Environmental
Protection Agency

john R. Kasich, Governor
Mary Taylor, Lt. Governor

Scott J. Nally, Director



# MAY 04 2011

Ms. Susan Hedman Regional Administrator
U.S. EPA Region V



### 77 W. Jackson Blvd. Chicago, IL 

### 60604

Re: PM2.5 redesignation request and maintenance plan for the 

### 1997 PM 2

. 5 Annual Standard for the Huntington-Ashland Area

Dear Administrator Hedman:

I am writing to formally request a redesignation to attainment of the Ohio portion of the Huntington-Ashland, OH-KY-WV area (Lawrence and Scioto Counties, and Monroe, Sprigg, and Cheshire townships, in Ohio; Boyd County and the area described by U.S.
Census 

### 2000 block group identifier 

### 21-127-9901-6 only in Kentucky; and Cabell and Wayne Counties, and Graham Tax District only in West Virginia) with respect to the


### 1997 PM2.5 annual standard. The enclosed submittal combines Ohio's redesignation request and the required maintenance plan for this area.

Monitoring of existing air quality indicates that the 

### 1997 National Ambient Air Quality
Standard (NAAQS) for PM 2

. 5 has been attained throughout this area based on 

### 2008-
2010 air quality data. Emissions projections indicate that current controls, existing State rules, existing federal rules, and Ohio's PSD program will be more than sufficient to
maintain the NAAQS indefinitely into the future. These programs will, therefore,
constitute the attainment and maintenance plan for Ohio's portion of the HuntingtonAshland area.

The enclosed information, compiled by the Ohio Environmental Protection Agency (Ohio EPA), West Virginia Department of Environmental Protection (WVDEP), Kentucky
Division of Air Quality (KDAQ), Ohio Department of Transportation, West Virginia Department of Transportation (WVDOT), Kentucky Transportation Cabinet (KYTC), and
the Kentucky-Ohio-West Virginia Interstate Planning Commission (KYOVA), shows significant emission reductions since ambient violations 

### have occurred. A significant portion of the improved air quality can be attributed to federal programs for the mobile

source sector, the regional reductions associated with the NOx Trading Program, and the Clean Air Interstate Rule (CAIR).

50 West Town Street, Suite 700
P.O. Box 1049 Columbus, OH 43216-1049 614 I 644 3020

614 I 644 3184 (fax) www.epa.ohio.gov

### Ohio EPA notified the public of the draft and the opportunity to provide comments on March 17, 2011. The public hearing for this package was held on April 21, 2011, in Portsmouth, Ohio.

If you have questions, please contact Jennifer Hunter in our Division of Air Pollution
Control at (614) 644-3696.

Sincerely, 

# r-t

Scott J. Nally
Director

# REDESIGNATION REQUEST AND
MAINTENANCE PLAN FOR
THE OHIO PORTION OF THE HUNTINGTON-ASHLAND,
OH-KY-WV
ANNUAL PM 2.5 

# NONATTAINMENT AREA

Adams, Gallia, Lawrence and Scioto Counties, Ohio

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

April 2011

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### TABLE OF CONTENTS

Chapter One
Introduction .................................................................................................................. ................. 1 Geographical description and background ................................................................................... 2 Status of air quality ......................................................................................................... .............. 3

Chapter Two Requirements for redesignation ................................................................................................ .... 4

Chapter Three
PM 2.5 monitoring ................................................................................................................... ......... 8
Annual PM 2.5 NAAQS .................................................................................................................... 8 Ambient data quality assured ........................................................................................................ 9 Three complete years of data .................................................................................................. ..... 9 Commitment to continue monitoring ........................................................................................... 1 3

Chapter Four Emission inventory ............................................................................................................ .......... 14 Base year inventory ........................................................................................................... ......... 14 Emission projections .......................................................................................................... ......... 15
Demonstration of maintenance .................................................................................................. . 24
Permanent and enforceable emissions reductions ..................................................................... 40 Provisions for future update .................................................................................................. ...... 41

Chapter Five Control measures and regulations .............................................................................................. 42 Marginal nonattainment areas to implement RACM and RACT .................................................. 42 Show Reasonable Further Progress (RFP) ................................................................................ 44
Emission inventories .......................................................................................................... ......... 44 Implementation of past SIP revisions .......................................................................................... 45 New source review provisions ................................................................................................. .. 47
Assurance of continued controls ............................................................................................... .. 48

Chapter Six Contingency measures .......................................................................................................... ..... 49 Commitment to revise plan ..................................................................................................... .... 49 Commitment for contingency measures ..................................................................................... 49 Potential contingency measures ................................................................................................ . 50
List of PM 2.5 , SO 2 , and NO

x sources ........................................................................................... 51

Chapter Seven Public participation .......................................................................................................... ............ 52

Chapter Eight
Conclusions ................................................................................................................... ............. 53FIGURES

Figure 1 Map of the Huntington-Ashland, OH-KY-WV nonattainment area and
monitor locations ................................................................................................... 9 Figure 2 PM 2.5 Annual Mean Trends LADCO States ......................................................... 12 Figure 3 PM 2.5 Annual Mean Trends Midwest States ........................................................ 12 Figure 4 PM 2.5 Annual Mean National Trends .................................................................. 13

TABLES

Table 1 Monitoring Data for Huntington-Ashland, OH-KY-WV Area for 2008 -

2010 ................................................................................................................. 11 Table 2 Adams County (partial), Ohio Emissions Estimations for On-Road
Mobile Sources .................................................................................................... 20 Table 3 Gallia County (partial), Ohio Emissions Estimations for On-Road
Mobile Sources .................................................................................................... 21 Table 4 Lawrence County, Ohio Emissions Estimations for On-Road Mobile
Sources ............................................................................................................... 21 Table 5 Scioto County, Ohio Emissions Estimations for On-Road Mobile
Sources ............................................................................................................... 21 Table 6 Summary of Ohio Emissions Estimations for On-Road Mobile Sources ............. 21 Table 7 Boyd County, Kentucky Emissions Estimations for On-Road Mobile
Sources ............................................................................................................... 21Table 8 Lawrence County (partial), Kentucky Emissions Estimations for OnRoad Mobile Sources .......................................................................................... 22 Table 9 Summary of Kentucky Emissions Estimations for On-Road Mobile
Sources ............................................................................................................... 22 Table 10 Cabell County, West Virginia Emissions Estimations for On-Road
Mobile Sources .................................................................................................... 22Table 11 Mason County (partial), West Virginia Emissions Estimations for OnRoad Mobile Sources .......................................................................................... 22 Table 12 Wayne County, West Virginia Emissions Estimations for On-Road
Mobile Sources .................................................................................................... 22 Table 13 Summary of West Virginia Emissions Estimations for On- Road
Mobile Sources .................................................................................................... 23
Table 14 Emission Estimations Totals for On-road Mobile Sources for the Huntington-Ashland Area .................................................................................... 23 Table 15 Percent of Mobile Emissions for the Huntington-Ashland Area in 2015
and 2022 ............................................................................................................. 23
Table 16 Reductions in SO 2 and 

### NO
x EGU Emissions Between 2008 and 2009. ............. 26

Table 17 Reductions in SO 2 and 

### NO
x EGU Emissions Between the First Half of
2008 and 2010.... ................................................................................................ 27 Table 18 Adams County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without
CAIR ................................................................................................................. 29 Table 19 Gallia County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without
CAIR ................................................................................................................. 29Table 20 Lawrence County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
Without CAIR ........................................................................................................... 29 Table 21 Scioto County, Ohio PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without
CAIR ................................................................................................................. 30 Table 22 Boyd County, Kentucky PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
Without CAIR ........................................................................................................... 30 Table 23 Lawrence County, Kentucky PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
Without CAIR. ...................................................................................................... 30 Table 24 Cabell County, West Virginia PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)
– Without CAIR .................................................................................................... 31 Table 25 Mason County, West Virginia PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)
– Without CAIR .................................................................................................... 31 Table 26 Wayne County, West Virginia PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy)
– Without CAIR .................................................................................................... 31 Table 27 Huntington-Ashland Area PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
Without CAIR. ...................................................................................................... 32 Table 28 Adams County, Ohio NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR ................................................................................................................. 32 Table 29 Gallia County, Ohio NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR ................................................................................................................ 32 Table 30 Lawrence County, Ohio NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR. ................................................................................................................. 33 Table 31 Scioto County, Ohio NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR. ................................................................................................................. 33 Table 32 Boyd County, Kentucky NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR. ................................................................................................................. 33 Table 33 Lawrence County, Kentucky NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR ................................................................................................................ 34 Table 34 Cabell County, West Virginia NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR. ............................................................................................................... 34 Table 35 Mason County, West Virginia NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR. ............................................................................................................... 34Table 36 Wayne County, West Virginia NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR. ............................................................................................................... 35 Table 37 Huntington-Ashland Area NO

x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR. ............................................................................................................... 35 Table 38 Adams County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR ................................................................................................................. 35 Table 39 Gallia County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR ................................................................................................................. 36 Table 40 Lawrence County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR ................................................................................................................. 36 Table 41 Scioto County, Ohio SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR ................................................................................................................. 36 Table 42 Boyd County, Kentucky SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With
CAIR. ................................................................................................................. 37 Table 43 Lawrence County, Kentucky SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR ................................................................................................................ 37 Table 44 Cabell County, West Virginia SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR ................................................................................................................ 37 Table 45 Mason County, West Virginia SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR ................................................................................................................ 38 Table 46 Wayne County, West Virginia SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR ................................................................................................................ 38 Table 47 Huntington-Ashland Area SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) –
With CAIR ................................................................................................................ 38 Table 48 Huntington-Ashland Comparison of 2008 attainment year and 2015 and 2022 projected emission estimates (tpy) ...................................................... 39 Table 49 Huntington-Ashland Area Combined Comparison of 2005 base year and 2008 attainment year on-road, non-road and EGU reductions ..................... 40

APPENDICES

A Air Quality System (AQS) Data B Ohio 2005 SIP Base Year Inventory Discussion C Mobile Source Emissions Inventory for the Huntington-Ashland PM 2.5 Nonattainment Area D LADCO Technical Support Documents E Analysis of Insignificance of Mobile EmissionsF Public Participation Documentation

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### REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO PORTION OF THE HUNTINGTON-ASHLAND, OH-KY-WV
ANNUAL PM 2.5 

### NONATTAINMENT AREA

Adams, Gallia, Lawrence, and Scioto Counties, Ohio



## CHAPTER ONE

Introduction The Clean Air Act (CAA), as amended, requi res each State with areas failing to
meet the annual PM 2.5 1 

### National Ambient Air Qualit y Standards (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain
the standards. The United St ates Environmental Protection Agency (U.S. EPA) revised the NAAQS for particulate matte r in July 1997. It replaced the existing
PM 10 

### standard with a health-based PM 2.5 

### standard and retained the PM 10 

### standard as a particulate standard protecting welfare. The stan dards include an annual standard set at 15.0 microgr ams per cubic meter (μg/m 3 

### ), based on the 3-year average of annual mean PM 2.5 

### concentrations and a 24-hour standard of 65 μg/m 3 

### , based on the 3-year average of the 98 th 

### percentile of 24-hour
concentrations.

The revised NAAQS was legally challenged in the U.S. Court of Appeals for the
District of Columbia Circuit (the D.C. Circuit). On May 14, 1999, the D.C. Circuit remanded, without vacatur, the standards ba ck to U.S. EPA. The remand did not question the level at wh ich U.S. EPA set the st andards but rather the constitutionality of the CAA provision that authorizes U.S. EPA to set national air quality standards. U.S. EPA requested a rehear ing which the D.C. Circuit denied. Therefore, in December 1999, U.S. EPA appealed the D. C. Circuit decision to the U.S. Supreme Court. The U.S. Supreme Court issued a decision on February 27, 2001 that unanimously affirm ed the constitutionality of the CAA provision but did remand several other i ssues back to the D.C. Circuit, including
the issue of whether U.S. EPA acted arbitrarily and capric iously in establishing the specific levels of the standards.

The D.C. Circuit heard arguments in this remanded case in December 2001, and issued its decision on March 26, 2002. The D. C. Circuit rejected the claims that

1 Particle pollution is a mixture of microscopic solid s and liquid droplets suspended in air. This pollution, also known as particulate matter, is made up of a number of components, including acids (such as nitrates and sulfates), organic chem icals, metals, soil or dust particles, and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is 2.5 micrometers in diameter and
smaller - 1/30th the diameter of a human hair. Fine particle pollution c an be emitted directly or formed secondarily in the atmosphere.2 

### the U.S. EPA had acted arbitr arily and capriciously in setting the levels of the
standards.

On December 17, 2004, U.S. EPA promulgated the initial PM 2.5 

### nonattainment areas designations for the PM 2.5 

### standards across the country. Modifications to those designations were made and an effect ive date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendment s of 1990 which defined five ozone
nonattainment classifications for the ar eas that exceed the NAAQS based on the severity of the ozone levels, PM 2.5 

### nonattainment designations are simply
labeled “nonattainment.” The CAA Amendments require states with PM 2.5 

### nonattainment areas to submit a plan within three years of the effective date of the designations (April 5, 2008) detailing how the PM 2.5 

### standards will be attained by April 5, 2010. Ohio EPA subm itted its attainment demonstration for the entire State of Ohio on July 16, 2008.

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

i) A determination that the area has attained the PM 2.5 

### standard. ii) An approved State Implementat ion Plan (SIP) for the area under Section 110(k). iii) A determination that the improvem ent in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Sect ion 110 and Part D requirements
have been met.

This document addresses each of these requirements, and provides additional information to support continued compliance with the annual PM 2.5 

### standard.

Geographical Description and Background The current Huntington-Ashland nonattainment area is located in southern Ohio and includes the following counties: Adam s (partial nonattainment of Monroe and Sprigg townships only), Gallia (partial nona ttainment of Cheshire Township only), Lawrence and Scioto in Ohio; Boyd and Law rence (partial nonattainment of the area described by U.S. Census 2000 block group identifier 21-127-9901-6 only ) in Kentucky; and Cabell, Wayne and Mas on (partial nonattainment of Graham Tax District only), in West Virginia. This area is shown in Figure 1 under Chapter
Three.

The Huntington-Ashland area has not previously been subject to nonattainment area rulemakings for fine particles.3 

### As a result of the 2005 PM 2.5 

### designations, U.S. EPA des ignated the HuntingtonAshland area nonattainment for the 15.0 μg/m 3 

### annual standard 2 

### , and Ohio EPA was required to develop a plan to reduce oxides of nitrogen (NO
x 

### ), sulfur dioxide (SO 2 

### ) and direct PM 2.5 

### emissions and to demonstrate that the area will meet the federal annual air quality standard by April 5, 2010. Ohio’s main PM 2.5 

### components are primary particles (or ganic carbon, crustal material, and elemental carbon), SO 2 

### and NO
x 

### , which were included in the attainment demonstration analysis. Volatile or ganic compounds (VOCs) and ammonia (NH3) were not included in the analysis si nce they were not part of Ohio’s current attainment strategy for PM 2.5 

### (although controls for VOCs have been implemented for ozone nonattainment). This is consistent with U.S. EPA’s “Clean Air Particle Implementation Rule” [ 74FR 20856] (hereafter referred to as “Implementation Rule”). In the Implem entation Rule U.S. EPA presumes NH3
emissions are not a PM 2.5 

### attainment plan precurso r and that States are not required to address VOC unless the St ate or U.S. EPA makes a technical
demonstration that emissions of VOCs si gnificantly contribute to nonattainment
of the annual PM 2.5 

### standard.

This document is intended to support Ohio’s request that the Ohio portions of the Huntington-Ashland area be r edesignated from nonattainment to attainment for
the annual PM 2.5 

### standard. In addition, the States of Kentucky and West Virginia also intend to submit requests for thei r respective portions of the HuntingtonAshland area.

Status of Air Quality
PM 2.5 

### complete quality-assured ambient ai r quality monitoring data for the most recent three (3) years, 2008 through 2010, demonstrate that the air quality has met the NAAQS for annual PM 2.5 

### in this nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter Four, supports a redesignation to atta inment for the Huntington-Ashland area based on the requirements in Section 107( d)(3)(E) of the CAA as amended.

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

.4 

## CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Directors. The redesignation request and maintenance pl an are based on the redesignation guidance, supplemented with additional guidanc e received from staff of U.S. EPA Region 5.

Below is a summary of each redesignat ion criterion as it applies to the Huntington-Ashland area.

i.) Attainment of the standard (CAA Section 107(d)(3)(E)(i)) There are two components involved in making this demonstration. The first component relies on ambi ent air quality data. The data
that are used to demonstrate atta inment should be the product of ambient monitoring that is repr esentative of t he area of highest
concentration. The data should be collected and quality-assured in
accordance with 40 CFR 58 and re corded in the Air Quality System (AQS) in order for it to be avail able to the public for review.

The second component relie s upon supplemental U.S. EPAapproved air quality modeling. While no modeling is required for redesignating nonattainment areas , the redesignation guidance states it is “generally necessary” for particulate matter redesignations. Appendix C and A ppendix D contains the most recent modeling results sho wing future attainment and maintenance are provided. C hapter Three discusses this requirement in more detail and provides the attainment
demonstration.

ii.) Permanent and enforceable improvem ent in air quality (CAA Section 107(d)(3)(E)(iii))
The state must be able to reasonabl y attribute the improvement in air quality to emission reductions which are permanent and
enforceable. The state should es timate the percent reduction
achieved from federal m easures as well as control measures that have been adopted and implement ed by the state.

It was not necessary for Ohio to adopt or implement control
measures for these counties beyond the federal measures.

Ohio EPA has adopted several rule s recently that will have an impact on statewide PM 2.5 

### emissions in the future:5 

### • Clean Air Interstate Rule (CAIR)

• NO
x 

### SIP Call Rules

In addition, since the initial designations were made federally
enforceable consent decrees hav e resulted in reductions in
emissions from utilities across the state.

Chapters Four and Five discuss this requirement in more detail.

iii.) Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v)) For purposes of redesignation, a st ate must meet all requirements
of Section 110 and Part D that were applicable prior to submittal of the complete redesignation request.

Subpart 1 of Part D consists of general requirements applicable to all areas which are designated nonat tainment based on a violation of the NAAQS. Subpart 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to
address PM 10 

### ). However, for the pur pose of implementing the
1997 PM 2.5 

### standard, U.S. EPA’s Implem entation Rule stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 

### .[72 FR 20589]

i.) Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Secti on 110(a)(2) provides that the implementation plan submitt ed by a state must have been adopted by the state after reasonable public notice and hearing, and that, among other things, it must include
enforceable emission limitat ions and other control measures, means or techniques necessary to meet the requirements of the CAA; pr ovide for establishment and operation of appropriate dev ices, methods, systems and procedures necessary to m onitor ambient air quality; provide for implementation of a source permit program to regulate the modification and cons truction of any stationary
source within the areas cove red by the plan; include provisions for the implementati on of Part C, prevention of significant deterioration (PSD) and Part D, NSR permit programs; include criteria fo r stationary source emission control measures, monito ring, and reporting; include provisions for air quality m odeling; and provide for public and local agency participation in planning and emission control rule development. In Ohio’s December 5, 2007 and September 4, 2009 infrastructure SIP submissions, Ohio6 

### verified that the State fulfills the requirements of Section 110(a)(2) of the Act.

Section 110(a)(2)(D) also requi res State plans to prohibit
emissions from within t he State which contribute significantly to nonattainment or maintenance areas in any other State, or which interf ere with programs under Part C to prevent significant deterio ration of air quality or to achieve reasonable progress towa rd the national visibility goal for Federal class I areas (national parks and wilderness areas). In order to assist States in addressing their obligations regarding r egionally transported pollution,
U.S. EPA finalized CAIR to reduce SO 2 

### and NO
x 

### emissions from large electric generating units (EGU). Ohio has met the requirements of the f ederal CAIR to reduce NO
x 

### and
SO 2 

### emissions contributing to downwind states. On February 1, 2008, U.S. EPA approved Ohio’s CAIR program, which can be found in Ohio Administrative Code (OAC) Chapter 3745-109 3 

### . On July 6, 2010, U.S. EPA proposed a replacement to the CAIR program, the Transport Rule. [75 FR 45210] Upon finalization, it will
further assist States in addressing their obligations regarding regionally transport ed pollution by providing
reductions in NO
x 

### and SO 2 

### emissions in 2012 and 2014.

ii.) Section 172(c) requirements
This Section contains general requirements for nonattainment plans. The r equirements for reasonable further progress, identificat ion of certain emissions increases, and other measur es needed for attainment will not apply for redesignations because they only have meaning for areas not atta ining the standard. The requirements for an emission in ventory will be satisfied by the inventory requirements of the maintenance plan. Chapters Four and Five discuss this requirement in more
detail.

iii.) Conformity
The state must work with U.S. EPA to show that its SIP provisions are consistent with the Section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedures in place. If a state does not have conformity procedures in place at the time that it submits a

3 http://www. epa.ohio.gov/dapc/regs /regs.aspx#3745-1097 

### redesignation request, the state must commit to follow U.S. EPA’s conformity regulation upon issuance, as applicable.

iv.) Maintenance plans (CAA Section 107(d)(3)(E)(iv)) Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a ma intenance plan that meets the requirements of Section 175( A). The maintenance plan will
constitute a SIP revision and must provide for maintenance of the relevant NAAQS in the area for at least 10 years after redesignation. Section 175(A) furt her states that the plan shall contain such additional measures, if any, as may be necessary to
ensure such maintenance.

In addition, the maintenance plan shall contain such contingency
measures as the Administrator d eems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all meas ures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a) attainment inventory; b) maintenance demonstration; c) monitoring network; d) verification of continued attainment; and e) contingency plan.

Chapter Six discusses this requirement in more detail.8 

## CHAPTER THREE

PM 2.5 

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

Requirement 1 of 4 A demonstration that the NAAQS for annual PM 2.5 

### , as published in 40 CFR 50.7,
has been attained.

Background There are 4 monitors measuring PM 2.5 

### concentrations in this
nonattainment area. Two are located in Ohio 4 

### and are operated by
Ohio EPA Division of Air Polluti on Control, Southeast District Office and the Portsmouth City H ealth Department Air Pollution Unit. A listing of the design values based on the three-year average of the annual mean conc entrations from 2008 through
2010 are shown in Table 1. The locations of the monitoring sites for this nonattainment area are shown on Figure 1.

4 The two remaining PM 2.5 monitors are located in Kentucky and West Virginia, respectively.9 

### Demonstration

Figure 1 - Map of the Huntington- Ashland, OH-KY-WV nonattainment
area and monitor locations

Requirement 2 of 4 Ambient monitoring data quality assur ed in accordance with 40 CFR 58.10, recorded in the U.S. EPA air quality syst em (AQS) database, and available for public view.

Demonstration Ohio EPA has quality assured all data shown in Appendix A in
accordance with 40 CFR 58.10 and all ot her federal requirements. Ohio EPA has recorded the data in the AQ S database and, therefore, the data are available to the public.

Requirement 3 of 4 A showing that the three-year av erage of the annual mean values, based on data from all monitoring sites in the ar ea or its affected downwind environs, are below 15.0 μg/m 3 

### . (This showing must rely on three complete, consecutive calendar years of quality assured data.)

Background

The following information is taken from U.S. EPA's "Guidelineon Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999.10 

### In accordance with the CAA Amendment s, three complete years of monitoring data are required to demonstrate attainment at a monitoring site. The annual PM 2.5 

### primary and secondary ambient air quality standards are met at an ambient air quality monitoring site when the three-year aver age of the annual average is less than 15.0 μg/m 3 

### . While calculating design values, three significant digits must be carried in the co mputations, with final values rounded to the nearest 0.1 μg/m 3 

### . Decimals 0.05 or greater are rounded up, and those less than 0. 05 are rounded down, so that 15.049 μg/m 3 

### is the largest concentration that is less than, or equal to 15.0 μg/m 3 

### . Values at or below 15.0 μg/m 3 

### meet the standard; values equal to or greater than 15.1 μg/m 3 

### exceed the standard. An area is in comp liance with the annual PM 2.5 

### NAAQS only if every monitoring site in the area meets the NAAQS. An individual site's 3-year average of the annual average concentrations is also called the site's design value. T he air quality design value for the area is the highest design value among all sites in the area.

Table 1 shows the monitori ng data for 2008-2010 that were retrieved from the U.S. EPA AQS. The air quality design value for the area is the highest design value among all sites in the area.11 

### Demonstration

Table 1 - Monitoring Data for th e Huntington-Ashland, OH-KY-WV
Area for 2008 – 2010

Average

2008 2009 2010 2008-2010

39-087-0010 [a] 10.8

39-087-0012 [b] 13.1 11.3 12.1

39-145-0013 Scioto, OH 12.1 10.9 11.8 11.6

21-019-0017 Boyd, KY 12.1 10.9 11.2 11.4

54-011-0006 Cabell, WV 14.1 12 13.2 13.1 Less than 75% capture in at least one quarter

[a] and [b] The monitoring site 39-087-0010 was shut down in 2/2008 due to the demolition

of the building that hosted the monitor. The monitor was moved approximately
one mile away to a new site (39-087-0012) which began samping in early
2/2008, making both sites incomplete for 2008 when viewed separately.
If the sites at Lawrence County were considered one site and data combined, it

would meet the 75% capture requirement. There are no significant industrial
sources in Ohio where this monitor is located (Ironton, Ohio). The closest
significant source is AK Steel in Ashland, Kentucky. Prior to relocation of this
monitor, it was approximately 1.58 miles from AK Steel. The new site is
approximately 0.85 miles from AK Steel. Notice that the new site collected data

from February 2008 and achieved a 2008 design value of 13.1 μ g/m3,

significantly lower than previous years design value even though it is now closer
to the largest industrial source. Both monitors show attainment of the standard

separately and combined.
In addition, on 4/1/2010 Ohio EPA submitted a Clean Data Request which
included an analysis that supports combining this data. Annual Standard

Site County Year

Lawrence, OH 11.8

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



### The design values calculated for the Huntington-Ashland area
demonstrate that the annual PM 2.5 

### NAAQS has been attained. The area's design values have trended downward as emissions have declined due to
such factors as cleaner automobiles and fuels, and controls for EGUs, at the national, regional and local level.

National monitoring for PM 2.5 

### began in 1999. With respect to each of the Lake Michigan Air Directors Consortium (LADCO) states, there has been a clear downward trend in design values:12 

### Figure 2 - PM 2.5 

### Annual Mean Trends LADCO States

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



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

Figure 3 - PM 2.5 

### Annual Mean Trends Midwest States

Source: LADCO; Recent Ozone and PM2.5 Trends - Aug 26 2010.pptx13 

### Design values have also trended downward nationally:

Figure 4 - PM 2.5 

### Annual Mean National Trends

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



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

status.

Demonstration Ohio EPA commits to continue monitoring PM 2.5 

### levels at the Ohio sites indicated in Figure 1 and T able 1. Ohio EPA will consult with U.S. EPA Region 5 prior to ma king changes to the existing monitoring network, should changes become necessary in the
future. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. Connection to a cent ral station and updates to the
Ohio EPA web site 5 

### will provide real time availability of the data and knowledgement of any exc eedances. Ohio EPA will enter all data into AQS on a timely basis in accordance with federal guidelines.

5 www. epa.ohio.gov/dapc14 

## CHAPTER FOUR

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

U.S. EPA’s redesignation guidance requires the submittal of a comprehensive inventory of PM 2.5 

### precursor emissions (primary par ticles (organic carbon, crustal matter, and elemental carbon), SO 2 

### and NO
x 6 

### ) representative of the year when
the area achieves atta inment of the annual PM 2.5 

### air quality standard. Ohio also
must demonstrate that the improvement in air qualit y between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable em ission reductions. Other emission inventory related requirements include a projection of the emission invent ory to a year at least 10 years following redesignation; a demonstration that t he projected level
of emissions is sufficient to maintain the annual PM 2.5 

### standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the 10-year maintenance period.

The emissions inventory development and emissions projection discussion below, with the exception of the mob ile (on-road) emi ssions inventory and projections, identifies procedures us ed by Ohio EPA and the LADCO regarding emissions from Ohio’s por tion of the counties in t he Huntington-Ashland area. Specific emissions data are provided for all counties, including those in Ohio, Kentucky and West Virginia. Kentucky and West Virginia emissions data were also obtained though the LADCO emissions inventory and projections. All of
these inventories and emi ssions projections were prepared using similar methodologies. Ohio recognizes that revi sions to the emissions data below may be necessary once Kentucky and West Virg inia prepare a redesignation request and maintenance plan for their portion of the nonattainment area. Mobile emissions inventories and projections fo r all counties were prepared by KimleyHorn and Associates Inc. on behalf of the Kentucky-Ohio-West Virginia In Interstate Planning Commission (KYOVA), with data provided by KYOVA, Ohio Department of Transportation (ODOT), Ohio EPA, West Virgin ia Department of Transportation (WVDOT), West Virginia Department of Envir onmental Protection (WVDEP), Kentucky Transportation Cabinet (KYTC), and Kentucky Division of Air Quality (KDAQ).

Requirement 1 of 5 A comprehensive emission inventory of PM 2.5 

### , SO 2 

### and NO
x 

### completed for the base year.

Background The point source data are tak en from Ohio's annual emissions reporting program. The 2005 periodi c inventory has been identified

6 VOC and NH 3 are not addressed.15 

### as one of the preferred dat abases for SIP development and coincides with nonattainment air qua lity in the Huntington-Ashland

area.

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

Demonstration The 2005 inventory is used as t he base year for the purpose of
this submittal and was submitt ed to U.S. EPA with Ohio’s PM 2.5 

### attainment demonstration SIP submitted on July 18, 2008 and revised on June 7, 2010. The det ailed emission inventory information for the Ohio portion of the Huntington-Ashland area is provided in Appendix B. Emissions of PM 2.5, 

### SO 2 

### and NO
x 

### for 2005 are identified under Requirement Three of this Chapter.

Requirement 2 of 5 A projection of the emission inventory to a year at least 10 years following redesignation.

Background Ohio EPA prepared a comprehensive invent ory for the Ohio portion of the Huntington-Ashland area including area, mobile, and point sources for
PM 2.5 

### , SO 2 

### and NO
x 

### for base year 2005. The 2005 inventory was submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM 2.5 

### attainment demonstration SIP for this area. The information below describes the procedures Ohio EPA us ed to generate the 2005 base year inventory and to develop SIP-ready m odeling inventories and future year projections (Pechan Report 7 

### ) based on a 2005 base year inventory. The report by Pechan generated future year estimates of annual emissions for each source sector using accepted gr owth surrogates. These inventories were provided to the LADCO and have been processed to develop average daily emissions for use in the air quality analyses. These processed modeling inventories hav e been identified as the correct iteration of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organization. Note that the on-road m obile source sector was addressed by specific PM 2.5 

### and NO
x 

### modeling as discussed below.

• Area sources were taken from the Ohio 2005 periodic inventory submitted to U.S. EPA. These projections were

7 http://www.ladco.org/tech/emis/r5/r eports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con trols%20Report_Final.pdf16 

### made from the U.S. Departm ent of Commerce Bureau of Economic Analysis (BEA) grow th factors, with some updated local information.

• Mobile source emissions were calculated from MOVES2010 produced emission factor s. In Ohio’s July 16,
2008 PM 2.5 

### Attainment Demonstration SIP 8 

### , Ohio found that the regional highway emissions of PM 2.5 

### , NO
x 

### , and SO 2 

### were insignificant contri butors to the nonattainment problems and, therefore, none of the three pollutants (necessitated emissions inventory analysis. As documented
in Ohio EPA’s attainment dem onstration SIP, Ohio EPA in
consultation with U.S. EPA det ermined that the HuntingtonAshland nonattainment area is not significantly impacted by
on-road mobile emissions as compared to other source emissions; in addition, mobile source emissions in the area were expected to decrease. Ba sed on the results of mobile source emission projections prepared as a part of this redesignation and maintenance plan, Ohio EPA is again making a finding that the regional highway emissions of
PM 2.5 

### , NO
x 

### , and SO 2 

### continue to be insignificant
contributors to the nonattainment problems in this area, as
discussed below.

• Point source information wa s compiled from Ohio EPA’s
2005 annual emissions inv entory database and the 2005
U.S. EPA Air Markets acid rain database 9



### .

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generated using U.S. EPA’s National Mobile Inventory M odel (NMIM) 2002 application. To address concerns about the accuracy of some of the categories in U.S. EPA’s non-road emissions model, LADCO contracted with two (2) companies to review the
base data and make recommendations. One of the
contractors also estimated emi ssions for three (3) non-road categories not included in U.S. EPA’s non-road model.
Emissions were estimated fo r aircraft, commercial marine vessels, and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment ca tegory were reviewed and updated based upon surveys completed in the Midwest, and the temporal allocation fo r agricultural sources also was updated.

8 http://www. epa.ohio.gov/portals /27/SIP/Attain/P M2_5/PM25Doc.pdf 9 http://www. epa.gov/airmarkets/acidrain17 

### Demonstration

On-Road Emission Estimations The Huntington-Ashland nonattain ment area for the on-road emission estimation analysis is divided into a modeled area composed of Cabell, Wayne, and Mas on (partial) Counties in West Virginia, Lawrence, Scioto, Adam s (partial), and Gallia (partial) Counties in Ohio, and Boyd and Law rence (partial) Counties in Kentucky. Cabell County, WV, Wayne County, WV, and Lawrence County, OH are represented wit hin the KYOVA Travel Demand Model. Boyd County, KY is repr esented by the KYTC’s Ashland Regional Travel Demand Model. For these areas, information
from the travel demand m odels combined with Highway Performance Monitoring Systems (HPMS) county-level data from each respective area were used in the emissions analysis. For the full or partial counties not encompa ssed within the available travel demand models, HPMS data was re lied upon more heavily for the travel characteristics. Appendix C of this report provides a full description of the data source s and analysis procedures used in this analysis effort.

Overview U.S.EPA published a Federal Register notice 10 

### of availability on March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions Simulator), hereafter referred to as MOVES. Upon publication of the Federal Register notic e, MOVES became U.S. EPA’s approved motor vehicle emission factor model for estimating VOCs, NO
x 

### , CO, PM 10 

### and PM 2.5 

### and other pollutants and precursors from cars, trucks, mo torcycles, and buses by state and local agencies. MOVES is a com puter program designed by the U.S. EPA to estimate air pollution emissions from mobile sources. MOVES replaces U.S. EPA’s prev ious emissions model for onroad mobile sources, MOBI LE6.2. MOVES can be used to estimate exhaust and evaporative em issions as well as brake and tire wear emissions from all types of on-road vehicles.

An updated version of this so ftware, MOVES2010a, was used for the purposes of this analysis. MOVES2010a is a minor update to MOVES2010. MOVES2010a includes general performance improvements from MOVES2010, and also allows users to
account for emissions under new car and light truck energy and greenhouse gas standards.

10 http://www.r egulations.gov/search/Regs/hom e.html#document Detail?R=0900006480ab1f9818 

### The CAA requires U.S. EPA to regul arly update its mobile source
emission models. U.S. EPA c ontinuously collects data and
measures vehicle emissions to ma ke sure the Agency has the best possible understanding of mobile source emissions. This assessment, in turn, informs the development of U.S. EPA’s
mobile source emission models. MOVES represents the Agency’s most up-to-date assessment of on -road mobile source emissions. MOVES also incorporates seve ral changes to the U.S. EPA’s approach to mobile source emission modeling based upon
recommendations made to the A gency by the National Academy
of Sciences.

U.S.EPA believes that MOVES shoul d be used in ozone, CO, PM, and nitrogen dioxide SIP developm ent as expeditiously as possible. The CAA requires that SIP inventories and control measures be based on the most current information and applicable models that are available when a SIP is developed.

Regarding transportation confo rmity, U.S. EPA and U.S. DOT intend to establish a two-year grace period before MOVES is required for new transportation conformity analyses.

The MOVES more detailed approac h (when compared with the previous MOBILE model) to mode ling allows U.S. EPA to easily incorporate large amounts of in-u se data from a wide variety of sources, such as data from v ehicle inspection and maintenance (I/M) programs, remote sensing dev ice (RSD) testing, certification testing, portable emission meas urement systems (PEMS), etc. This approach also allows users to incorporate a variety of activity
data to better estimate emissi on differences such as those resulting from changes to vehicl e speed and acceleration patterns. MOVES has a graphical user interfac e which allows users to more easily set up and run the m odel. MOVES database-centered design provides users much gr eater flexibility regarding output
choices. Unlike earlier models whic h provided emission factors in grams-per-mile in fixed output formats, MOVES output can be expressed as total mass (in tons, pounds, kilograms, or grams) or as emission factors (grams-per-m ile and in some cases grams-pervehicle). Output can be easily aggregated or disaggregated to examine emissions in a range of scales, from national emissions impacts down to the emissions impac ts of individual transportation projects. The database-centered des ign also allows U.S. EPA to update emissions data incorporat ed in MOVES more easily and will allow users to incorporate a much wider array of activity data to improve estimation of local emissions. For example, the19 

### improvements in MOVES will allow pr oject-level PM2.5 emissions
to be estimated.

The latest planning assumptions available for the HuntingtonAshland non-attainment area were used. Both the KYOVA Travel Demand Model and the KYTC Ashland Regional Travel Demand
Model are the most recent and approved regional travel demand models for their respective areas . For each travel demand model, model validation is a join t process between KYOVA and the appropriate state review agencies.

The KYOVA Travel Demand Model is a three step model. Trip generation, trip distribution, and trip assignment components are
included in the model. Mode choi ce is not an element of the
current model. The Travel Dem and Model covers Cabell County, WV, Wayne County, WV, and Lawrenc e County, OH. The current base year for the travel demand model is 2000. Socioeconomic data was forecasted to the year 2035 as a part of the most recent regional metropolitan transportati on plan. The QRS II modeling platform was used to develop this model. The KYOVA Interstate Planning Commission’s currently adopt ed transportation plan, titled Huntington-Ironton Area Transportati on Study (HIATS), The Year 2035 Long-Range Transportation Plan was prepared in May 2009. Appendix C of this document c ontains the assumptions and methodology used to develop the Travel Demand Model.

Similar to the KYOVA Travel De mand Model, the Ashland Regional
Travel Demand Model is a traditi onal three-step model. The model includes trip generation, trip di stribution, and trip assignment components. Transit operations ar e not included in the model; as a result, there is no mode choice component. The Travel Demand Model covers Boyd and Greenup Count ies in Kentucky. Updated in 2007, this model has a base year of 2007 and a final horizon year of 2040. 2010, 2020, and 2030 forecast years were also incorporated into the model. T he TransCAD modeling platform was used to develop this model . The document titled Ashland Regional Travel Demand Model, Model Update Report was developed in January 2008 for the Kentucky Tr ansportation Cabinet. This document contains the assump tions and methodology used to develop the current Travel Demand Model.

For areas of our modeling regi on within a county with a travel demand model, information from this model was applied for the analysis. Specifically, VMT data in the HPMS vehicle class format and ramp fractions for rural and urban restricted roadways were
obtained from the travel demand models. For areas outside of the20 

### travel demand model extents, ramp fractions were assumed to mirror those seen in their respective states. HPMS vehicle class
VMTs for areas outside the tr avel demand model limits were
derived and forecasted from current HPMS traffic data in those

areas.

In addition to the information above, numerous additional data
sources were consulted to obt ain the needed information for the MOVES software. Source type population and vehicle age
distribution data were obtained from ODOT, WVDEP, and KYTC for their respective states. ODOT and KYTC provided data about hourly vehicle distributions. Gu idance and data for meteorological, fuel supply, and fuel formulati on data was obtained from ODOT and KDAQ. The KYOVA supplied information on the transit vehicle population for the region.

The analysis was performed using t he emission rates method. As a result, post-processing of the dat a was required to arrive at the overall emissions output. To do this , the rate per di stance and rate per vehicle output data were matched with the appropriate geographic area, analysis year, source types, pollutant types, road types, modeling hours, and s peed classes and then aggregated with the corresponding source ty pe population and vehicle miles
traveled information. The result ing information was summarized by pollutant type for each full or partial county being analyzed to generate the overall emissions in tons per year. Appendix C provides additional detail on the data sources gathered, modeling assumptions, and post-processing steps.

On-Road Mobile Emission Estimations Tables 2 through 12 contain the results of the emissions analysis for the appropriate years. All emissions estimations are expressed in tons per year (tpy).

Table 2 - Adams County (partial), Ohio Emissions Estimations for
On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 122.49 103.66 54.82 26.21

SO2 (tpy) 2.10 0.71 0.32 0.32

PM2.5 (tpy) 4.20 3.69 2.17 1.39

Annual VMT 34,049,176 35,647,156 39,080,671 42,602,71721 

### Table 3 – Gallia County (partial), Ohio Emissions Estimations for
On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 59.34 50.43 26.89 12.94

SO2 (tpy) 1.02 0.34 0.16 0.16

PM2.5 (tpy) 2.03 1.81 1.06 0.68

Annual VMT 16,493,759 17,341,207 19,175,027 21,051,915



### Table 4 – Lawrence County, Ohio Emissions Estimations for OnRoad Mobile Sources

2005 2008 2015 2022

NOx (tpy) 1,692.81 1,403.49 759.82 397.98

SO2 (tpy) 28.08 9.16 4.14 4.48

PM2.5 (tpy) 57.15 48.87 28.76 20.08

Annual VMT 449,711,752 457,366,121 503,049,909 595,949,04

9



### Table 5 – Scioto County, Ohio Emissions Estimations for On-Road
Mobile Sources

2005 2008 2015 2022

NOx (tpy) 2,081.20 1,761.97 983.09 486.95

SO2 (tpy) 34.53 11.52 5.39 5.47

PM2.5 (tpy) 70.26 61.40 37.35 24.56

Annual VMT 552,962,632 575,354,151 655,158,989 728,816,580



### Table 6 – Summary of Ohio Emissions Estimations for On-Road
Mobile Sources

2005 2008 2015 2022

NO
x (tpy) 3,955.84 3,319.55 1,824.62 924.08

SO 2 (tpy) 65.73 21.73 10.01 10.43

PM 2.5 (tpy) 133.64 115.77 69.34 46.71

Annual VMT 1,053,217,31

9 1,085,708,63

5 1,216,464,59

6 1,388,420,26

1



### Table 7 – Boyd County, Kentucky Emissions Estimations for OnRoad Mobile Sources

2005 2008 2015 2022

NOx (tpy) 2,673.25 2,172.59 1,154.59 647.64

SO2 (tpy) 11.89 11.62 11.89 12.12

PM2.5 (tpy) 114.31 97.91 51.16 29.08

Annual VMT 488,758,339 473,274,668 510,947,840 560,930,98422 

### Table 8 – Lawrence County (par tial), Kentucky Emissions
Estimations for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 170.69 139.16 70.54 37.96

SO2 (tpy) 0.76 0.74 0.73 0.71

PM2.5 (tpy) 7.30 6.27 3.12 1.69

Annual VMT 31,232,092 30,348,132 31,171,751 32,686,140



### Table 9 – Summary of Kentucky Emissions Estimations for OnRoad Mobile Sources

2005 2008 2015 2022

NO
x (tpy) 2,843.94 2,311.75 1,225.13 685.60

SO 2 (tpy) 12.65 12.36 12.62 12.83

PM 2.5 (tpy) 121.61 104.18 54.28 30.77

Annual VMT 519,990,431 503,622,800 542,119,591 593,617,124



### Table 10 – Cabell County, West Virginia Emissions Estimations
for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 4,262.48 3,504.59 1,702.34 847.76

SO2 (tpy) 81.13 21.95 9.39 9.13

PM2.5 (tpy) 173.92 151.98 80.07 43.32

Annual VMT 960,538,915 989,243,546 1,059,033,672 1,140,870,56

3



### Table 11 – Mason County (partial ), West Virginia Emissions
Estimations for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 31.12 27.36 15.33 8.72

SO2 (tpy) 0.54 0.16 0.07 0.08

PM2.5 (tpy) 1.19 1.09 0.64 0.38

Annual VMT 6,176,333 6,741,932 8,005,850 9,286,512



### Table 12 – Wayne County, West Virginia Emissions Estimations
for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 1,720.01 1,432.79 676.93 386.80

SO2 (tpy) 32.87 9.02 3.76 4.26

PM2.5 (tpy) 70.36 62.37 32.03 20.13

Annual VMT 389,577,827 407,030,689 424,609,965 533,508,78123 

### Table 13 – Summary of West Virginia Emissions Estimations for
On-Road Mobile Sources

2005 2008 2015 2022

NO
x (tpy) 6,013.61 4,964.74 2,394.60 1,243.28

SO 2 (tpy) 114.54 31.13 13.22 13.47

PM 2.5 (tpy) 245.47 215.44 112.74 63.83

Annual VMT 1,356,293,075 1,403,016,167 1,491,649,48

7 1,683,665,856



### Table 14 – Emissions Estimations Totals for On-Road Mobile Sources for the Huntington-Ashland Area

2005 2008 2015 2022

NO
x (tpy) 12,813.39 10,596.04 5,444.35 2,852.96

SO 2 (tpy) 192.92 65.22 35.85 36.73

PM 2.5 (tpy) 500.72 435.39 236.36 141.31

Annual VMT 2,929,500,825 2,992,347,602 3,250,233,674 3,665,703,241



### The following table identif ies the percentage of mob ile emissions of all emissions, as identified under Appendix E, for each pollutant in the entire Huntington-Ashland area and Ohio’s portion of this area for 2015 and
2022.

Table 15 – Percent of Mobile Emissions for the HuntingtonAshland Area in 2015 and 2022 – With Apportionment Analysis for partial nonattainment areas

NO
x SO 2 PM 2.5

2015 2022 2015 2022 2015 2022

Huntington

‐ Ashland Area Total (tpy) 91,143.28 67,259.54 149,334.67 113,368.65 9,328.97 9,183.65

Mobile (tpy) 5,444.35 2,852.96 35.85 36.73 236.36 141.31

% Mobile 5.97% 4.24% 0.02% 0.03% 2.53% 1.54%

Ohio Portion Total (tpy) 54,804.31 35,561.33 70,174.55 44,625.35 5,379.15 5,313.53

Mobile (tpy) 1,824.62 924.08 10.01 10.43 69.34 46.71

% Mobile 3.33% 2.60% 0.01% 0.02% 1.29% 0.88%24 

### SO 2 

### constitutes less than one per cent (<1%) of the area’s
total SO 2 

### emissions in the 2015 and 2022 horizon years.

NO
x 

### constitutes less than six percent (<6%) of the area’s
total NO
x 

### emissions in the 2015 and 2022 horizon years.

PM 2.5 

### constitutes less than three percent (<3%) of the
area’s total PM 2.5 

### emissions in the 2015 and 2022 horizon

years.

Therefore, the Ohio EPA is herein making a finding that the area’s highway emissions for PM 2.5 

### , NO
x 

### , and SO 2 

### continue to be insignificant
contributors to the nonattainment problem of the Huntington-Ashland area, as agreed upon as a par t of the interagency consultation process. Moreover, the results from Table 15 show emissions adjusted for partial
nonattainment areas and does not inclu de Non-EGU emission sources in partial areas (refer to Appendix E) , providing higher percentages of mobile emissions (for all three po llutants) and showing a conservative (overestimated) percentage of mobile em issions. Because of this finding it is not necessary to establish mobile emission budgets for this area in the 2015 and 2022 horizon years.

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

### standard.

Background In consultation with U.S. EPA, Ohio EPA selected the year 2022 as the maintenance year for th is redesignation request. This document contains projected em issions inventories for 2015 and
2022.

Emission projections for the Huntington-Ashland area were performed using the following approaches:

• As performed by Kimley-Horn and Associates Inc., mobile source emission projections are based on the U.S. EPA MOVES model. The analysis is described in more detail in Appendix C. All projections we re made in accordance with “Procedures for Preparing Em issions Projections” U.S.
EPA-45/4-91-019. As discuss ed above, it was determined25 

### that the mobile emission cont ribution as a percent of the total emission inventory from the area is not significant.

• Emissions inventories are requi red to be projected to future dates to assess the influence growth and future controls will have. LADCO has developed grow th and control files for point, area, and non-road categorie s. These files were used to develop the future-year emissions estimates used in this
document. This was done so the inventories used for redesignation are consistent with modeling performed in the future. Appendix D contains LADCO’s technical support document detailing the analysis used to project emissions (Base M 11 

### ).

• For the Ohio portion of the Huntington-Ashland area, for the 2008 attainment year, emissions were grown from the 2005 LADCO modeling inventory, usi ng LADCO’s growth factors, for all sectors except point sources (electrical generating units and non-electrical generat ing units). Point source
emissions for 2008 were co mpiled from Ohio EPA’s 2008 annual emissions inventory database. The 2015 interim year emissions were es timated based on the 2009 and 2018 LADCO modeling inventory, using LADCO’s growth factors, for all sectors. The 2022 maintenance year is
based on emissions estima tes from the 2018 LADCO modeling.

The detailed inventory informati on for the Ohio portion of the Huntington-Ashland area for 2005 is in Appendix B. Emission trends are an important gauge for continued compliance with the
PM 2.5 

### standard. Therefore, Oh io EPA performed an initial comparison of the inventories for the base year and maintenance years. Mobile source emission in ventories are described in Section 5 of Appendix B.

Sectors included in the following tabl es are: Electrical Generating Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Ar ea (Other); Marine; Aircraft; Rail (MAR); and On-road Mobile (On-road).

Ohio EPA is identifying emissi ons projections for 2015 and 2022 for EGUs with implementation of the CAIR program. U.S. EPA has raised concerns regarding the CA IR program and its remand. However, as discussed bel ow, with the proposed CAIR

11 http://www.ladco.org/tech/emis/current/i ndex.php26 

### replacement, the Transport Rule, Ohio EPA believes these are the most appropriate and accurate future projections.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28
eastern states and the District of Columbia to significantly reduce
emissions of NO
x 

### and SO 2 

### . CAIR replaced the NOx SIP Call for
EGUs. The intent of the CAIR program is for national NO
x 

### emissions to be cut from 4.5 milli on tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were required to submit a CA IR SIP as part of this effort.
Ohio submitted a CAIR SIP wh ich was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final action on Sept ember 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA projec ts that in 2009 emissions of NO
x 

### will decrease from a baseline of 264,000 tons per year to 93,000 tons per year while in 2010 emissions of SO 2 

### will decrease from a baseline of 1,373,000 tons per y ear to 298,000 tons per year, within Ohio. And by 2015 U.S. EPA projects emissions of NO
x 

### will decrease to 83,000 tons per y ear while emissions of SO 2 

### will decrease to 208,000 tons per year, within Ohio 12



### .

On December 23, 2008, U.S. EPA’ s CAIR program was remanded without vacatur by the D.C. Circu it Court. As mentioned above, Ohio EPA has not incorporated t hese expected CAIR reductions into this redesignation request. It should also be noted that Ohio’s SIP-approved NOx SIP Ca ll program and regulat ions are still in place. Ohio EPA is currently in the process of revising these regulations to provide a “back st op” for the reinst atement of the NOx SIP Call program in the event the CAIR program, or an equivalent, is no longer implemented by U.S. EPA.

As can be seen in Table 15 below , Ohio has seen a significant decline in the 264, 000 tons of NO
x 

### and 1,373,000 tons of SO 2 

### emitted in 2005. In 2008 and 2009 facilities began preparing for and implementing control programs to address CAIR 13 

### and
consent decrees.

Table 16 - Reductions in SO 2 

### and NO x 

### EGU Emissions
Between 2008 and 2009

SO 2 NO
x 2008 2009 Change 2008 2009 Change

12 http://www. epa.gov/CAIR/oh.html 13 Under CAIR, NOx reductions are to occur begi nning in 2009 while SO2 reductions are to occur beginning in 2010.27 Ohio 709,444 601,101 15% 235,018 96,351 59%
LADCO States 2,019,036 1,620,071 20% 702,384 393,930 44%

National 7,616,262 5,747,353 25% 2,996,287 1,990,385 34% Source: Clean Air Markets Quarterly Emissions Tracking 14



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

### reductions are to be implemented under CAIR:

Table 17 – Reductions in SO 2 

### and NO x 

### EGU Emissions
Between the First Half of 2008 and 2010

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

Ohio 373,798 279,854 25% 130,598 53,187 59%
LADCO States 1,190,497 854,282 28% 419,114 220,907 47%

National 3,895,472 2,502,965 36% 1,487,179 930,148 37% Source: Clean Air Markets Quarterly Emissions Tracking 15



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

“Based on emissions monitoring data, EPA has observed
substantial reductions in SO 2 

### emissions from 2005 to 2009 and in the first two quarters of 2010 as companies installed more controls, electric demand declined, and low natural gas prices made combined-cycle gas-fired units more competitive in several parts of the country. Thus, even after CAIR's vacatur and subsequent remand in late 2008, t he controls in place generally have continued to operate, helping to drive continued progress in reducing emissions. 16 

### ”

On July 6, 2010, U.S. EPA propos ed a replacement to the CAIR program, the Transport Rule. [75 FR 45210] U.S. EPA intends to finalize the Transport Rule in time for reductions to begin in 2012. As proposed, the Transport Rule will preserve those initial
reductions achieved under CAIR and provide more reductions in
NO
x 

### and SO 2 

### emissions in 2012 and 2014, ahead of the 2015
CAIR Phase 2.

Ohio EPA is in agreement with t he analysis by U.S.EPA that the CAIR program is providing real reductions at this time, Ohio
believes these reductions have assisted with PM 2.5 

### attainment in

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

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

16 http://www. epa.gov/airmarkets/background.htm28 

### this nonattainment ar ea and throughout Ohio. It is also Ohio EPA’s belief that the Transport Rule, when finalized, will continue to provide the necessary reduc tions, and likely even greater reductions, that will be necessary for maintenance of the annual
PM 2.5 

### standard to occur. As stat ed by U.S. EPA regarding the proposed Transport Rule, “the result s of the air quality modeling
indicate that all but one site 17 

### is projected to be in attainment and only one site 18 

### is projected to have a maintenance problem for
annual PM2.5 in 2014 with the em issions reductions expected from this proposal.” [75 FR 45345] Therefore, it is Ohio EPA’s belief it is most appropriate to evaluate Ohio EPA’s demonstration that the projected leve l of emissions is suffi cient to maintain the
annual PM 2.5 

### standard by assessing future year emissions that include the CAIR program. Furt hermore, modeling conducted as part of the Transport Rule projects the Counties within this area
will not have maintenance iss ues in 2014 even without the Transport Rule (or CAIR).

Maintenance is demonstrated w hen the future-year (2022) projected emission totals are below the 2008 attainment year
totals.

The Ohio emissions data in t he tables below are based on the following data sources: - All On-Road data source: Kimley-Horn and Associates Inc.
- 2008 EGU and non-EGU for Ohio: Ohio EPA’s 2008 annual emissions inventory database.
- All other data source: Lake Mich igan Air Directors Consortium (LADCO).

Demonstration

PM 2.5



### The 2005 and 2008 actual PM 2.5 

### emissions data below generally contains particulate fraction emissions only and not the condensable fractions as
Ohio EPA did not have a consistent reporting requirement for those years. U.S. EPA IPM modeling was used to generate future year EGU emissions with the CAIR program . The IPM modeling added additional
PM 2.5 

### condensable emissions into future years. Therefore, comparing base and attainment year emissions with the future year predictions is not accurate in the IPM CAIR modeling. Th is step leads to a false perception of significant PM 2.5 

### emissions growth. Modeling performed by LADCO,

17 Allegheny, PA
18 Birmingham, AL29 

### without CAIR, did not incorporate added condensable fraction emissions. Although Ohio EPA has stated that it is most appropriate to evaluate future year emissions that include the CAIR program, because of this flaw it will be more accurate and appropr iate for the purposes of PM 2.5 

### to evaluate future year emissions without the CAIR program.

Table 18 - Adams County, Ohio PM 2.5 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 3344.63 3585.29 3569.95 3544.65 40.64

Non-EGU 6.90 7.28 13.13 15.64

‐ 8.36

Non-road 15.62 13.28 8.70 4.04 9.24

Area 247.97 278.00 285.55 282.69

‐ 4.69

MAR 7.39 6.79 4.21 1.74 5.05

On-road 4.20 3.69 2.17 1.39 2.30

TOTAL 3,626.71 3,894.33 3,883.71 3,850.15 44.18



### Table 19 - Gallia County, Ohio PM 2.5 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 1,011.4

9 1,031.94 1,073.20 1,100.12

‐ 68.18

Non-EGU 0.00 0.00 0.00 0.00 0.00

Non-road 11.87 10.33 7.22 4.07 6.26

Area 132.22 168.24 181.29 182.52

‐ 14.28

MAR 7.50 6.91 4.32 1.84 5.07

On-road 2.03 1.81 1.06 0.68 1.13

TOTAL 1,165.1

1 1,219.23 1,267.09 1,289.23 ‐ 70.00



### Table 20 - Lawrence County, Ohio PM 2.5 

### Emission Inventory Totals for Base Year 2005, Estimate d 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.00 0.94 0.69 0.14 0.80

Non-EGU 1.21 1.39 1.75 1.90

‐ 0.51

Non-road 13.78 11.67 7.90 4.02 7.65

Area 134.89 134.73 131.79 129.08 5.65

MAR 20.16 17.97 10.67 3.57 14.4030 On-road 57.15 48.87 28.76 20.08 28.79

TOTAL 227.19 215.57 181.56 158.79 56.78



### Table 21 - Scioto County, Ohio PM 2.5 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 84.20 138.92 111.08 102.50 36.42

Non-road 37.43 33.07 22.69 12.33 20.74

Area 199.12 290.87 327.40 330.38

‐ 39.51

MAR 37.29 32.74 18.94 5.44 27.30

On-road 70.26 61.40 37.35 24.56 36.84

TOTAL 428.30 557.00 517.46 475.21 81.79



### Table 22 - Boyd County, Kentucky PM 2.5 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.05 0.01 0.00 0.00 0.01

Non-EGU 1,200.70 1,449.68 1,455.23 1,458.01

‐ 8.33

Non-road 11.15 9.92 7.18 4.42 5.50

Area 345.58 355.57 377.29 386.49

‐ 30.92

MAR 113.42 110.64 86.34 63.71 46.93

On-road 114.31 97.91 51.16 29.08 68.83

TOTAL 1,785.21 2,023.73 1,977.20 1,941.71 82.02



### Table 23 - Lawrence County, Kentucky PM 2.5 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 400.00 407.67 422.88 433.23

‐ 25.56

Non-EGU 22.49 22.70 24.86 25.79

‐ 3.09

Non-road 9.68 9.77 7.21 4.91 4.86

Area 88.84 90.74 91.70 92.09

‐ 1.35

MAR 18.79 17.82 13.33 9.05 8.77

On-road 7.30 6.27 3.12 1.69 4.58

TOTAL 547.10 554.97 563.10 566.76 11.7931 

### Table 24 - Cabell County, West Virginia PM 2.5 

### Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 316.84 345.42 408.05 440.72

‐ 95.30

Non-road 31.58 30.57 22.72 15.39 15.18

Area 356.40 353.80 357.80 360.85

‐ 7.05

MAR 44.99 42.41 31.61 21.25 21.16

On-road 173.92 151.98 80.07 43.32 108.66

TOTAL 923.73 924.18 900.25 881.53 42.65



### Table 25 - Mason County, West Virginia PM 2.5 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU
Point 245.67 244.58 259.80 266.33

‐ 21.75

Non-EGU 5.80 5.73 6.49 6.81

‐ 1.08

Non-road 16.45 13.94 9.38 4.70 9.24

Area 135.88 136.83 139.42 141.99

‐ 5.16

MAR 47.73 46.01 35.53 25.66 20.35

On-road 1.19 1.09 0.64 0.38 0.71

TOTAL 452.72 448.18 451.26 445.87 2.31



### Table 26 - Wayne County, West Virginia PM 2.5 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 3.36 3.85 1.16 0.01 3.84

Non-EGU 48.01 51.14 54.62 56.11

‐ 4.97

Non-road 11.09 9.62 6.97 4.24 5.38

Area 188.18 185.27 182.15 178.69 6.58

MAR 107.34 104.45 81.73 60.51 43.94

On-road 70.36 62.37 32.03 20.13 42.24

TOTAL 428.34 416.70 358.66 319.69 97.0132 

### Table 27 – Huntington-Ashland Area PM 2.5 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and projected 2015 and 2022 (tpy) – Without CAIR

PM 2.5 2005
Base 2008
Attainment 2015
Interim 2022
Maintenanc

e Safety Margin

Adams, OH 3,626.71 3,894.33 3,883.71 3,850.15 44.18
Gallia, OH 1,165.11 1,219.23 1,267.09 1,289.23 ‐ 70.00
Lawrence, OH 227.19 215.57 181.56 158.79 56.78
Scioto, OH 428.30 557.00 517.46 475.21 81.79
Boyd, KY 1,785.21 2,023.73 1,977.20 1,941.71 82.02
Lawrence, KY 547.10 554.97 563.10 566.76 ‐ 11.79
Cabell, WV 923.73 924.18 900.25 881.53 42.65
Mason, WV 452.72 448.18 451.26 445.87 2.31
Wayne, WV 428.34 416.70 358.66 319.69 97.01

COMBINED PM 2.5 TOTAL 9,584.41 10,253.89 10,100.29 9,928.94 324.95



### NO x



### Table 28 - Adams County, Ohio NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 30,205.82 31,258.94 25,671.39 23,276.73 7,982.21

Non-EGU 665.42 703.45 1,266.52 1,770.27

‐ 1,066.82

Non-road 142.28 128.52 92.82 57.47 71.05

Area 127.85 132.58 134.84 137.93

‐ 5.35

MAR 325.30 307.93 199.67 97.77 210.16

On-road 122.49 103.66 54.82 26.21 77.45

TOTAL 31,589.16 32,635.08 27,420.06 25,366.38 7,268.70



### Table 29 - Gallia County, Ohio NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenanc

e Safety Margin

EGU Point 57,523.60 59,688.25 24,476.65 9,385.96 50,302.29

Non-EGU 0.00 0.00 0.00 0.00 0.00

Non-road 110.23 96.65 67.88 38.85 57.80

Area 122.81 128.27 131.45 135.53

‐ 7.26

MAR 316.92 299.78 194.41 95.18 204.60

On-road 59.34 50.43 26.89 12.94 37.4933 TOTAL 58,132.90 60,263.38 24,897.28 9,668.46 50,594.92



### Table 30 - Lawrence County, Ohio NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.00 96.19 105.90 110.06

‐ 13.87

Non-EGU 68.51 77.46 97.06 154.65

‐ 77.19

Non-road 165.50 142.30 92.01 41.36 100.94

Area 232.73 235.97 238.92 242.31

‐ 6.34

MAR 785.48 736.28 477.77 232.77 503.51

On-road 1,692.81 1,403.49 759.82 397.98 1,005.51

TOTAL 2,945.03 2,691.69 1,771.48 1,179.13 1,512.56



### Table 31 - Scioto County, Ohio NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 570.12 659.89 512.83 407.21 252.68

Non-road 324.89 281.37 185.85 89.77 191.60

Area 240.86 254.58 262.42 272.52

‐ 17.94

MAR 1,337.52 1,245.14 805.82 387.53 857.61

On-road 2,081.20 1,761.97 983.09 486.95 1,275.02

TOTAL 4,554.59 4,202.95 2,750.01 1,643.98 2,558.97



### Table 32 - Boyd County, Kentucky NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 39.41 9.85 2.96 0.00 9.85

Non-EGU 6,943.93 7,116.32 7,453.89 7,803.35

‐ 687.03

Non-road 171.09 150.58 100.47 50.57 100.01

Area 41.22 43.92 50.02 56.14

‐ 12.22

MAR 3,035.45 2,966.48 2,213.06 1,515.33 1,451.15

On-road 2,673.25 2,172.59 1,154.59 647.64 1,524.95

TOTAL 12,904.35 12,459.74 10,974.99 10,073.03 2,386.7134 

### Table 33 - Lawrence County, Kentucky NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 12,468.19 4,735.62 2,997.63 2,252.78 2,482.84

Non-EGU 2.72 1.95 1.85 1.43 0.52

Non-road 57.97 54.40 41.05 28.16 26.24

Area 85.89 88.43 92.45 96.64

‐ 8.21

MAR 635.31 613.37 444.15 286.03 327.34

On-road 170.69 139.16 70.54 37.96 101.20

TOTAL 13,420.77 5,632.93 3,647.67 2,703.00 2,929.93



### Table 34 – Cabell County, West Virginia NO x 

### Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 244.27 246.61 278.40 305.36

‐ 58.75

Non-road 316.80 284.81 202.59 121.07 163.74

Area 669.93 678.75 757.21 830.23

‐ 151.48

MAR 1,578.63 1,566.32 1,205.55 875.99 690.33

On-road 4,262.48 3,504.59 1,702.34 847.76 2,656.83

TOTAL 7,072.11 6,281.08 4,146.09 2,980.41 3,300.67



### Table 35 – Mason County, West Virginia NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 21,694.07 13,490.21 11,957.32 11,300.37 2,189.84

Non-EGU 80.53 82.91 91.22 99.02

‐ 16.11

Non-road 160.56 153.38 124.24 96.26 57.12

Area 356.63 368.52 391.32 414.58

‐ 46.06

MAR 1,334.41 1,303.31 971.05 663.19 640.12

On-road 31.12 27.36 15.33 8.72 18.64

TOTAL 23,657.32 15,425.69 13,550.48 12,582.14 2,843.5535 

### Table 36 – Wayne County, West Virginia NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 60.51 15.13 7.32 3.97 11.16

Non-EGU 3,279.16 2,817.34 2,847.64 2,674.22 143.12

Non-road 117.56 109.12 87.13 65.37 43.75

Area 156.84 159.33 175.43 190.56

‐ 31.23

MAR 2,872.80 2,846.00 2,184.79 1,579.84 1,266.16

On-road 1,720.01 1,432.79 676.93 386.80 1,045.99

TOTAL 8,206.88 7,379.71 5,979.24 4,900.76 2,478.95



### Table 37 - Huntington-Ashland Area NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

NOx 2005 Base 2008
Attainment 2015
Interim 2022
Maintenanc

e Safety Margin

Adams, OH 31,589.16 32,635.08 27,420.06 25,366.38 7,268.70
Gallia, OH 58,132.90 60,263.38 24,897.28 9,668.46 50,594.92
Lawrence, OH 2,945.03 2,691.69 1,771.48 1,179.13 1,512.56
Scioto, OH 4,554.59 4,202.95 2,750.01 1,643.98 2,558.97
Boyd, KY 12,904.35 12,459.74 10,974.99 10,073.03 2,386.71
Lawrence, KY 13,420.77 5,632.93 3,647.67 2,703.00 2,929.93
Cabell, WV 7,072.11 6,281.08 4,146.09 2,980.41 3,300.67
Mason, WV 23,657.32 15,425.69 13,550.48 12,582.14 2,843.55
Wayne, WV 8,206.88 7,379.71 5,979.24 4,900.76 2,478.95

COMBINED NOx
TOTAL 162,483.11 146,972.25 95,137.30 71,097.29 75,874.96



### SO 2



### Table 38 - Adams County, Ohio SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenanc

e Safety Margin

EGU Point 125,070.34 35,946.20 27,077.57 23,276.73 12,669.47

Non-EGU 4.37 3.73 8.04 11.62

‐ 7.89

Non-road 15.33 5.67 0.91 0.14 5.53

Area 33.56 33.54 31.73 30.08 3.46

MAR 28.54 19.33 6.61 1.79 17.54

On-road 2.10 0.71 0.32 0.32 0.3936 TOTAL 125,154.24 36,009.18 27,125.18 23,320.68 12,688.50



### Table 39 - Gallia County, Ohio SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenanc

e Safety Margin

EGU Point 100,102.91 91,889.46 41,924.16 20,510.45 71,379.01

Non-EGU 0.00 0.00 0.00 0.00 0.00

Non-road 10.76 3.98 0.67 0.15 3.83

Area 16.36 16.60 15.91 15.35 1.25

MAR 27.78 19.07 6.90 2.26 16.81

On-road 1.02 0.34 0.16 0.16 0.18

TOTAL 100,158.83 91,929.45 41,947.80 20,528.37 71,401.08



### Table 40 - Lawrence County, Ohio SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenanc

e Safety Margin

EGU Point 0.00 0.69 0.21 0.00 0.69

Non-EGU 0.24 0.05 0.35 0.55

‐ 0.50

Non-road 18.98 6.95 1.11 0.19 6.76

Area 30.33 29.94 28.93 27.94 2.00

MAR 68.18 53.99 29.93 5.03 48.96

On-road 28.08 9.16 4.14 4.48 4.68

TOTAL 145.81 100.78 64.67 38.19 62.59



### Table 41 - Scioto County, Ohio SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 977.12 1,477.24 993.09 723.09 754.15

Non-road 36.15 13.28 2.17 0.42 12.86

Area 36.63 37.53 35.89 34.61 2.92

MAR 116.50 100.91 66.76 32.41 68.50

On-road 34.53 11.52 5.39 5.47 6.05

TOTAL 1,200.93 1,640.48 1,103.30 796.00 844.4837 

### Table 42 - Boyd County, Kentucky SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005

Base 2008
Attainment 2015 Interim 2022
Maintenance Safety Margin

EGU
Point 1.14 0.29 0.09 0.00 0.29

Non-EGU 9,650.25 10,188.42 11,065.41 12,012.04

‐ 1,823.62

Non-road 8.46 3.67 0.85 0.24 3.43

Area 554.34 569.78 594.03 619.38

‐ 49.60

MAR* 426.27 387.85 292.02 196.77 191.08

On-road 11.89 11.62 11.89 12.12

‐ 0.50

TOTAL 10,652.35 11,161.63 11,964.29 12,840.55

‐ 1,678.92



### Table 43 - Lawrence County, Kentucky SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 49,858.09 40,717.49 20,475.34 11,800.13 28,917.36

Non-EGU 1.55 1.49 1.45 1.40 0.09

Non-road 4.06 1.76 0.41 0.12 1.64

Area 96.74 99.37 98.36 98.02 1.35

MAR 66.03 54.52 38.28 21.04 33.48

On-road 0.76 0.74 0.73 0.71 0.03

TOTAL 50,027.23 40,875.37 20,614.57 11,921.42 28,953.95



### Table 44 - Cabell County, West Virginia SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenanc

e Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 118.63 118.03 141.50 160.39

‐ 42.36

Non-road 16.75 7.30 1.75 0.56 6.74

Area 1,457.65 1,503.71 1,598.18 1,693.86

‐ 190.15

MAR 53.52 23.87 5.55 1.33 22.54

On-road 81.13 21.95 9.39 9.13 12.82

TOTAL 1,727.68 1,674.86 1,756.37 1,865.27

‐ 190.4138 

### Table 45 - Mason County, West Virginia SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 82,132.82 50,518.10 44,094.05 41,340.89 9,177.21

Non-EGU 1.91 1.90 2.13 2.32

‐ 0.42

Non-road 10.40 4.53 1.03 0.25 4.28

Area 119.53 120.73 123.14 125.60

‐ 4.87

MAR 42.13 18.81 4.38 1.06 17.75

On-road 0.54 0.16 0.07 0.08 0.08

TOTAL 82,307.33 50,664.23 44,224.80 41,470.20 9,194.03



### Table 46 - Wayne County, West Virginia SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005

Base 2008
Attainment 2015
Interim 2022
Maintenance Safety Margin

EGU Point 0.53 0.13 0.04 0.00 0.13

Non-EGU 285.67 277.75 281.84 281.79

‐ 4.04

Non-road 6.96 2.99 0.68 0.19 2.80

Area 490.95 507.00 540.51 574.39

‐ 67.39

MAR 98.34 48.22 19.46 13.44 34.78

On-road 32.87 9.02 3.76 4.26 4.76

TOTAL 915.32 845.11 846.29 874.07

‐ 28.96



### Table 47 - Huntington-Ashland Area SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

SO 2 2005 Base 2008
Attainment 2015
Interim 2022
Maintenanc

e Safety Margin

Adams, OH 125,154.24 36,009.18 27,125.18 23,320.68 12,688.50
Gallia, OH 100,158.83 91,929.45 41,947.80 20,528.37 71,401.08
Lawrence, OH 145.81 100.78 64.67 38.19 62.59 Scioto, OH 1,200.93 1,640.48 1,103.30 796.00 844.48 Boyd, KY 10,652.35 11,161.63 11,964.29 12,840.55

‐ 1,678.92
Lawrence, KY 50,027.23 40,875.37 20,614.57 11,921.42 28,953.95 Cabell, WV 1,727.68 1,674.86 1,756.37 1,865.27

‐ 190.41
Mason, WV 82,307.33 50,664.23 44,224.80 41,470.20 9,194.03 Wayne, WV 915.32 845.11 846.29 874.07

‐ 28.96

COMBINED
SO 2 TOTAL 372,289.72 234,901.09 149,647.27 113,654.75 121,246.3439 

### PM 2.5 

### , NO x 

### , and SO 2



### Table 48 - Huntington-Ashland Area Comparison of 2008
Attainment Year and 2015 and 2022 Projected Emission Estimates (tpy)

2008 Base 2015
Interim 2015 Projected
Decrease 2022
Maintenance 2022 Projected
Decrease

PM 2.5 10,253.89 10,100.29 153.60 9,928.94 324.95

NO
x 146,972.25 95,137.30 51,834.95 71,097.29 75,874.96

SO 2 234,901.09 149,647.27 85,253.82 113,654.75 121,246.34



### As shown in the t able above (Table 48), PM 2.5 

### emissions in the nonattainment area are projected to decrease by 153.60 tpy in 2015 and 324.95 tpy in 2022. NO
x 

### emissions in the nonattainment area are projected to decr ease by 51,834.95 tpy in 2015 and 75,874.96 tpy in 2022. SO 2 

### emissions in the nonattainment area are projected to decline by 85,253.82 tpy in 2015 and 121,246.34
in 2022.

Area source emissions and, to a le sser 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 t he Transport Rule will be implemented in 2012 and 2014 and t hese programs should cause an overall drop in all three pollu tants emissions. Decreases from U.S. EPA rules covering Tier 2 Mo tor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 19 

### , Highway Heavy-Duty Engine Rule 20 

### , and the Non-Road Diesel Engine Rule 21 

### are factored into the changes.

In addition to the above, the General J.M. Gavin St ation (AEP) in Gallia County implemented changes in 2009. The two units, #1 and #2 (each 1300 megawatt) were required by a federally enforceable consent decree to oper ate their SNCRs continuously,
to control and reduce NOx emissi ons, by December 2009. Also the Kyger Creek Station in Gallia County (units #1, #2, #3, #4, and #5) has installed SNCRs (t o reduce NOx emission) which they have been running continuous ly since January 2009. In addition, Kyger Creek Station has plans underway for installation of FGDs (to reduce SO 2 

### emissions). They are expecting the FGDs to be operational in 2012. Finally, the J.M. Stuart DP&L

19 http://www. epa.gov/fedrgstr/EPA-AIR/2000/ February/Day-10/a19a.htm 20 http://www. epa.gov/fedrgstr/EPA-AIR/1997 /October/Day-21/a27494.htm 21 http://www. epa.gov/fedrgstr/EPA-AIR/1998 /October/Day-23/a24836.htm40 

### Station in Adams County incorpor ated (in units #1, #2, #3, and #4) through a federally enforceable consent decree, year around operation of SNCR controls in 2009 to reduce NOx emissions.

Requirement 4 of 5
A demonstration that improvement in air quality bet ween the year violations occurred and the year attainment wa s achieved is based on permanent and
enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background Ambient air quality data from all monito ring sites indicate that air quality met the NAAQS for PM 2.5 

### in 2008-2010. U.S. EPA’s redesignation guidance (p 9) states: “A state ma y generally demonstrate maintenance of the NAAQS by either showing that fu ture emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the future mix of sources and emissions rates will not cause a violation of the NAAQS.”

Demonstration
Permanent and enforceable reductions of PM 2.5 

### , NO
x 

### , and SO 2 

### emissions
have contributed to the attainment of the annual PM 2.5 

### standard. Some of
these reductions were realized due to the application of tighter federal
standards on non-road diesel vehicles (Clean Air Non-road Diesel Rule), the application of tighter federal standards on new vehi cles, Title IV of the CAA, the NO
x 

### SIP Call, CAIR, and federal consent decrees requiring the
reductions of SO 2 

### and NO
x 

### emissions from utility sources. Reductions achieved are discussed in great er detail under Chapter Five.

Table 49 - Huntington-Ashland Area Combined Comparison of2005 base year and 2008 attainment year on-road, nonroad and EGU reductions

2005 2008

On-road PM 2.5 500.72 435.39

On-road NO

x 12,813.39 10,596.04

On-road SO 2 192.92 65.22

Non-road PM 2.5 158.65 142.17
Non-road NO

x 1,566.88 1,401.13
Non-road SO 2 127.85 50.13
EGU PM 2.5 5,005.20 5,274.28
EGU NO

x 121,991.60 109,294.19
EGU SO 2 357,165.83 219,072.3641 

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

Demonstration In Ohio, major point sources in a ll counties are required to submit air emissions information annually, in accordance with U.S. EPA’s Consolidated Emissions Reporti ng Rule (CERR). Ohio EPA prepares a new periodic inventory for all PM 2.5 

### precursor emission sectors every three years. These PM 2.5 

### precursor inventories will be prepared for future years as necessary to comply with the inventory reporting requirement s established in the CFR. Emissions information will be compared to the 2005 base year and the 2022 projected maintenance y ear inventories to assess emission trends, as necessary, and to assure continued compliance with the annual PM 2.5 

### standard.42 

## CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS CAA Section107 (d)(3)(E)(ii), 107( d)(3)(iv), and 107(d)(3)(E)(v)

Requirement 1 of 6 Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with nonattainment areas to implement RACM and RACT.

Background Section 172(c)(1) of the 1990 Cl ean Air Act Amendments requires
states with nonattainment areas to submit a SIP providing for implementation of all reasonably available control measures as expeditiously as practicable (i ncluding such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimu m, of reasonable available control technology).

U.S. EPA’s Implementati on Rule interprets this requirement in great detail. Under U.S. EPA’s appr oach, RACT is determined as part of the broader RACM analysi s and identification of all measures (for stationary, mob ile, and area sources) that are technically and economically feasib le, and that would collectively contribute to advancing the attain ment date (i.e. by one year or more). States are required to use a combined approach to RACT and RACM, that (1) identifies potential measures that are reasonable, (2) uses modeling to i dentify the attainment date that is as expeditious as practicabl e, and (3) selects the appropriate
RACT and RACM.

The Implementation Rule also prov ides for a presumption that in
States that fulfill their CAIR em ission reduction requirements, EGU compliance with CAIR is equivalent to RACM/RACT.

Demonstration In 1972, 1980, and 1991, Ohio pr omulgated rules requiring reasonably available controls meas ures for particulate emissions from stationary sources.

Statewide RACT rules have been applied to all new sources locating in Ohio since that time. RACT requirements are incorporated into permits along wit h monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA
also has an active enforcement program to address violations43 

### discovered by field office sta ff. The Ohio RACT rules for particulate matter are found in OAC Chapter 3745-17 22



### .

In addition, Ohio EPA promulgated NO
x 

### SIP Call rules (OAC Chapter 3745-14 23 

### ), CAIR (OAC Chapter 3745-109 24 

### ), and NO
x 

### Reasonably Available Control Technology rules (OAC Chapter

3745-110 25 

### ) over the past five years. Emissions from EGUs make up a significant contribution to Oh io’s inventory. Beginning in 2009, Ohio implemented CAIR which has, and will, provide for significant
reductions in NO
x 

### , PM 2.5 

### , and SO 2 

### until such time it is replaced by U.S. EPA’s proposed Transport Rule . Then the Transport Rule will provide for even greater reductions.

As part of a larger initiative , LADCO, in consultation with two contractors, performed a series of studies exploring control measures for reducing bot h ozone precursors and PM 2.5 

### precursors in Ohio, Illinois, I ndiana, Michigan, and Wisconsin area. The first consultant, MACTEC, prepared a series of white papers 26 

### researching different stationary source categories. The results were compiled into two reports 27 

### . The second consultant, Environ, investigated control options for m obile sources. The results were compiled into two reports 28 

### . The stationary and mobile source sectors (and associated control m easures) were selected by the
LADCO States based on several fa ctors presented in the report (See Chapter 2).

Photochemical modeling was t hen conducted (as part of LADCO Round 4 modeling) to assess t he air quality benefit of the
candidate control measures and a modeling report was developed 29 

### . Based on the results, the LA DCO project team felt it would not be possible to advance the attainment date for PM 2.5



### . Ohio EPA, in its attainment dem onstration submitted on July 18, 2008, demonstrated (using a weight of evidence approach) that

22 http://www. epa.ohio.gov/dapc/r egs/3745_17.aspx 23 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx

24 http://www. epa.ohio.gov/dapc/r egs/3745_109.aspx

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

26 http://www.ladco.org/r eports/control/white_papers

27 http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_i_april_2005.pdf; http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_ii_june_2006.pdf

28 http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_february_2006.pdf; http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_for_ladc o_states_in_2009_and_2012_march_2007.pdf

29 http://www.ladco.org/r eports/control/mode ling/round4_modeling.pdf44 

### attainment would be achieved in this area by 2009. Because of a projected 2009 attainment date, it would not have been reasonably possible or practicable for Ohio to develop RACT/RACM requirements, promulgate regulat ions and implement a control program prior to the proj ected attainment date.

Requirement 2 of 6 Section 172(c)(2) of the 1990 CAA Amendments requires attainment
demonstration SIPs for nonattainment areas to show reasonable further progress (RFP).

Background U.S. EPA’s Implementation Rule requires RFP only for any area which a State projects an atta inment date beyond 2010. The RFP would provide emission reductions showing linear progress
between 2002 and 2009. If a State dem onstrates attainment will occur by 2010 or earlier, U.S. EPA considers the attainment
demonstration to demonstrat e achievement of RFP.

Demonstration
In Ohio’s attainment demonstrat ion submitted on July 18, 2008, Ohio demonstrated (using a weight of evidence approach) that
attainment would be achieved in this area by 2009; and therefore, it was not necessary to submit a separate RFP plan.

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

Background Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions in the area, including the requirement for periodic revisi ons as determined necessary. 40 CFR 51.1008 requires such inventor y to be submitted within three years of designation and requires a baseline emission inventory for calendar year 2002 or other suitable year to be used for attainment planning.

Demonstration The 2005 comprehensive inventory was submitted to U.S. EPA
with Ohio’s PM 2.5 

### attainment demonstration SIP submitted on July 18, 2008. It was then subsequently revised and resubmitted on June 7, 2010.

Ohio also updates its inventor y in accordance with U.S. EPA’s CERR rule (i.e. emissions stat ements). Ohio EPA submitted its45 

### emissions statement SIP on Ma rch 18, 1994 which was approved by U.S. EPA on October 13, 1995 ( 59 FR 51863). As discussed in Chapter 4 (Requirement 4), Ohio EPA submits, and commits to submit, emission inventories (sta tements) every three years.

Requirement 4 of 6
Evidence that control meas ures required in past PM 2.5 

### SIP revisions have been fully implemented.

Background
In addition to the historic RACT requirements for PM, the U.S.
EPA NO
x 

### SIP Call required 22 states to pass rules that would result in significant emissi on reductions from large EGUs, industrial boilers, and cement kiln s in the eastern United States. Ohio passed this rule in 2001. NOx SIP Call requirements are incorporated into permits along wit h monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA
also has an active enforcement program to address violations discovered by field office staff. Compliance is tracked through the
Clean Air Markets data monitori ng program. Beginning in 2004,
this rule accounts for a reduction of approximately 31 percent of all
NO
x 

### emissions statewide compar ed to previous uncontrolled years. The other 21 states al so have adopted these rules.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28
eastern states and the District of Columbia to significantly reduce
emissions of NO
x 

### and SO 2 

### . CAIR replaced the NOx SIP Call for
EGUs. National NO
x 

### emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in
2018 in 28 states. States were r equired to submit a CAIR SIP as part of this effort. Ohio submi tted a CAIR SIP which was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final acti on on September 25, 2009 (74 FR 48857).

Demonstration
Controls for EGUs under the NO
x 

### SIP Call formally commenced May 31, 2004. Emissions cover ed by this program have been generally trending downward sinc e 1998 with larger reductions occurring in 2002 and 2003. Data ta ken from the U.S. EPA Clean Air Markets web site, quantify the gradual NO
x 

### reductions that
have occurred in Ohio as a resu lt of Title IV of the 1990 CAA Amendments and the beginning of the NO
x 

### SIP Call Rule. Ohio developed the NO
x 

### Budget Trading Program rules in OAC Chapter46 

### 3745-14 30 

### in response to the SI P Call. OAC Chapter 3745-14 regulates EGUs and certain non-EGUs under a cap and trade program based on an 85 percent reduc tion of NOx emissions from EGUs and a 60 percent reduction of NO
x 

### emissions from nonEGUs, compared to historical le vels. This cap was in place through 2008, at which time the CAIR program superseded it as discussed above. Requirement 3 of 5 under Chapter 4 above
discussed the reductions Ohio has seen as a result of CAIR.

On April 21, 2004, U.S. EPA published Phase II of the NO x 

### SIP Call that establishes a budget for la rge (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio EPA’s
OAC rule 3745-14-12 addresses stat ionary internal combustion engines, all used in natural gas pipeline transmissions. U.S. EPA approved this revision to the SIP on April 4, 2008. An 82 percent
NO x 

### reduction from 1995 levels is ant icipated. Completion of the compliance plan occurred by May 1, 2006, and the compliance demonstration began May 1, 2007.

Tier II Emission Standards for Vehicles and Gasoline Sulfur
Standards In February 2000, U.S. EPA finalized a federal rule to significantly
reduce emissions from cars and li ght trucks, including sport utility vehicles (SUVs). Under this pr oposal, automakers will be required to sell cleaner cars, and refiner ies will be required to make cleaner, lower sulfur gasoline. Th is rule will apply nationwide. The federal rules will phase in bet ween 2004 and 2009. U.S. EPA has
estimated that NO
x 

### emission reductions will be approximately 77 percent for passenger cars, 86 per cent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. The sulfur content of gasoline is estimated to be reduced by up to 90 percent. VOC emission reductions will be approxim ately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoli ne and diesel trucks and buses. This rule will result in a 40 percent reduction in NO
x 

### from diesel trucks and buses, a large sector of the mobile sources NO
x

30 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx47 

### inventory. It also estima ted the level of sulfur in highway diesel fuel will be reduced by 97 percent by mid-2006.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highw ay diesel program. The new
standards will cut emissions from non -road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this rule, currently accounts for 47 perc ent of diesel particulate matter (PM) and 25 percent of NO
x 

### from mobile sources nationwide.
Sulfur levels will be reduced in non -road diesel fuel by 99 percent from current levels, from appr oximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starti ng in 2008. Together, these rules will substantially reduce lo cal and regional sources of PM 2.5 

### precursors.

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

Background Ohio has a longstanding and fu lly implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-

31 31 

### . The Chapter includes provis ions for the Prevention of Significant Deterioration (PSD) permitting program in OAC rules 3745-31-01 to 3745-31-20. Ohio's PSD program was conditionally approved on October 10, 2001 (66 FR 51570) and received final approval on January 22, 2003 (68FR 2909) by U.S. E PA as part of
the SIP.

Demonstration Any facility that is not listed in the 2005 emission inventory, or for the closing of which credit was ta ken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable NSR requirements. Once the area is redesignated, Ohio EPA will im plement NSR through the PSD

program.

Requirement 6 of 6

31 http://www. epa.ohio.gov/dapc/r egs/3745_31.aspx48 

### Assure that all existing control measures will remain in effect after redesignation unless the State demonstrates through modeling that the standard can be
maintained without one or more control measures.

Demonstration Ohio commits to maintaining t he aforementioned control measures after redesignation. Ohio hereby co mmits that any changes to its rules or emission limits applicable to PM 2.5 

### , SO 2 

### , and NO
x 

### as required for maint enance of the annual PM 2.5 

### standard in the Huntington-Ashland area, will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal offi ce, has the legal authority and necessary resources to actively enf orce any violations of its rules or permit provisions. After redesi gnation, it intends to continue enforcing all rules that rela te to the emission of PM 2.5 

### precursors in the Huntington-Ashland area.49 

## CHAPTER SIX

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

Requirement 1 of 4 A commitment to submit a revised pl an eight years after redesignation.

Demonstration Ohio hereby commits to review its maintenance plan eight years after redesignation, as required by Section 175(A) of the CAA

.

Requirement 2 of 4 A commitment to expeditiously enact and implement additional contingency control measures in response to ex ceeding specified predetermined levels (triggers) or in the event that future vi olations of the ambient standard occur.

Demonstration Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response: A warning level response sha ll be prompted whenever the PM 2.5 

### average of the weighted annual mean of 15.5 μg/m 3 

### occurs in a single calendar year within the ma intenance area. A warning level response will consist of a study to determine whether the PM 2.5 

### value indicates a trend toward higher PM 2.5 

### values or whether emissions appear to be increas ing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse t he trend taking into consideration ease and timing for implementation as well as economic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expeditiously as possible, but in no event later than 12 months from the conclusion of the most recent calendar year.

Should it be determined through the wa rning level study that action is necessary to reverse the noted trend, the procedur es for control selection and implementation outlined under “action level response” shall be followed.

Action Level Response: An action level response shall be prompted whenever a two-year average of the weighted annual means of 15.0 μg/m 3 

### or greater
occurs within the maintenance area. A violation of the standard50 

### (three-year average of the we ighted annual means of 15.0 μg/m 3 

### or greater) shall also prompt an action level response. In the
event that the action level is tri ggered and is not found to be due to an exceptional event, malfunction , or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropolitan planning organizati on or regional council of governments, will determine additi onal control measures needed to assure future attainment of the NAAQS for annual PM 2.5 

### . In this case, measures that can be impl emented in a short time will be selected in order to be in place wit hin 18 months from the close of the calendar year that prompted the action level. Ohio EPA will also consider the timing of an ac tion level trigger and determine if additional, significant new regulations not currently included as part of the maintenance provisions will be implemented in a timely manner and will constitute our response.

Control Measure Sele ction and Implementation Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking.

If a new measure/control is alr eady promulgated and scheduled to be implemented at the federal or State level, and that
measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Ohio will submit to U.S. EPA an analysis to demonstrate the propos ed measures are adequate to
return the area to attainment.

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

event.

Demonstration Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appropriate and effective
at the time the selection is made. The selection of measures will be based on cost-effectiveness, emission reduction potential,
economic and social cons iderations or other factors that Ohio EPA deems appropriate. Ohio EPA will solic it input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Because it is not possible at
this time to determine what cont rol measures will be appropriate at an unspecified time in the future, the list of contingency measures
outlined below is not exhaustive.51 

### 1) Diesel reduction emission strategies. 2) Alternative fuel (e.g., li quid propane and compressed natural gas) and diesel retrofit programs for fleet vehicle operations. 3) Tighter PM 2.5 

### , SO 2 

### , and NO
x 

### emissions offsets for new and modified major sources. 4) Impact crushers located at recycle scrap yards – upgrade wet suppression. 5) Concrete manufacturing – upgrade wet suppression. 6) Additional NO
x 

### RACT statewide.

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

Requirement 4 of 4
A list of PM 2.5 

### , SO 2 

### , and NO
x 

### sources potentially subject to future additional control requirements.

Demonstration The following is a list of PM 2.5 

### , SO 2 

### , and NO
x 

### sources potentially subject to future controls.

• ICI Boilers - SO 2 

### and NO
x 

### controls;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• other sources greater than 100 tons per year;

• fleet vehicles;

• concrete manufacturers;

• aggregate processing plants;52 

## CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesignat ion petition and maintenance plan in the widely distributed county publications on March 17, 2011.

The public hearing to receive comment s on the redesignation request was held on April 21, 2011, at the Po rtsmouth City Health Depar tment, Portsmouth, Ohio. The public comment period closed on Ap ril 21, 2011. Appendix F includes a copy of the public notice, certification of publication, and the transcript from the public hearing.53 

## CHAPTER EIGHT

CONCLUSIONS

The Huntington-Ashland annual PM 2.5 

### nonattainment area has attained the 1997 annual NAAQS for PM 2.5 

### and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of PM 2.5 

### nonattainment areas.
Documentation to that effect is contained herein. Oh io EPA has prepared a redesignation request and maintenance plan that meet the requirements of Section 110 (a)(1) of the 1990 CAA.

Based on this presentation, the Huntington-Ashland annual PM 2.5 

### nonattainment area meets the requirements for r edesignation under t he CAA and U.S. EPA guidance. Ohio has performed an anal ysis that shows the air quality improvements are due to permanent and enf orceable measures. Furthermore, because this area is subject to signific ant transport of pollu tants, significant regional SO 2 

### and NO
x 

### reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of Ohio hereby reques ts that the Huntington-Ashland annual PM 2.5 

### nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenance plan provisions contained herein.

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