INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

Mitchell E. Daniels Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204 

(31 7) 232-8603 

Thomas K Easterly Toll Free (800) 451-6027 

Commissioner www.idem.lN.gov 

E 

Mr. Bharat Mathur January 21, 2010 

Acting Regional Administrator 

U.S. Environmental Protection Agency 

Region 5 

77 West Jackson Boulevard 

Chicago, IL 60604-3950 

Re: Request for Redesignation Petition and Maintenance 

Plan for Ozone Attainment for the Indiana Portion of 

the Cincinnati-Hamilton, OH-KY-IN 8-Hour Ozone 

Nonattainment Area 

Dear Mr. Mathur: 

With this letter the Indiana Department of Environmental Management (IDEM) submits 

the final Redesignation Petition and Maintenance Plan for the Indiana portion of the CincinnatiHamilton, OH-KY-IN, 8-hour ozone nonattainment area (Lawrenceburg Township in Dearborn 

County). IDEM conducted a public hearing concerning the Redesignation Petition and 

Maintenance Plan on January 7,201 0. The public comment period concluded on January 13, 

201 0 and no comments were received. 

i The attached document consists of the following: f 

Redesignation Petition and Maintenance Plan 

A formal request that the Indiana portion of the Cincinnati-Hamilton, OH-KY-IN 

nonattainment area (Lawrenceburg Township in Dearborn County) be redesignated to 

attainment and reclassified as "maintenance". It contains and meets the requirements 

set forth in Section 107 of the Clean Air Act and in U.S. EPA Redesignation 

Guidance. 

I A maintenance year of 2020 is established and 201 5 is analyzed as an interim year. 

The appendices of the document contain historic air quality trend data, projected 

emission inventory data and thorough documentation of the mobile emissions 

analysis. 

Recycled Paper @ An Equal Opportunity Employer Please Recycle 0 
B. Mathur, Page 2 

Motor Vehicle Emission Budgets 

Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget for 

2015 and 2020. The Ohio Kentucky Indiana (OKI) Regional Council of 

Governments' travel demand model and MOBILE6.2 were used to determine 

emissions for the area. 

A conservative margin of safety was applied to the 2015 and 2020 projected 

emissions. 

The travel demand model was updated with the best available assumptions. 

Vehicle registration data gathered from the Indiana Bureau of Motor Vehicles were 

used to replace the MOBILE6.2 default vehicle age distribution. 

IDEM requests that the U.S. EPA proceed with review and approval of this submittal. If 

you have any questions or need additional information, please contact Scott Deloney, Chief, Air 

Programs Branch, at (3 17) 233-5694. 

Commissioner 

TWEIsadlskr 

Attachments: Request for Redesignation and Maintenance Plan and Appendices 

Cc: John Surnrnerhays, U.S. EPA Region 5 (wl enclosures) 

Ed Doty, U.S. EPA Region 5 (wl enclosures) 

Cheryl L. Newton, U.S. EPA Region 5 (no enclosures) 

Pat Morris, U.S. EPA Region 5 (no enclosures) 

John Mooney, U.S. EPA Region 5 (no enclosures) 

Scott Deloney, IDEM-OAQ (no enclosures) 

Christine Pedersen, IDEM-OAQ (no enclosures) 

Sarah Raymond, IDEM-OAQ (wl enclosures) 
REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR OZONE 

ATTAINMENT IN THE INDIANA 

PORTION OF THE CINCINNATIHAMILTON, OH-KY-IN 8-HOUR OZONE 

NONATTAINMENT AREA 

Dearborn County, Indiana 

(Lawrenceburg Township) 

Developed By: 

The Indiana Department of Environmental Management 

January 2010 
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TABLE OF CONTENTS 

1.0 INTRODUCTION ...................................................................................................... 1 

1.1 Background ...............................................................................................................................................2 

1.2 Geographical Description of Indiana's Portion of the Nonattainment Area ............................................. 2 

1.3 Status of Air Quality..................................................................................................................................3 

2.0 REQUIREMENTS FOR REDESIGNATION ......................................................... 3 

2.1 General ......................................................................................................................................................3 

2.2 Ozone Monitoring............. ....................................................................................................................3 

2.3 Emission Inventory....................................................................................................................................4 

2.4 Modeling Demonstration...........................................................................................................................4 

2.5 Controls and Regulations ..........................................................................................................................4 

2.6 Corrective Actions for Potential Future Violations of the Standard..........................................................5 

3.0 OZONE MONITORING ........................................................................................... 5 

3.1 Ozone Monitoring Network ......................................................................................................................5 

3.2 Ambient Ozone Monitoring Data..............................................................................................................7 

3.3 Quality Assurance .....................................................................................................................................9 

3.4 Continued Monitoring .............................................................................................................................10 

4.0 EMISSION INVENTORY....................................................................................... 10 

4.1 Emission Trends......................................................................................................................................10 

4.2 Base Year Inventory................................................................................................................................17 

4.3 Emission Projections ...............................................................................................................................18 

4.4 Demonstration of Maintenance ...............................................................................................................23 

4.5 Permanent and Enforceable Emissions Reductions.................................................................................23 

4.6 Provisions for Future Updates .................................................................................................................24 

5.0 TRANSPORTATION CONFORMITY BUDGETS ............................................. 24 

5.1 On-Road Emission Estimates ..................................................................................................................24 

5.2 Overview .................................................................................................................................................24 

5.3 Emission Estimates..................................................................................................................................25 

i 
6.0 CONTROL MEASURES AND REGULATIONS................................................. 27 

6.1 Reasonably Available Control Technology (RACT)...............................................................................27 

6.2 Implementation of Past SIP Revisions ....................................................................................................27 

6.3 Nitrogen Oxides (NOx) Rule ...................................................................................................................27 

6.4 Measures B eyond Clean Air Act Requirements.....................................................................................28 

6.5 Controls to Remain in Effect...................................................................................................................29 

6.6 New Source Review Provisions ..............................................................................................................30

7.0 MODELING and METEOROLOGY..................................................................... 30 

7.1 Summary of Modeling Results................................................................................................................30 

7.2 U.S. EPA Modeling Analysis for HDE Final Rulemaking......................................................................30

7.3 U.S. EPA Modeling for Clean Air Interstate Rule (CAIR), 2005 ...........................................................31 

7.4 LADCO's Round 5 and Round 6 Modeling for 8-Hour Ozone Standard ................................................32 

7.5 Summary of Existing Modeling Results..................................................................................................33 

7.6 Temperature Analysis for the Cincinnati, Ohio Area..............................................................................34 

7.7 Summary of Meteorological Conditions .................................................................................................37 

8.0 CORRECTIVE ACTIONS ...................................................................................... 38 

8.1 Commitment to Revise Plan....................................................................................................................38 

8.2 Commitment for Contingency Measures.................................................................................................38 

8.3 Contingency Measures ............................................................................................................................39 

9.0 PUBLIC PARTICIPATION.................................................................................... 40 

10.0 CONCLUSIONS ..................................................................................................... 40

ii 
FIGURES 

3.1 Cincinnati-Hamilton, OH-KY-IN Nonattainment Area ...........................................................................6 

TABLES 

3.1 Monitoring Data for Kentucky’s Portion of the Nonattainment Area (Annual 4th High and Design 

Values in ppm) ............................................................................................................................................... 7 

3.2 Monitoring Data for Ohio’s Portion of the Nonattainment Area (Annual 4th High and Design Values in 

ppm) ............................................................................................................................................................... 8 

4.1 Comparison of 2008 Emissions and 2020 Projected NOx and VOC Emission Estimates, All 

Anthropogenic Sources in Lawrenceburg Township, Dearborn County (Tons Per Summer Day) .............. 22 

4.2 Comparison of 2008 Emissions and 2020 Projected NOx and VOC Emissions Estimates, All 

Anthropogenic Sources in the Entire Nonattainment Area (Tons Per Summer Day)................................... 22 

5.1 Emission Estimates for On-Road Mobile Sources for the Cincinnati-Hamilton, OH-KY-IN Ozone 

Nonattainment Area...................................................................................................................................... 25 

5.3 Motor Vehicle Emission Budgets (MVEB) for the Ohio and Indiana Portions of the CincinnatiHamilton, OH-KY-IN Ozone Nonattainment Area...................................................................................... 25 

6.1 Trends in EGU Ozone Season NOx Emissions Statewide in Indiana .....................................................28 

7.1 Modeling Results: U.S. EPA HDE Rulemaking for the Cincinnati-Hamilton, OH-KY-IN 

Nonattainment Area...................................................................................................................................... 31 

7.2 Modeling Results From U.S. EPA for the Clean Air Interstate Rule .....................................................32 

7.3 Application of Round 5 RRFs (with CAIR) to Most Current Base-Year Design Values...................... 33 

7.4 Application of Round 6 RRFs (without CAIR) to Most Current Base-Year Design Values................. 33 

7.5 Analysis of Maximum Temperatures for the Cincinnati, Ohio Area..................................................... 35 

7.6 Comparison of Days with 90° F and 8-hour Ozone Exceedance Days 1998-2008 ............................... 36 

iii 
GRAPHS 

3.1 2007-2009 Design Values for the Cincinnati-Hamilton, OH-KY-IN Nonattainment Area..................... 8 

3.2 Design Value Trends in the Cincinnati-Hamiton, OH-KY-IN Nonattainment Area, 2004-2009............ 9 

4.1 NOx Point Source Emissions, Lawrenceburg Township, Dearborn County, Indiana, 2005 and 2008 ... 11 

4.2 VOC Point Source Emissions, Lawrenceburg Township, Dearborn County, Indiana, 2005 and 2008. 11 

4.3 NOx Point Source Emissions, Entire Nonattainment Area, 2005 and 2008............................................12 

4.4 VOC Point Source Emissions, Entire Nonattainment Area, 2005 and 2008 ..........................................12 

4.5 NOx Emissions from Lawrenceburg Township, Dearborn County, Indiana Electric Generating Unit 

American Electric Power-Tanners Creek Generating Station, 1999-2008 ................................................... 14 

4.6 NOx Emissions from Entire Nonattainment Area Electric Generating Units, 1999-2008 ..................... 14 

4.7 NOx Emissions Trends, 2005 and 2008, All Anthropogenic Sources in Lawrenceburg Township, 

Dearborn County .......................................................................................................................................... 15 

4.8 VOC Emissions Trends, 2005 and 2008, All Anthropogenic Sources in Lawrenceburg Township, 

Dearborn County .......................................................................................................................................... 16 

4.9 NOx Emissions Trends, 2005 and 2008, All Anthropogenic Sources-Entire Nonattainment Area ....... 16 

4.10 VOC Emissions Trends, 2005 and 2008, All Anthropogenic Sources-Entire Nonattainment Area.... 17 

4.11 Comparison of 2008 Emissions and 2015 and 2020 Projected NOx Emissions for Lawrenceburg 

Township, Dearborn County ........................................................................................................................ 19 

4.12 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions for Lawrenceburg 

Township, Dearborn County ........................................................................................................................ 20 

4.13 Comparison of 2008 Emissions and 2015 and 2020 Projected NOx Emissions for Entire 

Nonattainment Area...................................................................................................................................... 20 

4.14 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions for Entire 

Nonattainment Area...................................................................................................................................... 21 

4.15 Comparison of 2008 Emissions and 2015 and 2020 Projected NOx Emissions for Lawrenceburg 

Township, Dearborn County Indiana and, Kentucky and Ohio.................................................................... 21 

4.16 Comparison of 2008 Emissions and 2015 and 2020 Projected NOx Emissions for Lawrenceburg 

Township, Dearborn County Indiana and, Kentucky and Ohio.................................................................... 22 

7.1 Actual Design Values for Cincinnati From 1996 Through 2008............................................................33 

7.2 Comparison of Days with 90° F and 8-hour Ozone Exceedance Days ..................................................37 

iv 
APPENDICES 

A Air Quality System (AQS) Monitor Data Values for Cincinnati-Hamilton OHKY-IN Nonattainment Area (2004-2009) 

B Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOC), Point Source 

Emissions, 2005 and 2008, for Lawrenceburg Township, Dearborn County 

Indiana and Entire Cincinnati-Hamilton OH-KY-IN Nonattainment Area 

C Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOC), All Emission 

Sources, 2005 and 2008, for Lawrenceburg Township, Dearborn County, Indiana 

and Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area 

D Nitrogen Oxides (NOx) Emissions from Electric Generating Units, Lawrenceburg 

Township, Dearborn County, Indiana and Entire Cincinnati-Hamilton OH-KY-IN 

Nonattainment Area 

E 2008 Base Year Emissions Inventory and 2015 and 2020 Projected Emissions 

Inventory for Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOC), 

All Emission Sources for Lawrenceburg Township, Dearborn County, Indiana 

and Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area 

F Mobile Source Input/Output Calculation Files 

G Indiana Department of Environmental Management (IDEM)-Area Source 

Inventory Standard Operating Procedure 

H Lake Michigan Air Directors Consortium (LADCO) Emission Estimates 

Technical Support Document 

I Lake Michigan Air Directors Consortium (LADCO) Round 5 Modeling Technical 

Support Document (Round 5 Photochemical Modeling Based on “Base M” 

Emissions Inventory, Revised Version of “Base K”) 

v 
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vi 
REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR OZONE ATTAINMENT 

IN THE INDIANA PORTION OF THE 

CINCINNATI-HAMILTON OH-KY-IN 

8-HOUR OZONE NONATTAINMENT AREA 

DEARBORN COUNTY, INDIANA (LAWRENCEBURG TOWNSHIP) 

1.0 INTRODUCTION

This document supports Indiana’s request that the Indiana portion (Lawrenceburg Township in 

Dearborn County, Indiana) of the Cincinnati-Hamilton OH-KY-IN area be redesignated from 

nonattainment to attainment for the 1997 8-hour ozone standard. In addition, the States of 

Kentucky and Ohio also intend to submit requests for their portions of the Cincinnati-Hamilton 

OH-KY-IN basic ozone nonattainment area to be redesignated from nonattainment to attainment 

for the 8-hour ozone national ambient air quality standard (NAAQS). The Cincinnati-Hamilton 

OH-KY-IN area has recorded three (3) years of complete, quality-assured ambient air quality 

monitoring data for the years 2007 through 2009, demonstrating attainment of the 8-hour ozone 

standard. 

Indiana’s request is based on Section 107(d)(3)(D) of the Clean Air Act (CAA), which states: 

The Governor of any State may, on the Governor’s own motion, submit to the 

Administrator a revised designation of any area or portion thereof within the State. 

Within 18 months of receipt of a complete State redesignation submittal, the 

Administrator shall approve or deny such redesignation. The submission of a 

redesignation by a Governor shall not affect the effectiveness or enforceability of the 

applicable implementation plan for the State. 

Section 107(d)(3)(E) of the CAA establishes specific requirements to be met in order for an area 

(or portion of an area) to be considered for redesignation as follows: 

The Administrator may not promulgate a redesignation of a nonattainment area (or 

portion thereof) to attainment unless-- 

(i) the Administrator determines that the area has attained the national 

ambient air quality standard;

(ii) the Administrator has fully approved the applicable implementation plan 

for the area under section 110(k);

(iii) the Administrator determines that the improvement in air quality is due to 

permanent and enforceable reductions in emissions resulting from 

implementation of the applicable implementation plan and applicable 

Federal air pollutant control regulations and other permanent and 

enforceable reductions;

1
(iv) the Administrator has fully approved a maintenance plan for the area as 

meeting the requirements of section 175A; and

(v) the state containing such area has met all requirements applicable to the 

area under section 110 and part D. 

This document addresses each of these requirements, and provides additional information to 

support continued compliance with the 1997 8-hour ozone standard. 

1.1 Background

The Clean Air Act (CAA) requires areas designated nonattainment for the NAAQS for ozone to 

develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard. In 

1997, the United States Environmental Protection Agency (U.S. EPA) revised the air quality 

standards for ozone, replacing the 1979 1-hour standard with an 8-hour ozone standard set at 

0.08 parts per million (ppm). The standard was challenged legally and upheld by the U.S. 

Supreme Court in February of 2001. The U.S. EPA designated areas under the 8-hour ozone 

standard on April 15, 2004 as attainment, nonattainment or unclassifiable. 

The U.S. EPA designated Lawrenceburg Township in Dearborn County, Indiana as a portion of 

the Cincinnati-Hamilton OH-KY-IN nonattainment area (40 CFR 81.315) and classified the area 

“basic” under Subpart 1 of Part D of the CAA. The specific counties and partial counties that 

comprise the nonattainment area, as defined in 40 CFR 81.315, 40 CFR 81.318 and 40 CFR 

81.336, include Lawrenceburg Township in Dearborn County, Indiana; Boone, Campbell and 

Kenton counties, Kentucky; and Butler, Clermont, Clinton, Hamilton and Warren counties, Ohio. 

This designation subjected the area to the new 8-hour ozone requirements, including 

development of a plan to reduce emissions of volatile organic compounds (VOCs) and nitrogen 

oxides (NOx) and a demonstration that the area will meet the federal 8-hour air quality standard 

for ozone by June 15, 2010. 

1.2 Geographical Description of Indiana’s Portion of the Entire Nonattainment Area

Following is a brief description of the Cincinnati basic nonattainment area. 

Lawrenceburg Township, located in Dearborn County in southeast Indiana, Boone, Campbell 

and Kenton counties located in north central Kentucky and Butler, Clermont, Clinton, Hamilton 

and Warren counties located in southwestern Ohio are part of the Cincinnati metropolitan 

statistical area. This area is surrounded by the Indiana counties of Franklin, Ohio, Ripley, 

Switzerland and Union, the Kentucky counties of Bracken, Gallatin, Grant and Pendleton and the 

Ohio counties of Brown, Fayette, Greene, Highland, Montgomery and Preble. The Ohio River 

flows along the borders of Indiana, Kentucky and Ohio and the area lies within the Ohio River 

Valley. The Cincinnati-Hamilton OH-KY-IN Basic Nonattainment Area is depicted in Figure 

3.1. 

The Indiana Department of Environmental Management (IDEM), on behalf of the State of 

Indiana, is requesting redesignation of Lawrenceburg Township, Dearborn County, Indiana. The 

Kentucky Department for Environmental Protection (KDEP) is responsible for Boone, Campbell 

2
and Kenton counties in Kentucky. The Ohio Environmental Protection Agency (Ohio EPA) is 

responsible for Butler, Clermont, Clinton, Hamilton and Warren counties in Ohio. KDEP and 

Ohio EPA are requesting redesignation of their portions of the nonattainment area from U.S. 

EPA Regions IV and V, concurrently. 

1.3 Status of Air Quality

Ozone monitoring data for the most recent three (3) years, 2007 through 2009, demonstrates that 

air quality has met the NAAQS for ozone throughout the nonattainment area, including 

Lawrenceburg Township in Dearborn County. This fact, accompanied by the permanent and 

enforceable decreases in emission levels discussed in Section 4.0, justifies a redesignation to 

attainment for Indiana’s portion of the nonattainment area based on Section 107(d)(3)(E) of the 

CAA. 

2.0 REQUIREMENTS FOR REDESIGNATION

2.1 General

Section 110 and Part D of the CAA list a number of requirements that must be met by 

nonattainment areas prior to consideration for redesignation to attainment. In addition, U.S. EPA 

has published detailed guidance in a document entitled Procedures for Processing Requests to 

Redesignate Areas to Attainment, issued September 4, 1992, to Regional Air Directors. This 

document is hereafter referred to as “Redesignation Guidance”. This Request for Redesignation 

and Maintenance Plan is based on the Redesignation Guidance, supplemented with additional 

guidance received from staff of the Criteria Pollutant Section of U.S. EPA Region V. The 

specific requirements for redesignation are listed below. 

2.2 Ozone Monitoring CAA Section 107(d)(3)(E)(i) 

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

been attained. Ozone monitoring data must show that violations of the ambient 

standard are no longer occurring. 

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

been recorded in the U.S. EPA Air Quality System (AQS) database, and made 

available for public view. 

3) A showing that the three-year average of the fourth highest values, based on data 

from all monitoring sites in the area or its affected downwind environs, are below 

85 parts per billion (ppb). This showing must rely on three (3) complete, 

consecutive calendar years of quality assured data. 

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

appropriate monitoring network to verify the maintenance of the attainment 

status. 

3
2.3 Emission Inventory CAA Section 107(d)(3)(E)(iii) 

1) A comprehensive emissions inventory of the precursors of ozone completed for 

the base year. 

2) A projection of the emissions inventory to a year at least 10 years following 

redesignation. 

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

ozone standard. 

4) A demonstration that improvement in air quality between the year violations 

occurred and attainment was achieved is based on permanent and enforceable 

emission reductions and not on temporary adverse economic conditions or 

unusually favorable meteorology. 

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

emission levels including an annual emission statement from major sources. 

2.4 Modeling Demonstration 

While no modeling is required for redesignating ozone nonattainment areas, IDEM has 

incorporated photochemical modeling information as part of this document to further 

support its request for Lawrenceburg Township in Dearborn County, Indiana, to be 

redesignated to attainment. 

2.5 Controls and Regulations CAA Section 107(d)(3)(E)(ii) & CAA Section 107(d)(3)(E)(v) 

1) A U.S. EPA approved SIP control strategy that includes Reasonably Available 

Control Technology (RACT) requirements for existing stationary sources covered 

by Control Technology Guidelines (CTG) and non-CTG RACT for all major 

sources. 

2) Evidence that control measures required in past ozone SIP revisions have been 

fully implemented. 

3) Acceptable provisions to provide for new source review. 

4) Assurances that existing controls will remain in effect after redesignation, unless 

the state demonstrates through photochemical modeling that the standard can be 

maintained without one or more controls. 

5) If appropriate, a commitment to adopt a requirement that all transportation plans 

conform with and are consistent with the SIP. 

4
2.6 Corrective Actions for Potential Future Violations of the Standard

1) A commitment to submit a revised plan eight (8) years after redesignation. 

2) A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

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

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

event. 

4) A list of VOC and NOx sources potentially subject to future controls. 

3.0 OZONE MONITORING 

3.1 Ozone Monitoring Network

There are currently eleven (11) monitors measuring ozone concentrations in the CincinnatiHamilton OH-KY-IN nonattainment area. Three monitors are located in Kentucky and eight 

monitors are located in Ohio. Indiana does not have any ozone monitors located in 

Lawrenceburg Township in Dearborn County. A listing of the sites along with their annual 

fourth highest readings from 2007 through 2009 are shown in Table 3.1 and Table 3.2 and were 

retrieved from U.S. EPA’s Air Quality System (AQS) database. The locations of the monitoring 

sites for this nonattainment area are shown on Figure 3.1. 

5
Figure 3.1 

Map of the Cincinnati-Hamilton OH-KY-IN Nonattainment Area

39-017-1004

39-061-0006

39-061-0010

21-117-0007 21-037-3002

39-017-0004

39-165-0007

39-025-0022

39-061-0040

39-027-1002

21-015-0003

BOONE

GRANT

MASON

PENDLETON

OWEN

BRACKEN

KENTON

LEWIS

CAMPBELL

GALLATIN

CARROLL

ROBERTSON HENRY HARRISON FLEMING

Butler

Brown

Clinton

Highland

Warren

Greene

Clermont

Adams

Preble

Hamilton

Fayette

Montgomery

Madison

Clark

Dearborn

Franklin

Union

Ohio

Wayne

Switzerland

Fayette

Ripley

Legend

Ozone Monitor

Interstate Higways

US Highways

Indiana Counties in Attainment

Ohio Counties in Attainment

Kentucky Counties in Attainment

Cincinnati-Hamilton OH-KY-IN Nonattainment Area

0 2 10 0 40 Miles

0 2 12.5 5 50 Kilometers

10/28/09

6
3.2 Ambient Ozone Monitoring Data

The following information is taken from U.S. EPA's "Guideline on Data Handling Conventions 

for the 8-Hour Ozone National Ambient Air Quality Standard (NAAQS)," EPA-454/R-98-017, 

December 1998. 

U.S. EPA requires three (3) complete years of ozone monitoring data to demonstrate attainment 

at a monitoring site. The 8-hour primary and secondary ozone ambient air quality standards are 

met at an ambient air quality monitoring site when the three-year average of the annual fourthhighest daily maximum 8-hour average ozone concentration is less than or equal to 0.08 parts per 

million (ppm). When this occurs, the site is deemed to be in attainment. Three (3) significant 

digits must be carried out in the computations. Because the third decimal digit, in ppm, is 

rounded, 0.084 ppm is the largest concentration that is less than or equal to 0.08 ppm. Therefore, 

for the purposes of this request, the 8-hour standard is considered to be 0.085 ppm. Values 

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

standard. These data handling procedures are applied on an individual basis at each monitor in 

the area. An area complies with the 8-hour ozone NAAQS only if every monitoring site in the 

area meets the NAAQS. An individual site's three-year average of the annual fourth highest 

daily maximum 8-hour average ozone concentration is also called the site's design value. The air 

quality design value for the area is the highest design value among all sites in the area. Table 3.1 

outlines the annual fourth high values and three-year design values for 2004 through 2009 for the 

three active monitoring sites in Kentucky’s portion of the nonattainment area. Table 3.2 outlines 

the annual fourth high values and three-year design values for 2004 through 2009 for the eight 

active monitoring sites within Ohio’s portion of the nonattainment area. None of the eleven 

monitors within the Cincinnati-Hamilton OH-KY-IN nonattainment area has a 2007 through 

2009 design value greater than 0.082 ppm. 

Table 3.1 

Monitoring Data for Kentucky’s Portion of the Nonattainment Area 

(Annual 4th High and Design Values in ppm) 

County Site ID 2004 2005 2006 2007 2008 2009 2004-

2006 

2005-

2007 

2006-

2008 

2007-

2009 

Boone 21-015-0003 0.070 0.082 0.071 0.078 0.064 0.064 0.074 0.077 0.071 0.069 

Campbell 21-037-3002 0.086 0.075 0.068 0.076 

Kenton 21-117-0007 0.073 0.084 0.075 0.085 0.073 0.074 0.077 0.081 0.078 0.077 

Red text indicates values are ≥ 0.085 ppm 

7
Table 3.2 

Monitoring Data for Ohio’s Portion of Nonattainment Area 

(Annual 4th High and Design Values in ppm) 

County Site ID 2004 2005 2006 2007 2008 2009 2004-

2006 

2005-

2007 

2006-

2008 

2007-

2009 

Butler 39-017-0004 0.075 0.086 0.079 0.091 0.071 0.073 0.080 0.085 0.080 0.078 

Butler 39-017-1004 0.076 0.088 0.076 0.091 0.079 0.076 0.080 0.085 0.082 0.082 

Clermont 39-025-0022 0.076 0.083 0.077 0.086 0.071 0.069 0.079 0.082 0.078 0.075 

Clinton 39-027-1002 0.078 0.083 0.081 0.082 0.076 0.070 0.081 0.082 0.080 0.076 

Hamilton 39-061-0006 0.076 0.089 0.081 0.089 0.086 0.072 0.082 0.086 0.085 0.082 

Hamilton 39-061-0010 0.075 0.085 0.081 0.086 0.077 0.065 0.080 0.084 0.081 0.076 

Hamilton 39-061-0040 0.076 0.087 0.078 0.086 0.080 0.074 0.080 0.084 0.081 0.080 

Warren 39-165-0007 0.081 0.092 0.086 0.088 0.082 0.077 0.086 0.089 0.085 0.082 

Red text indicates values are ≥ 0.085 ppm 

Graph 3.1 below visually demonstrates the design values for this nonattainment area. The 

highest design value within the nonattainment area is 0.082 ppm. The design values calculated 

for the Cincinnati-Hamilton OH-KY-IN nonattainment area demonstrate that the NAAQS for 

ozone has been attained. 

Graph 3.1 2007-2009 Design Values for the Cincinnati-Hamilton OH-KY-IN 

Nonattainment Area 

0.000

0.010

0.020

0.030

0.040

0.050

0.060

0.070

0.080

0.090

KY 338, KY Highland

Heights, KY

Covington,

KY

Hamilton, OH Middletow n,

OH

Batavia, OH Wilmington,

OH

Cincinnati,

OH-Grooms

Rd.

Cleves, OH Cincinnati,

OH-WM.

How ard Taft

Rd.

Lebanon, OH

21-015-0003 21-037-3002 21-117-0007 39-017-0004 39-017-1004 39-025-0022 39-027-1002 39-061-0006 39-061-0010 39-061-0040 39-165-0007

Parts per Million

2007-2009 8-Hour Ozone Standard

8
Graph 3.2 illustrates the design value trends for the Cincinnati-Hamilton OH-KY-IN 

nonattainment area. 

Graph 3.2 Design Value Trends in the Cincinnati-Hamilton OH-KY-IN Nonattainment 

Area, 2004-2009 

0.060

0.065

0.070

0.075

0.080

0.085

0.090

0.095

04-06 05-07 06-08 07-09

Parts per Million

21-015-0003 KY 338, KY

21-037-3002 Highland

Heights, KY

21-117-0007 Covington, KY

39-017-0004 Hamilton, OH

39-017-1004 Middletow n, OH

39-025-0022 Batavia, OH

39-027-1002 Wilmington, OH

39-061-0006 Cincinnati, OHGrooms Rd.

39-061-0010 Cleves, OH

39-061-0040 Cincinnati, OHWM. How ard Taft Rd.

39-165-0007 Lebanon, OH

8-Hour Ozone Standard

The above graph shows the trend in design values for the region over the past several years. A 

comprehensive list of the individual sites' design values over this period is in Appendix A. The 

area's design values have recently trended downward as emissions have declined due to 

programs such as the Acid Rain program and cleaner automobiles and fuels both regionally and 

locally. U.S. EPA’s rule to control nitrogen oxides from specific source categories (40 CFR 

Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the “NOx SIP Call”) 

has significantly reduced emissions from large electric generating units (EGUs), industrial 

boilers and cement kilns. Indiana's NOx Rule was approved on June 6, 2001 (326 IAC 10-3 and 

10-4). The SIP submittals of other Midwest states were approved in this timeframe as well. An 

analysis of meteorological conditions and monitoring values is in Section 7.0 and supports the 

conclusion that attainment of the standard as of 2009 is not the result of unusually favorable 

meteorological conditions. It is expected that this downward trend will continue as the above 

programs continue. 

3.3 Quality Assurance

Ohio and Kentucky have quality assured all data shown in Appendix A in accordance with 40 

CFR 58.10 and the Quality Assurance Manual. Ohio and Kentucky have recorded the data in the 

AQS database and, thus, the data are available to the public. 

9
3.4 Continued Monitoring

Ohio and Kentucky have committed to continue monitoring ozone levels at the sites indicated in 

Table 3.1 and Appendix A. IDEM will consult with Ohio, Kentucky and the U.S. EPA Region 

IV and V staff prior to making changes to the existing monitoring network, should changes 

become necessary in the future. Ohio and Kentucky will continue to quality assure the 

monitoring data to meet the requirements of 40 CFR 58. Updates to the IDEM website1 will 

provide real time availability of the data and knowledge of any exceedances at these monitors. 

Ohio and Kentucky will enter all data into AQS in a timely manner in accordance with federal 

guidelines. 

4.0 EMISSION INVENTORY 

U.S. EPA’s Redesignation Guidance requires the submittal of a comprehensive inventory of 

ozone precursor emissions (VOC and NOx) representative of the year when the area achieves 

attainment of the ozone air quality standard. Indiana must also demonstrate that the 

improvement in air quality between the year that violations occurred and the year that attainment 

was achieved is based on permanent and enforceable emission reductions. Other requirements 

related to the emissions inventory include a projection of the emission inventory to a year at least 

ten (10) years following redesignation, a demonstration that the projected level of emissions is 

sufficient to maintain the ozone standard and a commitment to provide future updates of the 

inventory to enable tracking of emission levels during the ten (10) year maintenance period. The 

following subsections address each of these requirements. 

4.1 Emission Trends

Point Sources

Graphs 4.1 and 4.2 show the trend within Indiana’s portion of the Cincinnati-Hamilton OH-KYIN nonattainment area, in point source emissions of NOx and VOC, respectively, that generally 

correspond to the years of monitored values referenced in this plan. The point source data is 

taken from Indiana's annual emissions reporting program. Graphs and data tables of emissions 

from each point source in Lawrenceburg Township, Dearborn County, Indiana are available in 

Appendix B. Although the Indiana data shows a slight increase in the point source emissions for 

NOx and VOC, the emissions within Indiana’s portion of the Cincinnati-Hamilton OH-KY-IN 

nonattainment area are insignificant compared to the point source emissions within the entire 

nonattainment area, as can be seen in Graphs 4.15 and 4.16. Graphs 4.3 and 4.4 show the trend 

of point source emissions within the entire Cincinnati-Hamilton OH-KY-IN nonattainment area. 

Although the emissions trend within the entire Cincinnati-Hamilton OH-KY-IN nonattainment 

area for VOC shows very little change in point source emissions, overall anthropogenic 

emissions for NOx and VOC are trending downward, as can be seen in Graphs 4.9 and 4.10. 

 

1 http://www.in.gov/idem/4670.htm

10
Graph 4.1 NOx Point Source Emissions, Lawrenceburg Township, Dearborn County, 

Indiana, 2005 and 2008 

-

5.00

10.00

15.00

20.00

25.00

30.00

35.00

2005 2008

Year

Tons Per Summer Day

NOx

Graph 4.2 VOC Point Source Emissions, Lawrenceburg Township, Dearborn County, 

Indiana, 2005 and 2008 

-

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

2005 2008 Year

Tons Per Summer Day

VOC

11
Graph 4.3 NOx Point Source Emissions, Entire Nonattainment Area, 2005 and 2008 

-

25.00

50.00

75.00

100.00

125.00

150.00

175.00

200.00

2005 2008

Year

Tons Per Summer Day

NOx

Graph 4.4 VOC Point Source Emissions, Entire Nonattainment Area, 2005 and 2008 

-

2.00

4.00

6.00

8.00

10.00

12.00

14.00

16.00

2005 2008

Year

Tons Per Summer Day

VOC

12
EGU Sources

Graph 4.5 shows the trend in NOx emissions from the American Electric Power (AEP)-Tanners 

Creek Generating Station in Lawrenceburg Township, Dearborn County, Indiana. Graph 4.6 

depicts the trends in NOx emissions from EGUs for the entire nonattainment area. While ozone 

and its precursors are also transported into this region from outside areas, this information does 

provide some indication of the impact that the EGUs located in the nonattainment area may have 

on the entire nonattainment area. The emissions are decreasing substantially in response to 

national programs affecting all EGUs, such as the Acid Rain program and the NOx SIP Call. 

Other sectors of the inventory also impact ozone formation, but large regional sources such as 

EGUs have a substantial impact on the formation of ozone. Graphs and data tables of emissions 

from each EGU source are available in Appendix D. 

These data were taken from U.S. EPA's Clean Air Markets database2. Data are available sooner 

for these units than other point sources in the inventory because of the NOx SIP Call budget and 

trading requirements. Information from 2003 is significant because some EGUs started 

operation of their NOx SIP Call controls in order to generate Early Reduction Credits for their 

future year NOx budgets. The first season of the NOx SIP Call budget period began May 31, 

2004. 

As part of the NOx SIP Call, the states were required to adopt into their rules a budget for all 

large EGUs. Indiana’s budget is found in Indiana’s rules at 326 IAC 10-4. The budget 

represents a statewide cap on NOx emissions. Although each unit is allocated emissions based 

upon historic heat input, utilities can meet this budget by over-controlling certain units or 

purchasing credits from the market to account for overages at other units. To summarize, NOx

emissions have dramatically decreased over the years as represented on these graphs. These 

emissions, capped by the state rule, should remain at least this low through the maintenance 

period covered by this request. 

 

2

 http://www.epa.gov/airmarkets/

13
Graph 4.5 NOx Emissions from Lawrenceburg Township, Dearborn County, Indiana 

Electric Generating Unit American Electric Power-Tanners Creek Generating Station, 

1999-2008 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

1999200020012002200320042005200620072008

Year

Tons per Year

NOx

Graph 4.6 NOx Emissions from Entire Nonattainment Area Electric Generating 

Units, 1999-2008 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

1999200020012002200320042005200620072008

Year

Tons per Year

NOx

14
All Anthropogenic Sources

Periodic inventories, which include emissions from all sectors (mobile, area, nonroad and point 

sources) were prepared for 2005 and will be prepared soon for 2008. The 2008 point source data 

for Lawrenceburg Township, Dearborn County, Indiana is taken from Indiana’s annual 

emissions reporting program. All other emission sources were extrapolated from Indiana’s 2005 

periodic inventory submitted to U.S. EPA. Graphs 4.7 and 4.8 show the trends for the total 

emissions for NOx and VOC for all anthropogenic source categories within Dearborn County, 

and Graphs 4.9 and 4.10 show the trends for the entire nonattainment area, which also roughly 

follow the years of monitored air quality trends discussed in Section 3.0. Although Indiana’s 

portion of the nonattainment area shows an increase in VOC, overall anthropogenic emissions in 

the entire nonattainment area have decreased as can be seen in Graph 4.10. Graphs and data 

tables of emissions from each source category are available in Appendix C. IDEM received 

emissions information for the Ohio and Kentucky portions of the nonattainment area for the 

years 2005, 2008, 2015 and 2020 from the Ohio EPA and Kentucky Division for Air Quality. 

Graph 4.7 NOx Emissions Trends, 2005 and 2008, All Anthropogenic Sources in 

Lawrenceburg Township, Dearborn County 

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5.00

10.00

15.00

20.00

25.00

30.00

35.00

2005 2008

Year

Tons Per Summer Day

NOx

15
Graph 4.8 VOC Emissions Trends, 2005 and 2008, All Anthropogenic Sources in 

Lawrenceburg Township, Dearborn County 

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1.00

2.00

3.00

4.00

5.00

6.00

7.00

8.00

2005 2008

Year

Tons Per Summer Day

VOC

Graph 4.9 NOx Emissions Trends, 2005 and 2008, All Anthropogenic Sources-Entire 

Nonattainment Area 

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100.00

150.00

200.00

250.00

300.00

350.00

400.00

2005 2008 Year

Tons Per Summer Day

NOx

16
Graph 4.10 VOC Emissions Trends, 2005 and 2008, All Anthropogenic Sources-Entire 

Nonattainment Area 

-

25.00

50.00

75.00

100.00

125.00

150.00

175.00

200.00

225.00

2005 2008

Year

Tons Per Summer Day

VOC

4.2 Base Year Inventory

IDEM prepared a comprehensive inventory for Lawrenceburg Township, Dearborn County, 

including area, mobile, nonroad and point sources for precursors of ozone (VOC and NOx) for 

the base year 2008. 

• Area sources were extrapolated from the Indiana 2005 periodic inventory submitted to U.S. 

EPA. 

• Mobile source emissions were calculated from MOBILE6.2 produced emission factors and 

data extracted from the region’s travel-demand model. Several adjustments were made to the 

travel demand model and calculation methodology since 1996. As a result, since the 1996, 

1999 and 2002 emission inventories were prepared with slightly different methodology, they 

do not provide a true comparison with the 2004 through 2020 estimates. The fluctuations 

referenced in the data, particularly 1996 through 2002 NOx emissions, are due to changes in 

the calculation methodology, not necessarily actual mobile source emissions. 

• Point source information was compiled from IDEM’s 2008 annual emissions statement 

database and the 2008 U.S. EPA Air Markets acid rain database3. 

• Biogenic emissions are not included in these summaries. 

• Nonroad emissions for 2008 were extrapolated from the 2005 National Emissions Inventory 

(NEI). To address concerns about the accuracy of some of the categories in U.S. EPA’s 

nonroad emissions model, the Lake Michigan Air Directors Consortium (LADCO), 

 

3 http://camddataandmaps.epa.gov/gdm/

17
contracted with two (2) companies to review the base data and make recommendations. One 

of the contractors also estimated emissions for two (2) categories not included in U.S. EPA’s 

nonroad model and reviewed model inputs for another. Emissions were estimated for 

commercial marine vessels and railroads. Recreational motorboat population and spatial 

surrogates (used to assign emissions to each county) were significantly updated. The 

populations for the construction equipment category were reviewed and updated based upon 

surveys completed in the Midwest and the temporal allocation for agricultural sources was 

also updated by the other contractor. A new nonroad estimation model was provided by U.S. 

EPA for the 2002 analysis. The 1996 and 1999 nonroad emission estimates were generated 

by a previous U.S. EPA model, and thus, cannot provide a true comparison. The fluctuations 

referenced in the data could be due to changes in the model and methodology and do not 

necessarily reflect changes in emissions. 

IDEM received emissions information for the Ohio and Kentucky portions of the nonattainment 

area for the years 2005, 2008, 2015 and 2020 from the Ohio EPA and Kentucky Division for Air 

Quality. This inventory was prepared using similar methodologies. 

Appendices B, C and E contain data tables and graphs of all these emissions. 

4.3 Emission Projections

In consultation with the U.S. EPA and other stakeholders, IDEM selected the year 2020 as the 

maintenance year for this redesignation request. This document contains projected NOx and 

VOC emissions inventories for 20154 and 20205.

 

IDEM, with assistance from LADCO, prepared NOx and VOC emission projections for 2015 and 

2020 for Indiana’s portion of the nonattainment area. IDEM received emissions information for 

Ohio and Kentucky portions of the nonattainment area for the years 2005, 2008, 2015 and 2020 

from the Ohio EPA and Kentucky Division for Air Quality. 

The detailed NOx and VOC inventory information for the entire nonattainment area for 2015 and 

2020 is in Appendix E. NOx and VOC emission trends are an important gauge for continued 

compliance with the ozone standard. Therefore, IDEM performed an initial comparison of the 

NOx and VOC inventories for the base year (2008), interim year (2015) and maintenance year 

(2020) for Lawrenceburg Township, Dearborn County. Graphs 4.11 and 4.12 visually compare 

the 2008 (base year) estimated NOx and VOC emissions with the 2015 and 2020 projected 

emissions for Lawrenceburg Township, Dearborn County, and Graphs 4.13 and 4.14 visually 

compare the 2008 (base year) estimated NOx and VOC emissions with the 2015 and 2020 

projected emissions for the entire nonattainment area. Graphs 4.15 and 4.16 visually compare 

the 2008 (base year) estimated NOx and VOC emissions with the 2015 and 2020 projected 

emissions for Lawrenceburg Township to the Kentucky and Ohio portions of the nonattainment 

area. Mobile source emission inventories are described in Section 5.0. In addition to LADCO’s 

 

4

 In Section 4.3 all emissions projections for area, non-road, and point/EGU emission projections for the year 2015 

are based on 2009 emission estimates. 

5

 In Section 4.3 all emission projections for area, non-road, and point/EGU emission projections for the year 2020 

are based on 2018 emission estimates. 

18
estimates, NOx emissions were projected based on the statewide EGU NOx budgets from the 

Indiana NOx rule. Although Indiana’s portion of the nonattainment area shows a slight increase 

in emissions from 2015 to 2020 for both NOx and VOC, overall anthropogenic emissions in the 

entire nonattainment area have decreased as can be seen in Graph 4.13 and Graph 4.14 

Graph 4.11 Comparison of 2008 Emissions and 2015 and 2020 Projected NOx Emissions for 

Lawrenceburg Township, Dearborn County 

-

5.00

10.00

15.00

20.00

25.00

30.00

35.00

2008 2015 2020

Year

Tons Per Summer Day

NOX

19
Graph 4.12 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions 

for Lawrenceburg Township, Dearborn County 

-

1.00

2.00

3.00

4.00

5.00

6.00

7.00

8.00

2008 2015 2020

Year

Tons Per Summer Day

VOC

Graph 4.13 Comparison of 2008 Emissions and 2015 and 2020 Projected NOx Emissions for 

the Entire Nonattainment Area 

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50.00

100.00

150.00

200.00

250.00

300.00

350.00

2008 2015 2020

Year

Tons Per Summer Day

NOX

20
Graph 4.14 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions 

for the Entire Nonattainment Area 

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75.00

100.00

125.00

150.00

175.00

200.00

2008 2015 2020

Year

Tons Per Summer Day

VOC

Graph 4.15 Comparison of 2008 Emissions and 2015 and 2020 Projected NOx Emissions for 

Lawrenceburg Township, Dearborn County Indiana and Kentucky and Ohio 

-

50.00

100.00

150.00

200.00

250.00

2008 2015 2020

Year

Tons Per Summer Day

Lawrenceburg Township, IN Kentucky Ohio

21
Graph 4.16 Comparison of 2008 Emissions and 2015 and 2020 Projected VOC Emissions 

for Lawrenceburg Township, Dearborn County Indiana and Kentucky and Ohio 

-

20.00

40.00

60.00

80.00

100.00

120.00

140.00

160.00

2008 Year 2015 2020

Tons Per Summer Day

Lawrenceburg Township, IN Kentucky Ohio

Table 4.1 Comparison of 2008 Emissions and 2020 Projected NOx and VOC Emission 

Estimates, All Anthropogenic Sources in Lawrenceburg Township, Dearborn County, 

Indiana (Tons per Summer Day) 

 

2008 2020 Change % Decrease 

NOX 33.09 32.56 -0.53 1.60% 

VOC 7.49 6.96 -0.53 7.07% 

Table 4.2 Comparison of 2008 Emissions and 2020 Projected NOx and VOC Emission 

Estimates, All Anthropogenic Sources in the Entire Nonattainment Area (Tons Per 

Summer Day) 

 

2008 2020 Change % Decrease 

NOX 309.47 262.47 47.00 15.18% 

VOC 187.78 157.37 30.41 16.19% 

VOC emissions within Lawrenceburg Township, Dearborn County are projected to decline by 

7.07% between 2008 and 2020 and by 16.19% in the entire nonattainment area. NOx emissions 

within Lawrenceburg Township, Dearborn County are projected to decline by 1.60% between 

2008 and 2020 and by 15.18% in the entire nonattainment area. Emission reduction benefits 

22
from U.S. EPA rules covering the NOx SIP Call, Tier 2 Motor Vehicle Emissions Standards and 

Gasoline Sulfur Control Requirements6

, Heavy-Duty Highway Engine Rule7 and Nonroad 

Diesel Engine Rule8 are factored into the changes. Further, due to implementation of the NOx

SIP Call across the eastern United States, NOx and ozone levels entering this area will decrease. 

4.4 Demonstration of Maintenance

Ambient air quality data from all monitoring sites indicate that air quality in the entire 

Cincinnati-Hamilton OH-KY-IN nonattainment area met the NAAQS for ozone in 2009. U.S. 

EPA’s Redesignation Guidance (pg. 9) states, “A state may generally demonstrate maintenance 

of the NAAQS by either showing that future emissions of a pollutant or its precursors will not 

exceed the level of the attainment inventory, or by modeling to show that the future mix of 

sources and emissions rates will not cause a violation of the NAAQS.” Emissions projections 

outlined in Section 4.0 of this document clearly illustrate that VOC and NOx emissions in 

Lawrenceburg Township, Dearborn County and the entire nonattainment area will continue to 

decline between 2008 (base year) and 2020. Section 7.0 further discusses the implications of 

these emissions trends and provides an analysis to support these conclusions. Therefore, air 

quality should meet the ozone NAAQS through the projected years of 2015 and 2020. 

In Indiana, major point sources in all counties are required to submit air emissions information 

once every three (3) years or annually if the VOC potential to emit is greater than 250 tons per 

year or the NOx potential to emit is greater than 2,500 tons per year, in accordance with Indiana’s 

Emission Statement Rule at 326 IAC 2-6. IDEM prepares a new periodic inventory for all ozone 

precursor emission sectors every three (3) years. These ozone precursor inventories will be 

prepared for 2011, 2014 and 2017, as necessary, to comply with the inventory reporting 

requirements established in the CAA. Emissions information will be compared to the 2008 base 

year and the 2020 projected maintenance year inventories to assess emission trends, as 

necessary, to assure continued compliance with the ozone standard. 

4.5 Permanent and Enforceable Emissions Reductions

Permanent and enforceable reductions of VOCs and NOx have resulted in attainment of the 8-

hour ozone standard. Some of these reductions were due to the application of Reasonably 

Available Control Technology (RACT) rules and some were due to the application of tighter 

federal standards on new vehicles. In addition, Title IV of the Clean Air Act and the NOx SIP 

Call required the reduction of NOx from utility sources. Section 6.0 identifies the emission 

control measures specific to Lawrenceburg Township, Dearborn County, as well as the 

implementation status of each measure. 

 

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

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

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

23
4.6 Provisions for Future Updates 

As required by Section 175A(b) of the CAA, Indiana commits to submit to the Administrator, 

eight (8) years after redesignation, an additional revision of this SIP. The revision will contain 

Indiana's plan for maintaining the national primary ozone air quality standard for ten (10) years 

beyond the first ten (10) year period after redesignation. 

5.0 MOBILE SOURCE EMISSION BUDGETS

U.S. EPA requirements outlined in 40 CFR 93.118(e) (4) stipulate that mobile source emissions 

budgets for VOC and NOx be established as part of a State Implementation Plan (SIP). The 

mobile source emissions budgets are necessary to demonstrate conformance of transportation 

plans and improvement programs with the SIP. The following is a summary of the detailed 

mobile input and output calculation files located in Appendix F. 

5.1 On-Road Emission Estimates

The Ohio-Kentucky-Indiana Regional Council of Governments (OKI) is the Metropolitan 

Planning Organization (MPO) for the Cincinnati-Hamilton OH-KY-IN area which includes 

Dearborn County in Indiana; Butler, Clermont, Clinton, Hamilton, and Warren Counties in Ohio; 

as well as, Boone, Campbell and Kenton Counties in Kentucky. This organization maintains a 

travel demand forecasting model that is used to simulate the traffic in the area and to predict 

what traffic would be in future years given growth expectations. The model is used mostly to 

identify where travel capacity will be needed and to determine the infrastructure requirements 

necessary to meet that need. It is also used to support the calculation of mobile source 

emissions. The travel demand forecasting model is used to predict the total daily vehicle miles 

traveled (VMT) and the U.S. EPA software program referred to as MOBILE6.2 is used to 

produce emission factors to calculate the emissions per mile. The product of these two outputs, 

once combined, is the total amount of pollution emitted by on-road vehicles for the particular 

analyzed area. 

5.2 Overview 

Broadly described, MOBILE6.2 is used to generate “emission factors”, which are the average 

emissions per mile (grams/mile) for ozone precursors: NOx and VOC. There are numerous 

variables that can affect the emission factors. The vehicle-fleet (vehicles on the road) age and 

the vehicle types have a major affect on the emission factors. The facility-type the vehicles are 

traveling on (MOBILE6.2 facility-types are Freeway, Arterial, Local and Ramp) and the vehicle 

speeds also affect the emission factor values. Meteorological factors such as air temperature and 

humidity affect the emission factors, as does fuel type, such as low RVP gasoline. These data 

are estimated using the best available data to generate emission factors for the appropriate ozone 

precursors, NOx and VOC. After emission factors are generated, the emission factor(s) must be 

multiplied by the VMT to determine the quantity of vehicle-related emissions. This information 

derives from the travel demand model (TDM). 

24
It should be noted that each year analyzed will have different emission factors, volumes, speeds 

and likely some additional links. MOBILE6.2 input and output files can all be found in 

Appendix F. 

5.3 Emission Estimations

Table 5.1 outlines the on-road emission estimates for the entire nonattainment area for the years 

2005, 2008 (Attainment Year), 2015 (Interim Year) and 2020 (Horizon Year). The following 

emission estimates are based on the actual TDM network runs for the years 2005, 2008, 2015 

and 2020. 

Table 5.1 

Emission Estimations for On-Road Mobile Sources 

for the Cincinnati-Hamilton OH-KY-IN Ozone Nonattainment Area 

Cincinnati-Hamilton OHKY-IN NA Area 2005 2008 2015 2020 

VOC (tons/day) 69.43 55.47 35.35 32.14 

NOx (tons/day) 136.73 113.45 51.04 38.17 

Lawrenceburg Township 

(Dearborn County Indiana) 

subtotal 

VOC (tons/day) 1.00 0.75 0.50 0.42 

NOx (tons/day) 1.44 1.14 0.60 0.42 

Lawrenceburg Township 

subtotal % 

VOC (tons/day) 1.44 1.35 1.41 1.31 

NOx (tons/day) 1.05 1.00 1.18 1.10 

Table 5.2 contains the 2015 and 2020 regional motor vehicle emissions budgets for the Ohio and 

Indiana portions of the nonattainment area. 

Table 5.2 

Motor Vehicle Emission Budgets (MVEB) for the 

Ohio and Indiana Portions of the Cincinnati-Hamilton OH-Ky-IN Ozone Nonattainment 

Area 

2015 2020 

VOC (tons/day) 31.73 28.82 

NOx (tons/day) 49.00 34.39 

This document creates an Interim Year Motor Vehicle Emission Budgets (MVEB) for 2015 and 

a Horizon Year MVEB for 2020 for the Ohio and Indiana portions of the nonattainment area. 

25
These budgets are based on the 2008 on-road emission inventory used to support photochemical 

modeling for the same year, and has incorporated a fifteen (15) percent safety margin as 

described below. 

Initial Base M (2005) CAMx modeling results indicated a worst case future design value in the 

Cincinnati-Hamilton OH-KY-IN nonattainment area of 83 ppb. In an effort to accommodate 

future variations in TDMs and vehicle miles traveled forecast when no change to the network is 

planned, Indiana consulted with the interagency consultation group, including U.S. EPA – 

Region 5, to determine a reasonable approach to address this variation. Based on this discussion, 

a fifteen (15) percent safety margin was approved and has been added to the MVEB for the Ohio 

and Indiana portions of this nonattainment area. 

A fifteen (15) percent safety margin is appropriate because; 1) there is an acknowledged 

potential variation in VMT forecast and potential estimated mobile source emissions due to 

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

emissions from all sources is sufficient to accommodate this fifteen (15) percent allocation of 

safety margin to mobile sources while still continuing to maintain total emissions in the 

Cincinnati-Hamilton OH-KY-IN area well below the 2008 attainment level of emissions. This 

fifteen (15) percent safety margin was calculated by adding a straight-line fifteen (15) percent to 

the mobile source emission estimates for the years 2015 and 2020. 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 fifteen (15) percent of the total emission reduction from all sources 

as can be seen from Tables 4.1 and 4.2. 

In summary, for all three states combined, the mobile budget safety margin allocation translates 

into: 

• An allocation of 6.14 tons/day for VOC and 9.39 tons/day for NOx for 2015; and 

• An allocation of 6.76 tons/day for VOC and 9.49 tons/day for NOx for 2020. 

40 CFR 93.101 defines safety margin as the amount by which the total projected emissions from 

all sources of a given pollutant area less than the total emissions that would satisfy the applicable 

requirement for reasonable further progress, attainment, or maintenance. When compared to the 

overall safety margin as defined by 40 CFR 93.101, it is evident this allocation to mobile sources 

is significantly below the total safety margin for all sources in the Cincinnati-Hamilton OH-KYIN area as detailed in Tables 4.1 and 4.2. 

While Indiana believes that this is sufficient to support the requested increase, Indiana and its 

partners will be conducting additional air quality modeling which will include the adjusted onroad mobile emissions as well as any additional corrections and modifications that may be 

necessary due to the constant review and evaluation of the model inputs. 

Appendix F of this document provides a detailed description of how the above budgets were 

established and also documents the consultation and coordination process among the effected 

environmental and transportation planning agencies in establishing the budgets. 

26
6.0 CONTROL MEASURES AND REGULATIONS 

This section provides specific information on the control measures implemented in 

Lawrenceburg Township, Dearborn County, including CAA requirements and additional state or 

local measures implemented beyond CAA requirements. 

6.1 Reasonably Available Control Technology (RACT)

As required by Section 172 of the CAA, in the mid-1990s, Indiana promulgated rules requiring 

RACT for emissions of VOCs. There were no specific rules required by the CAA such as RACT 

for existing sources beyond statewide rules. Statewide RACT rules have applied to all new 

sources locating in Indiana since that time. The Indiana rules are found in 326 IAC 8. The 

following is a listing of applicable rules: 

326 IAC 8-1 Best Available Control Technology-New Facilities 

326 IAC 8-2 Surface Coating Emission Limitations 

326 IAC 8-3 Solvent Degreasing Operations 

326 IAC 8-4 Petroleum Sources 

326 IAC 8-5 Miscellaneous Operations 

326 IAC 8-6 Organic Solvent Emission Limitations 

Additional rules specifically applicable to Lawrenceburg Township, Dearborn County are 

summarized in Section 6.4. 

6.2 Implementation of Past SIP Revisions

Lawrenceburg Township, Dearborn County was not required to develop an Attainment 

Demonstration SIP for the 1-hour NAAQS. The area was designated nonattainment for 8-hour 

ozone NAAQS in April 2004. Indiana previously submitted an Attainment Demonstration for 

Lawrenceburg Township, Dearborn County on June 13, 2007, but the area has now attained the 

standard. Emissions of VOCs are regulated by applicable statewide provisions of 326 IAC 8. 

6.3 Nitrogen Oxides (NOx) Rule

The U.S. EPA NOx SIP Call required twenty-two states to adopt rules that would result in 

significant emission reductions from large EGUs, industrial boilers and cement kilns in the 

eastern United States. Indiana adopted this rule in 2001. Beginning in 2004, this rule accounts 

for a reduction of approximately thirty-one percent (31%) of all NOx emissions statewide 

compared to the previous uncontrolled years. 

Twenty-one other states have also adopted these rules. The result is that significant reductions 

have occurred regionally and upwind within the nonattainment area because of the number of 

affected units within the region. Graphs 4.5 and 4.6 show that emissions covered by this 

program have been trending downward since 1999. Table 6.1, compiled from data taken from 

the U.S. EPA Clean Air Markets website, quantifies the gradual NOx reductions that have 

occurred in Indiana as a result of Title IV (Acid Rain) of the CAA and the NOx SIP Call Rule. 

27
Further, U.S. EPA more recently published Phase II of the NOx SIP Call that established a 

budget for large (greater than 1 ton per day emissions) stationary internal combustion engines. 

This rule decreases emissions statewide from natural gas compressor stations by 4,263 tons 

during the ozone season. The Indiana Phase II NOx SIP Call rule became effective February 26, 

2006 and implementation began in 2007. 

TABLE 6.1 Trends in EGU Ozone Season NOx Emissions Statewide in Indiana 

Statewide Indiana NOx Emissions from EGUs 

Year NOx Emissions (Tons per Year) 

1999 347,216.5 

2000 334,522.1 

2001 315,419.7 

2002 281,146.1 

2003 260,980.0 

2004 224,311.3 

2005 207,981.6 

2006 202,728.0 

2007 196,553.1 

2008 196,134.5 

Budget 2009-2014 108,935.0 

6.4 Measures Beyond Clean Air Act Requirements

 

Reductions in ozone precursor emissions have occurred, or are anticipated to occur, as a result of 

local and federal control programs. These additional control measures include: 

Tier 2 Emission Standards for Vehicles and Gasoline Sulfur Standards9

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

from light-duty trucks, including SUVs to meet an average standard of 0.07 grams of 

NOx per mile. Implementation began in 2004 and was completed in 2007. The Tier 2 

standards also cover passenger vehicles over 8,500 pounds gross vehicle weight rating 

(large pickup trucks and SUVs), which are not covered by the current Tier 1 standards. 

For these vehicles, the standards were phased in beginning in 2008, with full compliance 

in 2009. The new standards require vehicles to be 77% to 95% cleaner than those on the 

road prior to the new standards. The standards also reduced the sulfur content of gasoline 

to 30 ppm beginning in January 2006. 

Heavy-Duty Diesel Engines10

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

that includes low-sulfur diesel fuel standards that took effect in 2004. A second phase of 

standards and testing procedures took effect in 2007 that reduced highway diesel fuel 

 

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

10http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 

28
sulfur content to 15 ppm. The total program is expected to achieve a 95% reduction in 

NOx from diesel trucks and buses, a large sector of the mobile sources NOx inventory. 

Clean Air Nonroad Diesel Rule11

In May 2004, U.S. EPA issued the Clean Air Nonroad Diesel Rule. This rule applies to 

diesel engines used in industries such as construction, agriculture and mining. It also 

contains a cleaner fuel standard similar to the highway diesel program. The new 

standards will cut emissions from nonroad diesel engines by over ninety percent (90%). 

Nonroad diesel equipment, as described in this rule, currently accounts for forty-seven 

percent (47%) of diesel particulate matter (PM) and twenty-five percent (25%) of 

nitrogen oxides (NOx) from mobile sources nationwide. Sulfur levels will be reduced in 

nonroad diesel fuel by ninety-nine percent (99%) from current levels, from approximately 

three thousand (3,000) parts per million (ppm) now to (fifteen) 15 ppm in 2015. New 

engine standards take effect, based on engine horsepower, starting in 2008. 

Together, these rules will substantially reduce local and regional sources of ozone precursors. 

The modeling analyses discussed in Section 7.0 include these rules and show the ozone 

concentrations expected to result from their implementation. 

Local Reductions

Several permanent and enforceable reductions in emissions from local point sources have 

occurred beyond Clean Air Act Requirements. 

The American Electric Power (AEP) -Tanner’s Creek Generating Station power plant, located in 

Lawrenceburg Township in Dearborn County, is covered by a consent decree and several, but 

not all, electric generating units will have to apply controls. Currently, the power plant is 

controlled by low NOx burner technology (dry bottom only) and overfire air. AEP-Tanner’s 

Creek Generating Station will be installing selective non-catalytic reduction systems on three of 

its four electric generating units, with operation to begin in early 2010. This will achieve an 

additional 30% reduction in NOx. The reductions from facilities like the AEP-Tanners Creek 

power plant will help improve air quality in the Cincinnati-Hamilton OH-KY-IN nonattainment 

area. 

6.5 Controls to Remain in Effect

Indiana commits to maintaining the aforementioned control measures after redesignation. 

Indiana commits that any changes to its rules or emission limits applicable to VOC and/or NOx

sources, as required for maintenance of the ozone standard in Lawrenceburg Township, 

Dearborn County, will be submitted to U.S. EPA for approval as a SIP revision. 

Indiana, through IDEM’s Office of Air Quality (OAQ) and the Office of Legal Counsel has the 

legal authority and necessary resources to actively enforce any violations of its rules or permit 

provisions. After redesignation, it intends to continue enforcing all rules that relate to the 

emission of ozone precursors in Lawrenceburg Township, Dearborn County. 

 

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

29
6.6 New Source Review Provisions

Indiana has a long standing and fully implemented New Source Review (NSR) program that is 

outlined in 326 IAC 2. The rule includes the Prevention of Significant Deterioration (PSD) 

permitting program in 326 IAC 2-2. Indiana's PSD program was conditionally approved on 

March 3, 2003 (68 FR 9892) and received final approval on May 20, 2004 (69 FR 29071) by 

U.S. EPA as part of the SIP. 

Any facility that is not listed in the 2005 emission inventory, or for the closing of which credit 

was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or 

reconstruct without meeting all applicable permit rule requirements. The review process will be 

identical to that used for new sources. Once the area is redesignated, Indiana will implement 

NSR for major sources through the PSD program, which requires an air quality analysis to 

evaluate whether the new source will threaten the NAAQS. 

7.0 MODELING AND METEOROLOGY 

7.1 Summary of Modeling Results for National Emission Control Strategies in Final Rulemakings

Although U.S. EPA’s Redesignation Guidance does not require modeling for ozone 

nonattainment areas seeking redesignation, extensive modeling has been performed covering the 

Cincinnati, Ohio region to determine the effect of national emission control strategies on ozone 

levels. These modeling analyses determined that the Cincinnati-Hamilton OH-KY-IN 8-hour 

ozone nonattainment area is significantly impacted by ozone and ozone precursor transport and 

regional NOx reductions have helped the area attain the 8-hour standard. These results show that 

even in the absence of the Clean Air Interstate Rule (CAIR), the area will continue to attain the 

standard. Modeling results with or without CAIR do not differ significantly because the 

summertime CAIR program is essentially the same as the NOx SIP Call, which was already 

included in the modeling analysis. 

7.2 U.S. EPA Modeling Analysis for HDE Final Rulemaking

U.S. EPA conducted modeling for Tier II vehicles and low-sulfur fuels. This analysis was 

performed in 2000 to support final rulemaking for the Heavy Duty Engine (HDE) and Vehicle 

Standards and Highway Diesel Fuel and its expected impact on ozone levels. “Technical 

Support Document for the Heavy Duty Engine and Vehicle Standards and Highway Diesel Fuel 

Sulfur Control Requirements: Air Quality Modeling Analyses” (EPA420-R-00-028) was 

referenced for support of this ozone redesignation for the Cincinnati nonattainment area. Base 

year emissions from 1996 were modeled for three ozone episodes: June 12-24, 1995; July 5-15, 

1995; and August 7-21, 1995. Results of this modeling show that ozone impacts from these fuel 

emission control measures, as well as the NOx SIP Call, would be substantial in the CincinnatiHamilton OH-KY-IN nonattainment area. Relative Response Factors (RRF) were calculated for 

each monitor in the Cincinnati-Hamilton OH-KY-IN nonattainment area for future years 2007 

and 2020. IDEM has applied these RRFs to the most recent three-year (2007-2009) design 

values. The resulting future year design values for 2007 and 2020 were calculated and are 

30
shown below in Table 7.1. The 2007 modeled future year design values for all monitors in the 

Cincinnati-Hamilton OH-KY-IN nonattainment area are in attainment of the 8-hour ozone 

NAAQS of 0.08 ppm. 

Table 7.1 

Modeling Results: U.S. EPA HDE Rulemaking for the Cincinnati-Hamilton OH-KY-IN 

Nonattainment Area

Monitor ID Monitor Name County 

Design 

Value 

2006-

2008 

Modeled 

Relative 

Response 

Factor (RRFs) 

Future 

Design 

Value 

Modeled 

 Relative 

Response 

Factor (RRFs) 

Future 

Design 

Value 

2007 Base 2007 2020 Base 2020

390170004 Cincinnati CMSA Butler 0.080 0.8957 0.072 0.8710 0.074 

390171004 Cincinnati CMSA Butler 0.082 0.8816 0.072 0.8507 0.069 

390250020 Cincinnati CMSA Clermont 0.078 0.8834 0.069 0.8600 0.068 

390271002 Cincinnati CMSA Clinton 0.080 0.8560 0.068 0.8191 0.067 

390610006 Cincinnati CMSA Hamilton 0.085 0.8949 0.076 0.8771 0.074 

390610010 Cincinnati CMSA Hamilton 0.081 0.8826 0.071 0.8749 0.071 

390610037 Cincinnati CMSA Hamilton 0.081 0.9095 0.074 0.8969 0.073 

391650006 Cincinnati CMSA Warren 0.085 0.8851 0.075 0.8576 0.063 

210150003 Cincinnati CMSA- KY Boone 0.071 0.8478 0.060 0.8205 0.071 

210371001 Cincinnati CMSA- KY Campbell 0.081 0.8804 0.073 0.8804 0.067 

211170007 Cincinnati CMSA- KY Kenton 0.078 0.8940 0.069 0.8787 0.074 

7.3 U.S. EPA Modeling for Clean Air Interstate Rule (CAIR), 2005

On March 10, 2005, the U.S. EPA finalized CAIR. NOx emissions from power plants will be cut 

by 1.7 million tons by 2009 and emissions will be reduced by 1.3 million tons in 2015 in 28 

eastern states and the District of Columbia. Compared to a 2003 baseline, Indiana will reduce 

NOx emissions by 113,000 tons by 2009 and 149,000 tons by 2015. To support this rulemaking, 

U.S. EPA first conducted a base case future year modeling run to show future year 

concentrations resulting from existing emissions controls and then conducted future year 

modeling with emission reductions attributed to CAIR. Results in Table 7.2 show what the base 

case modeled results without CAIR (base) and with CAIR’s emission reductions included. The 

modeling was based on 1999 – 2003 (1999-2001, 2000-2002 and 2001-2003) design values. 

Future year modeling was conducted, including the Cincinnati-Hamilton OH-KY-IN 

nonattainment area, and the future year design values for 2010 and 2015 were evaluated for 

attainment of the 8-hour ozone NAAQS. Results of the base case future year modeling and 

future year modeling with CAIR show that the area will attain the 8-hour ozone NAAQS in 2010 

under both scenarios with modeled concentrations below 0.085 ppm and modeled concentrations 

decreasing further by 2015. On December 23, 2008, CAIR was remanded without vacatur by the 

D.C. Circuit Court. 

31
Table 7.2 

Modeling Results from U.S. EPA for the Clean Air Interstate Rule

County MSA/CMSA 

Design Value 

(ppm) 

Future Design Value 

(ppm) 

Future Design Value 

(ppm) 

1999-2003 2010 Base 2010 CAIR 2015 Base 2015 CAIR 

Butler Cincinnati, OH – KY 0.0890 0.0782 0.0780 0.0752 0.0736 

Clermont Cincinnati, OH – KY 0.0900 0.0781 0.0780 0.0751 0.0725 

Clinton Cincinnati, OH – KY 0.0957 0.0817 0.0814 0.0774 0.0757 

Hamilton Cincinnati, OH - KY 0.0893 0.0788 0.0786 0.0758 0.0743 

Warren Cincinnati, OH – KY 0.0920 0.0802 0.0800 0.0766 0.0751 

Boone Cincinnati, OH – KY 0.0853 0.0731 0.0731 0.0710 0.0680 

Campbell Cincinnati, OH – KY 0.0925 0.0816 0.0815 0.0788 0.0768 

Kenton Cincinnati, OH – KY 0.0863 0.0757 0.0756 0.0733 0.0713 

7.4 LADCO’s Round 5 and Round 6 Modeling for 8-Hour Ozone Standard

LADCO recently performed updated Comprehensive Air Quality Model (CAMx) modeling for 

ozone, referred to as “Round 5 and Round 6”, which used the most recent emissions inventories 

and model updates. This modeling was performed to support attainment demonstrations for the 

five-state LADCO region. The photochemical model used by LADCO and Indiana for the 8-

hour ozone standard analysis is CAMx, Version 4.5, developed by Environ. This model has 

been accepted by U.S. EPA as an approved air quality model for regulatory analysis and 

attainment demonstrations. Requirements of 40 CFR 51.112 as well as the “Guidance on the 

Use of Models and Other Analyses in Attainment Demonstrations for the 8-Hour Ozone 

NAAQS” (EPA-454/R-05-002, Oct. 2005) are satisfied with the use of CAMx for attainment 

demonstrations. Meteorology from 2005, as well as 2005 base year emissions, were used to 

conduct the modeling. The ozone modeling metrics for bias, error, fractional bias, and fractional 

error met U.S. EPA modeling guidance performance criteria. The base-year design value for 

attainment purposes was calculated from the periods 2003 - 2005, 2004 - 2006 and 2005 - 2007. 

Round 5 modeling included several scenarios for attaining the ozone NAAQS. One scenario 

included the implementation of "on-the-books" controls for future years such as U.S. EPA motor 

vehicle and fuel standards with the inclusion of CAIR. Round 6 modeling included the 

implementation of "on-the-books" controls, similar to the Round 5 modeling except without the 

inclusion of CAIR. The future years modeled were 2009, 2012 and 2018. Modeling results, in 

Table 7.3 and 7.4 below, show ozone concentrations in the Cincinnati-Hamilton OH-KY-IN 

nonattainment area below the 8-hour ozone standard in 2009. 

32
Table 7.3 

Application of Round 5 RRFs (with CAIR) to Most Current Base-Year Design Values

2009 2012 2018 

Monitor ID Site 

2003-2007 

Base DV 

2009 

RRF 

Future 

DV 

2012 

RRF 

Future 

DV 

2018 

RRF 

Future 

DV 

390170004 Butler Co. - OH 0.0833 0.947 0.078 0.922 0.076 0.851 0.070 

390171004 Butler Co. - OH 0.0823 0.95 0.078 0.925 0.076 0.853 0.070 

390250022 Clermont Co. - OH 0.0810 0.962 0.077 0.941 0.076 0.877 0.071 

390271002 Clinton Co. - OH 0.0823 0.941 0.077 0.910 0.074 0.830 0.068 

390610006 Hamilton Co. - OH 0.0847 0.967 0.081 0.948 0.080 0.881 0.074 

390610010 Hamilton Co. - OH 0.0820 0.955 0.078 0.934 0.076 0.878 0.071 

390610040 Hamilton Co. - OH 0.0817 0.975 0.079 0.958 0.078 0.900 0.073 

391650007 Warren Co. - OH 0.0877 0.947 0.083 0.921 0.080 0.846 0.074 

210150003 Boone Co. - KY 0.0753 0.949 0.071 0.919 0.069 0.856 0.064 

210370003 Campbell Co. – KY 0.0853 0.978 0.083 0.962 0.082 0.906 0.077 

211170007 Kenton Co. - KY 0.0783 0.965 0.075 0.949 0.074 0.898 0.070 

Table 7.4 

Application of Round 6 RRFs (without CAIR) to Most Current Base-Year Design Values

2009 2012 2018 

Monitor ID Site 

2003-2007 

Base DV 

2009 

RRF 

Future 

DV 

2012 

RRF 

Future 

DV 

2018 

RRF 

Future 

DV 

390170004 Butler Co. - OH 0.0833 0.947 0.0789 0.925 0.0771 0.868 0.0723 

390171004 Butler Co. - OH 0.0823 0.948 0.0781 0.927 0.0763 0.868 0.0715 

390250022 Clermont Co. - OH 0.0810 0.955 0.0774 0.939 0.0761 0.893 0.0723 

390271002 Clinton Co. - OH 0.0823 0.94 0.0774 0.913 0.0752 0.849 0.0699 

390610006 Hamilton Co. - OH 0.0847 0.962 0.0814 0.947 0.0802 0.898 0.0760 

390610010 Hamilton Co. - OH 0.0820 0.953 0.0781 0.935 0.0767 0.892 0.0731 

390610040 Hamilton Co. - OH 0.0817 0.964 0.0787 0.952 0.0777 0.912 0.0742 

391650007 Warren Co. - OH 0.0877 0.944 0.0828 0.92 0.0807 0.857 0.0751 

210150003 Boone Co. - KY 0.0753 0.945 0.0712 0.925 0.0697 0.878 0.0661 

210370003 Campbell Co. – KY 0.0853 0.968 0.0829 0.957 0.0817 0.920 0.0785 

211170007 Kenton Co. - KY 0.0783 0.961 0.0753 0.948 0.0743 0.912 0.0714 

7.5 Summary of Existing Modeling Results

U.S. EPA and LADCO modeling shows that existing national emission control measures have 

brought counties in the Cincinnati-Hamilton OH-KY-IN nonattainment area into attainment of 

the 8-hour ozone NAAQS. Rulemakings to be implemented in the next several years will 

provide even greater assurance that air quality will continue to meet the standard into the future. 

Modeling support for the NOx SIP Call, Heavy Duty Engine and Highway Diesel Fuel, and Tier 

II/Low Sulfur Fuel and CAIR has shown future year design values for counties in the CincinnatiHamilton OH-KY-IN nonattainment area will attain the ozone standard with modeled future year 

design values below 0.085 ppm. Review of the design values of the ozone monitors in the 

Cincinnati-Hamilton OH-KY-IN nonattainment area show an overall decline in ozone 

concentrations, as indicated by the trend line for the ozone monitor (390610006) in Hamilton 

County, Ohio with the highest design value for 2007-2009. 

33
Graph 7.1 

Actual Design Values for Cincinnati Nonattainment Area from 1997 through 2009 

0.06

0.065

0.07

0.075

0.08

0.085

0.09

0.095

0.1

0.105

0.11

1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

390170004

390171004

390250020

390250022

390271002

390610006

390610010

390610037

390610040

391650002

391650006

391650007

210150003

210371001

210373002

210370003

211170007

Linear (390610006)

On December 23, 2008, CAIR was remanded without vacatur by the D.C. Circuit Court. U.S. 

EPA has modeled base case future years with existing emission controls only and shown that 

counties in the Cincinnati-Hamilton OH-KY-IN nonattainment area will attain the 8-hour ozone 

NAAQS without proposed additional national emission control strategies. The application of the 

most current relative response factors from LADCO’s Round 5 and Round 6 modeling 

demonstrates that the area will continue to attain the standard into the future with or without 

implementation of CAIR. Future national and local emission control strategies will ensure that 

each county’s attainment will be maintained with an increasing margin of safety over time. 

7.6 Temperature Analysis for the Cincinnati, Ohio Area

Meteorological conditions are one of the most important factors that influence ozone 

development and transport. A temperature analysis was conducted to determine how the 

temperatures during the ozone conducive months of April, May, June, July, August, September 

and October compare to normal temperatures for the Cincinnati area for the years 1971 through 

2000. Temperature information was taken from the National Weather Service Station at 

Cincinnati Municipal Airport Lunken Field. Normal maximum temperatures from 1971-2000 

for the Cincinnati area are as follows: 

 May – 74.8o F 

 June – 82.7o F 

 July – 86.7o

 F 

 August – 85.1o F 

 September – 78.7o

 F 

 May - September – 81.6o

 F 

34
Monthly maximum temperatures for the previous 10 years (2000 – 2009) during the summer 

months are compared to normal summer month temperatures in Table 7.5. Overall, the 

temperatures during the 2002, 2003, 2005 and 2007 summer months of May, June, July, August 

and September were 1% to 6% above normal while temperatures during the 2000, 2001, 2004, 

2006, 2008 and 2009 summer months were at normal to 4% lower than the normal temperatures. 

Table 7.5 shows the average temperatures in the Cincinnati area for each of the past ten years 

and the percent difference from normal for each year. 

Table 7.5 

Analysis of Maximum Temperatures for the Cincinnati, Ohio Area 

(Percent Change from Maximum Temperature (oF) Normals (1971 – 2000)) 

Normal 2000 2001 2002 2003 2004 

Max Max % Max % Max % Max % Max % 

May 74.8 75.6 +1 75.1 0 70.5 -6 70.5 -6 76.5 +2 

June 82.7 81.2 -2 80.1 -3 83.1 0 83.1 0 80.4 -3 

July 86.7 81.9 -6 83.9 -3 89.0 +3 89.0 +3 82.3 -5 

August 85.1 81.4 -4 83.8 -2 88.0 +3 88.0 +3 80.2 -6 

September 78.7 74.9 -5 74.5 -5 82.8 +5 82.8 +5 79 0 

AVE 81.6 79.0 -3 79.5 -3 82.7 +1 82.7 +1 79.7 -2 

 Normal 2005 2006 2007 2008 2009 

 Max Max % Max % Max % Max % Max % 

May 74.8 71.6 -4 71.9 -4 79.9 +7 71.1 -5 74.2 -1 

June 82.7 85.3 +3 80.1 -3 85.6 +4 83.8 +1 82.1 -1 

July 86.7 86.5 0 86.7 0 85.8 -1 84.9 -2 78.7 -9 

August 85.1 87.5 +3 87 +2 93.6 +10 85.4 0 81.6 -4 

September 78.7 81.6 +4 73.1 -7 85.7 +9 82.4 +5 76.6 -3 

AVE. 81.6 82.5 +1 79.8 -2 86.1 +6 81.5 0 78.6 -4 

The number of days with temperatures of 90o F and higher were collected from the National 

Weather Service Station at Cincinnati Municipal Airport Lunken Field and compared to the 

average number of days from 1999 through 2009 as well as the number of 8-hour ozone 

exceedance days. Table 7.6 shows this comparison of 8-hour ozone exceedance days and 

number of 90o

 F temperature days while Graph 7.2 shows the correlation graphically. 

35
Table 7.6 

Comparison of Days with 90o F and 8-Hour Ozone Exceedance Days 1998- 2009 

Number of Days with Temperatures of 90o F and higher 

Site County Ave. 90o F Days 1998 1999 2000 2001 2002 2003 

Cincinnati, OH Hamilton Co. 21.2 15 33 4 9 37 5 

Number of 8-Hour Exceedance Days at Cincinnati Nonattainment area ozone monitors 

Monitor County 1998 1999 2000 2001 2002 2003 

390170004 Butler Co 18 28 9 17 29 17 

390171004 Butler Co 33 37 10 16 33 17 

390250020 Clermont Co 30 42 15 N/O N/O N/O 

390250022 Clermont Co N/O N/O N/O 14 28 8 

390271002 Clinton Co 35 45 17 24 35 16 

390610006 Hamilton Co 21 22 6 13 33 18 

390610010 Hamilton Co 22 15 6 8 24 12 

390610040 Hamilton Co N/O 24 10 13 29 10 

391650006 Warren Co 18 34 11 14 33 2 

391650007 Warren Co N/O N/O N/O N/O N/O 18 

210150003 Boone Co 18 22 6 9 21 5 

210371001 Campbell Co 22 21 N/O N/O N/O N/O 

210373002 Campbell Co N/O N/O N/O N/O N/O N/O 

210370003 Campbell Co N/O N/O 12 19 38 8 

211170007 Kenton Co 22 28 9 12 32 8 

Number of Days with Temperatures of 90o F and higher 

Site County Ave. 90o F Days 2004 2005 2006 2007 2008 2009 

Cincinnati, OH Hamilton Co. 21.2 4 30 25 52 25 4 

Number of 8-Hour Exceedance Days at Cincinnati Nonattainment area ozone monitors 

Monitor County 2004 2005 2006 2007 2008 2009 

390170004 Butler Co 3 22 11 20 1 0 

390171004 Butler Co 5 24 4 27 7 0 

390250020 Clermont Co N/O N/O N/O N/O N/O N/O 

390250022 Clermont Co 4 16 7 17 0 0 

390271002 Clinton Co 6 23 10 21 4 0 

390610006 Hamilton Co 4 22 9 33 12 0 

390610010 Hamilton Co 3 19 10 23 7 0 

390610040 Hamilton Co 4 20 8 15 7 0 

391650006 Warren Co N/O N/O N/O N/O N/O N/O 

391650007 Warren Co 10 24 12 32 11 0 

210150003 Boone Co 1 8 0 6 0 0 

210371001 Campbell Co N/O N/O N/O N/O N/O N/O 

210373002 Campbell Co N/O N/O N/O 19 2 0 

210370003 Campbell Co 5 23 N/O N/O N/O N/O 

211170007 Kenton Co 2 12 3 12 2 0 

 N/O – Not Operational 

36
Graph 7.2 

Comparison of Days with 90o F and 8-Hour Ozone Exceedance Days 

0

10

20

30

40

50

60

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Year

Number of Days

90o F Days

390170004

390171004

390250020

390250022

390271002

390610006

390610010

390610037

390610040

391650006

391650007

210150003

210371001

210373002

210370003

211170007

As can be seen, a greater number of ozone exceedance days per year correlate with a greater 

number of 90o F days per year. The effects of national control measures appear to have an 

impact on the number of ozone exceedance days per year. This is evident in that 2005 had a 

greater number of days with temperatures of 90o F or more but the number of 8-hour exceedance 

days was lower. While other meteorological factors may have influenced this result to some 

degree, it appears that the lower emissions helped to keep the number of 8-hour ozone 

exceedance days lower during the ozone-conducive conditions of 2005. In 2007, there were 52 

days of 90o

 F or more and three monitors with the number of 8-hour ozone exceedance days over 

25. In 2002 there were 37 days of 90o

 F or more and nine monitors with the number of 8-hour 

ozone exceedance days over 25. There were similar meteorological conditions in 2002 and 2007 

and less monitors had days over the 8-hour ozone standard in 2007, indicating that emission 

reductions are decreasing ozone concentrations in the area. 

7.7 Summary of Meteorological Conditions

The analysis of the departure from normal of the maximum temperatures during the summer 

months shows variation as illustrated in Table 7.6 and Graph 7.2. The analysis shows that 15 or 

more days with temperatures of 90o F and higher occurred in 1998, 1999, 2002, 2005, 2006, 

2007 and 2008. The number of 8-hour ozone exceedance days for those years shows a greater 

correlation to the number of higher temperature days. However, the years with a lesser number 

of 90o

 F days still yielded 8-hour ozone exceedance days. For example, 2000 and 2001 had 

fewer than the normal amount of 90o

 F days; however, there were still a significant number of 8-

hour ozone exceedances for those years. In comparison, 2004 was a cooler year, but due to 

37
national emission reduction measures in effect, there were fewer ozone exceedances. Lower 

ozone values correspond to lowered local and regional ozone precursor emissions despite ozone 

conducive conditions. The 8-hour ozone standard, expressed as a 4th high ozone value averaged 

over 3 years, accounts for variations in temperature. Despite such variations, ozone values in the 

Cincinnati nonattainment area have steadily decreased since 1998. 

8.0 CORRECTIVE ACTIONS 

8.1 Commitment to Revise Plan

As noted in Section 4.6 above, Indiana commits to review its Maintenance Plan eight (8) years 

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

8.2 Commitment for Contingency Measures

Indiana hereby commits to adopt and expeditiously implement necessary corrective actions in the 

following circumstances: 

Warning Level Response: 

A Warning Level Response shall be prompted whenever an annual (1-year) fourth high 

monitored value of 0.089 ppm occurs in a single ozone season, or a two (2)-year average 

fourth high monitored value of 0.085 ppm or greater occurs within the maintenance area. 

A Warning Level Response will consist of a study to determine whether the ozone value 

indicates a trend toward higher ozone values or whether emissions appear to be 

increasing. The study will evaluate whether the trend, if any, is likely to continue and, if 

so, the control measures necessary to reverse the trend taking into consideration ease and 

timing for implementation, as well as economic and social considerations. 

Implementation of necessary controls in response to a Warning Level Response trigger 

will take place as expeditiously as possible, but in no event later than twelve (12) months 

from the conclusion of the most recent ozone season (September 30). Should it be 

determined through the Warning Level study that action is necessary to reverse the noted 

trend, the procedures for control selection and implementation outlined under “Action 

Level Response” shall be followed. 

Action Level Response

An Action Level Response shall be prompted whenever a violation of the standard (three 

(3)-year average fourth high monitored value of 0.085 ppm or greater) occurs within the 

maintenance area. In the event that the Action Level is triggered and is not found to be 

due to an exceptional event, malfunction, or noncompliance with a permit condition or 

rule requirement, IDEM will determine additional control measures needed to assure 

future attainment of the NAAQS for ozone. In this case, measures that can be 

implemented in a short time will be selected and be in place within eighteen (18) months 

from the close of the ozone season that prompted the Action Level. 

38
Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative 

and legal process. This process will include publication of notices, an opportunity for 

public hearing and other measures required by Indiana law for rulemaking by state 

environmental boards. 

If a new measure/control is already promulgated and scheduled to be implemented at the 

federal or state level, and that measure/control is determined to be sufficient to address 

the upward trend in air quality, additional local measures may be unnecessary. 

Furthermore, Indiana will submit to U.S. EPA an analysis to demonstrate the proposed 

measures are adequate to return the area to attainment. 

8.3 Contingency Measures

Contingency measures to be considered will be selected from a comprehensive list of measures 

deemed appropriate and effective at the time the selection is made. Listed below are example 

measures that may be considered. The selection of measures will be based upon costeffectiveness, emission reduction potential, economic and social considerations, or other factors 

that IDEM and U.S. EPA deem appropriate. IDEM will solicit input from interested and affected 

persons in the maintenance area prior to selecting appropriate contingency measures. All of the 

listed contingency measures are potentially effective or proven methods of obtaining significant 

reductions of ozone precursor emissions. Because it is not possible at this time to determine 

what control measure will be appropriate at an unspecified time in the future, the list of 

contingency measures outlined below is not comprehensive. Indiana anticipates that if 

contingency measures should ever be necessary, it is unlikely that a significant number (i.e., all 

those listed below) will be required. 

1. Installation of a vehicle emissions testing program 

2. Asphalt paving (lower VOC formulation) 

3. Diesel exhaust retrofits 

4. Traffic flow improvements 

5. Idle reduction programs 

6. Portable fuel container regulation (statewide) 

7. Park and ride facilities 

8. Rideshare/carpool program 

9. VOC cap/trade program for major stationary sources 

10. Commercial/consumer solvents (statewide) 

11. NOx Reasonably Available Control Technology 

No contingency measure shall be implemented without providing the opportunity for full public 

participation during which the relative costs and benefits of individual measures, at the time they 

are under consideration, can be fully evaluated. 

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9.0 PUBLIC PARTICIPATION 

Indiana published notification for a public hearing and solicitation for public comment 

concerning the draft Redesignation Petition and Maintenance Plan in the Journal Press, 

Lawrenceburg, Indiana on December 7, 2009 and the Indianapolis Star, Indianapolis, Indiana on 

December 8, 2009. 

A public hearing to receive comments concerning the redesignation request was conducted on 

January 7, 2010 at the Lawrenceburg Public Library in Lawrenceburg, Indiana. The public 

comment period closed on January 13, 2009, no comments were received by the agency 

concerning this submission. Appendix J documents the public hearing process and includes a 

copy of the public notice, certifications of publication, and the transcript from the public hearing. 

10.0 CONCLUSIONS 

Lawrenceburg Township in Dearborn County, Indiana, along with the remaining portion of the 

Cincinnati-Hamilton OH-KY-IN nonattainment area, has attained the NAAQS standard for 

ozone. This petition demonstrates that Lawrenceburg Township in Dearborn County has 

complied with the applicable provisions of the CAA regarding redesignation of ozone 

nonattainment areas. IDEM has prepared a Redesignation Request and Maintenance Plan that 

meets the requirement of Section 110(a)(1) of the Clean Air Act. 

Indiana has performed an analysis that shows the air quality improvements are due to permanent 

and enforceable measures and that significant regional NOx reductions will ensure continued 

compliance (maintenance) with the standard. Additionally, Indiana has ensured that all CAA 

requirements necessary to support redesignation have been met. 

In addition to the corrective actions (should they be necessary) outlined in this submittal, Indiana 

continues to participate in the regional air quality planning efforts sponsored by LADCO. The 

current goal of the planning process is to establish a regional control strategy that provides for 

attainment of the ozone and fine particle standards throughout the states of Illinois, Indiana, 

Michigan, Ohio and Wisconsin. Along with the other LADCO states, Indiana is developing 

local and statewide emission control measures, where photochemical modeling and culpability 

analyses demonstrate a clear need and cost effectiveness analyses justify the implementation of 

such measures. These actions will provide for an even greater margin of safety for the 

Cincinnati, Ohio area and ensure continued maintenance well into the future. 

Based on this presentation, Indiana’s portion of the nonattainment area (Lawrenceburg Township 

in Dearborn County) meets the requirements for redesignation under Section 107(d)(3) of the 

CAA and U.S. EPA guidance. Furthermore, because this area is subject to transport, additional 

regional NOx and VOC reductions will ensure continued compliance (maintenance) with the 

standards and provide an increased margin of safety. 

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Consistent with the authority granted to the U.S. EPA under Section 107(d)(3) of the CAA, 

Indiana requests that Lawrenceburg Township in Dearborn County be redesignated to attainment 

simultaneously with U.S. EPA approval of the Redesignation Request and Maintenance Plan 

provisions contained herein.

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