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 PM2.5 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 PM2.5 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 PM2.5

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 

PM2.5 monitoring ............................................................................................................................ 8 

Annual PM2.5 NAAQS .................................................................................................................... 8 

Ambient data quality assured ........................................................................................................ 9 

Three complete years of data ....................................................................................................... 9 

Commitment to continue monitoring ........................................................................................... 13 

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 PM2.5, SO2, and NOx sources ........................................................................................... 51 

Chapter Seven 

Public participation ...................................................................................................................... 52 

Chapter Eight 

Conclusions ................................................................................................................................ 53 
FIGURES 

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

monitor locations ................................................................................................... 9 

Figure 2 PM2.5 Annual Mean Trends LADCO States ......................................................... 12 

Figure 3 PM2.5 Annual Mean Trends Midwest States ........................................................ 12 

Figure 4 PM2.5 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 ............................................................................................................... 21 

Table 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 .................................................................................................... 22 

Table 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 SO2 and NOx EGU Emissions Between 2008 and 2009. ............. 26 

Table 17 Reductions in SO2 and NOx EGU Emissions Between the First Half of 

2008 and 2010.... ................................................................................................ 27 

Table 18 Adams County, Ohio PM2.5 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without 

CAIR ................................................................................................................. 29 

Table 19 Gallia County, Ohio PM2.5 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without 

CAIR ................................................................................................................. 29 
Table 20 Lawrence County, Ohio PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR ........................................................................................................... 29 

Table 21 Scioto County, Ohio PM2.5 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without 

CAIR ................................................................................................................. 30 

Table 22 Boyd County, Kentucky PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR ........................................................................................................... 30 

Table 23 Lawrence County, Kentucky PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR. ...................................................................................................... 30 

Table 24 Cabell County, West Virginia PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) 

– Without CAIR .................................................................................................... 31 

Table 25 Mason County, West Virginia PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) 

– Without CAIR .................................................................................................... 31 

Table 26 Wayne County, West Virginia PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) 

– Without CAIR .................................................................................................... 31 

Table 27 Huntington-Ashland Area PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR. ...................................................................................................... 32 

Table 28 Adams County, Ohio NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

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

Table 29 Gallia County, Ohio NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

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

Table 30 Lawrence County, Ohio NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

CAIR. ................................................................................................................. 33 

Table 31 Scioto County, Ohio NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

CAIR. ................................................................................................................. 33 

Table 32 Boyd County, Kentucky NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

CAIR. ................................................................................................................. 33 

Table 33 Lawrence County, Kentucky NOx Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

With CAIR ................................................................................................................ 34 

Table 34 Cabell County, West Virginia NOx Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

With CAIR. ............................................................................................................... 34 

Table 35 Mason County, West Virginia NOx Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

With CAIR. ............................................................................................................... 34 
Table 36 Wayne County, West Virginia NOx Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

With CAIR. ............................................................................................................... 35 

Table 37 Huntington-Ashland Area NOx Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

With CAIR. ............................................................................................................... 35 

Table 38 Adams County, Ohio SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

CAIR ................................................................................................................. 35 

Table 39 Gallia County, Ohio SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

CAIR ................................................................................................................. 36 

Table 40 Lawrence County, Ohio SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

CAIR ................................................................................................................. 36 

Table 41 Scioto County, Ohio SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

CAIR ................................................................................................................. 36 

Table 42 Boyd County, Kentucky SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 

CAIR. ................................................................................................................. 37 

Table 43 Lawrence County, Kentucky SO2 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

With CAIR ................................................................................................................ 37 

Table 44 Cabell County, West Virginia SO2 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

With CAIR ................................................................................................................ 37 

Table 45 Mason County, West Virginia SO2 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

With CAIR ................................................................................................................ 38 

Table 46 Wayne County, West Virginia SO2 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

With CAIR ................................................................................................................ 38 

Table 47 Huntington-Ashland Area SO2 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 PM2.5

Nonattainment Area 

D LADCO Technical Support Documents 

E Analysis of Insignificance of Mobile Emissions 
F Public Participation Documentation 
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REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO 

PORTION OF THE HUNTINGTON-ASHLAND, OH-KY-WV 

ANNUAL PM2.5 NONATTAINMENT AREA 

Adams, Gallia, Lawrence, and Scioto Counties, Ohio 

CHAPTER ONE 

Introduction 

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

meet the annual PM2.5

1

 National Ambient Air Quality Standards (NAAQS) to 

develop State Implementation Plans (SIPs) to expeditiously attain and maintain 

the standards. The United States Environmental Protection Agency (U.S. EPA) 

revised the NAAQS for particulate matter in July 1997. It replaced the existing 

PM10 standard with a health-based PM2.5 standard and retained the PM10

standard as a particulate standard protecting welfare. The standards include an 

annual standard set at 15.0 micrograms per cubic meter (μg/m3), based on the 

3-year average of annual mean PM2.5 concentrations and a 24-hour standard of 

65 μg/m3

, based on the 3-year average of the 98th percentile of 24-hour 

concentrations. 

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 back to U.S. EPA. The remand did not 

question the level at which U.S. EPA set the standards but rather the 

constitutionality of the CAA provision that authorizes U.S. EPA to set national air 

quality standards. U.S. EPA requested a rehearing which the D.C. Circuit denied. 

 Therefore, in December 1999, U.S. EPA appealed the D.C. Circuit decision to 

the U.S. Supreme Court. The U.S. Supreme Court issued a decision on 

February 27, 2001 that unanimously affirmed the constitutionality of the CAA 

provision but did remand several other issues back to the D.C. Circuit, including 

the issue of whether U.S. EPA acted arbitrarily and capriciously in establishing 

the specific levels of the standards. 

The D.C. Circuit heard arguments in this remanded case in December 2001, and 

issued its decision on March 26, 2002. The D.C. Circuit rejected the claims that 

 

1 Particle pollution is a mixture of microscopic solids and liquid droplets suspended in air. This pollution, 

also known as particulate matter, is made up of a number of components, including acids (such as 

nitrates and sulfates), organic chemicals, metals, soil or dust particles, and allergens (such as fragments 

of pollen or mold spores). 

Fine particle pollution or PM2.5 describes particulate matter that is 2.5 micrometers in diameter and 

smaller - 1/30th the diameter of a human hair. Fine particle pollution can be emitted directly or formed 

secondarily in the atmosphere. 
2 

the U.S. EPA had acted arbitrarily and capriciously in setting the levels of the 

standards. 

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

areas designations for the PM2.5 standards across the country. Modifications to 

those designations were made and an effective date was set at April 5, 2005. 

Unlike Subpart 2 of the CAA Amendments of 1990 which defined five ozone 

nonattainment classifications for the areas that exceed the NAAQS based on the 

severity of the ozone levels, PM2.5 nonattainment designations are simply 

labeled “nonattainment.” The CAA Amendments require states with PM2.5

nonattainment areas to submit a plan within three years of the effective date of 

the designations (April 5, 2008) detailing how the PM2.5 standards will be 

attained by April 5, 2010. Ohio EPA submitted its attainment demonstration for 

the entire State of Ohio on July 16, 2008. 

Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas to 

be redesignated to attainment provided certain criteria are met. The following are 

the criteria that must be met in order for an area to be redesignated from 

nonattainment to attainment: 

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

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

under Section 110(k).

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

permanent and enforceable reductions in emissions resulting 

from implementation of the SIP and other federal requirements.

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

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

have been met. 

This document addresses each of these requirements, and provides additional 

information to support continued compliance with the annual PM2.5 standard. 

 

Geographical Description and Background 

The current Huntington-Ashland nonattainment area is located in southern Ohio 

and includes the following counties: Adams (partial nonattainment of Monroe and 

Sprigg townships only), Gallia (partial nonattainment of Cheshire Township only), 

Lawrence and Scioto in Ohio; Boyd and Lawrence (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 Mason (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 PM2.5 designations, U.S. EPA designated the HuntingtonAshland area nonattainment for the 15.0 μg/m3 annual standard2

, and Ohio EPA 

was required to develop a plan to reduce oxides of nitrogen (NOx), sulfur dioxide 

(SO2) and direct PM2.5 emissions and to demonstrate that the area will meet the 

federal annual air quality standard by April 5, 2010. Ohio’s main PM2.5

components are primary particles (organic carbon, crustal material, and 

elemental carbon), SO2 and NOx, which were included in the attainment 

demonstration analysis. Volatile organic compounds (VOCs) and ammonia 

(NH3) were not included in the analysis since they were not part of Ohio’s 

current attainment strategy for PM2.5 (although controls for VOCs have been 

implemented for ozone nonattainment). This is consistent with U.S. EPA’s “Clean 

Air Particle Implementation Rule” [74FR 20856] (hereafter referred to as 

“Implementation Rule”). In the Implementation Rule U.S. EPA presumes NH3 

emissions are not a PM2.5 attainment plan precursor and that States are not 

required to address VOC unless the State or U.S. EPA makes a technical 

demonstration that emissions of VOCs significantly contribute to nonattainment 

of the annual PM2.5 standard. 

This document is intended to support Ohio’s request that the Ohio portions of the 

Huntington-Ashland area be redesignated from nonattainment to attainment for 

the annual PM2.5 standard. In addition, the States of Kentucky and West Virginia 

also intend to submit requests for their respective portions of the HuntingtonAshland area.

Status of Air Quality 

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

recent three (3) years, 2008 through 2010, demonstrate that the air quality has 

met the NAAQS for annual PM2.5 in this nonattainment area. The NAAQS 

attainment, accompanied by decreases in emission levels discussed in Chapter 

Four, supports a redesignation to attainment 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 PM2.5 standard of 65 μg/m3. 
4 

CHAPTER TWO 

Requirements for Redesignation 

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

Processing Requests to Redesignate Areas to Attainment (redesignation 

guidance), issued September 4, 1992, to Regional Air Directors. The 

redesignation request and maintenance plan are based on the redesignation 

guidance, supplemented with additional guidance received from staff of U.S. 

EPA Region 5. 

Below is a summary of each redesignation criterion as it applies to the 

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 ambient air quality data. The data 

that are used to demonstrate attainment should be the product of 

ambient monitoring that is representative of the area of highest 

concentration. The data should be collected and quality-assured in 

accordance with 40 CFR 58 and recorded in the Air Quality 

System (AQS)in order for it to be available to the public for review. 

 The second component relies upon supplemental U.S. EPAapproved air quality modeling. While no modeling is required for 

redesignating nonattainment areas, the redesignation guidance 

states it is “generally necessary” for particulate matter 

redesignations. Appendix C and Appendix D contains the most 

recent modeling results showing future attainment and 

maintenance are provided. Chapter Three discusses this 

requirement in more detail and provides the attainment 

demonstration. 

ii.) Permanent and enforceable improvement in air quality (CAA Section 

107(d)(3)(E)(iii)) 

 The state must be able to reasonably attribute the improvement in 

air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures that 

have been adopted and implemented by the state. 

It was not necessary for Ohio to adopt or implement control 

measures for these counties beyond the federal measures. 

Ohio EPA has adopted several rules recently that will have an 

impact on statewide PM2.5 emissions in the future: 
5 

• Clean Air Interstate Rule (CAIR) 

• NOx SIP Call Rules 

 In addition, since the initial designations were made federally 

enforceable consent decrees have resulted in reductions in 

emissions from utilities across the state. 

 Chapters Four and Five discuss this requirement in more detail. 

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

For purposes of redesignation, a state must meet all requirements 

of Section 110 and Part D that were applicable prior to submittal of 

the complete redesignation request. 

Subpart 1 of Part D consists of general requirements applicable to 

all areas which are designated nonattainment based on a violation 

of the NAAQS. Subpart 4 of Part D consists of more specific 

requirements applicable to particulate matter (specifically to 

address PM10). However, for the purpose of implementing the 

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

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

implementing PM2.5.[72 FR 20589] 

 i.) Section 110(a) requirements 

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

requirements for a SIP. Section 110(a)(2) provides that the 

implementation plan submitted by a state must have been 

adopted by the state after reasonable public notice and 

hearing, and that, among other things, it must include 

enforceable emission limitations and other control 

measures, means or techniques necessary to meet the 

requirements of the CAA; provide for establishment and 

operation of appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 

provide for implementation of a source permit program to 

regulate the modification and construction of any stationary 

source within the areas covered by the plan; include 

provisions for the implementation of Part C, prevention of 

significant deterioration (PSD) and Part D, NSR permit 

programs; include criteria for stationary source emission 

control measures, monitoring, and reporting; include 

provisions for air quality modeling; 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, Ohio 
6 

verified that the State fulfills the requirements of Section 

110(a)(2) of the Act. 

Section 110(a)(2)(D) also requires State plans to prohibit 

emissions from within the State which contribute 

significantly to nonattainment or maintenance areas in any 

other State, or which interfere with programs under Part C 

to prevent significant deterioration of air quality or to 

achieve reasonable progress toward the national visibility 

goal for Federal class I areas (national parks and 

wilderness areas). In order to assist States in addressing 

their obligations regarding regionally transported pollution, 

U.S. EPA finalized CAIR to reduce SO2 and NOx emissions 

from large electric generating units (EGU). Ohio has met 

the requirements of the federal CAIR to reduce NOx and 

SO2 emissions contributing to downwind states. On 

February 1, 2008, U.S. EPA approved Ohio’s CAIR 

program, which can be found in Ohio Administrative Code 

(OAC) Chapter 3745-1093. On July 6, 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 transported pollution by providing 

reductions in NOx and SO2 emissions in 2012 and 2014. 

 ii.) Section 172(c) requirements 

 This Section contains general requirements for 

nonattainment plans. The requirements for reasonable 

further progress, identification of certain emissions 

increases, and other measures needed for attainment will 

not apply for redesignations because they only have 

meaning for areas not attaining the standard. The 

requirements for an emission inventory will be satisfied by 

the inventory requirements of the maintenance plan. 

Chapters Four and Five discuss this requirement in more 

detail. 

 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#3745-109 
7 

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

EPA’s conformity regulation upon issuance, as applicable. 

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

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

U.S. EPA must fully approve a maintenance plan that meets the 

requirements of Section 175(A). The maintenance plan will 

constitute a SIP revision and must provide for maintenance of the 

relevant NAAQS in the area for at least 10 years after 

redesignation. Section 175(A) further states that the plan shall 

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

ensure such maintenance. 

In addition, the maintenance plan shall contain such contingency 

measures as the Administrator deems necessary to ensure prompt 

correction of any violation of the NAAQS. At a minimum, the 

contingency measures must include a requirement that the state 

will implement all measures contained in the nonattainment SIP 

prior to redesignation. 

States seeking redesignation of a nonattainment area should 

consider the following provisions: 

a) attainment inventory; 

b) maintenance demonstration; 

c) monitoring network; 

d) verification of continued attainment; and 

e) contingency plan. 

 Chapter Six discusses this requirement in more detail. 
8 

CHAPTER THREE 

PM2.5 MONITORING 

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

Requirement 1 of 4 

A demonstration that the NAAQS for annual PM2.5, as published in 40 CFR 50.7, 

has been attained. 

Background

 There are 4 monitors measuring PM2.5 concentrations in this 

nonattainment area. Two are located in Ohio4 and are operated by 

Ohio EPA Division of Air Pollution Control, Southeast District 

Office and the Portsmouth City Health Department Air Pollution 

Unit. A listing of the design values based on the three-year 

average of the annual mean concentrations 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 PM2.5 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 assured in accordance with 40 CFR 58.10, 

recorded in the U.S. EPA air quality system (AQS) database, and available for 

public view. 

Demonstration

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

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

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

are available to the public. 

Requirement 3 of 4 

A showing that the three-year average of the annual mean values, based on 

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

below 15.0 μg/m3

. (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 "Guideline 

on Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999. 
10 

In accordance with the CAA Amendments, three complete years of 

monitoring data are required to demonstrate attainment at a 

monitoring site. The annual PM2.5 primary and secondary ambient 

air quality standards are met at an ambient air quality monitoring 

site when the three-year average of the annual average is less 

than 15.0 μg/m3. While calculating design values, three significant 

digits must be carried in the computations, with final values 

rounded to the nearest 0.1 μg/m3. Decimals 0.05 or greater are 

rounded up, and those less than 0.05 are rounded down, so that 

15.049 μg/m3

 is the largest concentration that is less than, or equal 

to 15.0 μg/m3. Values at or below 15.0 μg/m3 meet the standard; 

values equal to or greater than 15.1 μg/m3

 exceed the standard. 

An area is in compliance with the annual PM2.5 NAAQS only if 

every monitoring site in the area meets the NAAQS. An individual 

site's 3-year average of the annual average concentrations is also 

called the site's design value. The air quality design value for the 

area is the highest design value among all sites in the area. 

Table 1 shows the monitoring 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 the 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 μg/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 PM2.5 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 PM2.5 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 - PM2.5 Annual Mean Trends LADCO States 

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

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

Figure 3 - PM2.5 Annual Mean Trends Midwest States 

Source: LADCO; Recent Ozone and PM2.5 Trends - Aug 26 2010.pptx 
13 

Design values have also trended downward nationally: 

Figure 4 - PM2.5 Annual Mean National Trends 

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

Requirement 4 of 4 

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

appropriate monitoring network to verify the maintenance of the attainment 

status. 

Demonstration

 Ohio EPA commits to continue monitoring PM2.5 levels at the Ohio 

sites indicated in Figure 1 and Table 1. Ohio EPA will consult with 

U.S. EPA Region 5 prior to making changes to the existing 

monitoring network, should changes become necessary in the 

future. Ohio EPA will continue to quality assure the monitoring 

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

requirements. Connection to a central station and updates to the 

Ohio EPA web site5

 will provide real time availability of the data 

and knowledgement of any exceedances. Ohio EPA will enter all 

data into AQS on a timely basis in accordance with federal 

guidelines. 

 

5 www.epa.ohio.gov/dapc 
14 

CHAPTER FOUR 

EMISSION INVENTORY

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

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

inventory of PM2.5 precursor emissions (primary particles (organic carbon, crustal 

matter, and elemental carbon), SO2 and NOx

6

) representative of the year when 

the area achieves attainment of the annual PM2.5 air quality standard. Ohio also 

must demonstrate that the improvement in air quality between the year that 

violations occurred and the year that attainment was achieved is based on 

permanent and enforceable emission reductions. Other emission inventory 

related requirements include a projection of the emission inventory to a year at 

least 10 years following redesignation; a demonstration that the projected level 

of emissions is sufficient to maintain the annual PM2.5 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 mobile (on-road) emissions inventory and 

projections, identifies procedures used by Ohio EPA and the LADCO regarding 

emissions from Ohio’s portion of the counties in the 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 emissions projections were prepared using similar 

methodologies. Ohio recognizes that revisions to the emissions data below may 

be necessary once Kentucky and West Virginia prepare a redesignation request 

and maintenance plan for their portion of the nonattainment area. Mobile 

emissions inventories and projections for 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 Virginia Department of 

Transportation (WVDOT), West Virginia Department of Environmental Protection 

(WVDEP), Kentucky Transportation Cabinet (KYTC), and Kentucky Division of 

Air Quality (KDAQ).

Requirement 1 of 5 

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

base year. 

Background

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

reporting program. The 2005 periodic inventory has been identified 

 

6 VOC and NH3 are not addressed. 
15 

as one of the preferred databases for SIP development and 

coincides with nonattainment air quality in the Huntington-Ashland 

area. 

Periodic inventories, which include emissions from all sectors - 

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

three years. 

Demonstration

The 2005 inventory is used as the base year for the purpose of 

this submittal and was submitted to U.S. EPA with Ohio’s PM2.5

attainment demonstration SIP submitted on July 18, 2008 and 

revised on June 7, 2010. The detailed emission inventory 

information for the Ohio portion of the Huntington-Ashland area is 

provided in Appendix B. Emissions of PM2.5, SO2 and NOx for 2005 

are identified under Requirement Three of this Chapter. 

Requirement 2 of 5 

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

redesignation. 

Background

Ohio EPA prepared a comprehensive inventory for the Ohio portion of the 

Huntington-Ashland area including area, mobile, and point sources for 

PM2.5, SO2 and NOx for base year 2005. The 2005 inventory was 

submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM2.5

attainment demonstration SIP for this area. The information below 

describes the procedures Ohio EPA used to generate the 2005 base year 

inventory and to develop SIP-ready modeling inventories and future year 

projections (Pechan Report7

) based on a 2005 base year inventory. The 

report by Pechan generated future year estimates of annual emissions for 

each source sector using accepted growth surrogates. These inventories 

were provided to the LADCO and have been processed to develop 

average daily emissions for use in the air quality analyses. These 

processed modeling inventories have been identified as the correct 

iteration of the inventory for use in the redesignation. In this document, 

references to LADCO include the Midwest Regional Planning 

Organization. Note that the on-road mobile source sector was addressed 

by specific PM2.5 and NOx 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/reports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con

trols%20Report_Final.pdf 
16 

made from the U.S. Department of Commerce Bureau of 

Economic Analysis (BEA) growth factors, with some 

updated local information. 

• Mobile source emissions were calculated from 

MOVES2010 produced emission factors. In Ohio’s July 16, 

2008 PM2.5 Attainment Demonstration SIP8

, Ohio found that 

the regional highway emissions of PM2.5, NOx, and SO2 

were insignificant contributors to the nonattainment 

problems and, therefore, none of the three pollutants 

(necessitated emissions inventory analysis. As documented 

in Ohio EPA’s attainment demonstration SIP, Ohio EPA in 

consultation with U.S. EPA determined 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. Based 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 

PM2.5, NOx, and SO2 continue to be insignificant 

contributors to the nonattainment problems in this area, as 

discussed below. 

• Point source information was compiled from Ohio EPA’s 

2005 annual emissions inventory database and the 2005 

U.S. EPA Air Markets acid rain database9. 

• Biogenic emissions are not included in these summaries. 

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

National Mobile Inventory Model (NMIM) 2002 application. 

To address concerns about the accuracy of some of the 

categories in U.S. EPA’s non-road emissions model, 

LADCO contracted with two (2) companies to review the 

base data and make recommendations. One of the 

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

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

Emissions were estimated for aircraft, commercial marine 

vessels, and railroads. Recreational motorboat population 

and spatial surrogates (used to assign emissions to each 

county) were significantly updated. The populations for the 

construction equipment category were reviewed and 

updated based upon surveys completed in the Midwest, 

and the temporal allocation for agricultural sources also 

was updated. 

 

 

8 http://www.epa.ohio.gov/portals/27/SIP/Attain/PM2_5/PM25Doc.pdf 

9 http://www.epa.gov/airmarkets/acidrain 
17 

Demonstration

On-Road Emission Estimations 

The Huntington-Ashland nonattainment area for the on-road 

emission estimation analysis is divided into a modeled area 

composed of Cabell, Wayne, and Mason (partial) Counties in West 

Virginia, Lawrence, Scioto, Adams (partial), and Gallia (partial) 

Counties in Ohio, and Boyd and Lawrence (partial) Counties in 

Kentucky. Cabell County, WV, Wayne County, WV, and Lawrence 

County, OH are represented within the KYOVA Travel Demand 

Model. Boyd County, KY is represented by the KYTC’s Ashland 

Regional Travel Demand Model. For these areas, information 

from the travel demand models 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 encompassed within the available travel 

demand models, HPMS data was relied upon more heavily for the 

travel characteristics. Appendix C of this report provides a full 

description of the data sources and analysis procedures used in 

this analysis effort. 

Overview 

U.S.EPA published a Federal Register notice10 of availability on 

March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions 

Simulator), hereafter referred to as MOVES. Upon publication of 

the Federal Register notice, MOVES became U.S. EPA’s 

approved motor vehicle emission factor model for estimating 

VOCs, NOx, CO, PM10 and PM2.5 and other pollutants and 

precursors from cars, trucks, motorcycles, and buses by state and 

local agencies. MOVES is a computer program designed by the 

U.S. EPA to estimate air pollution emissions from mobile sources. 

MOVES replaces U.S. EPA’s previous emissions model for onroad mobile sources, MOBILE6.2. MOVES can be used to 

estimate exhaust and evaporative emissions as well as brake and 

tire wear emissions from all types of on-road vehicles. 

An updated version of this software, 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.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ab1f98 
18 

The CAA requires U.S. EPA to regularly update its mobile source 

emission models. U.S. EPA continuously collects data and 

measures vehicle emissions to make sure the Agency has the best 

possible understanding of mobile source emissions. This 

assessment, in turn, informs the development of U.S. EPA’s 

mobile source emission models. MOVES represents the Agency’s 

most up-to-date assessment of on-road mobile source emissions. 

MOVES also incorporates several changes to the U.S. EPA’s 

approach to mobile source emission modeling based upon 

recommendations made to the Agency by the National Academy 

of Sciences. 

U.S.EPA believes that MOVES should be used in ozone, CO, PM, 

and nitrogen dioxide SIP development as expeditiously as 

possible. The CAA requires that SIP inventories and control 

measures be based on the most current information and applicable 

models that are available when a SIP is developed. 

Regarding transportation conformity, U.S. EPA and U.S. DOT 

intend to establish a two-year grace period before MOVES is 

required for new transportation conformity analyses. 

The MOVES more detailed approach (when compared with the 

previous MOBILE model) to modeling allows U.S. EPA to easily 

incorporate large amounts of in-use data from a wide variety of 

sources, such as data from vehicle inspection and maintenance 

(I/M) programs, remote sensing device (RSD) testing, certification 

testing, portable emission measurement systems (PEMS), etc. 

This approach also allows users to incorporate a variety of activity 

data to better estimate emission differences such as those 

resulting from changes to vehicle speed and acceleration patterns. 

MOVES has a graphical user interface which allows users to more 

easily set up and run the model. MOVES database-centered 

design provides users much greater flexibility regarding output 

choices. Unlike earlier models which provided emission factors in 

grams-per-mile in fixed output formats, MOVES output can be 

expressed as total mass (in tons, pounds, kilograms, or grams) or 

as emission factors (grams-per-mile and in some cases 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 impacts of individual transportation 

projects. The database-centered design also allows U.S. EPA to 

update emissions data incorporated in MOVES more easily and will 

allow users to incorporate a much wider array of activity data to 

improve estimation of local emissions. For example, the 
19 

improvements in MOVES will allow project-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 joint 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 choice is not an element of the 

current model. The Travel Demand Model covers Cabell County, 

WV, Wayne County, WV, and Lawrence 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 transportation plan. The QRS II modeling 

platform was used to develop this model. The KYOVA Interstate 

Planning Commission’s currently adopted transportation plan, titled 

Huntington-Ironton Area Transportation Study (HIATS), The Year 

2035 Long-Range Transportation Plan was prepared in May 2009. 

 Appendix C of this document contains the assumptions and 

methodology used to develop the Travel Demand Model. 

Similar to the KYOVA Travel Demand Model, the Ashland Regional 

Travel Demand Model is a traditional three-step model. The model 

includes trip generation, trip distribution, and trip assignment 

components. Transit operations are not included in the model; as 

a result, there is no mode choice component. The Travel Demand 

Model covers Boyd and Greenup Counties 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. The 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 Transportation Cabinet. This 

document contains the assumptions and methodology used to 

develop the current Travel Demand Model. 

For areas of our modeling region 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 the 
20 

travel demand model extents, ramp fractions were assumed to 

mirror those seen in their respective states. HPMS vehicle class 

VMTs for areas outside the travel 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 obtain 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. Guidance and data for meteorological, 

fuel supply, and fuel formulation data was obtained from ODOT 

and KDAQ. The KYOVA supplied information on the transit vehicle 

population for the region. 

The analysis was performed using the emission rates method. As 

a result, post-processing of the data was required to arrive at the 

overall emissions output. To do this, the rate per distance and rate 

per vehicle output data were matched with the appropriate 

geographic area, analysis year, source types, pollutant types, road 

types, modeling hours, and speed classes and then aggregated 

with the corresponding source type population and vehicle miles 

traveled information. The resulting 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 42,602,717
21 

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

NOx (tpy) 3,955.84 3,319.55 1,824.62 924.08  

SO2 (tpy) 65.73 21.73 10.01 10.43  

PM2.5 (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 488,758,339 473,274,668 510,947,840 560,930,984
22 

Table 8 – Lawrence County (partial), 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

NOx (tpy) 2,843.94   2,311.75 1,225.13 685.60  

SO2 (tpy) 12.65   12.36 12.62 12.83  

PM2.5 (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 389,577,827 407,030,689 424,609,965 533,508,781
23 

Table 13 – Summary of West Virginia Emissions Estimations for 

On-Road Mobile Sources 

   2005 2008 2015 2022

NOx (tpy) 6,013.61   4,964.74 2,394.60 1,243.28  

SO2 (tpy) 114.54   31.13 13.22 13.47  

PM2.5 (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

NOx (tpy) 12,813.39   10,596.04 5,444.35 2,852.96  

SO2 (tpy) 192.92   65.22 35.85 36.73  

PM2.5 (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 identifies the percentage of mobile 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

NOx SO2 PM2.5

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 

SO2 constitutes less than one percent (<1%) of the area’s 

total SO2 emissions in the 2015 and 2022 horizon years. 

NOx constitutes less than six percent (<6%) of the area’s 

total NOx emissions in the 2015 and 2022 horizon years. 

PM2.5 constitutes less than three percent (<3%) of the 

area’s total PM2.5 emissions in the 2015 and 2022 horizon 

years. 

Therefore, the Ohio EPA is herein making a finding that the area’s 

highway emissions for PM2.5, NOx, and SO2 continue to be insignificant 

contributors to the nonattainment problem of the Huntington-Ashland 

area, as agreed upon as a part of the interagency consultation process. 

Moreover, the results from Table 15 show emissions adjusted for partial 

nonattainment areas and does not include Non-EGU emission sources in 

partial areas (refer to Appendix E), providing higher percentages of 

mobile emissions (for all three pollutants) and showing a conservative 

(overestimated) percentage of mobile emissions. 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 projected level of emissions is sufficient to maintain the 

PM2.5 standard. 

Background

In consultation with U.S. EPA, Ohio EPA selected the year 2022 

as the maintenance year for this redesignation request. This 

document contains projected emissions 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 were made in accordance with 

“Procedures for Preparing Emissions Projections” U.S. 

EPA-45/4-91-019. As discussed above, it was determined 
25 

that the mobile emission contribution as a percent of the 

total emission inventory from the area is not significant. 

• Emissions inventories are required to be projected to future 

dates to assess the influence growth and future controls will 

have. LADCO has developed growth and control files for 

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

to develop the future-year emissions estimates used in this 

document. This was done so the inventories used for 

redesignation are consistent with modeling performed in the 

future. Appendix D contains LADCO’s technical support 

document detailing the analysis used to project emissions 

(Base M11). 

• For the Ohio portion of the Huntington-Ashland area, for the 

2008 attainment year, emissions were grown from the 2005 

LADCO modeling inventory, using LADCO’s growth factors, 

for all sectors except point sources (electrical generating 

units and non-electrical generating units). Point source 

emissions for 2008 were compiled from Ohio EPA’s 2008 

annual emissions inventory database. The 2015 interim 

year emissions were estimated based on the 2009 and 

2018 LADCO modeling inventory, using LADCO’s growth 

factors, for all sectors. The 2022 maintenance year is 

based on emissions estimates from the 2018 LADCO 

modeling. 

The detailed inventory information 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 

PM2.5 standard. Therefore, Ohio EPA performed an initial 

comparison of the inventories for the base year and maintenance 

years. Mobile source emission inventories are described in Section 

5 of Appendix B. 

Sectors included in the following tables are: Electrical Generating 

Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Area (Other); Marine; Aircraft; Rail 

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

Ohio EPA is identifying emissions projections for 2015 and 2022 

for EGUs with implementation of the CAIR program. U.S. EPA has 

raised concerns regarding the CAIR program and its remand. 

However, as discussed below, with the proposed CAIR 

 

11 http://www.ladco.org/tech/emis/current/index.php 
26 

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 NOx and SO2. CAIR replaced the NOx SIP Call for 

EGUs. The intent of the CAIR program is for national NOx

emissions to be cut from 4.5 million tons in 2004, to a cap of 1.5 

million tons by 2009, and 1.3 million tons in 2018 in 28 states. 

States were required to submit a CAIR SIP as part of this effort. 

Ohio submitted a CAIR SIP which was approved by U.S. EPA on 

February 1, 2007. Revisions to the CAIR SIP were again 

submitted on July 15, 2009. The revised CAIR SIP was approved 

as a direct final action on September 25, 2009 (74 FR 48857). As 

a result of CAIR, U.S. EPA projects that in 2009 emissions of NOx

will decrease from a baseline of 264,000 tons per year to 93,000 

tons per year while in 2010 emissions of SO2 will decrease from a 

baseline of 1,373,000 tons per year to 298,000 tons per year, 

within Ohio. And by 2015 U.S. EPA projects emissions of NOx will 

decrease to 83,000 tons per year while emissions of SO2 will 

decrease to 208,000 tons per year, within Ohio12. 

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

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

Ohio EPA has not incorporated these expected CAIR reductions 

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

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

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

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

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

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

As can be seen in Table 15 below, Ohio has seen a significant 

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

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

and implementing control programs to address CAIR13 and 

consent decrees. 

Table 16 - Reductions in SO2 and NOx EGU Emissions 

Between 2008 and 2009 

SO2 NOx

2008 2009 Change 2008 2009 Change 

 

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

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

beginning in 2010.
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 Tracking14

Significant reductions also occurred regionally and nationally as 

can be seen from the above table. Data is also available for the 

first two quarters of 2010, the year SO2 reductions are to be 

implemented under CAIR: 

Table 17 – Reductions in SO2 and NOx EGU Emissions 

Between the First Half of 2008 and 2010 

SO2 NOx

2008 

 (1st half) 

2010 

(1st half) 

Change 2008 

(1st half) 

2010 

(1st half) 

Change 

Ohio 373,798 279,854 25% 130,598 53,187 59% 

LADCO States 1,190,497 854,282 28% 419,114 220,907 47% 

National 3,895,472 2,502,965 36% 1,487,179 930,148 37% 

Source: Clean Air Markets Quarterly Emissions Tracking15

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

“Based on emissions monitoring data, EPA has observed 

substantial reductions in SO2 emissions from 2005 to 2009 and in 

the first two quarters of 2010 as companies installed more 

controls, electric demand declined, and low natural gas prices 

made combined-cycle gas-fired units more competitive in several 

parts of the country. Thus, even after CAIR's vacatur and 

subsequent remand in late 2008, the controls in place generally 

have continued to operate, helping to drive continued progress in 

reducing emissions.16” 

On July 6, 2010, U.S. EPA proposed 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 

NOx and SO2 emissions in 2012 and 2014, ahead of the 2015 

CAIR Phase 2. 

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

CAIR program is providing real reductions at this time, Ohio 

believes these reductions have assisted with PM2.5 attainment in 

 

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

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

16 http://www.epa.gov/airmarkets/background.htm
28 

this nonattainment area and throughout Ohio. It is also Ohio EPA’s 

belief that the Transport Rule, when finalized, will continue to 

provide the necessary reductions, and likely even greater 

reductions, that will be necessary for maintenance of the annual 

PM2.5 standard to occur. As stated by U.S. EPA regarding the 

proposed Transport Rule, “the results of the air quality modeling 

indicate that all but one site17 is projected to be in attainment and 

only one site18 is projected to have a maintenance problem for 

annual PM2.5 in 2014 with the emissions 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 level of emissions is sufficient to maintain the 

annual PM2.5 standard by assessing future year emissions that 

include the CAIR program. Furthermore, modeling conducted as 

part of the Transport Rule projects the Counties within this area 

will not have maintenance issues in 2014 even without the 

Transport Rule (or CAIR). 

Maintenance is demonstrated when the future-year (2022) 

projected emission totals are below the 2008 attainment year 

totals. 

The Ohio emissions data in the 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 Michigan Air Directors Consortium 

(LADCO). 

Demonstration

PM2.5 

The 2005 and 2008 actual PM2.5 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 

PM2.5 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. This step leads to a false perception 

of significant PM2.5 emissions growth. Modeling performed by LADCO, 

 

17 Allegheny, PA

18 Birmingham, AL
29 

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 appropriate for the purposes of PM2.5 to 

evaluate future year emissions without the CAIR program. 

Table 18 - Adams County, Ohio PM2.5 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 PM2.5 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 PM2.5 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 0.94 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 14.40
30 

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 PM2.5 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 PM2.5 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 PM2.5 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 11.79
31 

Table 24 - Cabell County, West Virginia PM2.5 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 PM2.5 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 PM2.5 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    97.01  
32 

Table 27 – Huntington-Ashland Area PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

projected 2015 and 2022 (tpy) – Without CAIR 

PM2.5 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 PM2.5

TOTAL 9,584.41   10,253.89 10,100.29 9,928.94   324.95  

 

NOx 

Table 28 - Adams County, Ohio NOx 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 NOx 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 37.49
33 

TOTAL 58,132.90 60,263.38 24,897.28 9,668.46 50,594.92

Table 30 - Lawrence County, Ohio NOx 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 NOx 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 NOx 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 2,386.71
34 

Table 33 - Lawrence County, Kentucky NOx 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 NOx 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 NOx 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 2,843.55
35 

Table 36 – Wayne County, West Virginia NOx 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 NOx 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

SO2

Table 38 - Adams County, Ohio SO2 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 0.39
36 

TOTAL 125,154.24 36,009.18 27,125.18 23,320.68 12,688.50

Table 39 - Gallia County, Ohio SO2 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 SO2 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 SO2 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 1,103.30 796.00 844.48
37 

Table 42 - Boyd County, Kentucky SO2 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 SO2 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 SO2 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 ‐190.41
38 

Table 45 - Mason County, West Virginia SO2 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 SO2 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 SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR 

SO2

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 

SO2 TOTAL 372,289.72 234,901.09 149,647.27 113,654.75 121,246.34
39 

PM2.5, NOx, and SO2

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 

PM2.5 10,253.89 10,100.29 153.60 9,928.94 324.95

NOx 146,972.25 95,137.30 51,834.95 71,097.29 75,874.96

SO2 234,901.09 149,647.27 85,253.82 113,654.75 121,246.34

 

As shown in the table above (Table 48), PM2.5 emissions in the 

nonattainment area are projected to decrease by 153.60 tpy in 

2015 and 324.95 tpy in 2022. NOx emissions in the nonattainment 

area are projected to decrease by 51,834.95 tpy in 2015 and 

75,874.96 tpy in 2022. SO2 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 lesser extent, point sources show 

an increase due to expectations that the population will grow in this 

area; however, cleaner vehicles and fuels are expected to be in 

place in 2009 and 2018, and the Transport Rule will be 

implemented in 2012 and 2014 and these programs should cause 

an overall drop in all three pollutants emissions. Decreases from 

U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards 

and Gasoline Sulfur Control Requirements19, Highway Heavy-Duty 

Engine Rule20, and the Non-Road Diesel Engine Rule21 are 

factored into the changes. 

In addition to the above, the General J.M. Gavin Station (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 operate their SNCRs continuously, 

to control and reduce NOx emissions, by December 2009. Also 

the Kyger Creek Station in Gallia County (units #1, #2, #3, #4, 

and #5) has installed SNCRs (to reduce NOx emission) which 

they have been running continuously since January 2009. In 

addition, Kyger Creek Station has plans underway for installation 

of FGDs (to reduce SO2 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.htm 
40 

Station in Adams County incorporated (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 between the year violations 

occurred and the year attainment was achieved is based on permanent and 

enforceable emission reductions and not on temporary adverse economic 

conditions or unusually favorable meteorology. 

Background 

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

met the NAAQS for PM2.5 in 2008-2010. U.S. EPA’s redesignation 

guidance (p 9) states: “A state may generally demonstrate maintenance 

of the NAAQS by either showing that future emissions of a pollutant or its 

precursors will not exceed the level of the attainment inventory, or by 

modeling to show that the future mix of sources and emissions rates will 

not cause a violation of the NAAQS.” 

Demonstration 

Permanent and enforceable reductions of PM2.5, NOx, and SO2 emissions 

have contributed to the attainment of the annual PM2.5 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 vehicles, Title IV of the 

CAA, the NOx SIP Call, CAIR, and federal consent decrees requiring the 

reductions of SO2 and NOx emissions from utility sources. Reductions 

achieved are discussed in greater detail under Chapter Five. 

Table 49 - Huntington-Ashland Area Combined Comparison of 

2005 base year and 2008 attainment year on-road, nonroad and EGU reductions 

2005 2008 

On-road PM2.5 500.72 435.39 

On-road NOx 12,813.39 10,596.04 

On-road SO2 192.92 65.22 

Non-road PM2.5 158.65 142.17 

Non-road NOx 1,566.88 1,401.13 

Non-road SO2 127.85 50.13 

EGU PM2.5 5,005.20 5,274.28 

EGU NOx 121,991.60 109,294.19 

EGU SO2 357,165.83 219,072.36 
41 

Requirement 5 of 5 

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

emission levels, including an annual emission statement from major sources. 

Demonstration

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

air emissions information annually, in accordance with U.S. EPA’s 

Consolidated Emissions Reporting Rule (CERR). Ohio EPA 

prepares a new periodic inventory for all PM2.5 precursor emission 

sectors every three years. These PM2.5 precursor inventories will 

be prepared for future years as necessary to comply with the 

inventory reporting requirements established in the CFR. 

Emissions information will be compared to the 2005 base year and 

the 2022 projected maintenance year inventories to assess 

emission trends, as necessary, and to assure continued 

compliance with the annual PM2.5 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 Clean 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 (including such reductions in 

emissions from existing sources in the area as may be obtained 

through the adoption, at a minimum, of reasonable available 

control technology). 

U.S. EPA’s Implementation Rule interprets this requirement in 

great detail. Under U.S. EPA’s approach, RACT is determined as 

part of the broader RACM analysis and identification of all 

measures (for stationary, mobile, and area sources) that are 

technically and economically feasible, and that would collectively 

contribute to advancing the attainment date (i.e. by one year or 

more). States are required to use a combined approach to RACT 

and RACM, that (1) identifies potential measures that are 

reasonable, (2) uses modeling to identify the attainment date that 

is as expeditious as practicable, and (3) selects the appropriate 

RACT and RACM. 

The Implementation Rule also provides for a presumption that in 

States that fulfill their CAIR emission reduction requirements, EGU 

compliance with CAIR is equivalent to RACM/RACT. 

Demonstration

In 1972, 1980, and 1991, Ohio promulgated rules requiring 

reasonably available controls measures for particulate emissions 

from stationary sources. 

Statewide RACT rules have been applied to all new sources 

locating in Ohio since that time. RACT requirements are 

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio EPA 

also has an active enforcement program to address violations 
43 

discovered by field office staff. The Ohio RACT rules for 

particulate matter are found in OAC Chapter 3745-1722. 

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

Chapter 3745-1423), CAIR (OAC Chapter 3745-10924), and NOx

Reasonably Available Control Technology rules (OAC Chapter 

3745-11025) over the past five years. Emissions from EGUs make 

up a significant contribution to Ohio’s inventory. Beginning in 2009, 

Ohio implemented CAIR which has, and will, provide for significant 

reductions in NOx, PM2.5, and SO2 until such time 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 both ozone precursors and PM2.5 

precursors in Ohio, Illinois, Indiana, Michigan, and Wisconsin area. 

The first consultant, MACTEC, prepared a series of white papers26

researching different stationary source categories. The results 

were compiled into two reports27. The second consultant, Environ, 

investigated control options for mobile sources. The results were 

compiled into two reports28. The stationary and mobile source 

sectors (and associated control measures) were selected by the 

LADCO States based on several factors presented in the report 

(See Chapter 2). 

Photochemical modeling was then conducted (as part of LADCO 

Round 4 modeling) to assess the air quality benefit of the 

candidate control measures and a modeling report was 

developed29. Based on the results, the LADCO project team felt it 

would not be possible to advance the attainment date for PM2.5. 

Ohio EPA, in its attainment demonstration submitted on July 18, 

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

 

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

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

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

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

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

27 

http://www.ladco.org/reports/control/final_reports/identification_and_evaluation_of_candidate_control_meas

ures_i_april_2005.pdf; 

http://www.ladco.org/reports/control/final_reports/identification_and_evaluation_of_candidate_control_meas

ures_ii_june_2006.pdf 

28

http://www.ladco.org/reports/control/final_reports/final_report_evaluation_of_candidate_mobile_source_cont

rol_measures_february_2006.pdf; 

http://www.ladco.org/reports/control/final_reports/final_report_evaluation_of_candidate_mobile_source_cont

rol_measures_for_ladco_states_in_2009_and_2012_march_2007.pdf

29 http://www.ladco.org/reports/control/modeling/round4_modeling.pdf
44 

attainment would be achieved in this area by 2009. Because of a 

projected 2009 attainment date, it would not have been reasonably 

possible or practicable for Ohio to develop RACT/RACM 

requirements, promulgate regulations and implement a control 

program prior to the projected attainment date. 

Requirement 2 of 6

Section 172(c)(2) of the 1990 CAA Amendments requires attainment 

demonstration SIPs for nonattainment areas to show reasonable further 

progress (RFP). 

Background

U.S. EPA’s Implementation Rule requires RFP only for any area 

which a State projects an attainment date beyond 2010. The RFP 

would provide emission reductions showing linear progress 

between 2002 and 2009. If a State demonstrates attainment will 

occur by 2010 or earlier, U.S. EPA considers the attainment 

demonstration to demonstrate achievement of RFP. 

Demonstration

In Ohio’s attainment demonstration 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 submit 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 revisions as determined necessary. 40 

CFR 51.1008 requires such inventory to be submitted within three 

years of designation and requires a baseline emission inventory 

for calendar year 2002 or other suitable year to be used for 

attainment planning. 

Demonstration

The 2005 comprehensive inventory was submitted to U.S. EPA 

with Ohio’s PM2.5 attainment demonstration SIP submitted on July 

18, 2008. It was then subsequently revised and resubmitted on 

June 7, 2010. 

Ohio also updates its inventory in accordance with U.S. EPA’s 

CERR rule (i.e. emissions statements). Ohio EPA submitted its 
45 

emissions statement SIP on March 18, 1994 which was approved 

by U.S. EPA on October 13, 1995 (59 FR 51863). As discussed in 

Chapter 4 (Requirement 4), Ohio EPA submits, and commits to 

submit, emission inventories (statements) every three years. 

Requirement 4 of 6

Evidence that control measures required in past PM2.5 SIP revisions have been 

fully implemented. 

Background

In addition to the historic RACT requirements for PM, the U.S. 

EPA NOx SIP Call required 22 states to pass rules that would 

result in significant emission reductions from large EGUs, 

industrial boilers, and cement kilns in the eastern United States. 

Ohio passed this rule in 2001. NOx SIP Call requirements are 

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio EPA 

also has an active enforcement program to address violations 

discovered by field office staff. Compliance is tracked through the 

Clean Air Markets data monitoring program. Beginning in 2004, 

this rule accounts for a reduction of approximately 31 percent of all 

NOx emissions statewide compared to previous uncontrolled 

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

On March 10, 2004, the U.S. EPA promulgated the CAIR. 

Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 

eastern states and the District of Columbia to significantly reduce 

emissions of NOx and SO2. CAIR replaced the NOx SIP Call for 

EGUs. National NOx emissions will be cut from 4.5 million tons in 

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

2018 in 28 states. States were required to submit a CAIR SIP as 

part of this effort. Ohio submitted a CAIR SIP which was approved 

by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were 

again submitted on July 15, 2009. The revised CAIR SIP was 

approved as a direct final action on September 25, 2009 (74 FR 

48857). 

Demonstration

Controls for EGUs under the NOx SIP Call formally commenced 

May 31, 2004. Emissions covered by this program have been 

generally trending downward since 1998 with larger reductions 

occurring in 2002 and 2003. Data taken from the U.S. EPA Clean 

Air Markets web site, quantify the gradual NOx reductions that 

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

Amendments and the beginning of the NOx SIP Call Rule. Ohio 

developed the NOx Budget Trading Program rules in OAC Chapter 
46 

3745-1430 in response to the SIP Call. OAC Chapter 3745-14 

regulates EGUs and certain non-EGUs under a cap and trade 

program based on an 85 percent reduction of NOx emissions from 

EGUs and a 60 percent reduction of NOx emissions from nonEGUs, compared to historical levels. This cap was in place 

through 2008, at which time the CAIR program superseded it as 

discussed above. Requirement 3 of 5 under Chapter 4 above 

discussed the reductions Ohio has seen as a result of CAIR. 

On April 21, 2004, U.S. EPA published Phase II of the NOx SIP 

Call that establishes a budget for large (greater than 1 ton per day 

emissions) stationary internal combustion engines. Ohio EPA’s 

OAC rule 3745-14-12 addresses stationary internal combustion 

engines, all used in natural gas pipeline transmissions. U.S. EPA 

approved this revision to the SIP on April 4, 2008. An 82 percent 

NOx reduction from 1995 levels is anticipated. Completion of the 

compliance plan occurred by May 1, 2006, and the compliance 

demonstration began May 1, 2007. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur 

Standards 

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

reduce emissions from cars and light trucks, including sport utility 

vehicles (SUVs). Under this proposal, automakers will be required 

to sell cleaner cars, and refineries will be required to make 

cleaner, lower sulfur gasoline. This rule will apply nationwide. The 

federal rules will phase in between 2004 and 2009. U.S. EPA has 

estimated that NOx emission reductions will be approximately 77 

percent for passenger cars, 86 percent for smaller SUVs, light 

trucks, and minivans, and 65 to 95 percent reductions for larger 

SUVs, vans, and heavier trucks. The sulfur content of gasoline is 

estimated to be reduced by up to 90 percent. VOC emission 

reductions will be approximately 12 percent for passenger cars, 18 

percent for smaller SUVs, light trucks, and minivans, and 15 

percent for larger SUVs, vans, and heavier trucks. 

Heavy-Duty Diesel Engines 

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

Engines, a program which includes low-sulfur diesel fuel 

standards, which will be phased in from 2004 through 2007. This 

rule applies to heavy-duty gasoline and diesel trucks and buses. 

This rule will result in a 40 percent reduction in NOx from diesel 

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

 

30 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 
47 

inventory. It also estimated the level of sulfur in highway diesel fuel 

will be reduced by 97 percent by mid-2006. 

Clean Air Non-road Diesel Rule 

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

 This rule applies to diesel engines used in industries such as 

construction, agriculture, and mining. It also contains a cleaner 

fuel standard similar to the highway diesel program. The new 

standards will cut emissions from non-road diesel engines by more 

than 90 percent. Non-road diesel equipment, as described in this 

rule, currently accounts for 47 percent of diesel particulate matter 

(PM) and 25 percent of NOx from mobile sources nationwide. 

Sulfur levels will be reduced in non-road diesel fuel by 99 percent 

from current levels, from approximately 3,000 parts per million 

(ppm) now to 15 ppm in 2009. New engine standards take effect, 

based on engine horsepower, starting in 2008. Together, these 

rules will substantially reduce local and regional sources of PM2.5

precursors. 

Requirement 5 of 6

Acceptable provisions to provide for new source review. 

Background

Ohio has a longstanding and fully implemented New Source 

Review (NSR) program. This is addressed in OAC Chapter 3745-

3131. The Chapter includes provisions 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. EPA as part of 

the SIP. 

Demonstration

Any facility that is not listed in the 2005 emission inventory, or for 

the closing of which credit was taken in demonstrating attainment, 

will not be allowed to construct, reopen, modify, or reconstruct 

without meeting all applicable NSR requirements. Once the area 

is redesignated, Ohio EPA will implement NSR through the PSD 

program. 

Requirement 6 of 6

 

31 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx 
48 

Assure that all existing control measures will remain in effect after redesignation 

unless the State demonstrates through modeling that the standard can be 

maintained without one or more control measures. 

Demonstration

Ohio commits to maintaining the aforementioned control measures 

after redesignation. Ohio hereby commits that any changes to its 

rules or emission limits applicable to PM2.5, SO2, and NOx as 

required for maintenance of the annual PM2.5 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 office, has the legal authority and 

necessary resources to actively enforce any violations of its rules 

or permit provisions. After redesignation, it intends to continue 

enforcing all rules that relate to the emission of PM2.5 precursors in 

the 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 plan eight years after redesignation. 

Demonstration

Ohio hereby commits to review its maintenance plan eight years 

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

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

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

Demonstration

Ohio hereby commits to adopt and expeditiously implement 

necessary corrective actions in the following circumstances: 

Warning Level Response: 

A warning level response shall be prompted whenever the PM2.5

average of the weighted annual mean of 15.5 μg/m3 occurs in a 

single calendar year within the maintenance area. A warning level 

response will consist of a study to determine whether the PM2.5

value indicates a trend toward higher PM2.5 values or whether 

emissions appear to be increasing. The study will evaluate 

whether the trend, if any, is likely to continue and, if so, the control 

measures necessary to reverse the trend taking into consideration 

ease and timing for implementation as well as economic and social 

considerations. Implementation of necessary controls in response 

to a warning level response trigger will take place as expeditiously 

as possible, but in no event later than 12 months from the 

conclusion of the most recent calendar year. 

Should it be determined through the warning level study that action 

is necessary to reverse the noted trend, the procedures for control 

selection and implementation outlined under “action level 

response” shall be followed. 

Action Level Response: 

An action level response shall be prompted whenever a two-year 

average of the weighted annual means of 15.0 μg/m3

 or greater 

occurs within the maintenance area. A violation of the standard 
50 

(three-year average of the weighted annual means of 15.0 μg/m3

or greater) shall also prompt an action level response. In the 

event that the action level is triggered and is not found to be due to 

an exceptional event, malfunction, or noncompliance with a permit 

condition or rule requirement, Ohio EPA in conjunction with the 

metropolitan planning organization or regional council of 

governments, will determine additional control measures needed 

to assure future attainment of the NAAQS for annual PM2.5. In this 

case, measures that can be implemented in a short time will be 

selected in order to be in place within 18 months from the close of 

the calendar year that prompted the action level. Ohio EPA will 

also consider the timing of an action level trigger and determine if 

additional, significant new regulations not currently included as 

part of the maintenance provisions will be implemented in a timely 

manner and will constitute our response. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the 

necessary administrative and legal process. This process will 

include publication of notices, an opportunity for public hearing, 

and other measures required by Ohio law for rulemaking. 

If a new measure/control is already promulgated and scheduled to 

be implemented at the federal or State level, and that 

measure/control is determined to be sufficient to address the 

upward trend in air quality, additional local measures may be 

unnecessary. Furthermore, Ohio will submit to U.S. EPA an 

analysis to demonstrate the proposed measures are adequate to 

return the area to attainment. 

Requirement 3 of 4

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

event. 

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective 

at the time the selection is made. The selection of measures will 

be based on cost-effectiveness, emission reduction potential, 

economic and social considerations or other factors that Ohio EPA 

deems appropriate. Ohio EPA will solicit input from all interested 

and affected persons in the maintenance area prior to selecting 

appropriate contingency measures. Because it is not possible at 

this time to determine what control measures will be appropriate at 

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

outlined below is not exhaustive. 
51 

1) Diesel reduction emission strategies. 

2) Alternative fuel (e.g., liquid propane and compressed natural 

gas) and diesel retrofit programs for fleet vehicle operations. 

3) Tighter PM2.5, SO2, and NOx emissions offsets for new and 

modified major sources. 

4) Impact crushers located at recycle scrap yards – upgrade wet 

suppression. 

5) Concrete manufacturing – upgrade wet suppression. 

6) Additional NOx RACT statewide. 

No contingency measure shall be implemented without providing 

the opportunity for full public participation during which the relative 

costs and benefits of individual measures, at the time they are 

under consideration, can be fully evaluated. 

Requirement 4 of 4 

A list of PM2.5, SO2, and NOx sources potentially subject to future additional 

control requirements. 

Demonstration

The following is a list of PM2.5, SO2, and NOx sources potentially 

subject to future controls. 

• ICI Boilers - SO2 and NOx controls; 

• 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 redesignation petition and maintenance plan in the 

widely distributed county publications on March 17, 2011. 

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

on April 21, 2011, at the Portsmouth City Health Department, Portsmouth, Ohio. 

The public comment period closed on April 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 PM2.5 nonattainment area has attained the 1997 

annual NAAQS for PM2.5 and complied with the applicable provisions of the 1990 

Amendments to the CAA regarding redesignations of PM2.5 nonattainment areas. 

 Documentation to that effect is contained herein. Ohio EPA has prepared a 

redesignation request and maintenance plan that meet the requirements of 

Section 110 (a)(1) of the 1990 CAA. 

Based on this presentation, the Huntington-Ashland annual PM2.5 nonattainment 

area meets the requirements for redesignation under the CAA and U.S. EPA 

guidance. Ohio has performed an analysis that shows the air quality 

improvements are due to permanent and enforceable measures. Furthermore, 

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

regional SO2 and NOx reductions will ensure continued compliance 

(maintenance) with the standard with an increasing margin of safety. 

The State of Ohio hereby requests that the Huntington-Ashland annual PM2.5

nonattainment area be redesignated to attainment simultaneously with U.S. EPA 

approval of the maintenance plan provisions contained herein. 
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