John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Scott J. Nally, Director 

NOV 2 6 2012 

Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Blvd. R-19J 

Chicago, Illinois 60604-3507 

Re: Request for Review and Approval of the Revised Canton-Massillon Area Maintenance 

Plan Approval for the 1997 Eight-Hour Ozone Standard 

Dear Administrator Hedman: 

I am writing to formally request review and approval of a revision to the maintenance plan for 

the Ohio portion of the Canton-Massillon area (Stark County) with respect to the 1997 eighthour ozone standard. Ohio EPA submitted a redesignation request and maintenance plan for 

this area on June 20, 2006. U.S. EPA approved this requests on May 16, 2007 (72 FR 

27648). 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission 

projections and conformity budgets based on emission rates generated from U.S. EPA's 

latest mobile emissions model, the Motor Vehicle Emission Simulation (MOVES) 2010. In 

December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA's official emission factor 

model. The area is still attaining and maintaining the 1997 8-hour ozone standard and the 

point, area and non-road emissions have not changed significantly and did not need to be 

updated for this submittal. 

The enclosed information was compiled by Ohio EPA, Ohio Department of 

Transportation, and Miami Valley Regional Planning Commission. The public hearing 

for this package was held on November 8, 2012 in Canton, Ohio. No testimony was 

provided, nor were any comments received. 

This submittal consists of one (1) hard copy of the required documentation. An exact duplicate 

electronic version of the submittal in PDF format is available at 

http://epa.ohio.gov/dapc/SIP/1997.aspx under the heading" Redesignations and Maintenance 

Plans". 

50 WestTown Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 

www.epa.ohio.gov • (614) 644-3020 •(614) 644-3184(fax) 
If you have any questions, please contact Jennifer Dines in the Division of Air Pollution 

Control at (614) 644-3696. 

Sincerely, 

:::.:z 

Director 

enclosures 

cc: Bob Hodanbosi, DAPC 

Jennifer Dines, DAPC 
REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR THE 

CANTON-MASSILLON EIGHT-HOUR 

OZONE NONATTAINMENT AREA 

Stark County, Ohio

Developed By: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

June 20, 2006 

Revised November 2012
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i 

TABLE OF CONTENTS 

Chapter One 

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

Background ................................................................................................................................... 1 

Geographical description .............................................................................................................. 2 

Status of air quality ....................................................................................................................... 2 

Chapter Two 

Requirements for redesignation .................................................................................................... 3 

Chapter Three 

Ozone monitoring .......................................................................................................................... 6 

Ambient data quality assured ........................................................................................................ 7 

Three complete years of data ....................................................................................................... 7 

Commitment to continue monitoring ............................................................................................. 8 

Chapter Four 

Emission Inventory ........................................................................................................................ 9 

Base Year Inventory ..................................................................................................................... 9 

Emission Projections ................................................................................................................... 10 

Demonstration of Maintenance ................................................................................................... 14 

Permanent and Enforceable Emissions Reductions ................................................................... 16 

Provisions for Future Updates .................................................................................................... 17 

Chapter Five 

Control measures and regulations .............................................................................................. 18 

Implementation of Past SIP Revisions ........................................................................................ 18 

New Source Review Provisions ................................................................................................. 20 

Assurance of continued controls ................................................................................................. 20 

Chapter Six 

Contingency measures ............................................................................................................... 22 

Commitment to revise plan ......................................................................................................... 22 

Commitment for contingency measures ..................................................................................... 22 

Potential contingency measures ................................................................................................. 23 

List of VOC and NOx sources...................................................................................................... 24 

Chapter Seven 

Public participation ...................................................................................................................... 26 

Chapter Eight 

Conclusions ................................................................................................................................ 27 
ii 

FIGURES 

Figure 1 Stark County Basic Nonattainment Area ............................................................... 6 

TABLES 

Table 1 Monitoring Data for Stark County 2003 – 2005 ..................................................... 8 

Table 2 Emission estimations for on-road mobile sources ............................................... 13 

Table 3 Motor vehicle emissions budget .......................................................................... 13 

Table 4 Projected VOC emission estimates ..................................................................... 15 

Table 5 Projected NOx emission Inventory Totals ............................................................ 15 

Table 6 Projected emission estimates 2004-2018 VOC/NOx totals .................................. 16 

Table 7 Comparison of 2002-2004 on-road and EGU totals ............................................ 17 

APPENDICES 

A Aerometric Information Retrieval System (AIRS) Data 

B Emission Inventories 

C Emissions Analysis Method 

D Public Participation Documentation 
iii 

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1 

REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR CANTON-MASSILLON 

 EIGHT-HOUR OZONE NONATTAINMENT AREA 

STARK COUNTY, OHIO 

CHAPTER ONE 

Introduction 

The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air Quality 

Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) 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 one-hour standard with an eight-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. 

On April 15, 2004, U.S. EPA designated 134 nonattainment areas for the eight-hour ozone 

standard. Since that time, U.S. EPA has reclassified nine of the 134 original nonattainment 

areas to the next lower classification. Section 107(d)(3)(E) of the CAA allows states to 

request nonattainment areas be redesignated to attainment providing certain criteria are 

met. The following are the criteria that must be met in order for an area to be redesignated 

from nonattainment to attainment: 

i) A determination that the area has attained the eight-hour ozone standard.

ii) An approved SIP for the area under Section 110(k).

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

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

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

met. 

 

Background 

As part of the 1990 CAA Amendments re-evaluation, Stark County was designated as 

Unclassifiable/Attainment for the one-hour ozone standard pursuant to the CAA and 

therefore, has not previously been subject to nonattainment area rule-makings. As a result 

of the 2004 ozone designations, U.S. EPA designated Stark County basic nonattainment 

and subject to the eight-hour ozone requirements, including development of a plan to 

reduce volatile organic compounds (VOCs) and oxides of nitrogen (NOx) emissions and a 

demonstration that the area will meet the federal eight-hour air quality standard for ozone 

by June 2009. 

This document is intended to support Ohio’s request that Stark County be redesignated 

from nonattainment to attainment for the eight-hour ozone standard. Stark County has 
2 

recorded three (3) years of complete, quality-assured ambient air quality monitoring data 

for the years 2003 – 2005 demonstrating attainment of the eight-hour ozone standard. 

 Geographical Description

 Stark County is located in eastern Ohio and contains the City of Canton. Stark County is 

bordered by Summit and Portage Counties to the north, Mahoning and Columbiana to the 

east, Tuscarawas and Carroll to the south and Wayne and Holmes to the west. Stark 

County is shown in Figure 1. 

 Status of Air Quality 

Ozone monitoring data for the most recent three (3) years, 2003 through 2005, 

demonstrates that the air quality has met the NAAQS for ozone in this basic nonattainment 

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

Chapter four, supports a redesignation to attainment for Stark County based on 

requirements in Section 107(d)(3)(E) of the CAA. 
3 

CHAPTER TWO 

Requirements for Redesignation 

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

Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued 

September 4, 1992, to Regional Air Directors. This request for redesignation and 

maintenance plan is based on the redesignation guidance, supplemented with additional 

guidance received from staff of U.S. EPA Region V. 

Below is a summary of each redesignation criterion as it applies to Stark County. 

i.) Attainment of the standard: 

 There are two components involved in making this demonstration. The first 

component relies on ambient air quality data. The data that are used to 

demonstrate attainment should be the product of ambient monitoring that is 

representative of the area of highest concentration. The data should be 

collected and quality-assured in accordance with 40 CFR 58 and recorded in 

the Aerometric Information Retrieval System (AIRS) in order for it to be 

available to the public for review. 

 The second component relies upon supplemental U.S. EPA-approved air 

quality modeling. The supplemental modeling is not required for ozone 

nonattainment areas seeking redesignation. Therefore, this ozone 

redesignation request for Stark County does not include modeling data. 

However, in Appendix C the most recent modeling results showing future 

attainment and maintenance are provided. Chapter three discusses this 

requirement in more detail and provides the attainment demonstration. 

ii.) SIP approval: 

 The SIP for the area must be fully approved under Section 110(k) and must 

satisfy all requirements that apply to the area. Ohio’s SIP was approved on 

May 9, 1994 (59FR23799) March 23, 1995 (60FR15235) and includes Stark 

County. Chapter five discusses this requirement in more detail and provides 

the attainment demonstration. 

iii.) Permanent and enforceable improvement in air quality; 

 The state must be able to reasonably attribute the improvement in air quality 

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

well as control measures that have been adopted and implemented by the 

state. 

 Stark County was not designated nonattainment for ozone as part of the 

1990 CAA Amendments re-evaluation. As a result, Ohio has not adopted or 

implemented control measures beyond the federal measures, the initial 1979 

statewide rules and those 1994 and 1995 rules which applied to “rural” 
4 

attainment areas. Chapters four and five discuss this requirement in more 

detail and provide the attainment demonstration. 

iv.) Section 110 and Part D requirements: 

 For purposes of redesignation, a state must meet all requirements of Section 

110 and part D that were applicable prior to submittal of the complete 

redesignation request. 

 Part D consists of general requirements applicable to all areas which are 

designated nonattainment based on a violation of the NAAQS. 

 i.) Section 172(c) requirements 

 This section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for an 

emission inventory will be satisfied by the inventory requirements of 

the maintenance plan. 

 ii.) Conformity 

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

consistent with section 176(c)(4) conformity requirements. The 

redesignation request should include conformity procedures, if the 

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

conformity procedures in place at the time that it submits a 

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

conformity regulation upon issuance, as applicable. Chapter five 

discusses this requirement in more detail and provides the attainment 

demonstration. 

v.) Maintenance plans. 

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

must fully approve a maintenance plan which meets the requirements of 

Section 175(A). The maintenance plan will constitute a SIP revision and 

must provide for maintenance of the relevant NAAQS in the area for at least 

10 years after redesignation. Section 175 (A) further states that the plan 

shall contain such additional measures, if any, as may be necessary to 

ensure such maintenance. 

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

violation of the NAAQS. At a minimum, the contingency measures must 

include a requirement that the state will implement all measures contained in 

the nonattainment SIP prior to redesignation. 
5 

States seeking redesignation of a nonattainment area should consider the 

following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 

 Chapter six discusses this requirement in more detail and provides the 

attainment demonstration. 
6 

CHAPTER THREE 

OZONE MONITORING

CAA Section107 (d)(3)(E)(i) 

Requirement 1 of 4: 

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. 

Background: 

 There are three monitors measuring ozone concentrations in this 

nonattainment area. The monitors are operated by Canton City Health 

Department’s Air Pollution Control Section. The locations of the monitoring 

sites for this nonattainment area are shown in Figure 1. 

Demonstration: 

Figure 1 Map of Stark County 
7 

Requirement 2 of 4: 

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

U.S. EPA Air Quality System (AQS) database, and available for public view. 

Demonstration: 

The Ohio Environmental Protection Agency (Ohio EPA) has quality assured 

all data shown in Appendix A in accordance with 40 CFR 58.10 and the Ohio 

Quality Assurance Manual. Ohio EPA has recorded the data in the AQS 

database and therefore data are available to the public. 

Requirement 3 of 4: 

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. 

 

Background: 

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

Handling Conventions for the eight-hour Ozone National Ambient Air Quality 

Standard (NAAQS)," U.S. EPA-454/R-98-017, December 1998. 

Three (3) complete years of ozone monitoring data are required to 

demonstrate attainment at a monitoring site. The eight-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 eight-hour average ozone concentration is less than 

or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. 

Three (3) significant digits must be carried 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 eight-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 is in compliance with 

the eight-hour ozone NAAQS if, and only if, every monitoring site in the area 

meets the NAAQS. An individual site's three (3) year average of the annual 

fourth highest daily maximum eight-hour average ozone concentration is also 

called the site's design value. Table 1 shows the monitoring data for the 

three most recent years, 2003 - 2005, at the nonattainment area sites and 

was retrieved from the U.S. EPA AQS. 
8 

Demonstration: 

 Table 1: Monitoring Data for Stark County 2003 – 2005 

 Data source: U.S. EPA Air Quality System (AQS). 

 http://www.epa.gov/ttn/airs/airsaqs/index.htm

 1st 2nd 3rd 4th 2003-2005 

SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE 

39-151-0016 STARK MALONE COLLEGE 2003 100 .106 .104 .092 .087 

.079 

39-151-0016 STARK MALONE COLLEGE 2004 92 .086 .082 .076 .074 

39-151-0016 STARK MALONE COLLEGE 2005 96 .087 .080 .079 .076 

39-151-0021 STARK 245 WEST FIFTH 2003 100 .099 .099 .090 .085 

.077 

39-151-0021 STARK 245 WEST FIFTH 2004 99 .085 .075 .073 .071 

39-151-0021 STARK 245 WEST FIFTH 2005 100 .083 .078 .077 .076 

39-151-4005 STARK 1175 WEST VINE 2003 100 .116 .106 .101 .086 

.082 

39-151-4005 STARK 1175 WEST VINE 2004 98 .084 .079 .076 .076 

39-151-4005 STARK 1175 WEST VINE 2005 100 .106 .088 .087 .086 

Highest Average 0.82 ppm 

A comprehensive list of the site’s design values during the 2003-2005 time 

period is in Appendix A. The area's design value has trended downward as 

emissions have declined due to such factors as 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. Ohio's NOx Budget Trading Program rule was 

approved on May 25, 2004 [Ohio Administrative Code (OAC) Chapter 3745-

14]. It is expected that this downward trend will continue as the above 

programs continue and some form of the U.S. EPA Clean Air Interstate Rule 

(CAIR) is implemented. 

 

Requirement 4 of 4: 

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

monitoring network to verify the maintenance of the attainment status. 

Demonstration: 

 Ohio commits to continue monitoring ozone levels at the site indicated in 

Figure 1. Ohio EPA will consult with U.S. EPA Region V staff prior to making 

changes to the existing monitoring network, should changes become 

necessary in the future. Ohio EPA will continue to quality assure the 

monitoring data to meet the requirements of 40 CFR 58. Connection to a 

central station and updates to the Ohio EPA Web site1 will provide real time 

availability of the data and knowledge of any exceedances. Ohio EPA will 

enter all data into AQS on a timely basis in accordance with federal 

guidelines. 

 

1

 www.epa.state.oh.us/dapc/ 
9 

CHAPTER FOUR 

EMISSION INVENTORY

CAA Section107 (d)(3)(E)(iii) 

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. Ohio also must demonstrate that the 

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

attainment was achieved is based on permanent and enforceable emission reductions. 

Other emissions inventory related requirements include a projection of the emission 

inventory to a year at least 10 years following redesignation; a demonstration that the 

projected level of emissions is sufficient to maintain the ozone standard; and a commitment 

to provide future updates of the inventory to enable tracking of emission levels during the 

10 year maintenance period. 

Requirement 1 of 5: 

A comprehensive emission inventory of the precursors of ozone completed for the base 

year. 

Background: 

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

program. The 2002 periodic inventory has been identified as the preferred 

data base for SIP development and does coincide with nonattainment air 

quality in Stark County. 

As part of the NOx SIP Call, many states including Ohio were required to 

adopt into their rules a budget for all large EGUs. Ohio’s budget is adopted 

at OAC Chapter 3745-14. The budget represents a statewide cap on NOx

emissions. These emissions, capped by the state rule, should remain at or 

near this level through the maintenance period covered by this request. 

Periodic inventories, which include emissions from all sectors - mobile, area, 

non-road, and point sources - are prepared every three (3) years. 

Demonstration: 

While ozone and its precursors are transported into this region from outside 

areas, this information does provide some indication of the impact from Ohio 

sources near the nonattainment area. The emissions are decreasing 

substantially in response to regional and national programs affecting many 

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. 
10 

Requirement 2 of 5: 

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

Background: 

Ohio EPA prepared a comprehensive inventory for Stark County, including 

area, mobile, and point sources for precursors of ozone (volatile organic 

compounds and nitrogen oxides) for base year 2002. The information below 

describes the procedures Ohio EPA used to generate the 2002 base 

inventories. These inventories were provided to LADCO and have been 

processed to develop summer day emissions for use in the air quality 

analyses. These processed modeling inventories have been identified as the 

correct iteration of the inventory for use in the redesignation. In this 

document, references to LADCO include the Midwest Regional Planning 

Organization. 

• Area sources were taken from the Ohio 2002 periodic inventory 

submitted to U.S. EPA. These projections were made from the U.S. 

Department of Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information. 

• Mobile source emissions were calculated using emissions factors 

produced with MOVES 2010. 

• Point source information was compiled from Ohio EPA’s 2002 annual 

emissions inventory database and the 2002 U.S. EPA Air Markets 

acid rain database2. 

• Biogenic emissions are not included in these summaries. 

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

Mobile Inventory Model (NMIM) 2002 application. To address 

concerns about the accuracy of some of the categories in U.S. EPA’s 

non-road emissions model, LADCO contracted with two (2) 

companies to review the base data and make recommendations. One 

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

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

were estimated for aircraft, commercial marine vessels and railroads. 

Recreational motorboat population and spatial surrogates (used to 

assign emissions to each county) were significantly updated. The 

populations for the construction equipment category were reviewed 

and updated based upon surveys completed in the Midwest and the 

temporal allocation for agricultural sources also was updated. 

 

Demonstration: 

 

On-Road Emission Estimations 

In coordination with the Stark County Area Transportation Study (SCATS) 

the Ohio Department of Transportation (Ohio DOT) utilizes a regional travel 

demand forecast model to simulate traffic in the area and to forecast traffic 

 

2 http://www.epa.gov/airmarkets/acidrain 
11 

flows for given growth expectations. The model is primarily used as a long 

range planning tool to evaluate the transportation system including 

determination of locations where additional travel capacity may be needed 

and to determine the infrastructure requirements necessary to meet that 

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

emissions of pollution caused by vehicles in the area. The travel demand 

forecasting model is used to predict the total daily vehicle miles traveled 

(VMT) and an EPA computer program called MOVES 2010 is used to 

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

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

Overview 

Broadly described, MOVES 2010MOVES 2010 model includes a number of 

variables that affect the emission factors. These variables have national 

default values, some of which require modification to reasonably reflect local 

conditions. Some of these variables are discussed here. The vehicle fleet 

(vehicles on the road) age and the vehicle type have a major effect on the 

emission factors. The source types are traveling on road types (MOVES 

2010 road types are Rural Restricted Access, Rural Unrestricted Access, 

Urban Restricted Access, and Urban Unrestricted Access). The vehicle 

speeds also affect the emission factor values. Meteorological conditions 

such as air temperature and humidity have a significant effect on emission 

factors. Emission factors produced by MOVES 2010 can also include the 

effect of emission reduction strategies such as vehicle inspection and 

maintenance programs, regulation of fuels, etc. These MOVES 2010 inputs 

are estimated using the best available data. 

These inputs are reviewed and agreed to by U.S. EPA and transportation 

agencies in a formal interagency consultation process. Emission factors are 

multiplied by VMT from the travel demand model to estimate the total vehicle 

emissions. 

The emission factors from MOVES 2010 can be used with the travel demand 

model information by combining the disaggregate emission rates with VMT, 

and source type population for each road type, source type and hour of day, 

and then sum them up to get the total emissions for the area. 

The Stark County analysis method, developed by Ohio DOT, is to aggregate 

the emission rates by two source types (cars & trucks), then applying VMT 

and source type population, thereby reducing the intensive processes. In the 

first step emission factors are broadly classified into total vehicles, cars and 

trucks by pollutant, by average speed, road type and hour of day. Then the 

hourly link volumes generated from travel demand model are combined with 

emission factors for each network link for each hour. The on-road vehicle 

emissions for the area is the sum of all individual link-hour emissions. 

Vehicle-based emissions are obtained by the combination of corresponding 

emission factors and source type population. Intrazonal emissions are 
12 

computed using a separate method to account for those trips that use local 

roads to travel within a zone. Intrazonal VMT is combined with corresponding 

emission factors to get intrazonal emissions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions. 

Automated programs, using FORTRAN and CUBE scripting, were developed 

by Ohio DOT to generate total emissions. The process uses data on daily 

and directional traffic distributions as well as more up to date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process also 

handles the newer model network formats and MOVES 2010 generated 

emission factors. 

MOVES 2010 input and output files are provided in Appendix C. 

Best Available Data 

Most current vehicle age distribution data, temperature data, fuel properties 

data, source type distribution data, and I/M data provided by Ohio DOT’s 

ATRs and WIMs, NOAA, ODPS, and Ohio EPA were used by the Ohio DOT 

for generating emission factors. Likewise, the most current transportation 

planning data available from SCATS and most current Ohio DOT count data 

were used by Ohio DOT for the emissions estimates. 

Analysis Years 

Analysis years for this re-designation request include 2002, 2004, 2009, and 

2018 to meet the requirements specified by the CAA and U.S. EPA. The 

travel demand model presents the transportation system conditions for each 

of these years. Model runs for each future analysis year contain the road 

network SCATS and Ohio DOT expects to exist at the beginning of that year 

with corresponding socioeconomic forecasts for that year. 

Local Road VMT 

Most local roads such as subdivision streets are not explicitly modeled in a 

travel demand model. These local roads are represented as fictitious 

roadways called centroid connectors. Local road VMT is included in the Ohio 

DOT post process by including the traffic loaded on centroid connectors. In 

addition, some local road traffic is captured as intra-zonal trips which travel 

demand models usually do not assign to roadway segments. The Ohio DOT 

post process includes these trips as local road VMT. 

Model area VMT 

For Stark County, the travel demand model covers the entire county and a 

portion of Mahoning County. VMT for the portion of model which extends 

beyond Stark County is removed before total emissions are calculated. 

 
13 

Emission Estimations 

Table 2 contains the results of the emissions analysis for the appropriate 

years. 

Table 2 Emission Estimations for On-Road Mobile Sources for Stark 

County, Ohio 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Stark County 2002 2004 2009 2018 

VMT (miles/day) 8,245,109 8,511,311 8,597,080 8,916,054 

VOC (tons/day) 24.34 22.56 16.67 7.84 

NOx (tons/day) 35.19 33.14 24.66 9.89 

Motor Vehicle Emission Budget 

Table 3 contains the motor vehicle emissions budget for Stark County. 

Table 3 Mobile Vehicle Emission Budget for Stark County 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

2009 2018 

VOC (tons/day 19.17 9.02 

NOx (tons/day) 28.36 11.37 

This budget includes the emission estimates calculated for 2009 and 2018. The 

emission estimates are derived from the Tranplan travel demand model and MOVES 

2010 as described above under the expected SCATS 2030 Long Range Plan. The 

mobile source budget includes 9.02 tons/day for VOC and11.37 tons/day for NOx for 

2018 and 19.17 tons/day for VOC and 28.36 tons/day for NOx for 2009. These 

correspond to a 15 percent increase from the 2009 and 2018 on-road emissions for 

both VOC and NOx. Appendix C contains data tables and graphs of these 

emissions. 

 

All methodologies, latest planning assumptions and the safety margins were 

determined through the interagency consultation process described in the 

Transportation Conformity Memorandum of Understanding (MOU) for SCATS. 
14 

Requirement 3 of 5: 

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

standard. 

Background: 

In consultation with U.S. EPA, Ohio EPA selected the year 2018 as the 

maintenance year for this redesignation request. This document contains 

projected emissions inventories for 2009 and 2018. 

Ohio EPA performed emission projections for Stark County using the 

following approaches. 

• Mobile source emission projections are based on the U.S. EPA 

MOVES 2010 model. The analysis is described in more detail in 

Appendix C. All projections were made in accordance with 

“Procedures for Preparing Emissions Projections” U.S. EPA-45/4-91-

019. 

• Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. The 

LADCO have developed growth and control files for point, area, and 

non-road categories. These files were used to develop the future year 

emissions estimates used in this document. This was done so the 

inventories used for redesignation are consistent with modeling 

performed in the future. 

The detailed inventory information for Stark County for 2004, 2009 and 2018 

is in Appendix B. Emission trends are an important gauge for continued 

compliance with the ozone standard. Therefore, Ohio EPA performed an 

initial comparison of the inventories for the base year and maintenance years 

for Stark County. Mobile source emission inventories are described in 

Appendix B. In addition to LADCO estimates, point source emissions were 

projected based upon the statewide EGU NOx budgets from the Ohio NOx

rule. 

The following tables include sectors Electrical Generating Unit (EGU-Point), 

Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), 

Other Area (Other), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road). 
15 

Demonstration: 

 Table 4 Stark County VOC Emission Inventory Totals for Base Year 

 2002, Estimated 2004 and Projected 2009 and 2018 (tons per 

 day) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002 

Base 

2004 

Attainment

2009 

Interim 

2018 

Maintenance 

Safety 

Margin 

EGU Point n/a n/a n/a n/a 

Non-EGU 2.90 2.97 3.14 3.77 

Non-road 5.83 5.29 3.92 3.22 

Other 21.23 21.03 20.49 21.93 

MAR 0.15 0.15 0.14 0.14 

On-road 24.34 22.56 19.17* 9.02* 

TOTAL 54.45 52.00 46.86 38.08 13.92 

 * includes 15 percent increase to the mobile source budget 

 Table 5 Stark County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2004 and Projected 2009 and 2018 (tons per 

 day) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2004 

Attainment

2009 

Interim 

2018 

Maintenance 

Safety 

Margin 

EGU 

Point n/a n/a n/a n/a 

NonEGU 5.12 4.85 4.16 4.72 

Nonroad 6.78 6.22 4.81 2.50 

Other 1.23 1.40 1.46 

MAR 3.28 3.03 2.39 2.22 

On-road 35.19 33.14 28.36* 11.37* 

TOTAL 51.54 48.47 41.12 22.27 26.20 

 * includes 15 percent increase to the mobile source budget 
16 

Table 6 Stark County Comparison of 2004 attainment year and 2018 

 projected emission estimates (tons per day, Summer) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

2004 2018 Projected Change 

VOC 52.00 38.08 13.92 

NOx 48.47 22.27 26.20 

VOC emissions in the non-attainment area are projected to decrease by 

13.92 tons per day (tpd). Area source emissions and, to a lesser extent, 

point sources, show an increase due to expectations that the population will 

grow in this area. However, cleaner vehicles and fuels are expected to be in 

place in 2009 and 2018 and result in an overall drop in VOC emissions. 

NOx emissions in the nonattainment area are projected to decrease by 26.20 

tpd. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle 

Emissions Standards and Gasoline Sulfur Control Requirements3, Highway 

Heavy-Duty Engine Rule4 and Non-Road Diesel Engine Rule5 also factored 

into the changes. Further, due to implementation of the NOx SIP Call across 

the eastern United States, NOx and ozone levels entering this also 

decreased. 

Requirement 4 of 5: 

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. 

Background: 

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

the NAAQS for ozone in 2005. U.S. EPA’s redesignation guidance (p 9) 

states, “A state may generally demonstrate maintenance of the NAAQS by 

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

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

future mix of sources and emissions rates will not cause a violation of the 

NAAQS.” 

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

emissions information once every three (3) years or annually if VOC potential 

 

3 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 4 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 5 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 
17 

to emit is greater than 250 tons or NOx potential to emit is greater than 2500 

tons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule 

(CERR). Ohio EPA prepares a new periodic inventory for all ozone precursor 

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

will be prepared for 2005, 2008, and 2011 as necessary to comply with the 

inventory reporting requirements established in the CAA. Emissions 

information will be compared to the 2002 base year and the 2018 projected 

maintenance year inventories to assess emission trends, as necessary, to 

assure continued compliance with the ozone standard. 

Demonstration: 

Permanent and enforceable reductions of volatile organic compounds and 

oxides of nitrogen have contributed to the attainment of the eight-hour ozone 

standard. Some of these reductions were due to the application of tighter 

federal standards on new vehicles. Also, Title IV of the CAA and the NOx

SIP Call required the reduction of oxides of nitrogen from utility sources. 

While no EGU reductions occurred within Stark County, statewide NOx

reductions from EGUs were over 85 percent due to this program. 

Table 7 Stark County Comparison of 2002 base year and 2004 

attainment year on-road and EGU reductions 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

2002 2004 

On-road VOC 24.34 22.56 

On-road NOx 35.19 33.14 

EGU NOx n/a n/a 

Requirement 5 of 5: 

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

levels including an annual emission statement from major sources. 

Demonstration: 

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

Administrator, eight (8) years after redesignation, an additional revision of 

this SIP. The revision will contain Ohio's plan for maintaining the national 

primary ozone air quality standard for 10 years beyond the first 10 year 

period after redesignation 
18 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4:

An U.S. EPA approved SIP control strategy that includes RACT requirements for existing 

stationary sources covered by Control Technology Guidelines (CTG) as applied in Ohio’s 

rural counties. 

Background: 

As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were no 

specific rules required by the CAA such as RACT for existing sources beyond 

statewide rules. 

Demonstration: 

Statewide RACT rules have been applied to all new sources locating in Ohio 

since that time. The Ohio rules are found in OAC Chapter 3745-21. 

 

Requirement 2 of 4:

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

implemented. 

Background: 

The U.S. EPA NOx SIP Call required 22 states to pass rules that would result 

in significant emission reductions from large EGUs, industrial boilers, and 

cement kilns in the eastern United States. Ohio passed this rule in 2001. 

Beginning in 2004, this rule accounts for a reduction of approximately 31 

percent of all NOx emissions statewide compared to previous uncontrolled 

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

Demonstration: 

U.S. EPA and Ohio EPA performed modeling that indicated this area would 

attain the eight-hour ozone standard with the implementation of the NOx SIP 

Call. Controls for EGUs formally commenced May 31, 2004. Emissions 

covered by this program have been generally trending downward since 1998 

with larger reductions occurring in 2002 and 2003. Data taken from U.S. EPA 

Clean Air Markets Web site, quantifies the gradual NOx reductions that have 

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

beginning of the NOx SIP Call Rule. Ohio developed the NOx Budget Trading 

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

chapter 3745-14 regulated EGUs and certain non-EGUs under a cap and 

trade program based on an 85 percent reduction of NOx emissions from 

EGUs and a 60 percent reduction of NOx emissions from non-EGUs, 
19 

compared to historical levels. This cap will stay in place through 2008, at 

which time the CAIR program will supersede it. 

U.S. EPA has recently published Phase II of the NOx SIP Call that 

establishes a budget for large (greater than 1 ton per day emissions) 

stationary internal combustion engines. Ohio EPA’s proposed rule OAC 

3745-14-12 addresses stationary internal combustion engines, all used in 

natural gas pipeline transmissions. An 82 percent NOx reduction from 1995 

levels is anticipated. Completion of the compliance plan is expected by May 

1, 2006 and the compliance demonstration will begin May 1, 2007. The 

2007 controlled NOx emissions will be 599 tons per day. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards 

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

emissions from cars and light trucks, including sport utility vehicles (SUVs). 

Under this proposal, automakers will be required to sell cleaner cars, and 

refineries will be required to make cleaner, lower sulfur gasoline. This rule 

will apply nationwide. The federal rules will phase in between 2004 and 

2009. U.S. EPA has estimated that NOx emission reductions will be 

approximately 77 percent for passenger cars, 86 percent for smaller SUVs, 

light trucks, and minivans, 65 to 95 percent reductions for larger SUVs, vans, 

and heavier trucks. VOC emission reductions will be approximately 12 

percent for passenger cars, 18 percent for smaller SUVs, light trucks, and 

minivans, and 15 percent for larger SUVs, vans, and heavier trucks. 

Heavy-Duty Diesel Engines 

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

program which includes low-sulfur diesel fuel standards, which will be phased 

in from 2004 through 2007. This rule applies to heavy-duty gasoline and 

diesel trucks and buses. This rule will result in a 40 percent reduction in NOx

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

inventory. 

Clean Air Non-road Diesel Rule 

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

applies to diesel engines used in industries such as construction, agriculture, 

and mining. It also contains a cleaner fuel standard similar to the highway 

diesel program. The new standards will cut emissions from non-road diesel 

engines by more than 90 percent. Non-road diesel equipment, as described 

in this rule, currently accounts for 47percent of diesel particulate matter (PM) 

and 25 percent of NOx from mobile sources nationwide. Sulfur levels will be 

reduced in non-road diesel fuel by 99 percent from current levels, from 

approximately 3,000 ppm now to 15 ppm in 2009. 

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

ozone precursors. 
20 

Requirement 3 of 4:

Acceptable provisions to provide for new source review. 

Background: 

Ohio has a long standing and fully implemented New Source Review (NSR) 

program. This is addressed in OAC Chapter 3745-31. The chapter includes 

provisions for the Prevention of Significant Deterioration (PSD) permitting 

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

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

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

Demonstration: 

Any facility that is not listed in the 2002 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 requirement. The review process will be identical to that used for 

new sources. Once the area is redesignated, Ohio EPA will implement NSR 

through the PSD program. 

Requirement 4 of 4:

Assure that existing controls will remain in effect after redesignation unless the State 

demonstrates through photochemical modeling that the standard can be maintained without 

one (1) or more controls. 

Demonstration: 

Ohio commits to maintaining the aforementioned control measures after 

redesignation. Ohio hereby commits that any changes to its rules or 

emission limits applicable to VOC and/or NOx sources, as required for 

maintenance of the ozone standard in Stark County, will be submitted to U.S. 

EPA for approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal section, 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 Stark County. 

LADCO Modeling Analysis for eight-hour Ozone Standard Assessment 

LADCO performed modeling to evaluate the effect of the NOx SIP Call and 

Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. 

This modeling was originally designed to assess the one-hour ozone 

standard. Further analysis was conducted and documented in the LADCO’s 

White Paper “8-Hour Ozone Assessment” dated May 2, 2001. Base year 

design values used were the average of the design values for the three (3) 

three-year periods (1994-1996, 1995-1997, and 1996-1998). Base year 
21 

emissions were taken from 1996 and four (4) ozone episodes were 

evaluated: June 22-28, 1991; July 14-21, 1991 

While modeling results were not calculated for Stark County, the average 

decrease in ozone from the base case modeling run with modeling runs that 

applied emission controls required by the CAA, NOx SIP Call and Tier II /lowsulfur requirements was 15 ppb (2009 Future design value of 73.3ppb*.) [* 

LADCO Base K 2009 Future Base case with on-the-books” including CAIR]. 

 LADCO Modeling for CAIR of 2004 

On March 10, 2004, the U.S. EPA promulgated CAIR. NOx emissions will be 

cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 

million tons in 2018 in 28 eastern states and the District of Columbia. 

LADCO performed modeling to support the associated emission reductions 

for CAIR. This modeling was based on 2001 – 2002 design values for Stark 

County. Results of the CAIR modeling show Stark County will continue to 

attain the eight-hour ozone NAAQS well into the future. 
22 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4:

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

Demonstration: 

Ohio hereby commits to review its maintenance plan eight (8) years after 

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

Requirement 2 of 4:

A commitment to expeditiously enact and implement additional contingency control 

measures in response to exceeding specified predetermined levels (triggers) or in the event 

that future violations of the ambient standards occur. 

Demonstration: 

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

Warning Level Response: 

A warning level response shall be prompted whenever an annual (1-year) 

fourth high monitored value of 88 ppb occurs in a single ozone season 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 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 two (2) year average 

fourth high monitored value of 85 ppb occurs within the maintenance area. In 

the event that the action level is triggered and is not due to an exceptional 

event, malfunction, or noncompliance with a permit condition or rule 

requirement, Ohio EPA will determine additional control measures needed to 

assure future attainment of NAAQS for ozone. In this case, measures that 
23 

can be implemented in a short time will be selected in order to be in place 

within eighteen (18) months from the close of the ozone season that 

prompted the action level. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the necessary 

administrative and legal process. This process will include publication of 

notices, an opportunity for public hearing, and other measures required by 

Ohio law for rulemaking 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, Ohio will 

submit to U.S. EPA an analysis to demonstrate the proposed measures are 

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration: 

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the time 

the selection is made. The selection of measures will be based on costeffectiveness, emission reduction potential, economic and social 

considerations or other factors that Ohio EPA deems appropriate. Ohio EPA 

will solicit input from all interested and affected persons in the maintenance 

area prior to selecting appropriate contingency measures. Because it is not 

possible at this time to determine what control measure will be appropriate at 

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

below is not comprehensive. 

1) Lower Reid vapor pressure gasoline program. 

2) Tighten RACT on existing sources covered by U.S. EPA Control 

Technique Guidelines issued in response to the 1990 CAA. 

3) Apply RACT to smaller existing sources. 

4) One or more transportation control measures sufficient to achieve at 

least half a percent reduction in actual area wide VOC emissions. 

Transportation measures will be selected from the following, based 

upon the factors listed above after consultation with affected local 

governments: 
24 

a) trip reduction programs, including, but not limited to, employerbased transportation management plans, area wide rideshare 

programs, work schedule changes, and telecommuting; 

b) traffic flow and transit improvements; 

c) other new or innovative transportation measures not yet in 

widespread use that affects state and local governments 

deemed appropriate.

5) Alternative fuel and diesel retrofit programs for fleet vehicle 

operations. 

6) Controls on consumer products consistent with those adopted 

elsewhere in the United States. 

7) Require VOC or NOx emission offsets for new and modified major 

sources. 

8) Require VOC or NOx emission offsets for new and modified minor 

sources. 

9) Increase the ratio of emission offsets required for new sources. 

10) Require VOC or NOx controls on new minor sources (less than 100 

tons). 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

benefits of individual measures, at the time they are under consideration, can 

be fully evaluated. 

Requirement 4 of 4:

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

Demonstration: 

The following is a list of VOC and NOx sources potentially subject to future 

controls. 

NOx RACT 

• EGUs 

• asphalt batching plants 

• industrial/commercial and institutional boilers 

• process heaters 

• internal combustion engines 
25 

• combustion turbines 

• other sources greater than 100 tons per year 

VOC RACT 

• consumer products 

• architectural and industrial maintenance coatings 

• stage I gasoline dispensing facilities (including pressure valves) 

• automobile refinishing shops 

• cold cleaner degreasers 

• portable fuel containers 

• synthetic organic compound manufacturing 

• organic compound batch processes 

• wood manufacturing 

• industrial wastewater 

• aerospace industry 

• shipbuilding 

• bakeries 

• plastic parts coating 

• volatile organic liquid storage 

• industrial solvent cleaning 

• offset lithography 

• industrial surface coating 

• other sources greater than 50 tons per year 
26 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio will publish a notification for a public hearing and solicitation for public comment 

concerning the draft redesignation petition and maintenance plan in a widely distributed 

newspaper in the area. 

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

November 8, 2012 at 189 25th St. NW Canton, Ohio. The public comment period closed 

on November 8, 2012. No comments were received during the public comment period and 

no testimony was provided at the hearing. Appendix D includes a copy of the public notice 

and hearing transcript. 

 
27 

CHAPTER EIGHT 

CONCLUSIONS

The Stark County basic nonattainment area has attained the NAAQS standard and 

complied with the applicable provisions of the 1990 Amendments to the CAA regarding 

redesignations of basic ozone nonattainment areas. Documentation to that effect is 

contained herein. Ohio EPA has prepared a state implementation and maintenance plan 

that meets the requirement of Section 110 (a)(1) of the 1990 CAA. 

Ohio has performed an analysis that shows the air quality improvements are due to 

permanent and enforceable measures. In addition, significant regional NOx reductions will 

ensure continued compliance (maintenance) with the standard and that all CAA 

requirements necessary for redesignation have been met. 

Based on this presentation, the Stark County ozone basic nonattainment area meets the 

requirements for redesignation under the CAA and U.S. EPA guidance. Furthermore, 

because this area is subject to significant transport of pollutants, significant regional NOx

reductions will ensure continued compliance (maintenance) with the standards with an 

increasing margin of safety. 

The State of Ohio hereby requests that the Stark County ozone basic nonattainment area 

be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio state 

implementation and Maintenance Plan provisions contained herein. 
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Synopsis of Changes 

Revised Canton-Massillion Maintenance Plan under the 1997 Ozone Standard 

The original redesignation request and maintenance plan document was submitted to 

U.S. EPA on June 20, 2006. U.S. EPA approved this requests on May 16, 2007 (72 FR 

27648). 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile 

emission projections and conformity budgets based on emission rates generated from 

U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation 

(MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s 

official emission factor model. The area is still attaining and maintaining the 1997 8-hour 

ozone standard and the point, area and non-road emissions have not changed 

significantly and did not need to be updated for this submittal. 

A redline/strike-out version of the original document follows this synopsis and identifies all 

changes that were made to the original approved request. In summary, revisions were 

made to the on-road (mobile) source emission estimates and budgets contained within 

the tables and text below. In addition, the discussion section regarding on-road modeling 

protocols was updated to identify the latest process applicable to the use of the newer 

MOVES model. Other minor changes were made to conform to current terminology, 

grammar, and formatting conventions. 

In addition to this document, additional changes were also made to the Appendices of the 

original submittal, as follows: 

• Appendix C: this appendix contains the detailed modeling protocol used to 

generate on-road mobile source emission estimates. The document contained 

within this revised submittal is an entirely new document compared to the original 

modeling protocol document submitted in 2006. Both the original and revised 

documents are available on Ohio EPA’s website under the “Appendix” link. 

• Appendix E: this appendix contains documents relevant to the public comment 

period and the public hearing. This will contain a revised public notice and revised 

hearing transcript. In some cases, if comments are received or testimony provided, 

it will also contain a revised response to comments document. Both the original 

and revised documents are available on Ohio EPA’s website under the “Appendix” 

link. 

These documents can all be found at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx in the 

table under the heading “Redesignations and Maintenance Plans.” 
REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR

OZONE ATTAINMENT 

IN THE CANTON-MASSILLON EIGHT-HOUR OZONE BASIC 

NONATTAINMENT AREA

Stark County, Ohio

Developed By: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

June 20, 2006 

Revised November 2012

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i 

TABLE OF CONTENTS 

Chapter One 

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

Background ................................................................................................................................... 1 

Geographical description .............................................................................................................. 2 

Status of air quality ....................................................................................................................... 2 

Chapter Two 

Requirements for redesignation .................................................................................................... 3 

Chapter Three 

Ozone monitoring .......................................................................................................................... 6 

Ambient data quality assured ........................................................................................................ 7 

Three complete years of data ....................................................................................................... 7 

Commitment to continue monitoring ............................................................................................. 8 

Chapter Four 

Emission Inventory ........................................................................................................................ 9 

Base Year Inventory ..................................................................................................................... 9 

Emission Projections ................................................................................................................... 10 

Demonstration of Maintenance ................................................................................................... 14 

Permanent and Enforceable Emissions Reductions ................................................................... 16 

Provisions for Future Updates .................................................................................................... 17 

Chapter Five 

Control measures and regulations .............................................................................................. 18 

Implementation of Past SIP Revisions ........................................................................................ 18 

New Source Review Provisions ................................................................................................. 20 

Assurance of continued controls ................................................................................................. 20 

Chapter Six 

Contingency measures ............................................................................................................... 22 

Commitment to revise plan ......................................................................................................... 22 

Commitment for contingency measures ..................................................................................... 22 

Potential contingency measures ................................................................................................. 23 

List of VOC and NOx sources...................................................................................................... 24 

Chapter Seven 

Public participation ...................................................................................................................... 26 

Chapter Eight 

Conclusions ............................................................................................................................ 2627
ii 

FIGURES 

Figure 1 Stark County Basic Nonattainment Area ............................................................... 6 

TABLES 

Table 1 Monitoring Data for Stark County 2003 – 2005 ..................................................... 8 

Table 2 Emission estimations for on-road mobile sources ............................................... 13 

Table 3 Motor vehicle emissions budget ...................................................................... 1413

Table 4 Projected VOC emission estimates ................................................................. 1415

Table 5 Projected NOx emission Inventory Totals ........................................................ 1315

Table 6 Projected emission estimates 2004-2018 VOC/NOx totals .............................. 1416

Table 7 Comparison of 2002-2004 on-road and EGU totals ........................................ 1417

APPENDICES 

A Aerometric Information Retrieval System (AIRS) Data 

B Emission Inventories 

C Emissions Analysis Method 

D Public Participation Documentation 
iii 

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1 

REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR OZONE ATTAINMENTCANTON-MASSILLON

IN THE EIGHT-HOUR OZONE BASIC 

NONATTAINMENT AREA 

STARK COUNTY, OHIO 

CHAPTER ONE 

Introduction 

The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air Quality 

Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) 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 one-hour standard with an eight-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. 

On April 15, 2004, U.S. EPA designated 134 nonattainment areas for the eight-hour ozone 

standard. Since that time, U.S. EPA has reclassified nine of the 134 original nonattainment 

areas to the next lower classification. Section 107(d)(3)(E) of the CAA allows states to 

request nonattainment areas be redesignated to attainment providing certain criteria are 

met. The following are the criteria that must be met in order for an area to be redesignated 

from nonattainment to attainment: 

i) A determination that the area has attained the eight-hour ozone standard.

ii) An approved SIP for the area under Section 110(k).

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

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

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

met. 

 

Background 

As part of the 1990 CAA Amendments re-evaluation, Stark County was designated as 

Unclassifiable/Attainment for the one-hour ozone standard pursuant to the CAA and 

therefore, has not previously been subject to nonattainment area rule-makings. As a result 

of the 2004 ozone designations, U.S. EPA designated Stark County basic nonattainment 

and subject to the eight-hour ozone requirements, including development of a plan to 

reduce volatile organic compounds (VOCs) and oxides of nitrogen (NOx) emissions and a 

demonstration that the area will meet the federal eight-hour air quality standard for ozone 

by June 2009. 

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2 

This document is intended to support Ohio’s request that Stark County be redesignated 

from nonattainment to attainment for the eight-hour ozone standard. Stark County has 

recorded three (3) years of complete, quality-assured ambient air quality monitoring data 

for the years 2003 – 2005 demonstrating attainment of the eight-hour ozone standard. 

 Geographical Description

 Stark County is located in eastern Ohio and contains the City of Canton. Stark County is 

bordered by Summit and Portage Counties to the north, Mahoning and Columbiana to the 

east, Tuscarawas and Carroll to the south and Wayne and Holmes to the west. Stark 

County is shown in Figure 1. 

 Status of Air Quality 

Ozone monitoring data for the most recent three (3) years, 2003 through 2005, 

demonstrates that the air quality has met the NAAQS for ozone in this basic nonattainment 

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

Chapter four, supports a redesignation to attainment for Stark County based on 

requirements in Section 107(d)(3)(E) of the CAA. 
3 

CHAPTER TWO 

Requirements for Redesignation 

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

Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued 

September 4, 1992, to Regional Air Directors. This request for redesignation and 

maintenance plan is based on the redesignation guidance, supplemented with additional 

guidance received from staff of U.S. EPA Region V. 

Below is a summary of each redesignation criterion as it applies to Stark County. 

i.) Attainment of the standard: 

 There are two components involved in making this demonstration. The first 

component relies on ambient air quality data. The data that are used to 

demonstrate attainment should be the product of ambient monitoring that is 

representative of the area of highest concentration. The data should be 

collected and quality-assured in accordance with 40 CFR 58 and recorded in 

the Aerometric Information Retrieval System (AIRS) in order for it to be 

available to the public for review. 

 The second component relies upon supplemental U.S. EPA-approved air 

quality modeling. The supplemental modeling is not required for ozone 

nonattainment areas seeking redesignation. Therefore, this ozone 

redesignation request for Stark County does not include modeling data. 

However, in Appendix C the most recent modeling results showing future 

attainment and maintenance are provided. Chapter three discusses this 

requirement in more detail and provides the attainment demonstration. 

ii.) SIP approval: 

 The SIP for the area must be fully approved under Section 110(k) and must 

satisfy all requirements that apply to the area. Ohio’s SIP was approved on 

May 9, 1994 (59FR23799) March 23, 1995 (60FR15235) and includes Stark 

County. Chapter five discusses this requirement in more detail and provides 

the attainment demonstration. 

iii.) Permanent and enforceable improvement in air quality; 

 The state must be able to reasonably attribute the improvement in air quality 

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

well as control measures that have been adopted and implemented by the 

state. 
4 

 Stark County was not designated nonattainment for ozone as part of the 

1990 CAA Amendments re-evaluation. As a result, Ohio has not adopted or 

implemented control measures beyond the federal measures, the initial 1979 

statewide rules and those 1994 and 1995 rules which applied to “rural” 

attainment areas. Chapters four and five discuss this requirement in more 

detail and provide the attainment demonstration. 

iv.) Section 110 and Part D requirements: 

 For purposes of redesignation, a state must meet all requirements of Section 

110 and part D that were applicable prior to submittal of the complete 

redesignation request. 

 Part D consists of general requirements applicable to all areas which are 

designated nonattainment based on a violation of the NAAQS. 

 i.) Section 172(c) requirements 

 This section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for an 

emission inventory will be satisfied by the inventory requirements of 

the maintenance plan. 

 ii.) Conformity 

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

consistent with section 176(c)(4) conformity requirements. The 

redesignation request should include conformity procedures, if the 

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

conformity procedures in place at the time that it submits a 

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

conformity regulation upon issuance, as applicable. Chapter five 

discusses this requirement in more detail and provides the attainment 

demonstration. 

v.) Maintenance plans. 

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

must fully approve a maintenance plan which meets the requirements of 

Section 175(A). The maintenance plan will constitute a SIP revision and 

must provide for maintenance of the relevant NAAQS in the area for at least 

10 years after redesignation. Section 175 (A) further states that the plan 

shall contain such additional measures, if any, as may be necessary to 

ensure such maintenance. 
5 

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

violation of the NAAQS. At a minimum, the contingency measures must 

include a requirement that the state will implement all measures contained in 

the nonattainment SIP prior to redesignation. 

States seeking redesignation of a nonattainment area should consider the 

following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 

 Chapter six discusses this requirement in more detail and provides the 

attainment demonstration. 
6 

CHAPTER THREE 

OZONE MONITORING

CAA Section107 (d)(3)(E)(i) 

Requirement 1 of 4: 

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. 

Background: 

 There are three monitors measuring ozone concentrations in this 

nonattainment area. The monitors are operated by Canton City Health 

Department’s Air Pollution Control Section. The locations of the monitoring 

sites for this nonattainment area are shown in Figure 1. 

Demonstration: 

Figure 1 Map of Stark County 
7 

Requirement 2 of 4: 

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

U.S. EPA Air Quality System (AQS) database, and available for public view. 

Demonstration: 

The Ohio Environmental Protection Agency (Ohio EPA) has quality assured 

all data shown in Appendix A in accordance with 40 CFR 58.10 and the Ohio 

Quality Assurance Manual. Ohio EPA has recorded the data in the AQS 

database and therefore data are available to the public. 

Requirement 3 of 4: 

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. 

 

Background: 

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

Handling Conventions for the eight-hour Ozone National Ambient Air Quality 

Standard (NAAQS)," U.S. EPA-454/R-98-017, December 1998. 

Three (3) complete years of ozone monitoring data are required to 

demonstrate attainment at a monitoring site. The eight-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 eight-hour average ozone concentration is less than 

or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. 

Three (3) significant digits must be carried 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 eight-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 is in compliance with 

the eight-hour ozone NAAQS if, and only if, every monitoring site in the area 

meets the NAAQS. An individual site's three (3) year average of the annual 

fourth highest daily maximum eight-hour average ozone concentration is also 

called the site's design value. Table 1 shows the monitoring data for the 

three most recent years, 2003 - 2005, at the nonattainment area sites and 

was retrieved from the U.S. EPA AQS. 
8 

Demonstration: 

 Table 1: Monitoring Data for Stark County 2003 – 2005 

 Data source: U.S. EPA Air Quality System (AQS). 

 http://www.epa.gov/ttn/airs/airsaqs/index.htm

1st 2nd 3rd 4th 2003-2005 

SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE 

39-151-0016 STARK MALONE COLLEGE 2003 100 .106 .104 .092 .087 .079 

39-151-0016 STARK MALONE COLLEGE 2004 92 .086 .082 .076 .074 

39-151-0016 STARK MALONE COLLEGE 2005 96 .087 .080 .079 .076

39-151-0021 STARK 245 WEST FIFTH 2003 100 .099 .099 .090 .085 .077 

39-151-0021 STARK 245 WEST FIFTH 2004 99 .085 .075 .073 .071 

39-151-0021 STARK 245 WEST FIFTH 2005 100 .083 .078 .077 .076

39-151-4005 STARK 1175 WEST VINE 2003 100 .116 .106 .101 .086 .082 

39-151-4005 STARK 1175 WEST VINE 2004 98 .084 .079 .076 .076

39-151-4005 STARK 1175 WEST VINE 2005 100 .106 .088 .087 .086

Highest Average 0.82 ppm 

A comprehensive list of the site’s design values during the 2003-2005 time 

period is in Appendix A. The area's design value has trended downward as 

emissions have declined due to such factors as 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. Ohio's NOx Budget Trading Program rule was 

approved on May 25, 2004 [Ohio Administrative Code (OAC) Chapter 3745-

14]. It is expected that this downward trend will continue as the above 

programs continue and some form of the U.S. EPA Clean Air Interstate Rule 

(CAIR) is implemented. 

 

Requirement 4 of 4: 

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

monitoring network to verify the maintenance of the attainment status. 

Demonstration: 

 Ohio commits to continue monitoring ozone levels at the site indicated in 

Figure 1. Ohio EPA will consult with U.S. EPA Region V staff prior to making 

changes to the existing monitoring network, should changes become 

necessary in the future. Ohio EPA will continue to quality assure the 

monitoring data to meet the requirements of 40 CFR 58. Connection to a 

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9 

central station and updates to the Ohio EPA Web site1 will provide real time 

availability of the data and knowledge of any exceedances. Ohio EPA will 

enter all data into AQS on a timely basis in accordance with federal 

guidelines. 

CHAPTER FOUR 

EMISSION INVENTORY

CAA Section107 (d)(3)(E)(iii) 

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. Ohio also must demonstrate that the 

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

attainment was achieved is based on permanent and enforceable emission reductions. 

Other emissions inventory related requirements include a projection of the emission 

inventory to a year at least 10 years following redesignation; a demonstration that the 

projected level of emissions is sufficient to maintain the ozone standard; and a commitment 

to provide future updates of the inventory to enable tracking of emission levels during the 

10 year maintenance period. 

Requirement 1 of 5: 

A comprehensive emission inventory of the precursors of ozone completed for the base 

year. 

Background: 

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

program. The 2002 periodic inventory has been identified as the preferred 

data base for SIP development and does coincide with nonattainment air 

quality in Stark County. 

As part of the NOx SIP Call, many states including Ohio were required to 

adopt into their rules a budget for all large EGUs. Ohio’s budget is adopted 

at OAC Chapter 3745-14. The budget represents a statewide cap on NOx

emissions. These emissions, capped by the state rule, should remain at or 

near this level through the maintenance period covered by this request. 

Periodic inventories, which include emissions from all sectors - mobile, area, 

non-road, and point sources - are prepared every three (3) years. 

Demonstration: 

 

1

 www.epa.state.oh.us/dapc/ 
10 

While ozone and its precursors are transported into this region from outside 

areas, this information does provide some indication of the impact from Ohio 

sources near the nonattainment area. The emissions are decreasing 

substantially in response to regional and national programs affecting many 

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. 

Requirement 2 of 5: 

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

Background: 

Ohio EPA prepared a comprehensive inventory for Stark County, including 

area, mobile, and point sources for precursors of ozone (volatile organic 

compounds and nitrogen oxides) for base year 2002. The information below 

describes the procedures Ohio EPA used to generate the 2002 base 

inventories. These inventories were provided to LADCO and have been 

processed to develop summer day emissions for use in the air quality 

analyses. These processed modeling inventories have been identified as the 

correct iteration of the inventory for use in the redesignation. In this 

document, references to LADCO include the Midwest Regional Planning 

Organization. 

• Area sources were taken from the Ohio 2002 periodic inventory 

submitted to U.S. EPA. These projections were made from the U.S. 

Department of Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information. 

• Mobile source emissions were calculated using emissions factors 

produced with MOBILE6.2MOVES 2010. 

• Point source information was compiled from Ohio EPA’s 2002 annual 

emissions inventory database and the 2002 U.S. EPA Air Markets 

acid rain database2

. 

• Biogenic emissions are not included in these summaries. 

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

Mobile Inventory Model (NMIM) 2002 application. To address 

concerns about the accuracy of some of the categories in U.S. EPA’s 

non-road emissions model, LADCO contracted with two (2) 

companies to review the base data and make recommendations. One 

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

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

were estimated for aircraft, commercial marine vessels and railroads. 

 

2 http://www.epa.gov/airmarkets/acidrain 
11 

Recreational motorboat population and spatial surrogates (used to 

assign emissions to each county) were significantly updated. The 

populations for the construction equipment category were reviewed 

and updated based upon surveys completed in the Midwest and the 

temporal allocation for agricultural sources also was updated. 

 

Demonstration: 

 

On-Road Emission Estimations 

In coordination with the Stark County Area Transportation Study (SCATS) 

the Ohio Department of Transportation (Ohio DOT) utilizes a regional travel 

demand forecast model to simulate traffic in the area and to forecast traffic 

flows for given growth expectations. The model is primarily used as a long 

range planning tool to evaluate the transportation system including 

determination of locations where additional travel capacity may be needed 

and to determine the infrastructure requirements necessary to meet that 

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

emissions of pollution caused by vehicles in the area. The travel demand 

forecasting model is used to predict the total daily vehicle miles traveled 

(VMT) and an EPA computer program called MOBILE6.2MOVES 2010 is 

used to calculate emissions per mile. The product of these is the total 

amount of pollution emitted by the on-road vehicles for the particular 

analyzed area. In areas outside the regional travel demand model, traffic 

counts and statewide traffic growth rates are used for the VMT estimates. 

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. The MOBILE6.2Broadly described, MOVES 2010MOVES 2010

model includes a number of variables that affect the emission factors. These 

variables have national default values, some of which require modification to 

reasonably reflect local conditions. Some of these variables are discussed 

here. The vehicle fleet (vehicles on the road) age and the vehicle type have 

a major effect on the emission factors. The vehiclesource types are traveling 

on facilityroad types. Vehicle (MOVES 2010 road types are Rural Restricted 

Access, Rural Unrestricted Access, Urban Restricted Access, and Urban 

Unrestricted Access). The vehicle speeds also affect the emission factor 

values. Meteorological conditions such as air temperature and humidity also 

significantly affectshave a significant effect on emission factors. Emission 

factors produced by MOBILE6.2MOVES 2010 can also include the effect of 

emission reduction strategies such as vehicle inspection and maintenance 

programs, regulation of fuels, etc. These MOBILE6.2MOVES 2010 inputs 

are estimated using the best available data and. 

These inputs are reviewed and agreed to by U.S. EPA and transportation 

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agencies in a formal interagency consultation process. Emission factors are 

multiplied by VMT from the travel demand model to estimate the total vehicle 

emissions.

There are a number of ways emission factors from MOBILE6.2 can be used 

with the travel demand model information. One of the simplest methods is to 

input extensive vehicle fleet, area-specific speed and facility type information 

MOBILE6.2 to generate a single emission factor that represents the average 

for all vehicles and facility types in the modeled area. This only requires 

multiplying this emission factor by the total VMT of the analyzed area to get 

the total emissions for the area. Another method is to create multidimensional emission factor “look-up” tables that describe the emission 

factors by speed, temperature, and facility type. This requires more 

extensive processing, but the resulting total emissions of this method are 

more sensitive to even minor changes in the roadway system. Tables of 

emission factors are created using MOBILE6.2 for each facility type, 

temperature, and speed given the vehicle fleet on that facility. Then, the 

travel model provides information on each segment of road (or “link”) 

regarding speed and facility type which is then “looked-up” in the appropriate 

emission factor table. It should be noted that speed is estimated as a post 

process to the travel demand model. Speeds are not taken directly from the 

travel demand model. The post process for emissions analysis by Ohio DOT 

is by hour of day. This emission factor is multiplied by the link’s trafficvolume and length or VMT to get the emissions from that link for that hour. 

There are other methods as well, each with its advantages and 

disadvantages. The Stark County analysis uses the latter more complex 

method, a table of emission factors. 

It should be noted that each year analyzed will have different emission 

factors, volumes, speeds and roadway networks. 

Some of the assumptions built into MOBILE6.2 are: older vehicles have 

much higher emission factors than newer vehicles, diesel vehicles have 

much higher NOx emission factors and lower VOC emission factors than 

gasoline vehicles, and higher average speeds have lower emission factors 

except for diesel vehicles which have higher NOx at higher speeds. 

MOBILE6.2 

The emission factors from MOVES 2010 can be used with the travel demand 

model information by combining the disaggregate emission rates with VMT, 

and source type population for each road type, source type and hour of day, 

and then sum them up to get the total emissions for the area. 

The Stark County analysis method, developed by Ohio DOT, is to aggregate 

the emission rates by two source types (cars & trucks), then applying VMT 

and source type population, thereby reducing the intensive processes. In the 
13 

first step emission factors are broadly classified into total vehicles, cars and 

trucks by pollutant, by average speed, road type and hour of day. Then the 

hourly link volumes generated from travel demand model are combined with 

emission factors for each network link for each hour. The on-road vehicle 

emissions for the area is the sum of all individual link-hour emissions. 

Vehicle-based emissions are obtained by the combination of corresponding 

emission factors and source type population. Intrazonal emissions are 

computed using a separate method to account for those trips that use local 

roads to travel within a zone. Intrazonal VMT is combined with corresponding 

emission factors to get intrazonal emissions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions. 

Automated programs, using FORTRAN and CUBE scripting, were developed 

by Ohio DOT to generate total emissions. The process uses data on daily 

and directional traffic distributions as well as more up to date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process also 

handles the newer model network formats and MOVES 2010 generated 

emission factors. 

MOVES 2010 input and output files are provided in Appendix C. 

Best Available Data 

Most current vehicle age distribution data, temperature data, and fuel 

properties data, source type distribution data, and I/M data provided by Ohio 

DOT’s ATRs and WIMs, NOAA, ODPS, and Ohio EPA waswere used by the 

Ohio DOT for generating emission factors. Likewise, the most current 

transportation planning data available from the SCATS and most current 

Ohio DOT count data waswere used by the Ohio DOT for the emissions 

estimates. Details about each data set and how it was used is documented 

in Ohio DOT’s “SCATS 8-Hour Ozone Air Quality Conformity Analysis 

Technical Memo” dated 5/24/2006. 

Analysis Years 

Analysis years for this re-designation request include 2002, 2004, 2009, and 

2018 to meet the requirements specified by the CAA and U.S. EPA. The 

travel demand model presents the transportation system conditions for each 

of these years. Model runs for each future analysis year contain the road 

network SCATS and ODOTOhio DOT expects to exist at the beginning of 

that year with corresponding socioeconomic forecasts for that year. 

Local Road VMT 

Most local roads such as subdivision streets are not explicitly modeled in a 

travel demand model. These local roads are represented as fictitious 

roadways called centroid connectors. Local road VMT is included in the Ohio 

DOT post process by including the traffic loaded on centroid connectors. In 

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14 

addition, some local road traffic is captured as intra-zonal trips which travel 

demand models usually do not assign to roadway segments. The Ohio 

DotDOT post process includes these trips as local road VMT. 

Model area VMT 

For Stark County, the travel demand model covers the entire county and a 

portion of Mahoning County. VMT for the portion of model which extends 

beyond Stark County is removed before total emissions are calculated. 

Emission Estimations 

Table 2 contains the results of the emissions analysis for the appropriate 

years. 

Table 2 Emission Estimations for On-Road Mobile Sources for Stark 

County, Ohio 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Stark County 2002 2004 2009 2018 

VMT (miles/day) 7,929,7908,245,109 8,014,259511,311 8,490,027597,080 8,811,255916,054

VOC (tons/day) 16.5624.34 14.0322.56 8.7116.67 4.677.84

NOx (tons/day) 25.35.19 22.0033.14 15.6824.66 6.169.89

Motor Vehicle Emission Budget 

Table 3 contains the motor vehicle emissions budget for Stark County. 

Table 3 Mobile Vehicle Emission Budget for Stark County 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

2009 2018

VOC (tons/day 10.0219.17 5.379.02

NOx (tons/day) 18.0328.36 7.0811.37

This budget includes the emission estimates calculated for 2009 and 2018. The 

emission estimates are derived from the Tranplan travel demand model and 

MOBILE6.2MOVES 2010 as described above under the expected Stark County 

Area Transportation Study (SCATS) 2030 Long Range Plan. The mobile source 

budget includes 59.02 tons/day for VOC and11.37 tons/day for VOC and 7.08 

tons/day for NOx. for 2018 and 19.17 tons/day for VOC and 28.36 tons/day for NOx 

for 2009. These correspond to a 15 percent increase from the 2009 and 2018 onFormatted: Normal, Level 2, Keep with next

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road emissions for both VOC and NOx. Appendix C contains data tables and graphs 

of these emissions. 

 

All methodologies, latest planning assumptions and the safety margins were 

determined through the interagency consultation process described in the 

Transportation Conformity Memorandum of Understanding (MOU) for SCATS. 

Requirement 3 of 5: 

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

standard. 

Background: 

In consultation with U.S. EPA, Ohio EPA selected the year 2018 as the 

maintenance year for this redesignation request. This document contains 

projected emissions inventories for 2009 and 2018. 

Ohio EPA performed emission projections for Stark County using the 

following approaches. 

• Mobile source emission projections are based on the U.S. EPA 

MOBILE6.2MOVES 2010 model. The analysis is described in more 

detail in Appendix C. All projections were made in accordance with 

“Procedures for Preparing Emissions Projections” U.S. EPA-45/4-91-

019. 

• Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. The 

LADCO have developed growth and control files for point, area, and 

non-road categories. These files were used to develop the future year 

emissions estimates used in this document. This was done so the 

inventories used for redesignation are consistent with modeling 

performed in the future. 

The detailed inventory information for Stark County for 2004, 2009 and 2018 

is in Appendix B. Emission trends are an important gauge for continued 

compliance with the ozone standard. Therefore, Ohio EPA performed an 
16 

initial comparison of the inventories for the base year and maintenance years 

for Stark County. Mobile source emission inventories are described in 

Appendix B. In addition to LADCO estimates, point source emissions were 

projected based upon the statewide EGU NOx budgets from the Ohio NOx

rule. 

The following tables include sectors Electrical Generating Unit (EGU-Point), 

Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), 

Other Area (Other), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road). 

Demonstration: 

 Table 4 Stark County VOC Emission Inventory Totals for Base Year 

 2002, Estimated 2004 and Projected 2009 and 2018 (tons per 

 day) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2004 

Attainment 

2009 

Interim

2018 

Maintenance

Safety 

Margin

EGU Point n/a n/a n/a n/a 

Non-EGU 2.90 2.97 3.14 3.77 

Non-road 5.83 5.29 3.92 3.22 

Other 21.23 21.03 20.49 21.93 

MAR 0.15 0.15 0.14 0.14 

On-road 16.5624.34 14.0322.56 

10.0219.17*

 5.379.02* 

TOTAL 46.6754.45 43.4752.00 37.7146.86 34.4338.08 9.0413.92

 * includes 15 percent increase to the mobile source budget 

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 Table 5 Stark County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2004 and Projected 2009 and 2018 (tons per 

 day) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2004 

Attainment 

2009 

Interim 

2018 

Maintenance 

Safety 

Margin 

EGU 

Point 

n/a n/a n/a n/a 

NonEGU 

5.12 4.85 4.16 4.72 

Nonroad 

6.78 6.22 4.81 2.50 

Other 1.17 1.23 1.40 1.46 

MAR 3.28 3.03 2.39 2.22 

On-road 25.35.19 22.0033.14

18.0328.36*

 7.0811.37* 

TOTAL 41.7051.54 37.3348.47 30.7941.12 17.9822.27 19.3526.20

 * includes 15 percent increase to the mobile source budget 

Table 6 Stark County Comparison of 2004 attainment year and 2018 

 projected emission estimates (tons per day, Summer) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

2004 2018 Projected Change

VOC 43.4752.00 34.4338.08 8.0413.92

NOx 37.3348.47 17.9822.27 19.3526.20

VOC emissions in the non-attainment area are projected to decrease by 

8.0413.92 tons per day (tpd). Area source emissions and, to a lesser extent, 

point sources, show an increase due to expectations that the population will 

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18 

grow in this area. However, cleaner vehicles and fuels are expected to be in 

place in 2009 and 2018 and result in an overall drop in VOC emissions. 

NOx emissions in the nonattainment area are projected to decrease by 

19.3526.20 tpd. Decreases from U.S. EPA rules covering Tier 2 Motor 

Vehicle Emissions Standards and Gasoline Sulfur Control Requirements3, 

Highway Heavy-Duty Engine Rule4

 and Non-Road Diesel Engine Rule5 also 

factored into the changes. Further, due to implementation of the NOx SIP 

Call across the eastern United States, NOx and ozone levels entering this 

also decreased. 

Requirement 4 of 5: 

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. 

Background: 

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

the NAAQS for ozone in 2005. U.S. EPA’s redesignation guidance (p 9) 

states, “A state may generally demonstrate maintenance of the NAAQS by 

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

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

future mix of sources and emissions rates will not cause a violation of the 

NAAQS.” 

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

emissions information once every three (3) years or annually if VOC potential 

to emit is greater than 250 tons or NOx potential to emit is greater than 2500 

tons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule 

(CERR). Ohio EPA prepares a new periodic inventory for all ozone precursor 

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

will be prepared for 2005, 2008, and 2011 as necessary to comply with the 

inventory reporting requirements established in the CAA. Emissions 

information will be compared to the 2002 base year and the 2018 projected 

maintenance year inventories to assess emission trends, as necessary, to 

assure continued compliance with the ozone standard. 

Demonstration: 

Permanent and enforceable reductions of volatile organic compounds and 

oxides of nitrogen have contributed to the attainment of the eight-hour ozone 

 

3 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 4 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 5 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 
19 

standard. Some of these reductions were due to the application of tighter 

federal standards on new vehicles. Also, Title IV of the CAA and the NOx

SIP Call required the reduction of oxides of nitrogen from utility sources. 

While no EGU reductions occurred within Stark County, statewide NOx

reductions from EGUs were over 85 percent due to this program. 

Table 7 Stark County Comparison of 2002 base year and 2004 

attainment year on-road and EGU reductions 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

2002 2004

On-road VOC 16.5624.34 14.0322.56

On-road NOx 25.35.19 22.0033.14

EGU NOx n/a n/a 

Requirement 5 of 5: 

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

levels including an annual emission statement from major sources. 

Demonstration: 

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

Administrator, eight (8) years after redesignation, an additional revision of 

this SIP. The revision will contain Ohio's plan for maintaining the national 

primary ozone air quality standard for 10 years beyond the first 10 year 

period after redesignation. 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4:

An U.S. EPA approved SIP control strategy that includes RACT requirements for existing 

stationary sources covered by Control Technology Guidelines (CTG) as applied in Ohio’s 

rural counties. 

Background: 

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20 

As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were no 

specific rules required by the CAA such as RACT for existing sources beyond 

statewide rules. 

Demonstration: 

Statewide RACT rules have been applied to all new sources locating in Ohio 

since that time. The Ohio rules are found in OAC Chapter 3745-21. 

 

Requirement 2 of 4:

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

implemented. 

Background: 

The U.S. EPA NOx SIP Call required 22 states to pass rules that would result 

in significant emission reductions from large EGUs, industrial boilers, and 

cement kilns in the eastern United States. Ohio passed this rule in 2001. 

Beginning in 2004, this rule accounts for a reduction of approximately 31 

percent of all NOx emissions statewide compared to previous uncontrolled 

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

Demonstration: 

U.S. EPA and Ohio EPA performed modeling that indicated this area would 

attain the eight-hour ozone standard with the implementation of the NOx SIP 

Call. Controls for EGUs formally commenced May 31, 2004. Emissions 

covered by this program have been generally trending downward since 1998 

with larger reductions occurring in 2002 and 2003. Data taken from U.S. EPA 

Clean Air Markets Web site, quantifies the gradual NOx reductions that have 

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

beginning of the NOx SIP Call Rule. Ohio developed the NOx Budget Trading 

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

chapter 3745-14 regulated EGUs and certain non-EGUs under a cap and 

trade program based on an 85 percent reduction of NOx emissions from 

EGUs and a 60 percent reduction of NOx emissions from non-EGUs, 

compared to historical levels. This cap will stay in place through 2008, at 

which time the CAIR program will supersede it. 

U.S. EPA has recently published Phase II of the NOx SIP Call that 

establishes a budget for large (greater than 1 ton per day emissions) 

stationary internal combustion engines. Ohio EPA’s proposed rule OAC 

3745-14-12 addresses stationary internal combustion engines, all used in 

natural gas pipeline transmissions. An 82 percent NOx reduction from 1995 

levels is anticipated. Completion of the compliance plan is expected by May 

1, 2006 and the compliance demonstration will begin May 1, 2007. The 

2007 controlled NOx emissions will be 599 tons per day. 
21 

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards 

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

emissions from cars and light trucks, including sport utility vehicles (SUVs). 

Under this proposal, automakers will be required to sell cleaner cars, and 

refineries will be required to make cleaner, lower sulfur gasoline. This rule 

will apply nationwide. The federal rules will phase in between 2004 and 

2009. U.S. EPA has estimated that NOx emission reductions will be 

approximately 77 percent for passenger cars, 86 percent for smaller SUVs, 

light trucks, and minivans, 65 to 95 percent reductions for larger SUVs, vans, 

and heavier trucks. VOC emission reductions will be approximately 12 

percent for passenger cars, 18 percent for smaller SUVs, light trucks, and 

minivans, and 15 percent for larger SUVs, vans, and heavier trucks. 

Heavy-Duty Diesel Engines 

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

program which includes low-sulfur diesel fuel standards, which will be phased 

in from 2004 through 2007. This rule applies to heavy-duty gasoline and 

diesel trucks and buses. This rule will result in a 40 percent reduction in NOx

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

inventory. 

Clean Air Non-road Diesel Rule 

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

applies to diesel engines used in industries such as construction, agriculture, 

and mining. It also contains a cleaner fuel standard similar to the highway 

diesel program. The new standards will cut emissions from non-road diesel 

engines by more than 90 percent. Non-road diesel equipment, as described 

in this rule, currently accounts for 47percent of diesel particulate matter (PM) 

and 25 percent of NOx from mobile sources nationwide. Sulfur levels will be 

reduced in non-road diesel fuel by 99 percent from current levels, from 

approximately 3,000 ppm now to 15 ppm in 2009. 

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

ozone precursors. 

Requirement 3 of 4:

Acceptable provisions to provide for new source review. 

Background: 

Ohio has a long standing and fully implemented New Source Review (NSR) 

program. This is addressed in OAC Chapter 3745-31. The chapter includes 

provisions for the Prevention of Significant Deterioration (PSD) permitting 

program in OAC 3745-31-01 to 3745-31-20. Ohio's PSD program was 
22 

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

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

Demonstration: 

Any facility that is not listed in the 2002 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 requirement. The review process will be identical to that used for 

new sources. Once the area is redesignated, Ohio EPA will implement NSR 

through the PSD program. 

Requirement 4 of 4:

Assure that existing controls will remain in effect after redesignation unless the State 

demonstrates through photochemical modeling that the standard can be maintained without 

one (1) or more controls. 

Demonstration: 

Ohio commits to maintaining the aforementioned control measures after 

redesignation. Ohio hereby commits that any changes to its rules or 

emission limits applicable to VOC and/or NOx sources, as required for 

maintenance of the ozone standard in Stark County, will be submitted to U.S. 

EPA for approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal section, 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 Stark County. 

LADCO Modeling Analysis for eight-hour Ozone Standard Assessment 

LADCO performed modeling to evaluate the effect of the NOx SIP Call and 

Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. 

This modeling was originally designed to assess the one-hour ozone 

standard. Further analysis was conducted and documented in the LADCO’s 

White Paper “8-Hour Ozone Assessment” dated May 2, 2001. Base year 

design values used were the average of the design values for the three (3) 

three-year periods (1994-1996, 1995-1997, and 1996-1998). Base year 

emissions were taken from 1996 and four (4) ozone episodes were 

evaluated: June 22-28, 1991; July 14-21, 1991 

While modeling results were not calculated for Stark County, the average 

decrease in ozone from the base case modeling run with modeling runs that 

applied emission controls required by the CAA, NOx SIP Call and Tier II /lowsulfur requirements was 15 ppb (2009 Future design value of 73.3ppb*.) [* 

LADCO Base K 2009 Future Base case with on-the-books” including CAIR]. 
23 

 LADCO Modeling for CAIR of 2004 

On March 10, 2004, the U.S. EPA promulgated CAIR. NOx emissions will be 

cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 

million tons in 2018 in 28 eastern states and the District of Columbia. 

LADCO performed modeling to support the associated emission reductions 

for CAIR. This modeling was based on 2001 – 2002 design values for Stark 

County. Results of the CAIR modeling show Stark County will continue to 

attain the eight-hour ozone NAAQS well into the future. 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Formatted: Left
24 

Requirement 1 of 4:

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

Demonstration: 

Ohio hereby commits to review its maintenance plan eight (8) years after 

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

Requirement 2 of 4:

A commitment to expeditiously enact and implement additional contingency control 

measures in response to exceeding specified predetermined levels (triggers) or in the event 

that future violations of the ambient standards occur. 

Demonstration: 

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

Warning Level Response: 

A warning level response shall be prompted whenever an annual (1-year) 

fourth high monitored value of 88 ppb occurs in a single ozone season 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 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 two (2) year average 

fourth high monitored value of 85 ppb occurs within the maintenance area. In 

the event that the action level is triggered and is not due to an exceptional 

event, malfunction, or noncompliance with a permit condition or rule 

requirement, Ohio EPA will determine additional control measures needed to 

assure future attainment of NAAQS for ozone. In this case, measures that 

can be implemented in a short time will be selected in order to be in place 

within eighteen (18) months from the close of the ozone season that 

prompted the action level. 
25 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the necessary 

administrative and legal process. This process will include publication of 

notices, an opportunity for public hearing, and other measures required by 

Ohio law for rulemaking 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, Ohio will 

submit to U.S. EPA an analysis to demonstrate the proposed measures are 

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration: 

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the time 

the selection is made. The selection of measures will be based on costeffectiveness, emission reduction potential, economic and social 

considerations or other factors that Ohio EPA deems appropriate. Ohio EPA 

will solicit input from all interested and affected persons in the maintenance 

area prior to selecting appropriate contingency measures. Because it is not 

possible at this time to determine what control measure will be appropriate at 

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

below is not comprehensive. 

1) Lower Reid vapor pressure gasoline program. 

2) Tighten RACT on existing sources covered by U.S. EPA Control 

Technique Guidelines issued in response to the 1990 CAA. 

3) Apply RACT to smaller existing sources. 

4) One or more transportation control measures sufficient to achieve at 

least half a percent reduction in actual area wide VOC emissions. 

Transportation measures will be selected from the following, based 

upon the factors listed above after consultation with affected local 

governments: 

a) trip reduction programs, including, but not limited to, employerbased transportation management plans, area wide rideshare 

programs, work schedule changes, and telecommuting; 
26 

b) traffic flow and transit improvements; 

c) other new or innovative transportation measures not yet in 

widespread use that affects state and local governments 

deemed appropriate.

5) Alternative fuel and diesel retrofit programs for fleet vehicle 

operations. 

6) Controls on consumer products consistent with those adopted 

elsewhere in the United States. 

7) Require VOC or NOx emission offsets for new and modified major 

sources. 

8) Require VOC or NOx emission offsets for new and modified minor 

sources. 

9) Increase the ratio of emission offsets required for new sources. 

10) Require VOC or NOx controls on new minor sources (less than 100 

tons). 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

benefits of individual measures, at the time they are under consideration, can 

be fully evaluated. 

Requirement 4 of 4:

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

Demonstration: 

The following is a list of VOC and NOx sources potentially subject to future 

controls. 

NOx RACT 

• EGUs 

• asphalt batching plants 

• industrial/commercial and institutional boilers 

• process heaters 

• internal combustion engines 

• combustion turbines 

• other sources greater than 100 tons per year 
27 

VOC RACT 

• consumer products 

• architectural and industrial maintenance coatings 

• stage I gasoline dispensing facilities (including pressure valves) 

• automobile refinishing shops 

• cold cleaner degreasers 

• portable fuel containers 

• synthetic organic compound manufacturing 

• organic compound batch processes 

• wood manufacturing 

• industrial wastewater 

• aerospace industry 

• shipbuilding 

• bakeries 

• plastic parts coating 

• volatile organic liquid storage 

• industrial solvent cleaning 

• offset lithography 

• industrial surface coating 

• other sources greater than 50 tons per year 
28 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio will publish a notification for a public hearing and solicitation for public comment 

concerning the draft redesignation petition and maintenance plan in severala widely 

distributed publications 30 days prior tonewspaper in the public hearingarea. 

The public hearing to receive comments on the redesignation request will bewas held on 

July 27, 2006,November 8, 2012 at the189 25th St. NW Canton, Ohio University-Eastern 

Branch Shannon Hall Room 218, located at 45425 National Road, St. Clairsville, Ohio.. 

The public comment period will closeclosed on July 28, 2006.November 8, 2012. No 

comments were received during the public comment period and no testimony was provided 

at the hearing. Appendix D will includeincludes a copy of the public notice, certifications of 

publication, and the and hearing transcript from the public hearing.. 

 
29 

CHAPTER EIGHT 

CONCLUSIONS

The Stark County basic nonattainment area has attained the NAAQS standard and 

complied with the applicable provisions of the 1990 Amendments to the CAA regarding 

redesignations of basic ozone nonattainment areas. Documentation to that effect is 

contained herein. Ohio EPA has prepared a state implementation and maintenance plan 

that meets the requirement of Section 110 (a)(1) of the 1990 CAA. 

Ohio has performed an analysis that shows the air quality improvements are due to 

permanent and enforceable measures. In addition, significant regional NOx reductions will 

ensure continued compliance (maintenance) with the standard and that all CAA 

requirements necessary for redesignation have been met. 

Based on this presentation, the Stark County ozone basic nonattainment area meets the 

requirements for redesignation under the CAA and U.S. EPA guidance. Furthermore, 

because this area is subject to significant transport of pollutants, significant regional NOx

reductions will ensure continued compliance (maintenance) with the standards with an 

increasing margin of safety. 

The State of Ohio hereby requests that the Stark County ozone basic nonattainment area 

be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio state 

implementation and Maintenance Plan provisions contained herein. 

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UNITES STATES ENVIRONMENTAL PROTECTION AGENCY

QUICKLOOK CRITERIA PARAMETERS

Report Request ID: 396645 Report Code: AMP450 Jan. 11, 2007

Selection Criteria Page 1

User ID: GYE

State County Site Parameter POC City AQCR UAR MSA CMSA

EPA

Region Method Duration Begin Date End Date

39 151

GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS

Parameter

Classification Parameter Method Duration

CRITERIA 44201 W

SELECTED OPTIONS

MERGE PDF FILES

EVENTS PROCESSING

Option Type Option Value

YES

EXCLUDE REGIONALLY CONCURRED EVENTS

SORT ORDER

1

2

3

4

5

6

7

Order Column

PARAMETER_CODE

STATE_CODE

COUNTY_CODE

SITE_ID

POC

DATES

EDT_ID

GLOBAL DATES

2004

Start Date End Date

2006

Tribal
Jan. 11, 2007

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 1 of 4

EXCEPTIONAL DATA TYPES

EDT DESCRIPTION

0

1

2

3

4

5

6

7

NO EVENTS

EVENTS EXCLUDED

EVENTS INCLUDED

EXCEPTIONAL EVENTS EXCLUDED

NATURAL EVENTS EXCLUDED

EVENTS WITH CONCURRENCE EXCLUDED

EXCEPTIONAL EVENTS WITH CONCURRENCE EXCLUDED

NATURAL EVENTS WITH CONCURRENCE EXCLUDED
Jan. 11, 2007

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 2 of 4

Ozone (44201) Ohio Parts per million (007)

SITE ID

P

O

C

REP

ORG CITY COUNTY ADDRESS YEAR METH

VALID

DAYS

MEAS

4TH

MAX

8-HR CERT EDT

39-151-0016

39-151-0016

39-151-0016

39-151-0021

39-151-0021

39-151-0021

39-151-1009

39-151-4005

39-151-4005

39-151-4005

1

1

1

1

1

1

1

1

1

1

0151

0151

0151

0151

0151

0151

0151

0151

0151

0151

Canton

Canton

Canton

Brewster

Brewster

Brewster

Not in a city

Alliance

Alliance

Alliance

Stark

Stark

Stark

Stark

Stark

Stark

Stark

Stark

Stark

Stark

515 25TH. ST.

515 25TH. ST.

515 25TH. ST.

245 W. 5TH ST.

245 W. 5TH ST.

245 W. 5TH ST.

6318 HEMINGER

AVE. NE., PLAIN

TOWNSHIP

1175 WEST VINE

1175 WEST VINE

1175 WEST VINE

2004

2005

2006

2004

2005

2006

2004

2004

2005

2006

047

047

047

047

047

047

047

047

047

047

.086

.087

.083

.085

.083

.085

.084

.084

.106

.082

.082

.080

.081

.075

.078

.081

.081

.079

.088

.078

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

0

0

0

0

0

0

0

0

0

0

8-HOUR 

NUM

DAYS

REQ

214

214

214

214

214

214

214

214

214

214

.076

.079

.080

.073

.077

.079

.077

.076

.087

.075

.074

.076

.078

.071

.076

.079

.076

.076

.086

.075

DAY

MAX>/=

0.085

1

1

0

1

0

1

0

0

5

0

197

205

195

211

213

208

196

210

214

199

%OBS

92

96

91

99

100

97

92

98

100

93

1ST

MAX

8-HR

2ND

MAX

8-HR

3RD

MAX

8-HR
Jan. 11, 2007

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 3 of 4

44201 047 INSTRUMENTAL ULTRA VIOLET

PARAMETER

METHOD

CODE COLLECTION METHOD ANALYSIS METHOD

METHODS USED IN THIS REPORT
Jan. 11, 2007

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 4 of 4

REPORTING ORGANIZATIONS USED IN THIS REPORT

REPORTING

ORGANIZATION

CODE AGENCY DESCRIPTION

0151 Canton City Health Department Air Pollution Control
STREET ADDRESS: 

Lazarus Government Center 

122 S. Front Street 

Columbus, Ohio 43215 

CERTIFIED MAIL 

January 10, 2007 

State of Ohio Environmental Protection Agency 

TELE: (614) 644·3020 FAX: (614) 644·3184 

www.epa.state.oh.us 

Mr. Steve Rothblatt, Chief 

Air and Radiation Branch 

U.S.EPA, Region V 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

RE: 2006 SLAMS Ozone Data Certification 

Dear Mr. Rothblatt: 

MAILING ADDRESS: 

P.O. Box 1049 

Columbus, OH 43216·1049 

Please find enclosed our SLAMS Reports (AMP-450 and AMP-240) for 

calendar year 2006 ozone data as required in 40 CFR, Part 58, 

Section 58.26. 

I certify that the data in the report are accurate to the best of 

our knowledge. There were no incidents of air pollution that 

reached or exceeded levels as specified by Section 51.151 which 

could cause significant harm to the he.alth of persons. 

Sincerely, 

Robert Hodanbosi 

Chief, Division of Air Pollution Control 

Enclosure 

@ Printed on Recycled Paper 

Bob Taft, Governor 

Bruce Johnson, Lieutenant Governor 

Joseph P. Koncelik, Director 

Ohio EPA is an Equal Opportunity Employer 
1

Ohio 

2002 Base Year SIP Inventory 

Ohio Environmental Protection Agency 

Lazarus Government Center 

122 South Front Street 

Columbus Ohio 43215 
2

Table of Contents 

Section Page 

 Introduction ................................................................................................ 3 

1.0 Point Sources ............................................................................................. 4 

 

2.0 Non Road Sources ..................................................................................... 8 

3.0 Area Sources ........................................................................................... 12 

4.0 MAR Sources ........................................................................................... 25 

5.0 On Road Sources ..................................................................................... 28 
3

2002 Base Year SIP Inventory for Ohio 

Introduction 

In April 2004, the United States Protection Agency (U.S. EPA) designated over 

400 counties nationwide as non-attainment for the new eight-hour ozone ambient 

air quality standard, including thirty three counties in Ohio. The 1990 Clean Air 

Act Amendments (CAAA) requires all states to revise and submit state 

implementation plans (SIPs) for areas which are classified as nonattainment of 

the National Ambient Air Quality Standards (NAAQS) for ozone. The following 

site provides a map of Ohio’s counties with either a Moderate or basic nonattainment designation: http://www.epa.state.oh.us/dapc/general/Ohio8-

Hour_Non-attainmentAreas0415204_1.pdf

As part of the designation of nonattainment areas for the eight-hour ozone 

standard, a new attainment demonstration SIP will be necessary. A key element 

in the overall SIP planning process is an updated emission inventory. This 

document presents the 2002 Base Year Ozone State Implementation Plan (SIP) 

Emissions Inventory for Ohio as required by the 1990 CAAA. It includes oxides 

of nitrogen (NOx) and volatile organic compounds (VOC) emissions for point, 

area, on-road mobile, non-road mobile and biogenic emissions for Ohio. 

This technical report documents the procedures and the methodologies that were 

used in the development of summer day volatile organic compound and nitrogen 

oxides emissions for all Ohio counties. This report describes the following: 

1. Identification of stationary and mobile sources included in the 

inventory; 

2. Sources of data, and data collection methods used in the 

development of the inventory; 

3. Methods and procedures used to estimate volatile organic and 

nitrogen oxides; and 

4. Assumptions considered in the development of emission 

inventories. 

The intent of this report is to describe how the inventory was prepared, and what 

information was considered in the inventory development. 

This document comprises of five sections; one section for each inventory 

category. The biogenic inventory is not being discussed in the document. Ohio 

EPA did not participate in the generation of the biogenic inventory. The Lake 

Michigan Air Directors Consortium (LADCO) utilized U.S. EPA’s Biogenic 

Emission Inventory System (BEIS) model in the Emission Modeling System 

(EMS) to generate summer weekday emissions for VOC and NOx. 
4

SECTION 1 

POINT SOURCES 

Emissions and source specific data for point sources are collected for the 2002 

base year SIP inventory by the Ohio Environmental Protection Agency (Ohio 

EPA.) The primary source of data for point sources is facility-reported STARShip 

files. STARShip is a software package developed by Ohio EPA, Division of Air 

Pollution Control (DAPC), to assist the regulated community in preparing and 

submitting a variety of electronic permit applications and reports to DAPC. 

These data are reported by the Title V facilities annually as part of the emissions 

fee/inventory process conducted by Ohio EPA and include emissions, process 

rates, operating schedules, emissions control data and other relevant 

information. The STARShip files are electronically transferred to DAPC and 

stored into the division’s Oracle database, STARS. The files are reviewed by the 

local air agencies and Ohio EPA district and central office staff. After review, the 

data are imported into Excel and linked with an Access® database to further 

process the information into the federally approved National Emission Inventory 

(NEI) database format in version 3.0. The files are quality assured again using 

U.S.EPA QA/QC software for format and content. The data are finally submitted 

to LADCO for emissions processing through the EMS. The State provided 

inventory for Electric Generating Units (EGU) is replaced with the federal EGU 

inventory. The EGU inventory is compiled by U.S. EPA’s Acid Rain Program. It 

is based on facility reported emissions as measured by continuous emissions 

monitors. In conclusion, the final point source inventory is a hybrid of the federal 

EGU inventory and the state provided non-EGU units. 

A major distinction typically made in emissions inventories is that between point 

and area sources. In this inventory, point sources are sources for which 

individual records are maintained for that source. Such records are maintained 

for all Ohio Title V facilities (753 facilities statewide). The area source inventory 

accounts for facilities from non-Title V facilities and calculates emissions 

information using surrogate emissions factors based on energy usage, 

population or other reliable data. A more detailed discussion of the area source 

inventory is provided in Section 3. The point source inventory described herein is 

considered to be the most current and accurate source of emissions data 

available for 2002. 

1.1 Point Source Process Emissions 

Ohio EPA defines point source process emissions as those which occur at an 

identifiable Title V stationary stack or vent. Point source emissions not emitted 

from discrete stacks or vents are termed fugitive emissions and are discussed in 

Section 1.2. 
5

1.1.1 Source Identification and Data Collection 

The sources to be included in the 2002 base year inventory are identified using 

the Title V STARS database. Facility production and emissions data are 

included in this database. This information is facility-reported actual 2002 

emissions. 

1.1.2 Non-reactive VOC Emission Adjustments 

Sources are required to identify emissions of photochemically non-reactive VOC. 

Based upon this information, those emissions have been specifically excluded 

from the 2002 base line inventory in accordance with U.S. EPA’s “Recommended 

Policy on the Control of Volatile Organic Compounds.” A complete list of the 

compounds that U.S. EPA has identified as being photochemically non-reactive, 

and therefore not included in the inventory, are listed below: 

• Methane 

• Ethane 

• Methylene chloride 

• Methyl chloroform 

• Trichlorofluoromethane (CFC-11) 

• Dichlorodifluoromethane (CFC-12) 

• Chlorodifluoromethane (CFC-22) 

• Trifluoromethane (HFC-23) 

• Chlorofluoromethance (HCFC-31) 

• Difluoromethane (HFC-32) 

• Decafluoropentane (HFC-43-10mee) 

• Ethylfluoride (HFC-161) 

• Trichlorotrifluoroethane (CFC-113) 

• Dichlorotetrafluoroethane (CFC-114) 

• Chloropentafluoroethane (CFC-115) 

• 2,2-Dichloro-1,1,1-trifluoroethane (HCFC-123) 

• 1,1,2-Trifluoroethane (HCFC-123a) 

• 2-Chloro-1,1,1,2-tetrafluoroethane (HCFC-124) 

• Pentafluoroethane (HFC-125) 

• 1,1,2,2,-Tetrafluoroethane (HFC-134) 

• 1,1,1,2-Tetrafluoroethane (HFC-134a) 

• 1,1-Dichloro-1-fluoroethane (HCFC-141b) 

• 1-Chloro-1,1,-difluoroethane (HCFC-142b) 

• 1,1,1-Trifluoroethane (HFC-143a) 

• Fluoroethane (HCFC-151a) 

• 1,1-Difluoroethane (HFC-152a) 

• Pentafluoropropane (HFC-225ca) 

• Pentafluoropropane (HFC-225cb) 

• Hexafluoropropane (HFC-236ea) 

• Hexafluoropropane (HFC-236fa) 

• Pentafluoropropane (HFC-245ca) 

• Pentafluoropropane (HFC-245ea) 

• Pentafluoropropane (HFC-245eb) 
6

• Pentafluoropropane (HFC-245fa) 

• Pentafluorobutane (HFC-365mfc) 

• Parachlorobenzotrifluoride (PCBTF) 

• Methoxybutane 

• Nonaflourobutane 

• Heptafluoropropane ((CF3)2CFCF2OCH3) 

• Heptafluoropropane ((CF3)CFCF2OC2H5) 

• Perchloroethylene 

• Cyclic, branched or linear completely methylated siloxanes 

• Methyl acetate 

• Volatile methyl siloxanes 

• Acetone 

1.1.3 Emissions Estimation Methodologies 

Since source reported actual annual emissions are used in the 2002 base year 

inventory, no estimation methods are necessary. The reports are provided to 

LADCO in National Emissions Inventory Input Format (NIF) 3.0 format. LADCO 

imported and processed the NIF files in EMS and applied temporal and spatial 

profiles to the annual emissions to calculate the July weekday emissions rates. 

The final point source inventory is split into two separate reports, the EGU which 

is the U.S. EPA inventory for electric generating units and the non-EGU which is 

the state inventory minus the EGU units. 

1.2 Point Source Fugitive Emissions 

Another type of emissions data which is required to be filed from point sources is 

fugitive emissions. Before 1990, fugitive emissions were categorized as area 

sources due to the lack of detailed information available for fugitive sources. 

However, since these emissions are now electronically reported in the state’s 

ORACLE database, STARS, these emissions can be classified as point sources. 

1.3 References 

Recommended Policy on the Control of Volatile Organic Compounds. U.S. 

Environmental Protection Agency, Research Triangle Park, NC, Revised January 

18, 1989. 

Procedures for the Preparation of Emission Inventories for Carbon Monoxide and 

Precursors of Ozone, Volume I: General Guidance for Stationary Sources. EPA450/4-91-016, Office of Air Quality Planning & Standards Research, Triangle 

Park, NC. May 1991. 

Compilation of Air Pollution Emission Factors, Fourth Edition and Supplements, 

AP-42. U.S. Environmental Protection Agency, Research Triangle Park, NC, 

September 1985. 
7

Guidance for the Preparation of Quality Assurance Plans for O3/CO SIP 

Emission Inventories. EPA-450/4-88-023, U.S. EPA Office of Air Quality Planning 

and Standards, Research Triangle Par, NC, December 1988. 

Documentation for the 2002 Electric Generating Unit National Emissions 

Inventory (NEI). Eastern research group, Inc., 1600 Perimeter Park Drive, 

Morrisville, NC 27560 and E.H. Pechan and Associates, Inc., 5528–B 

Hempstead Way 
8

SECTION 2 

NON-ROAD SOURCES 

The non-road inventory is generated regionally by running U.S. EPA’s National 

Mobile Inventory Model (NMIM) model. The Wisconsin Department of Natural 

Resources undertook the responsibility of customizing the NMIM input files and 

submit the output file in NIF format to LADCO and U.S. EPA. LADCO processed 

the NMIM files in their emissions model and generated summer emissions rates. 

Below are two e-mails from Grant Heatherington from the Wisconsin Department 

of Natural Resources that were distributed to the LADCO States. The first e-mail 

provides a summary of activities to revise the NMIM county profile files while the 

second e-mail provides an overall description of the modifications related to 

NMIM.

First e-mail from Grant Heaterington on NMIM Model and Input 

Descriptions 11/7/05 

2.1 Activity Data 

LADCO states: The activity data have been revised to include E. H. Pechan & 

Associates, Inc. (Pechan), an air quality consulting firm www.pechan.com, 

construction data. There are 130 source classification codes (SCC) impacted. 

The revised NMIM files are saved as five separate files: 1700002.act, 

1800002.act, 2600002.act, 3900002.act and 5500002.act even though each file 

is identical. These duplicates simplify the external file structures in NMIM. NonLADCO states: Minnesota provided revised activity data. The revised activity 

data are saved as 2700002.act. 

2.2 Allocation Data 

LADCO states: The allocation data have been revised to include Environ’s 

recreational marine data. The revised NMIM files are saved as 

17000wib_rev.alo, 17000wob_rev.alo, 18000wib_rev.alo, 18000wob_rev.alo, 

26000wib_rev.alo, 26000wob_rev.alo, 39000wib_rev.alo, 39000wob_rev.alo, 

55000wib_rev.alo and 55000wob_rev.alo. [“wib” stands for watercraft inboard 

and “wob” stands for watercraft outboard.] 

Non-LADCO states: Minnesota provided revised watercraft inboard, watercraft 

outboard and snowmobile allocation data. The revised NMIM files are saved as 

27000wib_rev.alo, 27000wob_rev.alo and 27000snm_rev.alo. [“snm” stands for 

snowmobile.] 

2.3 Emission Factor Data 

All states: The brake specific fuel consumption (BSFC) emission factor data have 

been revised to include Pechan’s data for diesel tampers/rammers 

(2270002006). The revised NMIM file is saved as revBSFC.EMF. 
9

2.4 Population Data 

LADCO states: The recreational marine and construction population data have 

been modified by Environ and Pechan respectively. The revised NMIM files are 

saved as 17000_rev.pop, 18000_rev.pop, 26000_rev.pop, 39000_rev.pop and 

55000_rev.pop files. 

2.5 Seasonality Data 

LADCO states: The recreational marine and agricultural seasonality data have 

been modified by Environ and Pechan respectively. The revised NMIM files are 

saved as 17000_rev.sea, 18000_rev.sea, 26000_rev.sea, 39000_rev.sea and 

55000_rev.sea. 

Non-LADCO states: For Iowa, Minnesota and Missouri, the agricultural 

seasonality data have been modified by Pechan. The revised NMIM files are 

saved as 19000_rev.sea, 27000_rev.sea and 29000_rev.sea. 

2.6 Growth Data

LADCO states: Pechan revised the growth file. The revised NMIM files are 

saved as five separate files: 17000_rev.grw, 18000_rev.grw, 26000_rev.grw, 

39000_rev.grw and 55000_rev.grw even though each file is identical. These 

duplicates are needed for the external file structures in NMIM. 

2.7 Fuel Data 

LADCO states: Pechan revised four tables (countyyear, countyyearmonth, 

datasource and gasoline) in the National County Database (NCD) used by NMIM 

to incorporate new fuel data. Additional revisions are incorporated into 2002 data 

for non-road Stage 2 controls. Depending on the year being modeled, different 

versions of the revised tables are used. Also, the countynrfile, countyyear and 

datasource tables are revised to reference the new activity, allocation, growth, 

population, and seasonality files described above. NCD tables with names 

ending in “def” are default versions of the table. See Table 2-1 for the 

appropriate versions of the tables for the selected years. 

Non-LADCO states: The countynrfile, countyyear and datasource tables are 

revised to reference the new activity, allocation and seasonality files described 

above. See Table 2-1 below for the appropriate versions of the tables for the 

selected years. 
10

Table 2-1 NMIM NCD Tables for Specific Years and States 

States Year 

2002 2007 – 2009, 2012 & 2018 

LADCO states countynrfile_rev_all, 

countyyear_rev_2002, 

countyyearmonth_rev_all, 

datasource_rev_all, 

gasoline_rev_all

countynrfile_rev_all, 

countyyear_rev_post_2002, 

countyyearmonth_rev_all, 

datasource_rev_all, 

gasoline_rev_all

MN countynrfile_rev_all, 

countyyear_rev_2002, 

countyyearmonth_def, 

datasource_rev_all, 

gasoline_def 

countynrfile_rev_all, 

countyyear_rev_post_2002, 

countyyearmonth_def, 

datasource_rev_all, 

gasoline_def 

IA and MO countynrfile_rev_all, 

countyyear_def, 

countyyearmonth_def, 

datasource_rev_all, 

gasoline_def 

countynrfile_rev_all, 

countyyear_def, 

countyyearmonth_def, 

datasource_rev_all, 

gasoline_def 

A more recent e-mail by Grant Heatherington on 5/26/2006, provides a synopsis 

of changes with no references to the file names 

Second e-mail mail from Grant Heatherington on NMIM Model and Input 

Descriptions 5/26/06 

The NMIM model developed by U.S. EPA, was used to estimate emissions for all 

other non-road mobile categories. NMIM consolidates non-road mobile 

emissions and on-road emissions modeling into a single modeling system. Only 

the non-road emissions modeling portion of NMIM was used in the development 

of this emission inventory. NMIM uses the U.S. EPA’s non-road model to 

calculate non-road mobile emissions. The basic non-road algorithm for 

calculating emissions uses base year equipment populations, average load 

factors, available engine powers, activity hours and emission factors. Before 

NMIM was run, modifications and additions were made to the NMIM input data 

and the non-road model. 

a. Revised activity data for construction equipment using updates 

provided by E.H. Pechan & Associates, Inc. Activity data describes 

typical usage for different types of non-road mobile equipment. 

b. Revised allocation data for recreational marine equipment using 

updates provided by ENVIRON International Corporation. 

Allocation data is used to spatially allocate emissions. 
11

c. Added emission factors for diesel tampers/rammers provided by 

E.H. Pechan & Associates, Inc. Diesel tampers/rammers are a 

type of construction equipment. 

d. Revised seasonality data for construction and recreational marine 

equipment using updates provided by E.H. Pechan & Associates, 

Inc. and ENVIRON International Corporation respectively. 

Seasonality data is used to temporally allocate emissions across 

the months of the year. 

e. Revised population data for construction and recreational marine 

equipment using updates provided by E.H. Pechan & Associates, 

Inc. and ENVIRON International Corporation respectively. 

f. Revised growth rates using updates provided by E.H. Pechan & 

Associates, Inc. If equipment populations aren’t provided for the 

modeled year (e.g. 2002), growth rates and scrappage rates are 

used to adjust the available equipment populations to the modeled 

year. 

g. Revised gasoline parameters using updates provided by the state 

and E.H. Pechan & Associates, Inc. Gasoline parameters include 

Reid vapor pressure (RVP), oxygenate content and sulfur content. 

h. Replaced the default version of the non-road model included with 

NMIM with an improved version that generates a more complete 

estimate of permeation emissions. The new version of the nonroad model was provided by Air Improvement Resources, Inc. 

Permeation emissions are due to the permeation of hydrocarbon 

molecules through plastic and rubber equipment components. 
12

SECTION 3 

AREA SOURCES 

Area sources are those sources which are typically small, individual and 

numerous, and have not been inventoried as specific point, mobile, or biogenic 

sources. For inventory purposes, these sources are grouped with other like 

sources into area source categories to allow emissions to be calculated 

collectively using one methodology. Area sources have been traditionally 

defined at the county level and therefore, most area source methods are 

designed to estimate area source emissions at the county level. 

Ohio EPA has either used published Emission Inventory Improvement Program 

(EIIP) methodologies or selected other methodologies which are shared by other 

states. The decision of which methodology to use was largely based on Ohio’s 

data availability. Data which was not available on a county-level is estimated by 

assigning a percentage of the state’s total activity to each county based on the 

state’s population or employment information. 

The area sources discussed in this document are those that emit NOX and/or 

VOC into Ohio’s atmosphere. Table 3-1 lists the categories included in the 2002 

area source inventory: 

Table 3-1 Categories included in the 2002 area source inventory 

VOC 

Emissions 

NOX & VOC 

Emissions 

NOX 

Emissions 

Agricultural Pesticides Residential Coal Combustion Human Cremation 

Architectural Surface Coatings Residential Distillate Oil Combustion 

Auto Body Refinishing Residential LPG Combustion 

Consumer & Commercial Solvents Residential Natural Gas Combustion 

Degreasing (Solvent Cleaning) Residential Wood Combustion 

Fuel Marketing Industrial Distillate Oil Combustion 

Graphic Arts Industrial Natural Gas Combustion 

Hospital Sterilizers Industrial Residual Oil Combustion 

Industrial Surface Coating Structure Fires 

Industrial Rubber & Plastics 

Landfills 

Portable Fuel Containers 

POTW 

Traffic Markings 
13

3.1 Agricultural Pesticides (SCC 246850000) 

 VOC 

Ohio farmers use mostly Atrizine and 2, 4-D chemicals in pesticide formulations 

for the three main crops: corn, soybean and wheat. According to Ohio’s 

Department of Agriculture, Ohio farmers use Atrizine pesticide with 42.6 percent 

active ingredient and 56.5 percent inert ingredient. The 2, 4-D pesticide contains 

46.8 percent active ingredient and 53.2 percent inert ingredient. While these 

percentages are not across the board, they represent the majority of what is 

being used. Ohio farmers use Atrizine and 2, 4-D in a liquid solution formulation 

type which is mixed with water when ready to use, and spray applied 90 percent 

of the time. 

The emission factor of 700 lb/ton for surface application for Atrizine and 2, 4-D is 

applied. To estimate the VOC emissions for all pesticides for each crop, an 

alternative method from the EIIP document is used because Ohio lacked the 

level of detail needed to calculate emissions for each pesticide formulation. 

E = VOC emissions 

A= Harvested acres 

R = Pounds of pesticide applied per year per harvested acre (see above). 

I = Pounds of active ingredient per pound of pesticide (assume a factor of one) 

ER = Evaporation rate (typically 0.9) (Wiens, 1977) 

3.2 Architectural Surface Coatings (SCC 2401001000) 

 VOC 

Architectural surface coatings is typically considered to be a non-industrial 

category which homeowners and painting contractors use for coating the interior 

and exterior of houses, buildings, and other surfaces. Two types of paint are 

used to categorize this area source: water-based and solvent-based paint. 

Solvent-based paint typically contains substantially higher volatile solvent 

contents than water-based paint. 

Table 3-2 lists the emission factors in calculating the VOC emissions which are 

acquired from the “Documentation for the 2002 Non-point Source NEI for Criteria 

Air Pollutants (CAPS) and Hazardous Air Pollutants (HAPS)”, January 2004, by 

Pechan1 and prepared for Emission Factor and Inventory Group (EFIG).

E(VOC) = A x R x I x ER x 2.45 
14

Table 3-2 VOC Emission Factors and Paint Usage Factors: 

Paint Type VOC Emission Factor

(lb/gal) 

Usage Factors 

(gal/person) 

Solvent-Based Paint 3.87 0.4158 

Water-Based Paint 0.74 2.0444 

The per capita usage factors are estimated by dividing the total volume of each 

type of coating shipped by the 2002 U.S. population2 288,368,698. 

3.3 Auto Body Refinishing (SCC 2401005000) 

 VOC 

The repairing of damaged vehicles to any coating applications which occur after 

those applied at the original manufacturers’ assembly plant are included in this 

category (only auto repair shops not coating of new cars). This area source 

includes paint and thinning solvents used as well as for surface preparation and 

clean-up. Since auto body repair shops may also be point sources, the area 

source emissions estimate will have to be adjusted by removing the total point 

source emissions. However, in Ohio, there are no point sources identified for 

this category so no such adjustment is made. 

The methodology is based on the per capita emissions factor because it is 

considered a more reliable factor that the employment factor. The VOC 

emissions factor (EF) of 1.3 lb/person is applied to each county’s population. 

This EF includes a thirty-three (33) percent promulgated rule reduction. 

3.4 Consumer & Commercial Solvents (SCC 2465000000) 

 VOC 

This area source includes a wide array of products including personal care 

products, household cleaning products and household pesticides. The majority 

of VOC emitted into the air from this category is a result of evaporation of the 

solvent contained in the product or from the propellant released during use. This 

category includes household use as well as businesses, institutions, and 

industrial manufacturing operations. 

Industrial solvent applications may also be point sources so adjustment must be 

made to the area source emissions by removing emissions due to point sources. 

However, in Ohio there are no point sources which contributed VOC emissions 

from this category. 

Ohio used the population2

 based methodology. A 7.3 lb/person EF is used to 

calculate VOC emissions. 
15

3.5 Solvent Cleaning (SCC 2415000000) 

 VOC 

This area source (also known as “degreasing”) includes two classifications: 

• Solvent Cleaning

– Cold Cleaning for Automobile Repair (2415360000) 

– Cold Cleaning for Manufacturing (2415345000) 

– Vapor/in-line Cleaning for Electronics & Electrical (2415230000) 

– Vapor/in-line Cleaning for Other (2415245000) 

• Solvent Cleanup 

– Wipe Cleaning of External Surfaces 

Ohio utilizes the methodology requiring employment3

 data. Each solvent-cleaning 

SCC identified above has an EF as indicated below in Table 3-4 which is used to 

calculate the VOC emissions by county. The resultant emissions are reduced by 

thirty (30) percent to account for the Maximum Achievable Control Technology 

(MACT) rules and are also reduced to account for point source emissions. 

Table 3-4 Solvent Cleaning SCC Emission Factors 

2415360000 270 lb/employee 

2415345000 24 lb/employee 

2415230000 29 lb/employee 

2415245000 9.8 lb/employee 

3.6 Fuel Marketing 

 VOC 

Truck Transit (SCC 2505030120) 

Gasoline tank trucks in transit are considered an evaporative loss of VOC 

emissions. This category consists of the VOC losses during the transit of 

gasoline in the trucks. The VOC calculation formula came from EIIP. Because 

gasoline may go through bulk gasoline plants before distribution to service 

stations, gasoline throughput figures are multiplied by 1.25 to estimate total 

gasoline transported. The total gasoline transported is multiplied with an EF of 

5.5 E-03 lb/1000 gallon transported for tank transit under loaded conditions and 

5.5 E-02 lb/1000 gallon transported for tank transit under unloaded conditions.
16

Filling Losses (SCC 2501060050) 

This category consists of the VOC loading losses from underground storage 

tanks during the transfer of fuel from the trucks. VOC calculations are based on 

ninety-five (95) percent submerged fill and five (5) percent splash for all counties. 

The VOC emissions calculation is also based on a ninety (90) percent rule 

effectiveness and a hundred (100) percent rule penetration. 

Standing Losses (SCC 2501060201) 

Breathing emissions losses from storage tanks occur during diurnal changes in 

barometric pressure, temperature and from gasoline evaporation. To calculate 

VOC emissions from the storage or breathing losses an EF of 1.000E+00 lb per 

1000 gallon gas throughput is used for all counties except of the 16 original nonattainment counties for ozone which employ a 1.000E-01 lb/1000 gallon of gas 

throughput. The value for the non-attainment counties was discussed with Bill 

Juris, Ohio EPA-DAPC and familiar with Ohio’s gasoline dispensing facilities 

(GDF) VOC regulations and practices.

Gasoline Distribution Stage 2 (SCC 2501060100 & 250106103) 

Vehicles refueling at service stations are the source of VOC emissions as vapors 

are displaced from automobile tanks during filling (2501060100) and from 

spillage (2501060103) of gasoline. The quantity of displaced vapors is based on 

gasoline throughput and is affected by gasoline temperature, gasoline volatility 

and, most importantly, by the presence of vapor recovery equipment. Stage II 

vapor recovery equipment is required at all service stations in the 16 original nonattainment counties for ozone that market in excess of 10,000 gallons per month. 

The VOC emissions factor for filling operations is 1.0E+01 lbs/1000 gallons. For 

the 16 counties that are subject to controls, a control efficiency of ninety-five (95) 

percent with ninety (90) percent rule effectiveness and a ninety (90) percent rule 

penetration is used in the calculation of emissions. The VOC emissions factor 

for spillage is 0.7 lbs/1000 gallons of gasoline for the 72 unregulated counties 

and 0.4 lbs/1000 gallons of gasoline for the controlled counties. 

Since the actual gallons of gasoline sold in each county could not be obtained, 

the methodology uses the vehicle miles traveled (VMT) data and the State’s 

consumption of gasoline to apportion the gasoline consumption within a county. 

3.7 Graphic Arts (SCC 2425000000) 

 VOC 

This area source includes printing of newspaper, books, magazines, fabrics and 

other materials. VOC emissions from this category are calculated using Ohio’s 

population5

 rather and the per capita emissions factor for VOC of 1.3 lb/year. 
17

3.8 Hospital Sterilizers (SCC 2850000010) 

 VOC 

Small amounts of ethylene oxide (EO) are used in sterilization of hospital surgical 

equipment and plastic devices that cannot be sterilized by steam. EO is used as 

a sterilizer because of its potency and effectiveness in destroying pathogens 

without damaging the integrity of the device. The methodology used to calculate 

EO emissions in Ohio called for the number of beds in each hospital size to use 

the appropriate EF. Based on national sales of EO in 2002, Ohio’s EO 

emissions are calculated to be 7.3 tons (based on Ohio’s share of hospital beds 

of 3.5 percent). 

3.9 Industrial Rubber/Plastics (SCC 2430000000) 

 VOC 

This category is calculated using employment3

 data for each county for the 

following North American Industry Classification System (NAICS): 

31332 32613 32614 32615 32616 32621 

32622 316211 325991 326113 326121 326122 

326191 326199 326291 326299 335121 339991 

A VOC EF of 203 lbs/employee is recommended to estimate the area source 

VOC estimate. Even after subtracting the point source VOC contribution (1116 

annual tons of VOC), this category would have been the highest category of 

emissions. After raising this issue with other states in the LADCO region, it is 

decided that the emissions factor has a high degree of uncertainty and it will 

significantly skew the overall VOC estimate from the area source categories. This 

category is left out from the emissions table but it is kept here for documentation. 

3.9 Industrial Surface Coating 

 VOC 

This area source contains several categories as listed below in Table 3-5. The 

appropriate NAICS codes are used for each category, shown in Table 3-6, to 

obtain employment data3

 from Bureau of Labor Statistics for each county. Net 

VOC emissions are calculated by subtracting the portion of VOC contributed from 

point sources. 
18

Table 3-5 Categories included in Area Sources 

 CATEGORY SCC NAICS VOC EF 

Factory Finished Wood 2401015000 321 131 

Lb/employee/year 

Furniture and Fixtures 2401020000 337 944 

Lb/employee/year 

Metal Containers 2401040000 332431 6029 

Lb/employee/year 

Sheet, Strip and Coil 2401045000 332812 2877 

Lb/employee/year 

Machinery & Equipment 2401055000 333 77 Lb/employee/year

Large Appliances 2401060000 3352 463 

Lb/employee/year 

Electrical Insulation 2401065000 334 290 

Lb/employee/year 

Automobiles (new) 2401070000 3361 794 

Lb/employee/year 

Other Transportation 

Equipment 2401075000 336 35 Lb/employee/year

Marine Coatings 2401080000 3366 308 

Lb/employee/year 

Other Product Coatings 2401090000 339 0.6 Lb/person/year 

High Performance 

Coatings 2401100000 811 0.8 Lb/person/year 

Other Special Purpose 2401200000 NOT DONE 0.8 Lb/person/year

Table 3-6 NAICS Codes Used for Area Sources 

Automobile Repair 488490, 441110, 441120, 4471, 441222, 441210, 

81111 

Manufacturing 337, 331, 332, 333, 335, 336, 334, 339 

Electronics and Electrical 335 

Other 337, 337, 331, 332, 333, 335, 336, 334, 339, 

488490, 441110, 441120, 4471, 441222, 441210, 

8111 

3.10 Municipal Solid Waste (SCC 2620030000) 

 VOC 

The methodology for methane gas emissions from landfills requires the tonnage 

deposited in the landfills for the last 25 years. However, Ohio EPA’s Division of 

Solid and Infectious Waste’s input data only spanned 20 years. Therefore, any 

landfill which did not record or report its waste intake for that period was not 

included in the database. Landfills with controls are identified as having flares. 

The preferred method is used which is based on landfill capacity and tonnage 

input of waste and the number of years the landfill operated and the number of 
19

years it has been closed. A seventy five (75) percent collection efficiency and a 

ninety-five (95) percent control efficiency are used per AP-42 Compilation of Air 

Pollutant Emission Factors. 

The toxic pollutants are calculated using the methane production rate and the 

EIIP calculation formula that involves the compound molecular weight and the 

co-disposal factor. The VOC emissions are equal to the emissions from all toxics 

minus methylene chloride, mercury, and perchloroethylene (PERC.) 

3.11 Portable Fuel Containers 

 VOC 

 RESIDENTIAL 2501011010 / COMMERCIAL 2501012010 

This area source’s VOC is the sum of emissions obtained from both commercial 

and residential containers. The residential and commercial container total 

emissions for the year are based on 250 days per year and include losses from 

refueling vapor displacement, permeation, diurnal, equipment refueling spillage, 

and transport-spillage. Emissions estimates are based on population2

 and 

consistent with California’s approach. Although the California methodology 

generates rather high emissions estimates, it is the only available estimate at the 

time of generating the 2002 inventory. 

3.12 POTW (SCC 2630020000) 

 VOC 

Ohio EPA’s Division of Surface Water does not review minor flows because they 

are not mandated by U.S. EPA. Therefore, Ohio’s wastewater flow data only 

represents eighty (80) percent of the total flow for this area source category. A 

twenty (20) percent increased flow is added to compensate for Publicly Owned 

Treatment Works (POTW) facilities which are not part of Ohio’s database. The 

VOC emissions factor is based on the Pennsylvania (PA) factor of the 1996 

Protocol. 

The 1996 EIIP methodology only offered EF for HAPs. Ohio’s VOC emissions 

for this category are calculated based on an EF obtained from the PA 1996 

Protocol which was the factor being used at the time of this inventory. 

3.13 Traffic Markings (SCC 2401008000)

 VOC

The number of lane miles per county is obtained from Ohio’s Department of 

transportation. The national gallon of traffic markings are apportioned to the 

state using the ratio of state dollar disbursements in relation to the national 

disbursement. The county level apportionment of paint2 is made using the 

number of lane miles. The VOC factor (3.36 lb/gal) is calculated based on Ohio's 

assumption of ninety (90) percent water based and ten (10) percent oil based 

paint. 
20

3.14 Human Cremation (SCC 2810060100) 

 NOX

Not all Ohio counties possess a crematory so only those counties with 

crematories are used to calculate the number of cremations. These numbers are 

adjusted to account for the cremation of bodies which are brought in from out of 

county since the calculations are based on number of deaths per county2. Ohio 

has an eighteen (18) percent cremation rate. Particular matter (PM) emissions 

are calculated for this category but the methodology did not call for the 

calculation of NOX emissions so they are not calculated. Furthermore, since 

current NOX EF in Ohio’s crematory permits vary significantly, the EIS program 

will develop a less variable one for future use in inventory NOX calculations. 

3.15 Industrial Fuel Combustion 

 VOC & NOX

Industrial Distillate Oil Combustion (SCC 2102004000) 

Ohio’s fuel consumption is apportioned per county based on the county’s 

population5

. The area source VOC and NOX emissions are calculated and 

adjusted to subtract the emissions due to point sources. A heating value of 140 

mmbtu/1000 gallon is used and 4,795,000 barrels are consumed in 2002. 

[MMBTU stand for Million British Thermal Units]. 

Industrial Residual Oil Combustion (SCC 2102005000) 

Ohio’s fuel consumption is apportioned per county based on the county’s 

population5. The area source VOC and NOX emissions are calculated and 

adjusted to subtract the emissions due to point sources. There are 1,806,000 

barrels consumed and a heating value of 140 mmbtu/1000 gallon is used. 

Industrial Natural Gas Combustion (SCC 2102006000) 

Ohio’s fuel consumption is apportioned per county based on the county’s 

population5

. The area source VOC and NOX emissions are calculated and 

adjusted to subtract the emissions due to point sources. 

3.16 Residential Fuel Combustion 

 VOC & NOX

Residential Coal Combustion (SCC 2104001000) 

Ohio’s household consumption of coal is apportioned per county based on 

county population5

. NOX and VOC emissions are calculated using EF of 9.1 and 

10 lb/ton of coal respectively. 

Residential Distillate Oil Combustion (SCC 2104004000) 

Ohio’s household consumption of distillate oil is apportioned per county based on 

county population5. NOX and VOC emissions are calculated using EF of 18 and 
21

0.71 lb/1000 gallons distillate fuel respectively. A heating value of 140 

mmbtu/1000 gallon is used. 

Residential Liquid Petroleum Gas Combustion (LPG) 

(SCC 2104007000) 

Ohio’s household consumption of LPG is apportioned per county based on 

county population5

. NOX and VOC emissions are calculated using EF of 13 and 

0.49 lb/1000 gallons LPG respectively. There are 11,432 barrels estimated to be 

used in 2002. 

Residential Natural Gas Combustion (SCC 2104006010) 

Ohio’s household consumption of LPG is apportioned per county based on 

county population5. NOX and VOC emissions are calculated using EF of 94 and 

5.5 lb/MMSCF respectively. [MMSCF stands for Million Standard Cubic Feet]. 

Residential Wood Combustion 

VOC and NOX emissions from this area source are estimated for seven types of 

equipment that may be used for residential heating involving wood. They are 

listed below with the appropriate SCC: 

Fireplaces without inserts 2104008001 

Fireplaces with inserts catalytic (non-U.S. EPA cert) 2104008002 

Fireplaces with inserts non -catalytic 2104008003 

Fireplaces with inserts catalytic (U.S. EPA cert) 2104008004 

Wood stoves – Conventional 2104008010 

Woodstoves – Catalytic 2104008030 

Wood stoves – Non catalytic 2104008050 

The number of Ohio homes with fireplaces are adjusted for those that burn wood. 

The following assumptions are applied to those adjusted homes: 

92 percent of wood combusted in non-certified units 

5.7 percent of wood combusted in non-catalytic units 

2.3 percent of wood combusted in catalytic units 

A state consumption value is applied which is apportioned to each county based 

on a county’s population. Table 3-7 shows the EF used for each of the seven 

types of wood burners which make-up this category: 
22

Table 3-7 Emission Factors Used for Wood Burners included in Area 

 Sources 

SCC 2104008002 2104008003 2104008004 

SCC 2104008010 2104008050 2104008030 

SCC 2104008001 

RAPIDS Code Non-Certified Non-Catalytic Catalytic Units 

VOC 53 12 15 Lb/ton 

NOX 2.80E+00 2.80E+00 2.00E+00 Lb/ton 

3.17 Structure Fires (SCC 2810030000) 

 VOC & NOX

This area source is considered a combustion source for VOC and NOX emissions 

which is calculated using EF of 11 and 1.4 lb/ton burned respectively. The 

residential and commercial structures fires for each county are tabulated and a 

fuel loading per fire EF of 1.15 ton/fire is applied. 

3.18 Miscellaneous Categories 

Although the area sources described above are the categories which contribute 

VOC & NOX emissions into Ohio’s ambient air, other area sources are calculated 

as well. These additional sources are listed below and contribute the associated 

pollutants into Ohio’s air. 

Dry Cleaning Perchloroethylene 

Lamp breakage Mercury 

The following area sources are attempted to be calculated but due to insufficient 

Ohio data available or unreliable emissions factors, they remain incomplete. 

Asphalt Paving VOC 

Forest Fires VOC & NOX

Gas & Oil Production VOC 

Open Burn VOC 

3.19 References 

1. Documentation For the 2002 Non-Point Source National Emission Inventory 

For CAPS and HAPS. U.S. Environmental Protection Agency. Emissions 

Factor and Inventory Group. E.H Pechan and Associates, Inc. January 2004. 

2. United States Census Bureau. Population Division. 

http://eire.census.gov/popest/data/counties/tables/CO-EST2002/COEST2002-01-39.php 

 (Accessed 2003) 
23

3. United States Census Bureau. County Business Patterns. 

http://censtats.census.gov/cbpnaic/cbpnaic.shtml

 (Accessed 2003) 

Pesticides - Agricultural and Non-Agricultural. U. S. Environmental Protection 

Agency. Emissions Inventory Improvement Program. Eastern Research Group, 

Volume III. Chapter 9, June 2001. 

Agricultural Chemical Use. U. S. Department of Agriculture. National 

Agricultural Statistics Service. 

http://usda.mannlib.cornell.edu/reports/nassr/other/pcu-bb/agcs0503.txt 

(Accessed 2003) 

Telephone conversation with Diane Roll. Ohio Department of Agriculture, 

Columbus, Ohio. Percentage of active ingredients and method of application. 

Daily Vehicle Miles Traveled Reports. Ohio Department of Transportation, Office 

of Technical Services. http://dot.state.oh.us/techservsite/availpro/Road_ 

Infor/KDVMT/kDVMT.htm (Accessed 2003) 

Motor Vehicle Fuel Tax. Ohio Department of Taxation. www.state.oh.us/tax

(Accessed 2003) 

Advancing Health in America Guide. Health Forum. American Hospital 

Association. 2001-2002 

Documentation for the Draft 1999 National Emissions Inventory (Version 3.0) For 

Criteria Air Pollutants and Ammonia. Area Sources. E. H. Pechan & Associates, 

Inc. March 3, 2003 

Compilation of Air Pollutant Emission Factors, Fourth Edition and Supplements, 

AP- 42, U.S. Environmental Protection Agency, Research Triangle Park, NC, 

September 1985 landfill.

Landfills. U. S. Environmental Protection Agency. Emissions Inventory 

Improvement Program. Eastern Research Group Volume III: Chapter 15. 

January 2001. 

Ohio EPA, Division of Solid & Infectious Waste. Columbus, Ohio. 

California’s Portable Gasoline Container Emissions Inventory. Air Resources 

Board Mobile Source Control Division. California Air Resource Board Inventory 

method (September 23, 1999). http://www.arb.ca.gov/homepage.htm. (Accessed 

2003). 
24

Spreadsheet formulation provided by “Buzz” David Asselmeier, Air Quality 

Planning Section, Inventory Group, Springfield, Illinois. 

Ohio EPA Division of Surface Water. Columbus, Ohio. 

Paint and Allied Products: 2002. U.S. Census Bureau. U.S. Department of 

Commerce. Economics and Statistics Administration. 

http://www.census.gov/industry/1/ma325f02.pdf 

(Accessed 2003) 

Highway Statistics 2002. Federal Highway Administration. U. S. Department of 

Transportation. http://www.fhwa.dot.gov/policy/ohim/hs02/sf2.htm 

(Accessed 2003) 

Ohio Department of Transportation. Columbus, Ohio. 

Cremation Association of North America. 

http://www.cremationassociation.org/docs/Web01Prelim.pdf (Accessed 2003) 

State of California Air Resources Board Test Report 

http://www.arb.ca.gov/homepage.htm (Accessed 2003) 

Industrial Sector Energy Price and Expenditure Estimates, 1970-2001, Ohio. 

Energy Information Administration. U. S. Department of Energy. 

http://www.eia.doe.gov/emeu/states/sep_prices/ind/pr_ind_oh.html

http://www.eia.doe.gov/emeu/aer/pdf/pages/sec1_27.pdf (Accessed 2003) 

Ohio Department of Commerce. State Fire Marshal Division. Columbus, Ohio. 

http://www.com.state.oh.us/odoc/sfm/firecont.htm (Accessed 2003) 
25

SECTION 4 

MARINE, AIRCRAFT and RAIL (MAR) SOURCES 

MAR sources are those non-road sources which are significant enough in terms 

of emissions to be considered separately from the rest of the non-road sources. 

The MAR inventory consists of commercial marines, aircraft and locomotive 

sources. The marine and locomotive inventory is generated by Environ1

 under 

contract with LADCO and the aircraft inventory is generated by U.S. EPA. 

4.1 Marine Vessel Sources 

Commercial marines consist of several different categories of vessel types and 

for each category there are unique activity data sources, engine types and 

emissions rates. A summary of commercial marine activity categories and data 

sources is shown at Table 4-1. 

Table 4-1 Summary of Commercial Marine Activity Categories and Data 

 Sources 

Commercial 

Marine Activity 

Spatial Range Activity Estimation Data Source 

Large Deep Draft Near Port Ports and Army Corps of Engineers 

Large Deep Draft Mid Lake Army Corps of Engineers 

Barge Traffic Inland Rivers Tennessee Valley Authority Fuel 

Consumption Estimation 

Barge Traffic Lake Traffic Army Corps of Engineers Freight 

Carried 

Tug Near Port Coast Guard Vessel List and 

Selected Surveys 

Ferries Regular Route Coast Guard Vessel List and 

Selected Surveys 

Excursion Near Home Port Coast Guard Vessel list 

Dredging Area by Contract Army Corps of Engineers Contracts 

Commercial Fishing Dock State Registration 

Military Near shore and 

Mid-Lake 

Coast Guard Fuel Purchases 

The procedure that is followed in estimating emissions for each commercial 

marine category or boat type is documented by Environ1

. The summary of 

commercial marine emissions estimate for Ohio is 248 tons of VOC and 10,307 

tons of NOX. This is significantly lower than what is estimated by NEI for 1999 

which was 1376 tons of VOC and 44,020 tons of NOX. 
26

4.2 Locomotive Sources 

Locomotives are usually the most important source of NOX from non-road 

engines. This category is especially important for Ohio because the State is an 

important rail center. Rail activity is typically broken into five subcategories. 

These subcategories are listed in Table 4.2. 

Table 4.2 Rail Categories 

SCC Description Comment 

2285002006 Class I operations Norfolk Southern (NS), CSX 

2285002007 Class II/III operations Regional and local railroads 

2285002008 Passenger Trains AMTRAK 

2285002009 Commuter Lines METRA 

2285002010 Yard Operations Class I yard rail and small 

switching railroads 

Because the Class I railroads are expected to be the most significant rail 

operations in most areas, every Class I railroad is asked for information about its 

rail operation. Norfolk Southern (NS) and CSX provided estimates for their fuel 

consumption by rail line for line-haul estimates but are unable to detail their 

switching rail activity. They provided activity by county in terms of ton-mile of 

freight movement and estimated fuel consumption using typical system-wide fuel 

consumption per ton-mile. The Class II rail estimate which is of lesser 

importance than the Class I rail is based on national consumption and an 

employee emissions factor of 10,000 gallons per employee. The passenger rail 

estimate is based on information provided by AMTRAK on the weekly schedule 

of trains and emissions are based on 2.35 gallons per train-mile fuel 

consumption. Emissions factors and detailed calculation procedures are 

documented on the Environ1 study and it is referenced at the end of this section. 

4.3 Aircraft Vessel Sources 

U.S. EPA contracted with ERG Consulting Firm http://www.erg.com/ to generate 

this inventory. The estimate is based on information collected by the Federal 

Aviation Administration (FAA) on published (landing and take-off) LTO cycle by 

engine type for each airline and major airport in the state. The LTO is multiplied 

by emissions factors developed by the International Civil Aviation Organization 

(ICAO). Finally, the LTO data are combined and entered into the FAA Emissions 

and Dispersion Modeling System (EDMS), which is designed to calculate aircraftspecific emissions. 

For all of the above three categories, LADCO processed the data in EMS 2003 to 

calculate summer day emissions for VOC and NOX. The tables are provided as 

an attachment. 
27

4.4 References 

LADCO Non-road Emissions Inventory Project for Locomotive, Commercial 

Marine and Recreational Marine Emission Sources, prepared by Christian E. 

Lindhjem, ENVIRON International Corporation, September 8. 2004. 
28

SECTION 5 

ON-ROAD SOURCES 

A mobile source of air pollution is a self-propelled or portable emitter of air 

pollutants, and mobile source emissions are those generated by the engines or 

motors that power such sources. Most mobile sources, except jet or turboprop 

aircraft, are powered by internal combustion (IC) piston engines, and nearly all 

use liquid fuels. 

Gaseous fuels, such as compressed natural gas (CNG) or liquefied petroleum 

gas (LPG), had only a very small fraction of the motor fuel market in Ohio in 

2002. Solid fuels have not been used by mobile sources in significant amounts 

since railroads retired their coal-powered steam locomotives in the 1950s. 

5.1 Categories of Mobile Sources 

For inventory and planning purposes, mobile sources are divided into two major 

categories. 

1. On-highway mobile sources, i.e., motor vehicles such as cars, vans, 

trucks, buses and motorcycles used for transportation of goods and 

passengers on roads and streets. 

2. Off-highway (usually referred to as non-road) mobile sources including: 

• Modes of powered transportation that do not use roads, such as 

aircraft, trains, ships and boats, and motor vehicles used off-road. 

• Self-propelled or portable motorized machines or equipment not used 

for transportation, ranging from construction equipment and farm 

tractors to lawnmowers and hand-held power weed choppers. 

Mobile Sources: All on-highway mobile sources are self-propelled. 

Non-road Mobile Sources: Some non-road mobile sources (e.g., farm tractors), 

are self-propelled, but many non-road sources are not. A gasoline-powered 

chain saw is a familiar example of a non-self-propelled non-road mobile source. 

Stationary Sources: Not all movable or portable emission sources are mobile 

sources, however. A small truck-portable cement or hot-mix asphalt plant, for 

example, may be set up near a construction or road-building site. Such plants 

are classified as stationary sources, not mobile sources for two reasons: (1) they 

may operate for weeks or months at a single location, and (2) the trucks that 

move the plants do not supply power for them. 
29

NOTE: Not all IC or turbine engines are mobile sources. Fixed IC engines, such 

as those that power pipeline compressors or standby generators in electricity 

plants and elsewhere, are also classified as stationary sources. 

5.1.1 Categories and Components of Mobile Source Emissions 

There are three categories of mobile source emissions: 

• Exhaust or tailpipe emissions, which result from the combustion of fuel in 

the source’s engine 

• Evaporative emissions, which result from evaporation of fuel from the 

engine or it’s fuel system 

• Refueling emissions 

Exhaust Emissions: Are the result of fuel combustion and occur only when the 

engine is running. 

Evaporative emissions: Are VOC based only and are continuously emitted 

from an engine’s fuel system, whether the engine is running or not. Gasoline is a 

very volatile fuel, so total VOC emissions from gasoline powered vehicles have a 

large evaporative component. Diesel and jet fuels are of very low volatility, so 

evaporative emissions from diesel and turbine engines are a much smaller part 

of their total VOC emissions. Evaporative emissions for CNG or LPG powered 

vehicles are negligible because their fuel tanks and systems are of necessity, 

sealed. 

Evaporative and exhaust VOC emissions can be calculated separately for most 

mobile source categories, but in this inventory these two components are 

combined into total VOC. Evaporative emissions do not include VOC emissions 

that occur during refueling. 

Refueling Emissions: Are the third category of mobile source emissions. 

Refueling emissions are entirely VOC. Although they result from the evaporation 

of fuel, they are distinct from, and not directly related to, evaporative emissions 

as defined above. 

Refueling emissions have two subcomponents: 

• Displacement emissions. These occur when new fuel is transferred into a 

partly filled tank--be it a service station storage tank, a portable fuel 

container (gas can), or a vehicle or engine’s fuel tank; displacing the air in 

the tank and forcing that vapor-rich air out the inlet pipe or other vent. 

There are two stages of displacement emissions: 
30

o “Stage I” emissions occur when the underground storage tanks at a 

service station are being refilled; 

o “Stage II” emissions occur when a motor vehicle (or gas can) is 

being refueled. 

NOTE: These emissions are covered in, “Area Sources,” section 3.6. 

• Spill emissions. These occur when drops of fuel drip or splash on the 

ground during or after refueling and evaporate away. 

5.2 Ohio On-Highway Mobile Source Inventory 

The inventory of on-highway mobile source emissions was developed in 

conjunction with the Ohio Department of Transportation (Ohio DOT), LADCO, 

U.S. EPA, and the Ohio EPA. Estimates of the amounts of NOx and VOC are 

reported by county in tons per day. Emissions are reported for a typical ozone 

season weekday in the summer of 2002. 

5.2.1 Emission Inventories Developed with MOBILE6.2 Model 

MOBILE6.2 Overview: 

MOBILE6.2 is a computer program that estimates hydrocarbon (HC), carbon 

monoxide (CO), NOx, exhaust particulate matter (which consists of several 

components), tire wear particulate matter, brake wear particulate matter, sulfur 

dioxide (SO2), ammonia (NH3), six hazardous air pollutant (HAP), and carbon 

dioxide (CO2) emission factors for gasoline-fueled and diesel highway motor 

vehicles, and for certain specialized vehicles such as natural-gas-fueled or 

electric vehicles that may replace them. The program uses the calculation 

procedures presented in technical reports posted on U.S. EPA's MOBILE6.2 

Web page http://www.epa.gov/otaq/models.htm. 

MOBILE6.2 emission factor estimates depend on various conditions, such as 

ambient temperatures, travel speeds, operating modes, fuel volatility, and 

mileage accrual rates. Many of the variables affecting vehicle emissions can be 

specified by the user. MOBILE6.2 will estimate emission factors for any calendar 

year between 1952 and 2050, inclusive. Vehicles from the 25 most recent model 

years are considered to be in operation in each calendar year. 

5.2.2 MOBILE6 Defaults: 

MOBILE6.2 includes default values for a wide range of conditions that affect 

emissions. These defaults are designed to represent “national average” input 

data values. Users who desire a more precise estimate of local emissions can 

substitute information that more specifically reflects local conditions. Use of local 
31

input data will be particularly common when the local emission inventory is to be 

constructed from separate estimates of roadways, geographic areas, or times of 

day, in which fleet or traffic conditions vary considerably. 

A list of MOBILE6.2 input parameters is provided below. Most of these inputs are 

optional because the model will supply default values unless alternate data are 

provided. 

5.2.3 MOBILE6 Input Parameters 

• Calendar year

• Month (January, July) 

• Hourly Temperature 

• Altitude (high, low) 

• Weekend/weekday 

• Fuel characteristics (Reid vapor pressure, sulfur content, 

 oxygenate content, etc.) 

• Humidity and solar load 

• Registration (age) distribution by vehicle class 

• Annual mileage accumulation by vehicle class 

• Diesel sales fractions by vehicle class and model year 

• Average speed distribution by hour and roadway 

• Distribution of vehicle miles traveled by roadway type 

• Engine starts per day by vehicle class and distribution by hour 

• Engine start soak time distribution by hour 

• Trip end distribution by hour 

• Average trip length distribution 

• Hot soak duration 

• Distribution of vehicle miles traveled by vehicle class 

• Full, partial, and multiple diurnal distribution by hour 

• Inspection and maintenance (I/M) program description 

• Anti-tampering inspection program description 

• Stage II refueling emissions inspection program description 

• Natural gas vehicle fractions 

• HC species output 

• Particle size cutoff 

• Emission factors for PM and HAPs 

• Output format specifications and selections

5.2.4 MOBILE6 References 

The following publications provide much of the guidance for the preparation of 

the on-highway inventory. 
32

EPA-450/4-81-026d (Revised), now EPA/450-R-92-009, Procedures for 

Emission Inventory Preparation, Volume IV: Mobile Sources, December 

1992. Hereafter “Procedures Vol. IV”. The 1992 version is still the definitive 

document on inventories. If a previous edition is referred to, the fact will be 

noted as, for example, “the 1989 Procedures Vol. IV” or “Volume IV, 1989 

edition”. 

EPA420-R-03-010, User’s Guide to MOBILE6.1 and MOBILE6.2: Mobile 

Source Emission Factor Model, August 2003. This is the User’s Guide for 

the official MOBILE6.2.03 on-highway mobile source emission factor model 

and will usually be referred to as the M6.2 (or simply M6) User’s Guide (UG). 

The M6 model in its various versions was developed and published by 

Assessment & Modeling Division (AMD) of the National Vehicle & Fuels 

Emissions Laboratory (NVFEL) in Ann Arbor, Michigan. The NVFEL is part of 

U.S. EPA’s Office of Transportation & Air Quality (OTAQ), formerly the Office 

of Mobile Sources (OMS). 

Technical Guidance on the Use of MOBILE6 for Emission Inventory 

Preparation, August 2004. Hereafter the M6 “Technical Guidance 

[Document]” or “TGD”. The TGD is the primary source of guidance on M6 

inputs and an invaluable adjunct to the M6 User’s Guide. 

U.S. EPA document “Frequently Asked Questions on MOBILE6”, 16 

January 2002. Hereafter [M6] “FAQ”. This document was published along 

with the M6 TGD. 

U.S. EPA memo, “Policy Guidance on the Use of MOBILE6 for SIP 

Development and Transportation Conformity”, dated 18 January 2002, 

from John Seitz, Director of OAQPS, and Margo Oge, Director of OTAQ, to 

Regional Air Division Directors. 

5.3 Ohio’s Alternate Data for MOBILE6.2 

5.3.1 Vehicle Registration Distribution by Age 

Overview: 

The vehicle age distribution determines the fraction of vehicles operating within 

each emissions control requirement standard and the deterioration of the 

emission control technology. 

Emission rates vary widely between new and older vehicles. Thus, even small 

changes in fleet age, particularly for older vehicles, may result in large changes 

in emission totals. 
33

The MOBILE6.2 model requires estimates of a distribution of registered vehicles 

by age and vehicle category for current and future years. MOBILE6.2 default 

values were developed using national level vehicle registration data by age and 

class for July 1, 1996. U.S. EPA developed a methodology to convert the July 1, 

1996 registration profile into a general registration distribution by age and by 

vehicle category for some six composite (gasoline and diesel) vehicle types plus 

motorcycles. To project future changes, U.S. EPA evaluated general sales 

growth and vehicle scrappage trends for the total light-duty vehicle in-use fleet 

and the total heavy duty vehicle in-use fleet, and made minor adjustments, where 

possible, to reflect some of the differences between vehicle categories. 

Description: The MOBILE6.2 model requires estimates of a distribution of 

registered vehicles by age and vehicle category for current and future years. 

Ohio EPA chose to use local vehicle registration data provided by the Ohio 

Bureau of Motor Vehicles (BMV) to LADCO to develop these inputs. 

Method Applicability: This approach is most applicable in areas where there 

are significant differences in the local vehicle fleet age distribution relative to the 

national average. 

Data Sources and Procedures: This approach involves using local vehicle 

registration data. This is typically available at the county level, but may also be 

applied using statewide data from the state motor vehicle registration office. The 

fleet age should be representative of the vehicle fleet over the small urban or 

rural area under question. If the pollutants of concern are ozone precursors. 

Advantages: 

• Uses locally specific registration data, which is likely more representative 

of the local area than the national default. 

• Requires minimal additional resources, particularly if data is readily 

available at the county or local level from the State department of motor 

vehicle registration. 

• Recommended by U.S. EPA and generally is encouraged as a preferred 

approach over the national default approach.

Details: 

Meredith Weatherby of ERG, a subcontractor to LADCO, sent Ohio EPA the files 

that completed the Ohio registration distribution calculations. 

These files contained the registration distribution fractions for each county code 

as well as for the entire state. Each county file was in a format that was directly 
34

useable in the MOBILE6.2 model runs. Additional files contained the fractions as 

well as the numbers of vehicles for each county in a space-delimited file. 

5.3.2 Daily Vehicle Miles Traveled (DVMT) 

Overview: 

Ohio DOT provided the Daily Vehicle Miles Traveled (DVMT) data. DVMT is a 

simple mechanism to measure how much traffic is flowing along a roadway 

during an average 24 hour period. This simple formula multiplies Average Annual 

Daily Traffic (AADT) by the length of the roadway. For example; if a roadway was 

2 miles in length and the AADT was 4000 vehicles per day the DVMT would be 

computed by multiplying 2*4,000 =8,000 or 8,000 DVMT. 

County-by-county DVMT is computed using Ohio DOT roadway information files 

and the annual Highway Performance Monitoring System (HPMS) summary 

reports. DVMT’s are computed for all of the Federal Functional Class (FC) 

categories within each of Ohio’s 88 counties. 

The AADT and roadway length information are very accurate for the state 

highway system (interstate, highway and state routes, ). For roadways that are 

not part of the state highway system, various representative counts were used, 

such as: railroad crossing counts, HPMS sample section counts etc. All traffic 

count data that was not collected during the current year has had a statewide 

growth factor applied that accounts for systematic growth. 

Given the previously mentioned methodologies, the DVMT data is more accurate 

on roads functionally classified as collector or above. 

Functional class categories: 

01 - Rural Interstate 

02 - Rural Principal 

Arterial 

06 - Rural Minor Arterial 

07 - Rural Major Collector

08 - Rural Minor Collector

09 – Rural Local 

11 - Urban Interstate 

12 - Urban Freeway & 

Expressway 

14 - Urban Principal Arterial 

16 - Urban Minor Arterial 

17 - Urban Collector 

19 - Urban Local 

For PDF web based tables of DVMT by county see: 

www.dot.state.oh.us/techservsite/availpro/Road_%20Infor/KDVMT/vmt2002.pdf 
35

Disclaimer by Ohio DOT: 

The above PDF web based tables contain the State of Ohio's adjusted county 

DVMT's and road mileage for the years 1990 - 2004. Please be aware that the 

numbers are estimates only. The factoring process used annual, estimated, and 

statewide ADT (average daily traffic) growth factors, derived from the output of a 

limited number of traffic counting stations around the state. Although the growth 

factors are available by functional class, they are more reliable for major roads 

such as interstates or expressways, which are relatively well-sampled, than for 

local roads or collectors. The numbers also do no allow for periodic, large-scale 

functional reclassification actions which reassign selected roads or road 

segments from one functional class to another. Ohio DOT therefore does not 

warrant the accuracy, completeness, or reliability of these estimates for your 

research. We also do not assume responsibility for any incorrectness that may 

occur. 

5.3.3 Speed Distribution Profile 

Overview: 

According to Mark Byram of Ohio DOT, the speeds that have been used to date 

for air quality analysis were developed by Chuck Gebhardt of Ohio DOT and 

Harry Judson of OHIO EPA for addressing “1 hour standards” conformity rules 

established due to 1990 emissions exceedances. No documentation was found 

in Ohio DOT’s files on the origin of these average speed values or how they were 

estimated. Therefore, staff believed that it was best to use the most recent 

available data to estimate average speeds. Year 2002 speed data was obtained 

from Ohio DOT’s Traffic Monitoring Section’s automatic traffic recorder data and 

summarized for comparison with space mean speeds from Ohio DOT’s travel 

time study done in 2001 (Statewide Travel Time Study, May 2001 by Greg 

Giaimo, Ohio DOT.) These speeds were compared with those developed for 

addressing the one hour standards. The graph below shows the comparison. 

Speeds Comparison

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

FC01

FC06

FC08

FC11

FC14

FC17

Functional Class

Speed

Average Speed

1990 Analysis

Speeds

2001 Speed Study
36

CAUTION: It should be noted that speeds on facilities falling in any one of the 

federal functional classifications vary greatly between roadways, between hour of 

the day, and day of the week. So these provide only very rough estimates of 

speed and should be used with caution. In addition, it is expected that these 

average statewide speeds are higher than the average speeds in the nonattainment areas because the non-attainment counties tend to be more 

populated and more congested. The document “Highway Vehicle Speed 

Estimation Procedures for Use in Emission Inventories”, September 1991 by Earl 

Ruiter or Cambridge Systematics Inc. is referenced by U.S. EPA’s documented 

procedures for emission inventory preparation. This document suggests post 

processing travel demand model traffic assignment results to estimate average 

speeds. 

The Ohio DOT Modeling & Forecasting Section recommends that Ohio’s travel 

demand forecasting models and Ohio DOT’s conformity analysis methods be 

used to establish the roadway mobile source portion of Ohio’s SIP budget to 

assure consistent methods are used for transportation conformity analysis and 

budgets. 

Research: 

Time Mean Sped-- Summarizing Automatic Traffic Recorder (ATR) Speed 

Data by Functional Class 

Year 2002 speed data for July 2002 was provided by the Traffic Monitoring (TM) 

Section as requested by the Modeling & Forecasting Section (MF). 

The TM section generated reports for each ATR in the state of Ohio, grouped the 

reports by federal functional class and provided the summary reports to the MF 

section. The report includes average speed for each day in July 2002, a 31 day 

period. The data was imported to a spreadsheet where a minimum speed, 

maximum speed and average speed over the 31 day period for all ATR’s located 

on a given functional class was computed, see Table 1 

Table 1 – Comparison of Average Daily speeds from ATR Data with Daily 1990 

Air Quality Speeds 

 Average Min. Avg 

Max. 

Avg. 1990 AQ

 Speed Speed Speed Speeds 

FC01 68.33810 53.9 76.3 57.3

FC02 60.14802 36.2 71.8 45.3

FC06 58.05665 53.5 62.1 39.9

FC07 57.06160 52.9 60.9 35.1

FC08 57.45161 55.2 59.3 30.5

FC09 57.45161 55.2 59.3 28.0

FC11 65.64372 49.7 73.0 46.3
37

FC12 63.89579 50.3 73.2 43.3

FC14 48.97748 31.3 70.1 18.9

FC16 34.52353 30.6 53.2 19.6

FC17 34.52353 30.6 53.2 19.6

FC19 _- _- _- 19.6

The ATR speeds represent our best estimate of “time mean speed”. The speeds 

represent the speed at a point in the middle of a roadway section and does not 

account for slowdowns and delays created by vehicles turning into driveways, 

stopping at intersections, slowing due to incidents, etc. 

Estimating SPACE MEAN SPEED by Functional Class 

Greg Giaimo generated average speed by urban and rural area facility types as 

shown in Table 2 Below. 

Table 2 Speed by Facility Type 

Information from Table 2 was used to estimate space mean speed by functional 

class by assigning federal functional classes as shown in Table 3 with 

consultation with Giaimo. Some speed classes were ignored based on 

Facility 

Type Facility Type Description 

Average 

Speed 

1rural freeway 64

 2rural arterial 53

 3rural 4+ lane collector 42

4rural 2 lane collector, flat 47

5rural 2 lane collector, hilly 44

6rural local, flat 46

7rural local, hilly 37

8rural local, township, flat 40

9rural local, township, hilly 30

11urban freeway 63

 12urban arterial 30

 13urban collector 30

16urban local 25

21cbd freeway 50

 22cbd arterial 23

 23cbd collector 21

26cbd local 12

41rural ramp, off 36

42rural ramp, on 44

51urban ramp, off 32

52urban ramp, on 46
38

recommendation by Giaimo because of the small number miles of those types of 

roadways. 

Table 3 – Functional Class Equivalents 

FT Facility Type 

Speed 

(mph) FunClass Equiv 

1 rural freeway 64 01 Rural Interstate 

2 rural arterial 53 02 06 - Principal & 06Minor Arterial

3 rural 4+ lane collector 42 Ignore 

4 rural 2 lane collector, flat 47 07 08- Major Collector, Minor 

5 rural 2 lane collector, hilly 44 Ignore 

6 rural local, flat 46 09 - local 

7 rural local, hilly 37 ignore 

8 rural local, township, flat 40 09 - local 

9 rural local, township, hilly 30 ignore 

11 urban freeway 63 11Urban Interstate & 12 EXPY 

12 urban arterial 30 14,16 Princ, Major, Minor Art 

13 urban collector 30 17 - Collector 

16 urban local 25 19 - local 

21 cbd freeway 50 11 &12 urban interstate, 50-55mph

22 cbd arterial 23 14,16 - Major&minorArt 

23 cbd collector 21 17 - Collector 

26 cbd local 12 19 – local 

The following formulas were used to estimate the speed: 

Where: 

S=Speed 

FT=Facility Type 

FC=Functional Class 

S(FC01) = S(FT1) 

S(FC02) = S(FT2) 

S(FC06) = S(FT2) 

S(FC07) = AVERAGE(FT3,FT4,FT8) 

S(FC08) = AVERAGE(FT3,FT4,FT8) 

S(FC07) = AVERAGE(FT6,FT8) 

S(FC09) = AVERAGE(FT6,FT8) 

S(FC11) = 0.91*S(FT11)+0.09*S(FT21) 

S(FC12) = 0.91*S(FT11)+0.09*S(FT21) 

S(FC14) = 0.94*S(FT12)+0.06*S(FT22) 

S(FC16) = 0.94*S(FT12)+0.06*S(FT22) 

S(FC17) = 0.94*S(FT13)+0.06*S(FT23) 

S(FC19) = 0.93*S(FT16)+0.07*S(FT26) 
39

Percentage splits for the urban federal functional classes (11trhu 19) were 

derived by summarizing VMT by Facility Types 1 to 26 using the statewide travel 

demand model. The results are shown in Table 4 along with speeds previously 

used for comparison purposes. 

Table 4 – Speed by Federal Functional Class 

1990 

Analysis 

2001 Speed 

Study 

 Speeds Speeds NOACA*

FC01 57.3 64.0 54.7

FC02 45.3 53.0 43.7

FC06 39.9 53.0 38.7

FC07 35.1 43.1 34.2

FC08 30.5 43.1 29.4

FC09 28 43.1- 

FC11 46.3 61.6 44.9

FC12 43.3 61.6 42

FC14 18.9 29.3 18.4

FC16 19.6 29.3 19.6

FC17 19.6 29.2 19

FC19 19.6 23.8- 

* From informal documentation found in files, labeled “Speeds From Bill Davis” 

Figure 1 - Speed Comparison Graphs 

Speeds Comparison

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

FC01FC02FC06FC07FC08FC09FC11FC12FC14FC16FC17FC19

Functional Class

Speed

Average Speed

1990 Analysis

Speeds

2001 Speed Study

Speeds

2001 Speed

Study Speed

from Bill Davis
40

Speeds Comparison

0

20

40

60

80

100

FC01FC06FC08FC11FC14FC17

RAMPS

Functional Class

Speed

Average Speed

Min. Avg Speed

Max. Avg. Speed

Gebhardt's Speeds

Spd Study Est

Speeds

Spd Study Greg Est

In discussions with James McQuirt, Greg Giaimo and Ansen Wu, it was decided 

that because there is no record of the origin of the speeds established for the 

1990 exceeded emissions/one hour emissions standard, Ohio DOT would be 

best served to use the speeds estimated from the speed study if the origin is well 

documented. 

Conclusion: 

It was decided by mutual agreement among individuals in the Modeling & 

Forecasting Section that these new space mean speed based average speed 

estimates were reproducible and defensible if documented and should therefore 

be the speeds used with HPMS VMT if any year 2002 emissions budget work is 

done using only HPMS VMT. 

Results: 

Speeds used in the speed distribution files from Ohio DOT for the 2002 inventory 

were taken from the 2001 space mean speed study. (See Table 4) 

 

Reference: 

“Draft Technical Memorandum Estimation of Average Speed by Functional 

Class for MOBILE6 Runs,” by Mark Byram, Ohio DOT, Office of Technical 

Services, May 26, 2004 
41

5.4 Ohio’s Non-Alternate (Default) Data for MOBILE6.2 

Per conversation with Mark Janssen at LADCO on 5/14/04, he recommended 

Ohio use the national defaults for the rest of the MOBILE6.2 inputs with the 

exception of providing an RVP value for Ohio. 

5.4.1 Ohio’s Fuel Characteristics 

Background: 

Tom Darlington of Hyper Anemo was contracted by LADCO to evaluate the fuel 

parameters at the county level. In a memo to Mike Koerber, at LADCO he 

states; 

 

“As a part of our project to evaluate the benefits of lower RVP in various 

nonattainment areas in the LADCO 5-state area, we obtained the LADCO 

county-by-county MOBILE6.2 inputs and reviewed the various fuel input 

commands. This memo reviews plots of those inputs, and requests that the 

various states verify these inputs. The inputs that we have selected to review 

have a direct bearing on the baseline RVP of the fuel in each of the counties, and 

thus the benefits of any lower RVP proposal such as 7 RVP.” 

Tom summarized his study saying, “Evaluation of the fuels inputs for the LADCO 

modeling system has shown perhaps a need to reevaluate some of the fuels 

inputs, so that the baseline VOC inventories are correct, and so that the benefits 

of RVP control will be accurately estimated. 

In particular, ethanol market fractions for Michigan, Wisconsin, Indiana, and Ohio 

should be developed by the states or LADCO and utilized. This will also involve a 

change in the July RVP waiver for these states. In addition, areas with RFG 

should be checked to ensure that the appropriate counties have RFG.” 

Process: 

Fuel data parameters were collected from Ohio’s MPOs and analyzed. 

Variations in data suggested the need to determine the source of input values. 

After considerable effort it was determined that the origins of input values were 

unclear. The reevaluation process resulted in establishing the following 

guidelines. 

Guidelines: 

• No MTBE (ether oxygenated fuel) in Ohio 

• 40 percent of Ohio's fuel is ethanol oxygenated with 10 percent oxygen 

content by volume 
42

• Reid Vapor Pressure (RVP) is 9.0 

• RVP waiver switch is 1.0 psi 

5.5 LADCO Data Processing 

LADCO processed Ohio’s data using the Emissions Modeling System 

(EMS-2003). A description of LADCO’s methodology should be 

forthcoming from LADCO in the near future. 
SIP INVENTORY 

MOBILE-EMISSIONS ESTIMATE 

(OZONE) 

FOR STARK COUNTY, OHIO 

May, 2012 

Revised August, 2012 

Prepared By: 

STARK COUNTY AREA TRANSPORTATION STUDY 

201 Third Street NE, Suite 201 

Canton, Ohio 44702 

This report is the product of a study financed in part by the US Department of Transportation, 

Federal Highway Administration, Federal Transit Administration and the Ohio Department of 

Transportation. The contents of this report reflect the views of the Stark County Area 

Transportation Study, which is responsible for the facts and the accuracy of the data presented 

herein. The contents do not necessarily reflect the official views or policy of the U. S. 

Department of Transportation. This report does not constitute a standard, specification, or 

regulation. 
Table of Contents 

1. Overview 3

2. Urban Travel Demand Models 5

3. Emission Factor Generation 7

4. Post Processing 15

Appendix A Interagency Consultation Documentation 

SCATS Ozone SIP Emmissions Estimates Page 2 
1. Overview 

This memorandum is intended to document the air quality analysis and underlying assumptions 

performed by the Ohio Department of Transportation (ODOT), Division of Transportation 

System Development-Modeling and Forecasting Section and the Stark County Area 

Transportation Study (SCATS) for the 8-hour ozone on-road mobile-source emissions 

inventories for the Canton-Massillon Metropolitan Statistocal Area (MSA) State Implementation 

Plan (SIP) revision in coordination with the Ohio Environmental Protection Agency (OEPA). 

The Canton-Massillon MSA is comprised of Stark County in northeastern Ohio. Although the 

MSA area also includes Carroll County, OEPA and USEPA concurred that only Stark County is 

needs to be analyzed within the MSA as Carroll County is rural in nature with a population of 

less than 30,000. Stark County is designated as attainment for the 8-hour Ozone Standard. 

SCATS serves as the Metropolitan Planning Organization (MPO) for Stark County. 

The ODOT Modeling and Forecasting section performed the MOVES runs to generate traveldemand-model-based emission factors as well as the air-quality analysis for Stark County. 

Latest Planning Assumptions 

The ozone inventory runs meet the latest planning assumption requirement. As discussed in 

Section 2 of this report, the modeling process used to develop the MPO emissions is calibrated 

using the latest population and land-use data available and is validated using corresponding 

traffic-count data. Currently, the travel demand model is validated for the year 2000. 

U.S. EPA’s most recent emissions software, MOVES, is used for all mobile-source emission 

analyses with MOVES inputs being established at various interagency consultations between 

January, 2012, and May, 2012, (See Appendix A)

Finally, the regional emissions analysis includes emissions for Hydrocarbons (HC) and Nitrogen 

Oxides (NOX). 

SCATS Ozone SIP Emmissions Estimates Page 3 
On-Road Mobile Emission Summary 

Table 1 presents a summary of emissions for the SCATS Region for the required precursors HC 

and NOX for the requested scenarios: 2002 base year, 2004 attainment year, 2009 interim-budget 

year, and 2018 maintenance-budget year. The remainder of the document focuses on the 

assumptions behind the analysis. 

Table 1 – SCATS Region On-Road Mobile Emissions 

VMT or HC NOX

TYPE YEAR # Vehicles (tons) (tons)

LINK 2002 8,196,644 8.401 27.788

VEHICLE 2002 474,615 15.862 7.200

INTRA-ZONAL 2002 48,465 0.075 0.197

TOTAL 8,245,109 24.339 35.185

LINK 2004 8,462,377 7.304 25.595

VEHICLE 2004 477,279 15.192 7.367

INTRA-ZONAL 2004 48,934 0.064 0.178

TOTAL 8,511,311 22.559 33.141

LINK 2009 8,544,607 4.071 17.657

VEHICLE 2009 483,940 12.560 6.867

INTRA-ZONAL 2009 52,473 0.039 0.135

TOTAL 8,597,080 16.671 24.659

LINK 2018 8,864,133 1.416 6.084

VEHICLE 2018 495,933 6.413 3.761

INTRA-ZONAL 2018 51,921 0.013 0.044

TOTAL 8,916,054 7.842 9.888

SCATS Ozone SIP Emmissions Estimates Page 4 
2. Urban Travel Demand Models 

SCATS maintains regional travel demand forecasting models for use in the urban transportation 

planning process. The models employ the traditional four step modeling process to project 

existing and future traffic volumes and travel patterns on the regional transportation network. 

The four step process consists of trip generation, trip distribution, modal split, and route 

assignment. Output from the urban models is link-by-link directional 24-hour traffic volumes. 

In 2000 SCATS, in cooperation with the Ohio Department of Transportation (ODOT), updated 

its travel demand model. The new model includes changes to the model interface to Cube 

Voyager, and improves model functionality. The changes primarily affected trip generation 

distribution functions in the SCATS region. 

Networks 

The SCATS modeled network accurately reflects projects in the Transportation Improvement 

Program (TIP) and Long-Range Transportation Plan (LRTP). Project lists can be found online 

as listed below: 

TIP 

http://www.co.stark.oh.us/internet/docs/rpc/SCATS%202012%20-

15%20TIP%20Final%20Draft.pdf

Long-Range Transportation Plan 

http://www.co.stark.oh.us/internet/docs/rpc/2030%20Transportation%20Plan%20Update.

pdf

Landuse and Socio-economic Data 

The SCATS socio-economic variables reflect the current and expected future regional land uses. 

The socio-economic variables were developed for the May 2009, 2030 LRTP Update and are 

based on 2000 Census variables and 2030 county-level Ohio Department of Development 

population projections. 

Independent variables are available for the 3 analysis years (2004, 2009, and 2018) and the travel 

demand model has the ability of interpolating data for any year between available data sets. A 

summary of SCATS’ socio-economic data is available in Table 2. As can be seen from the table, 

population, households, and employment are expected to make modest gains between 2004 and 

2018. 

SCATS Ozone SIP Emmissions Estimates Page 5 
Table 2 – SCATS Socio-Economic Variables 

2002 2004 2009 2018

Population 384,889 385,483 386,965 389,728

Households 150,643 145,290 133,763 157,447

Employment 168,699 177,196 197,518 214,350

SCATS Ozone SIP Emmissions Estimates Page 6 
 3. Emission-Factor Generation

Attainment and Budget Years 

Using MOVES, emission factors were generated for the attainment year, 2004, the interimbudget year, 2009, and the maintenance-budget year, 2018, to represent the programs being 

implemented in the SCATS Region. Programs and corresponding MOVES parameters were 

developed in consultation with the OEPA. 

Technical Details 

Table 3 summarizes the settings used in the MOVES run specification file and the MOVES 

County-Data Manager. Further details in specific inputs that are not using default values are 

provided below. 

Table 3 – MOVES Inputs 

RunSpec Parameter Settings 

MOVES Version MOVES2010A 

Scale Custom Domain 

MOVES Modeling Technique Emission Factor Method 

Rates per Profile (grams/vehicle) 

Rates per Distance (grams/mile) 

Rates per Vehicle (grams/vehicle) 

Time Span Time Aggregation: Hour 

1 Month representing average summer temperatures 

All hours of day selected 

16 speed bins 

Weekdays only 

Geographic Bounds Stark County 

Vehicles/Equipment All source types, gasoline and diesel 

Road Type All road types including off-network 

Pollutants and Processes Total Gaseous Hydrocarbons, Non-Methane Hydrocarbons, 

Volitile Organic Compounds, NOx, NO, NO2, Total Energy 

Consumption 

Strategies Default values with assumed CNG buses removed 

General Output Units = grams, joules and miles 

Output Emissions Time = hour, Location = custom area, on-road emission rates by 

road type and source use type. 

Advance Performance None 

County Data Manager Sources 

Source Type Population Combination of local and default data 

Local data (2010) ODOT from motor vehicle registration 

Default data used for source types 41, 51, 54, 61, and 62 

Future year growth rate based on MPO model Household 

growth rate. 

SCATS Ozone SIP Emmissions Estimates Page 7 
Vehicle Type VMT Combination of local and default data 

HPMSVTypeYear VMT = daily VMT from travel demand 

model 

monthVMTFraction = default 

dayVMTFraction=default 

hourVMTFraction=local 

I/M Program None 

Fuel Formulation Default 

Fuel Supply Default 

Metereology Data Local data obtained from NOAA National Climatic Data Center. 

Data will consist of monthly high and low temperatures and 

daily relative humidity for 2002. 

Ramp Fraction Using the base year travel demand model for VHT fractions. 

Future fractions will be assumed constant 

Road Type Distribution Use ODOT county summary VMT categorized by federal 

functional classes 

Age Distribution Combination of local and default data. 

Local data (2010) ODOT from motor vehicle registration 

Default data used for source types 41, 51, 54, 61, and 62 

The same age distribution will be used for all analysis years 

Average Speed Distribution Default 

Alternative Fuel Type Default 

SCATS Ozone SIP Emmissions Estimates Page 8 
Temperature and Relative Humidity 

Temperatures used for the single season approach are representative of July 2004 based on 

NOAA data from the National Climate Data Center webiste. Data for Akron-Canton Airport 

was also used. The EPA provided a spreadsheet to convert Mobile6 data into a format 

compatable with MOVES. The average July hourly temperature and relative humidity 

distribution profile can be seen in Table 4. 

Table 4 – Temperature and Relative Humidity Data 

Hour Average Average

Temperature Relative Humidity

1 60.8

2 57.2

3 57.2

4 60.8

5 60.8

6 62.6

7 62.6

8 64.4

9 66.2

10 66.2 72

11 68.0 68

12 69.8 64

13 69.8 64

14 71.6 60

15 69.8 60

16 69.8 60

17 69.8 64

18 66.2 68

19 66.2 63

20 66.2 68

21 66.2 68

22 64.4 72

23 64.4 72

24 60.8 82

82

93

93

82

87

82

82

77

72

SCATS Ozone SIP Emmissions Estimates Page 9 
Ramp Fraction 

Ramp fractions were derived using the base year travel demand model VHT fractions. Ramp 

fractions can be seen in Table 5. Base year fractions were assumed to apply to future years. 

Table 5 – Ramp Fractions 

roadTypeID roadDesc rampFraction 

2 Rural Restricted Access 0.05 

4 Urban Restricted Access 0.13 

Source-Type Population 

Source-type population is based on a combination of local and MOVES default data. Local data 

was provided by ODOT based on 2010 motor vehicle registration. Default data is used for 

source types 41, 51, 54, 61, and 62. Table 6 shows source-type population for Stark county in 

2004. 

Table 6 – Source-Type Population for year 2004 

Source-Type Source-Type Source-Type

ID Name Population

11 MotorCycle 24,132

21 Passenger Car 282,125

31 Passenger Truck 128,769

32 Light Commercial Truck 2,908

41 Intercity Bus 129

42 Transit Bus 19

43 School Bus 742

51 Refuse truck 86

52 Single Unit Short-haul Truck 181 

53 Single Unit Long-haul Truck 138

54 Motor Home 416

61 Combination Short-haul Truck 1,060 

62 Combination Long-haul Truck 1,220 

Vehicle-Age Distribution 

Vehicle-age distribution information was derived using Ohio Bureau of Motor Vehicle 

registration data. The data was given to OEPA which supplied a VIN decoder that allowed 

ODOT to create correctly formatted MOVES inputs. MOVES default data is used for source 

types 41, 51, 54, 61, and 62. The vehicle-age distribution for Stark County is shown in Table 7. 

The same age distribution will be used for all analysis years 

SCATS Ozone SIP Emmissions Estimates Page 10 
Table 7 – Vehicle-Age Distribution 

Year Source-Type Age Age Year Source-Type Age Age

ID Fraction ID Fraction

2004 11 0 0.0015 2004 21 0 0.006

2004 11 1 0.0214 2004 21 1 0.0238

2004 11 2 0.0508 2004 21 2 0.0362

2004 11 3 0.0633 2004 21 3 0.044

2004 11 4 0.079 2004 21 4 0.0471

2004 11 5 0.0733 2004 21 5 0.051

2004 11 6 0.0719 2004 21 6 0.0491

2004 11 7 0.0794 2004 21 7 0.053

2004 11 8 0.0576 2004 21 8 0.0562

2004 11 9 0.053 2004 21 9 0.0545

2004 11 10 0.0446 2004 21 10 0.0624

2004 11 11 0.0365 2004 21 11 0.0613

2004 11 12 0.026 2004 21 12 0.0562

2004 11 13 0.0217 2004 21 13 0.0543

2004 11 14 0.0203 2004 21 14 0.0487

2004 11 15 0.021 2004 21 15 0.05

2004 11 16 0.0167 2004 21 16 0.0398

2004 11 17 0.0114 2004 21 17 0.0337

2004 11 18 0.0087 2004 21 18 0.0282

2004 11 19 0.0077 2004 21 19 0.0215

2004 11 20 0.0073 2004 21 20 0.0178

2004 11 21 0.0088 2004 21 21 0.015

2004 11 22 0.0091 2004 21 22 0.0111

2004 11 23 0.0103 2004 21 23 0.0082

2004 11 24 0.0177 2004 21 24 0.0069

2004 11 25 0.0159 2004 21 25 0.0057

2004 11 26 0.0135 2004 21 26 0.0045

2004 11 27 0.0162 2004 21 27 0.0026

2004 11 28 0.0241 2004 21 28 0.0017

2004 11 29 0.0186 2004 21 29 0.0017

2004 11 30 0.0927 2004 21 30 0.0478

SCATS Ozone SIP Emmissions Estimates Page 11 
Road-Type Distribution 

Road-type distribution is based on the 2008 ODOT county summary, HPMS VMT data 

categorized by federal functional class for the SCATS area. Road-type distribution can be seen 

in Table 8.

Table 8 – Road-Type Distribution 

Source-Type Road-Type Road-Type Source-Type Road-Type Road-Type

ID ID VMT Fraction ID ID VMT Fraction

11 1 0.00 43 4 0.19

11 2 0.01 43 5 0.62

11 3 0.18 51 1 0.00

11 4 0.19 51 2 0.01

11 5 0.62 51 3 0.18

21 1 0.00 51 4 0.19

21 2 0.01 51 5 0.62

21 3 0.18 52 1 0.00

21 4 0.19 52 2 0.01

21 5 0.62 52 3 0.18

31 1 0.00 52 4 0.19

31 2 0.01 52 5 0.62

31 3 0.18 53 1 0.00

31 4 0.19 53 2 0.01

31 5 0.62 53 3 0.18

32 1 0.00 53 4 0.19

32 2 0.01 53 5 0.62

32 3 0.18 54 1 0.00

32 4 0.19 54 2 0.01

32 5 0.62 54 3 0.18

41 1 0.00 54 4 0.19

41 2 0.01 54 5 0.62

41 3 0.18 61 1 0.00

41 4 0.19 61 2 0.01

41 5 0.62 61 3 0.18

42 1 0.00 61 4 0.19

42 2 0.01 61 5 0.62

42 3 0.18 62 1 0.00

42 4 0.19 62 2 0.01

42 5 0.62 62 3 0.18

43 1 0.00 62 4 0.19

43 2 0.01 62 5 0.62

43 3 0.18

SCATS Ozone SIP Emmissions Estimates Page 12 
Vehicle-Type VMT and VMT Fractions

The first component of the VMT inputs is the Yearly HPMS VMT, but the travel demand model 

was used instead of ODOT’s HMPS data since it was felt that the model would better predict 

future year VMT. ODOT’s CMS post-processor was run for each year to generate congestion 

reports, which includes total daily VMT. The vehicle-type percentages of the total VMT were 

based on ODOT’s weigh-in-motion (WIM) data. Since there are not enough WIM stations for 

lower class facilties in the area, a statewide average of all ODOT WIM data collectors was used. 

Daily VMT was then converted to yearly VMT. Yearly HPMS VMT for 2004 can be seen in 

Table 9. The same method was to generate all other analysis years 

Table 9 – Yearly HPMS VMT for 2004 

HPMS Vtype Year HPMS Base-Year Base-Year

ID VMT Off-Net VMT

10 2004 11,106,492 0

20 2004 1,980,755,140 0

30 2004 611,157,640 0

40 2004 6,246,845 0

50 2004 46,180,207 0

60 2004 109,640,294 0

SCATS Ozone SIP Emmissions Estimates Page 13 
Monthly and daily VMT fractions used MOVES default data. The hourly VMT fractions were 

derived from ODOT WIM data. Hourly VMT fractions vary for each of the five MOVES road 

types but do not change for each of the 16 MOVES source types. A representative sample of the 

hourly-VMT-fraction input file can be seen in Table 10, the entire file is too large to include in 

this document. 

Table 10 – Hourly VMT Fractions 

Source-Type Road-Type Day Hour Hourly- VMT

ID ID Fraction

11 1 5 1 0.0089

11 1 5 2 0.0056

11 1 5 3 0.0042

11 1 5 4 0.0043

11 1 5 5 0.0070

11 1 5 6 0.0180

11 1 5 7 0.0381

11 1 5 8 0.0570

11 1 5 9 0.0577

11 1 5 10 0.0554

11 1 5 11 0.0555

11 1 5 12 0.0556

11 1 5 13 0.0558

11 1 5 14 0.0605

11 1 5 15 0.0677

11 1 5 16 0.0776

11 1 5 17 0.0843

11 1 5 18 0.0797

11 1 5 19 0.0601

11 1 5 20 0.0452

11 1 5 21 0.0365

11 1 5 22 0.0291

11 1 5 23 0.0214

11 1 5 24 0.0149

SCATS Ozone SIP Emmissions Estimates Page 14 
4. Post Processing

Total emissions were computed with the aid of several custom programs by ODOT. The process 

uses data on daily and directional traffic distributions as well as more up-to-date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process, described below, also 

uses rewritten codecompatable with the newer model network formats and MOVES-generated 

emission factors. 

The first step in the the process involves running postcms.exe to calculate hourly link volumes 

based on the percentage of the daily volume (travel demand model output) determined by a 

link’s facility and area type. Link speeds from the travel demand model are not used in the 

analysis. The speeds are estimated as a post-process to the model based on HCM methods using 

a link’s volume-to-capacity ratio and link-group code. 

The second step (movesnet.exe) uses a combination of the MOVES emission factors and the 

hourly link volumes that are output of the postcms.exe program. The hourly volumes are 

multiplied by the MOVES emission factor for the corresponding hour of day, speed bin, and 

roadtype to calculate emissions for every network link for each hour. The final total for link onroad vehicle emissions for the area is the sum of all individual link-hour emissions. 

The third step, (movesveh.exe), calculates vehicle-based emissions (using a combination of the 

Rate per Distance and Rate per Profile files) for each source type for each hour of the day. The 

vehicle source type is based on a combination of local and default data. The final vehicle 

emissions are the sum of all individual hourly emissions for all vehicle types. 

Intrazonal trips are not loaded onto the network, so the fourth step in the process requires a 

separate method to account for those trips that use local roads to travel within a zone. The 

movesintra.exe program uses intrazonal trips to estimate VMT using the area in square miles and 

intrazonal trips of each zone. The zone is assumed circular and the radius of the circle is used as 

the average trip length for these intrazonal trips. Intrazonal emissions are then calculated by 

combining MOVES-generated emissions with estimated intrazonal VMT. The emission rates are 

the same as those used to calculated link-based emissions. 

The final step is to summarize link, vehicle, and intrazonal emissions for each county, pollutant, 

and analyzed year. 

SCATS Ozone SIP Emmissions Estimates Page 15 
Appendix A 

Interagency Consultation Documentation 
>>> "Moore, Dave" <Dave.Moore1@dot.state.oh.us> 1/30/2012 9:17 AM >>> 

All,

The current Ohio Ozone SIP budgets were developed using US EPA’s MOBILE software.  Effective March

2, 2012 US EPA’s AQ software of record will be MOVES.  Post March 2nd all new SIP and Transportation

Conformity actions will be required to use MOVES.  In order to assure ongoing positive Ohio MPO T‐

Plan/TIP conformity actions, the Ohio Ozone SIP budgets need updated to reflect MOVES outputs.

Updating the Ozone SIP budgets to MOVES requires new MOVES based mobile emission inventories for

the SIP attainment year and budget years, consistent with the attached pdf.  Please contact your ODOT

CO travel demand modeling liaison to coordinate needed transportation network, modeling runs, and

emission factor post processing to establish these new SIP mobile emission inventories.  Our goal is to

submit the new inventories and documentation to OEPA on or before April 1, 2012.

We have a working agreement with OEPA to establish SIP budgets, assuming sufficient safety margin is

available, at 15% above the emission inventory.  As you are developing the new MOVES based budget

year inventories, it may be a good idea to compare the resulting inventories plus 15% to MOVES based

T‐Plan interim and horizon year emissions as a check to assure positive future year conformity findings.

Thanks

DM
>>> "Brunello, Nino" <Nino.Brunello@dot.state.oh.us> 4/2/2012 9:19 AM >>> 

Jeff/Dan,

I forgot to send these files that summarize the yearly emission totals that will be needed for your air

quality document.

I’ve included the Dayton document that can be used as a starting point if desired, and I’ve created tables

for SCATS that would correspond to that document.

You may already know most of what is needed to put together your SIP, but questions can be directed

to Dave Moore, or to me if they are more technically related.

Thanks,
Nino

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

Nino Brunello, P.E. 

Modeling & Forecasting Section 

Division of Planning 

Ohio Department of Transportation 

(614) 752-5742

From: Durham, William F [mailto:William.F.Durham@wv.gov] 

Sent: Friday, April 06, 2012 8:50 AM 

To: Brunello, Nino 

Cc: Dines, Jennifer 

Subject: Ozone Summer Day Factors 

Nino: 

I spoke with Jenn this morning and outlined the issue of Summer day VMT v. Average daily 

VMT. 

We agreed that Pat Morris may be able to shed some light on the question. 

Jenn & my calendars are open next Mon. and Tues. afternoon. Please give me a call & I’ll patch 

Jenn in. 

Fred 

From: Brunello, Nino 

Sent: Monday, April 09, 2012 12:59 PM 

To: Dines, Jennifer; Durham, William F 

Subject: RE: Ozone Summer Day Factors 

Jennifer/Fred,

There is another item that needs to be discussed.  Since we now calculate emission rates for both VMT

and number of vehicles, does there need to be a summer adjustment factors for vehicles as well?  This

was not done with MOBILE, so we have nothing to follow.  If I had to guess, I would think that there

would be an increase, but I couldn’t guess as to how many or what factor to use.  Maybe just use 1.08 in

absence of anything better?  Thoughts?

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

Nino Brunello, P.E. 

Modeling & Forecasting Section 

Division of Planning 

Ohio Department of Transportation 

(614) 752-5742
From: Dines, Jennifer 

Sent: Thursday, April 12, 2012 9:04 AM 

To: Brunello, Nino; Durham, William F 

Cc: Moore, Dave 

Subject: RE: Ozone Summer Day Factors 

Nino and Fred, talked to Pat and she agrees that BOTH VMT and number of vehicles should have the

1.08 factor applied.

Pat suggested we should have consultation on this. I told her ODOT is taking the lead on this project and

I’d let Dave know........she says email is fine.

Thanks,

Jennifer Dines

Manager, State Implementation Plan and Rulemaking Section

Division of Air Pollution Control

Ohio Environmental Protection Agency

Wk (614) 644‐3696

Fax (614) 644‐3681

>>> "Brunello, Nino" <Nino.Brunello@dot.state.oh.us> 4/19/2012 2:30 PM >>> 

All:

After discussions with ODOT, OEPA, WVDEP, and USEPA, we are of the opinion that there needs to be an

additional seasonal factor for summer when calculating ozone pollutants.

There is currently an adjustment for increasing average daily VMT (+ 8%) which was used in previously

when using Moblie6 to generate emission factors.  With MOVES, there is a vehicle component used in

addition to VMT, so there needs to be an adjustment from average number of vehicles to the number of

vehicles in summer day.  We propose to use the same 8% increase.

We need to have an inter‐agency agreement on this, and would prefer to do it via email (to make it

easier on all of us).  Please respond with your approval and/or questions.

Thanks,

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

Nino Brunello, P.E. 

Modeling & Forecasting Section 

Division of Planning 

Ohio Department of Transportation 

(614) 752-5742

>>> Jeffrey Dutton 4/19/2012 3:43 PM >>> 
SCATS concurs 

 

Jeff 

 

Jeff Dutton 

SCATS Technical Director 

Stark County Regional Planning Commission 

201 3rd Street NE, Suite 201 

Canton, Ohio 44702 

>>> "Moore, Dave" <Dave.Moore1@dot.state.oh.us> 4/20/2012 7:53 AM >>> 

Dan,

Responses below.

Thanks

DM

From: Dan Slicker [mailto:dkslicker@co.stark.oh.us] 

Sent: Thursday, April 19, 2012 2:32 PM 

To: Moore, Dave 

Subject: Ozone SIP and PM2.5 

Dave, 

 

I can't stand air-quality stuff, whenever I see anything having to do with it, my brain partially shuts 

down. Until today, I didn't realize that we were dealing with two separate air-quality issues. Whenever I 

see "ozone", "PM2.5", "conformity", or "redesignation" my brain files it under "air quality", and I make I 

note that I'll have to send some networks down to Nino and plagiarize an air-quality document in the 

near future. 

 

So, I have a few questions that need answers, so I can set my priorities. 

 

1. When is the 8-Hour Ozone SIP document due? We’ve missed a number of due dates for 

submitting this documentation to OEPA. The most recent date was April 1st. OEPA is ready to 

move (pun intended) on the MOVES based budget SIP revisions. As you know, SCATS’ T-Plan 

conformity lapse date is 6/15/13. Conformity for the Plan Update will need to be coordinated 

with the new 2014-2017 TIP. Considering standard review/approval schedules the T-Plan 

Update and Conformity Determination documentation will need to be submitted to US 

DOT/EPA by 5/1/13. This conformity work needs to be MOVES based. So, the SIP revision 

must be fully approved or have budget adequacy finding in time for SCATS’ T-Plan/TIP 

approval/conformity findings. So backing up some more, OEPA needs a minimum 45 days to 

incorporated SCATS’ results in the SIP revision for submission to US EPA. US EPA needs a 
minimum 90 days to process the revision through the Federal Register process. The 

schedules/dates identified above put us somewhere in the Winter 2012/2013 timeframe. 

Accordingly, there’s still time to accomplish the work, but schedules have a way of slipping. 

Should we even discuss the matter of the new .075 Ozone standard, potential revocation of

the exiting 8‐Hour standard, the matter of Stark attaining the new standard and whether any

of the above matters if the new standard is implemented?

2. When is the PM2.5 Redesignations for Stark County document due? Similar schedules as above. Note, 

Stark County is a PM2.5 nonattainment area for both the 1997 annual and 2006 daily standards. Based 

on recent OEPA streams it appears the intent is for the 1997 and 2006 standard budgets to be exactly 

the same.

3. Do we need to do an interagency consultation for either of these? Interagency consultation on the 

current Stark County aq SIP efforts is warranted just to make sure everyone is on the same page.

4. Besides the TIP and T-Plan air-quality analyses, are there any other air-quality issues we need to deal 

with in the next 2 years? Once the SIPs are updated, likely just Plan/TIP conformity.

There are two other matters:

• OEPA is updating the “Conformity SIP”.  SCATS may want to review the conformity SIP MOU

that was prepared circa 2008‐2009 to re‐familiarize themselves with this topic.

• Not really air quality SIP/Conformity related, but SCATS should review its current suballcated

funds CMAQ projects to assure they all have affirmative CMAQ eligibility findings.   

 

Dan Slicker 

>>> "Dines, Jennifer" <Jennifer.Dines@epa.state.oh.us> 4/20/2012 8:02 AM >>> 

I will offer that the PM2.5 redesignations is listed as one of the top priorities by our director and this is 

the last area to be done. I will also add that if we do not do the redesignation and update mobiles 

numbers via that mechanism we will have to do the same work to update old mobile6 to MOVES numbers 

for Stark county for PM2.5 via the previous attainment SIP. So it has to be done either way. 

I believe Nino completed all the modeling in accordance with all procedures used across the state for all 

other redesignations and all that needs done is the write-up, which he provided a template for. So I 

don't think it will take much effort to complete that piece of the puzzle so the redesignation can move 

forward quickly. But if this is a problem please let me know as I am being asked routinely on the status 

and will need to be able to provide my management with an update. 

Until I crunch the numbers from Nino's modeling I won't be able to have much of a meaningful 

consultation process on that issue. Typically we consult after I incorporate mobile numbers in with all the 

other pollutant sectors to determine our possible safety margin options if budgets are necessary. Then 

we typically discuss if that is agreeable. 

Thanks, 

Jennifer Dines 

Manager, State Implementation Plan and Rulemaking Section 

Division of Air Pollution Control 

Ohio Environmental Protection Agency 

Wk (614) 644-3696 

Fax (614) 644-3681 
From: Dan Slicker [mailto:dkslicker@co.stark.oh.us] 

Sent: Thursday, April 26, 2012 3:18 PM 

To: Brunello, Nino 

Subject: Re: Ozone emissions for SIP document 

Nino, 

 

Now I'm moving on to ozone. In the table that shows the emissions, what is the VMT/VEH column 

supposed to mean? VMT per vehicle doesn't make sense. 

 

What are the different analysis years called? 2004 is the base year. What are 2009 and 2018? 

 

That's all for now. 

 

Dan

From: Dan Slicker [mailto:dkslicker@co.stark.oh.us] 

Sent: Thursday, April 26, 2012 3:19 PM 

To: Brunello, Nino 

Subject: Re: Ozone emissions for SIP document 

One more question. The Dayton-Springfield doc refers to an I/M program. What is that? 

 

Dan 

>>> "Brunello, Nino" <Nino.Brunello@dot.state.oh.us> 4/27/2012 7:59 AM >>> 

Hey Dan,

Yeah, that table was put together by Greg, so I didn’t mess with any of the formatting, but it’s a little

confusing.  The header on the third column should really be VMT or VEH.  So the units for links and

intrazonals are in miles, and VEH is number of vehicles.

The analysis years are:

2004 – Attainment Year

2009 – Interim Budget Year

2018 – Maintenance Budget Year

I/M is short for inspection and maintenance.  Akron and Cleveland have it.  It’s where you are required

to take your vehicle to a service station and they do some testing like putting a sensor on the tailpipe,

check the gas cap, make sure the catalytic converters aren’t missing, etc.  You have to do it before you

can get new tags for your car.  There’s also things like vapor recovery, where there is a rubber funnel at

the gas pumps that capture fumes while refueling.

Nino
>>> "Brunello, Nino" <Nino.Brunello@dot.state.oh.us> 5/18/2012 1:32 PM >>> 

Ok, I need to update the emission totals (Table 1).  I’ll get to you by Monday, maybe later today if

nothing else comes up.

>>> "Brunello, Nino" <Nino.Brunello@dot.state.oh.us> 5/21/2012 2:08 PM >>> 

Attached is the latest spreadsheet with updated emission totals.  I had to rerun some assignments, and I

have also adjusted the VMTs to reflect summer traffic.

From: Dines, Jennifer 

Sent: Wednesday, June 13, 2012 8:17 AM 

To: Moore, Dave 

Cc: Brunello, Nino; Fetty, Erica 

Subject: RE: Ozone SIP budgets 

Dave, we need to make sure all the MPOs know the numbers we need to complete our analysis. There

should be 4 years for everyone (nonattainment/base, attainment, interim and maintenance years, using

the years in the first tab of the attached sheet.  Note that for Dayton there is an asterisk showing that

2005 was the interim budget year but 2009 was modeled...so we need both 2004 and 2009 years

remodeled (with all four years being 2002, 2005, 2009, 2018)

Jennifer Dines

Manager, State Implementation Plan and Rulemaking Section

Division of Air Pollution Control

Ohio Environmental Protection Agency

Wk (614) 644‐3696

Fax (614) 644‐3681

>>> "Moore, Dave" <Dave.Moore1@dot.state.oh.us> 6/13/2012 9:36 AM >>> 

All,

See below, OEPA Ozone SIP Update message. Please review your region’s Ozone SIP update 

submissions to OEPA to assure it includes base year mobile emissions inventory (see attached 

spreadsheet – 2002 is the base year for most regions). 

Thanks 

DM 

From: Dan Slicker [mailto:dkslicker@co.stark.oh.us] 

Sent: Wednesday, June 13, 2012 9:56 AM 

To: Jeffrey Dutton 

Cc: Moore, Dave; Brunello, Nino 

Subject: Re: Fwd: FW: Ozone SIP budgets 

Ours does not include the base year 2002. 
 

Nino, do you have our 2002 network or should I send it to you? 

 

Dan

>>> "Brunello, Nino" <Nino.Brunello@dot.state.oh.us> 6/13/2012 10:37 AM >>> 

Dan,

I looked at what I used in the past, and we had used the base 2000 network for running 2002.  I think

that would still be okay.

Also, last week you had sent 2010 network and prohibitor files.  Is there a new transit line file?

Nino

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

Nino Brunello, P.E. 

Modeling & Forecasting Section 

Division of Planning 

Ohio Department of Transportation 

(614) 752-5742

>>> "Brunello, Nino" <Nino.Brunello@dot.state.oh.us> 7/27/2012 2:54 PM >>> 

Jeff/Dan,

The attached file has the ozone emission estimates needed for the SIP.  The 2002 run has been added,

and I also reran the other years because there was a problem with a seasonal adjustment process that

we had done earlier.

If you need anything else or have any questions, please let me know.

Thanks,

Nino
Public Notice 

Ohio Environmental Protection Agency 

Redesignation and Maintenance Plan for the Ohio Portion of the CantonMassillon Area 

Stark County 

Notice is hereby given that the Director of the Ohio Environmental Protection Agency, 

(Ohio EPA) is requesting that the United States Environmental Protection Agency (U.S. 

EPA) revise the current maintenance plan for the Canton-Massillon Area, including 

Stark County, with respect to the 1997 eight-hour ozone national ambient air quality 

standard (NAAQS). Ohio EPA submitted a redesignation request and maintenance plan 

for this area on June 20, 2006 Subsequently, U.S. EPA approved this requests on May 

16, 2007. Air quality monitoring data collected in the region demonstrated attainment of 

the NAAQS and there was evidence that the improved air quality is due to permanent, 

enforceable emission reductions. In addition, existing requirements are sufficient to 

maintain the 1997 eight-hour ozone standard in this area throughout the maintenance 

period. 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile 

emission projections and conformity budgets based on emission rates generated from 

U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation 

(MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s 

official emission factor model. 

These actions must be noticed to allow public comment and to satisfy U.S. EPA 

requirements for public involvement in SIP related activities. This notice addresses 

Ohio EPA’s reliance on the emission projections as evidence of attainment and 

maintenance and the commitment to institute contingency measures if ambient 

exceedances or violations trigger the contingency plan requirements. Written comments 

will be received on or before November 08, 2012 at the following address: 

E-mail: erica.fetty@epa.state.oh.us

Mailing address: Erica Fetty 

Ohio Environmental Protection Agency, DAPC 

Lazarus Government Center 

P.O. Box 1049 

Columbus, Ohio 43216-1049 

Phone: (614) 644-2310 

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this 

redesignation request will be conducted as follows: Thursday November 08, 2012 at 

2:00P.M., at Stark County District Library North Branch located at 189 25th St. NW 

Canton, Ohio. 

All interested persons are entitled to attend or be represented at the hearings and give 
written or oral comments on these changes. All oral comments presented at the 

hearing, and all written statements submitted at the hearing or to the above address by 

the close of business on November 08, 2012 will be considered by Ohio EPA prior to 

final action on this redesignation. Written statements submitted after November 08, 

2012 may be considered as time and circumstances permit, but will not be part of the 

official record of the hearing. 

This redesignation and maintenance request is available on Ohio EPA DAPC’s Web 

page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx. 

Questions regarding accessing the web site should be directed to Arunee Niamlarb at 

614-728-1342; other questions or comments about this document should be directed to 

either Erica Fetty, (614)-644-2310, Erica.Fetty@epa.state.oh.us or Jennifer Dines at 

(614) 644-3696, Jennifer.Dines@epa.state.oh.us or mailed to Erica Fetty or Jennifer 

Dines at the above address. 
1 

2 

3 

OHIO ENVIRONMENTAL PROTECTION AGENCY 

PUBLIC HEARING 

4------------- --· 

5 In Re: 

6 Redesignation and Maintenance 

Plan for Ozone Basic 

7 Nonattainment Area 

Stark County, Ohio 

8 

9 

10 

11 Transcript of proceedings 

12 held before the Ohio Environmental Protection 

PClbe 1 

13 Agency, at the Stark County Library, North Branch, 

14 189 25th Street, N.W., Canton, Ohio 44709, 

15 on November 8, 2012, commencing at 2:00 p.m. 

16 

17 

18 APPEARANCES: 

19 Mary McCarron, Ohio EPA Public Interest Center 

20 Erica Fetty, Ohio EPA, Division of Air Quality 

21 

22 

23 

24 

25 

FINCUN-Ml\NCIN1 -- TI::lE COURT REPORTER& 

('216) 696-'2'272 

' <I ;.:J, 

NOV 1 :.5 2012 

~I·'"'. J "'-" 
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PCJ8e 2 

PROCEEDINGS 

MS. McCARRON: My name is Mary 

McCarron. I am the public involvement manager 

for Ohio Environmental Protection Agency's 

Public Interest Center. I will be presiding 

over today's public hearing. 

Thank you for taking the time to attend 

this hearing before the Ohio Environmental 

Protection Agency. The purpose of the hearing 

today is to obtain comments from any 

interested person regarding Ohio EPA's 

proposed action. 

The State of Ohio is requesting that 

U.S. EPA revise the current maintenance plan 

for the Canton-Massillon area, including Stark 

County, with respect to the 1997 eight-hour 

ozone national ambient air quality standard. 

Ohio EPA is now requesting a revision 

to the maintenance plan to update mobile 

emission projections and conformity budgets 

based on emission rates generated from U.S. 

EPA's latest mobile emissions model, the Motor 

Vehicle Emission Simulation 2010. In December 

2009, MOVES replaced MOBILE6.2 as the U.S. 

EPA's official emission factor model. 

Ji'INCUN-MANCINI -- T!::IE COURT REPORTERS 

(216) 696-2212 
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All interested persons are entitled to 

attend or be represented, and to present oral 

and/or written comments concerning the 

proposed action. All written and oral 

comments received as part of the official 

record will be considered by the Director of 

Ohio EPA. 

To be included in the official record, 

written comments must be received by Ohio EPA 

by close of business, today, November 8, 2012. 

These comments may be filed with me today or 

e-mailed to erica.fetty®epa.ohio.gov. All 

written comments submitted for the record 

receive the same consideration as oral 

testimony given today. 

Written statements submitted after 

today may be considered as time and 

circumstances permit, but will not be part of 

the official record of the hearing. 

If you wish to present oral testimony 

at this hearing today and have not already 

signed the registration sheet, please do so at 

this time. The sheet is available at the 

registration table. Persons will be called in 

the order in which they have registered. 

f!NCUN-MANCINI -- TtlE COURT REPORTER& 

(216) 696-227'2 
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There is no cross-examination of 

speakers or of representatives of Ohio EPA in 

public hearings such as this. Ohio EPA 

hearings such as this afford citizens the 

opportunity to provide comments on the 

official record. Therefore, we will not be 

able to answer questions during the public 

hearing. However, members of the panel may 

ask clarifying questions of those providing 

testimony to make sure it is as complete as 

possible. 

What I am going to do is I'm going to 

read the names of folks who have signed-in. 

If you want to put anything on the record at 

this time, just go ahead and state your name 

and spell it for our court reporter. If you 

don't, go ahead and say "pass". After that, 

if nobody wants to provide testimony we'll go 

off the record until 2:30 and then we will 

reopen the hearing at 2:30 to see if anybody 

has any comments and then close out the 

hearing. 

The first person who has registered at 

this time, is Renee 

MS. BOGUE: Bogue. 

flNCUN-ML\NCINI -- TllE COURT REPORTER& 

(216) 696-2272 

Pelbe 4 
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MS. McCARRON: 

MS. BOGUE: 

MS. McCARRON: 

Annie Shimko. 

MS. SHIMKO: 

MS. McCARRON: 

MS. LOWRY: 

MS. McCARRON: 

MS. TOLOE: 

MS. McCARRON: 

MS. TOLOE: 

Bogue. 

At this time, no. 

Okay. 

No. 

Jennifer Lowry. 

Pass. 

Sylvia 

Toloe. 

Toloe. 

No. 

Paoe? 

MS. McCARRON: At this time, we will 

go off the record until 2:30. 

(Recess taken.) 

At this time, there isn't anyone who 

wishes to testify. Just a reminder, we will 

accept written comments by the close of 

business today. The time is now 2:30 and we 

will adjourn the hearing. 

Thanks for coming. 

(Hearing concluded at 2:30p.m.) 

f!NCUN-MANCINI -- TliE COURT REPORTER&> 

('216) 696-'2'272 
1 State of Ohio, 

SS: 

2 County of Cuyahoga. 

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C E R T I F I C A T E 

This certifies that the foregoing is a true 

and correct transcript of the proceedings had 

before the State of Ohio, Environmental 

Protection Agency, at the Stark County 

Library, North Branch, 189 25th Street, N.W., 

Canton, Ohio 44709, on Thursday, 

November 8, 2012, commencing at 

2:00p.m. 

In Re: 

Redesignation and Maintenance 

Plan for Ozone Basic 

Nonattainment Area 

Stark County, Ohio. 

FINCUN-MANCINI COURT REPORTERS 

1801 East Ninth Street 

Suite 1720 

Cleveland, Ohio 44114 

(216) 696-2272 

(216) 696-2275 FAX 

FINCUN-MANCIN1 -- Tf!E COURT REPORTER~ 

(216) 696-2272