable measures. Furthermore, because this area is subject to significant transport of pollutants, significant regional SO 2 and NO x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of Ohio hereby reques ts that the Canton-Massillon annual and 24- hour PM 2.5 nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenanc e plan provisions contained herein.This page left intentionally blank