Siaie of Ohio Envirorirneniai Proteciioi~ Ayei~cy

STREET ADDRESS: MAILING ADDRESS:

Lazarus Government Center TELE: (614) 644-3020 FAX. (614) 644-3184 P.0. BOX 1049 50 W. Town St., Suite 700 w epa state.oh.us Columbus, OH 43216-1049 Columbus, Ohio 43215



### BEC 

### 1 4 2009

Mr. Bharat Mathur Acting Regional Administrator U.S. EPA, Region 

### 5 77 West Jackson Blvd. R-19J Chicago, Illinois 60604-3507

Re: Request for Cincinnati - Hamilton Area Redesignation and Maintenance Plan Approval for the 1997 Eight-Hour Ozone Standard

Dear Administrator Mathur:



### I am writing to formally request a redesignation to attainment of the Ohio portion of the Cincinnati-Hamilton, OH-IN-KY area (Butler, Clermont, Clinton, Hamilton and Warren Counties in Ohio; Dearborn Township in Indiana; and Boone, Campbell, and Kenton Counties in Kentucky) with respect to the 1997 eight-hour ozone standard. The enclosed submittal combines the 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 ozone has been attained throughout this area based on 2007- 2009 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 CincinnatiHamilton area.

The enclosed information, compiled by Ohio Environmental Protection Agency (EPA), Ohio Department of Transportation, and the Ohio, Indiana and Kentucky Regional Council of Governments (associated planning organization), shows significant emission reductions in point and mobile sources 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 control strategies implemented by Ohio, such as Low Reid Vapor Pressure Fuel requirements. Note that Ohio's maintenance plan and emission projections do not account for the reductions that have resulted, and will continue to result, from the Clean Air Interstate Rule (CAIR), both regionally and directly within the Cincinnati-Hamilton area; however, Ohio EPA believes this program, or its future replacement, will also continue to ensure maintenance in this area.

Ted Strickland, Governor Lee Fisher, Lieutenant Governor Chris Korleski, Director @ Printed on Recycled Paper Ohio EPA is an Equal Opportunity EmployerU.S. EPA - Administrator Mathur Re: Cincinnati-Hamilton area ozone redesignation request Page 2 of 2

The public hearing for this package was held on December 9, 2009, in Cincinnati, Ohio and public comments were accepted through December 11, 2009.



### I am also requesting that this redesignation be processed by U.S. EPA as expeditiously

as possible due to the potential reclassification of this area to a moderate nonattainment area, as proposed by U.S. EPA on January 16, 2009 ("Proposed Rule To Implement the 1997 8-Hour Ozone National Ambient Air Quality Standard: Revision on Subpart 1 Area Reclassification and Anti-Backsliding Provisions Under Former I-Hour Ozone Standard; Proposed Deletion of Obsolete I-Hour Ozone Standard Provision," 74 Fed. Reg. 2936).

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

Sincerely,

Chris Korleski Director

enclosures

cc: Bob Hodanbosi, DAPC Jennifer Hunter, DAPC

# REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE CINCINNATI-HAMILTON, OH-KY-IN 8- HOUR OZONE NONATTAINMENT AREA

Butler, Clermont, Clinton, Hamilton, and Warren Counties, Ohio

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

December 2009This page left intentionally blanki 

### TABLE OF CONTENTS

Chapter One Introduction .................................................................................................................. ................. 1 Background .................................................................................................................... ............... 1 Geographical description ...................................................................................................... ........ 2 Status of air quality ......................................................................................................... .............. 2

Chapter Two Requirements for redesignation ................................................................................................ .... 3

Chapter Three Ozone monitoring .......................................................................................................................... 7 Ozone NAAQS ................................................................................................................... ........... 7 Ambient data quality assured ........................................................................................................ 8 Three complete years of data .................................................................................................. ..... 9 Commitment to continue monitoring ........................................................................................... 1 1

Chapter Four Emission inventory ............................................................................................................ .......... 13 Base year inventory ........................................................................................................... ......... 13 Emission projections .......................................................................................................... ......... 14 Demonstration of maintenance .................................................................................................. . 22 Permanent and enforceable emissions reductions ..................................................................... 36 Provisions for future updates ................................................................................................. ..... 36

Chapter Five Control measures and regulations .............................................................................................. 38 Marginal nonattainment areas to implement RACT .................................................................... 38 Emission inventories/statements ............................................................................................... . 38 Implementation of past SIP revisions .......................................................................................... 39 New source review provisions ................................................................................................. .. 43 Assurance of continued controls ............................................................................................... .. 43

Chapter Six Contingency measures .......................................................................................................... ..... 44 Commitment to revise plan ..................................................................................................... .... 44 Commitment for contingency measures ..................................................................................... 44 Potential contingency measures ................................................................................................ . 45 List of VOC and NO x sources...................................................................................................... 47

Chapter Seven Public participation .......................................................................................................... ............ 48

Chapter Eight Conclusions ................................................................................................................... ............. 49ii FIGURES

Figure 1 Cincinnati-Hamilton Basic Nonattainment Area..................................................... 8

TABLES

Table 1 Monitoring Data for Cincinnati-Hamilton 2007 – 2009 ......................................... 10 Table 2 Emission Estimations for On-road Mobile Sources for Butler Co., Ohio ............. 18 Table 3 Emission Estimations for On-road Mobile Sources for Clermont Co., Ohio ........ 18 Table 4 Emission Estimations for On-road Mobile Sources for Clinton Co., Ohio ............ 18 Table 5 Emission Estimations for On-road Mobile Sources for Hamilton Co., Ohio ......... 18 Table 6 Emission Estimations for On-road Mobile Sources for Warren Co., Ohio ........... 18 Table 7 Emission Estimations for On-road Mobile Sources for Dearborn Co., Indiana .... 19 Table 8 Summary of Ohio and Indiana Emission Estimations for On-Road Mobile Sources ............................................................................................................... 19 Table 9 Emission Estimations for On-road Mobile Sources for Boone Co., Kentucky ..... 19 Table 10 Emission Estimations for On-road Mobile Sources for Campbell Co., Kentucky 19 Table 11 Emission Estimations for On-road Mobile Sources for Kenton Co., Kentucky .... 19 Table 12 Summary of Kentucky Emission Estimations for On-Road Mobile Sources ........ 20 Table 13 Emission Estimations for On-road Total Cincinnati-Hamilton Sources ................ 20 Table 14 Mobile Vehicle Emission Budget for Ohio and Indiana ....................................... 20 Table 15 Mobile Vehicle Emission Budget for Kentucky .................................................... 21 Table 16 NOx Emission Inventory Butler Co, Ohio. ........................................................... 24 Table 17 NOx Emission Inventory Clermont Co., Ohio. ..................................................... 25 Table 18 NOx Emission Inventory Clinton Co., Ohio. ......................................................... 25 Table 19 NOx Emission Inventory Hamilton Co., Ohio. ...................................................... 26 Table 20 NOx Emission Inventory Warren Co., Ohio. ........................................................ 26 Table 21 NOx Emission Inventory Dearborn Co., Indiana. ................................................. 27 Table 22 NOx Emission Inventory Boone Co., Kentucky ................................................... 27 Table 23 NOx Emission Inventory Campbell Co., Kentucky. ............................................. 28 Table 24 NOx Emission Inventory Kenton Co., Kentucky. ................................................. 28 Table 25 NOx Emission Inventory Cincinnati-Hamilton, Total ............................................ 29 Table 26 VOC Emission Inventory Butler Co, Ohio. ........................................................... 29 Table 27 VOC Emission Inventory Clermont Co., Ohio. ..................................................... 30 Table 28 VOC Emission Inventory Clinton Co., Ohio. ........................................................ 30 Table 29 VOC Emission Inventory Hamilton Co., Ohio. ..................................................... 31 Table 30 VOC Emission Inventory Warren Co., Ohio. ....................................................... 31 Table 31 VOC Emission Inventory Dearborn Twp., Indiana. .............................................. 32 Table 32 VOC Emission Inventory Boone Co., Kentucky ................................................... 32 Table 33 VOC Emission Inventory Campbell Co., Kentucky. ............................................. 33 Table 34 VOC Emission Inventory Kenton Co., Kentucky. ................................................. 33 Table 35 VOC Emission Inventory Cincinnati-Hamilton, Total ........................................... 34 Table 36 Projected Emission Estimates 2008-2020 Cincinnati-Hamilton........................... 34 Table 37 Combined Comparison of 2005 and 2008 On-road and EGU Totals .................. 36iii APPENDICES

A Air Quality System (AQS) Data B Ohio 2005 SIP Base Year Inventory Discussion C “Mobile Source Emissions Inventory for the Cincinnati Ozone Nonattainment Area” D LADCO Technical Support Document E Public Participation Documentationiv This page left intentionally blank1 REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE CINCINNATI-HAMILTON, OHIO OZONE NONATTAINMENT AREA

Butler, Clermont, Clinton, Hamilton, and Warren Counties, Ohio



### CHAPTER ONE

Introduction The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air Quality Standard (NAAQS) for oz one to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standard. In 1997, the United States Environment al Protection Agency (U.S. EPA) revised the air quality standard for ozone replacing the 1979 one-hour standard with an eighthour ozone standard set at 0.08 parts per million (ppm). The standard was challenged legally and upheld by the U.S. Supreme Court in February of 2001.

On April 30, 2004, U.S. EPA designat ed 134 nonattainment areas for the eight-hour ozone standard. Se ction 107(d)(3)(E) of the CAA allows states to request nonattainment areas to be r edesignated 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 eight-hour ozone standard. ii) An approved State Implementat ion Plan (SIP) for the area under Section 110(k). iii) A determination that the improv ement in air quality is due to permanent and enforceable r eductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirements have been met.

Background The current Cincinnati-Hamilton nonatta inment area includes the following Counties: Butler, Clermont, Clinton, Hamilton, and Warren in Ohio; Dearborn (partial nonattainment of Lawrenceburg Township only ) in Indiana; and Boone, Campbell, and Kenton in Kentucky.

As part of the 1990 CAA Amendments re-e valuation, the following Counties within the Cincinnati-Ha milton area were designated as moderate nonattainment for the one-hour ozone standard pursuant to the CAA and,2 therefore, were subject to nonattainme nt area rulemakings: Butler, Clermont, Hamilton, and Warren Counties in Oh io and Boone, Campbell and Kenton Counties in Kentucky. The Ohio por tion of the Cincinnat i-Hamilton area was redesignated to attainment on June 19, 2000 (65 FR 37879). Clinton County, Ohio was designated as a transitional nonattainment area. Clinton County was redesignated to attainment on March 21, 1996 (61 FR 11560). A maintenance plan was approved at those times.

As a result of the 2004 ozone des ignations, U.S. EPA designated the Cincinnati-Hamilton area basic nonattainm ent for the eight-hour standard, and Ohio EPA was required to develop a plan to reduce volatile organic compounds (VOCs) and nitrogen oxides (NO x ) emissions to meet the federal eight-hour air quality standard for ozone by June 2009.

This document is intended to support Ohio ’s request that the Ohio portions of the Cincinnati-Hamilton area be redes ignated from nonattainment to attainment for the eight-hour ozone st andard. In addition, the States of Kentucky and Indiana also intend to subm it requests for their respective portions of the Cin cinnati-Hamilton area. The Cincinnati-Hamilton area has recorded three (3) years of complete quality-assured am bient air quality monitoring data for the years 2007 – 2009 demonstrating attainment of the eight-hour ozone standard.

Geographical Description The Cincinnati-Hamilton ei ght-hour ozone nonattainment area is located in southwest Ohio and includes the follo wing Counties of: Butler, Clermont, Clinton, Hamilton, and Warren in Ohio; Dearborn (partial nonattainment of Lawrenceburg Township only ) in Indiana; and Boone, Campbell, and Kenton in Kentucky. This area is shown in Figure 1 under Chapter Three.

Status of Air Quality Ozone monitoring data for the most re cent three (3) years, 2007 through 2009, demonstrate that the air quality has met the NAAQS for ozone in this basic nonattainment area. The NAAQ S attainment, accompanied by decreases in emission levels discu ssed in Chapter Four, supports a redesignation to attainment for t he Cincinnati-Hamilton area based on the requirements in Section 107(d)(3)(E) of the CAA.3 

### CHAPTER TWO

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

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

i.) Attainment of the standard There are two components involved in making this demonstration. The first component relies on ambient air quality data. The data that are used to demonstrate attainment should be the product of ambi ent 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 Ai r Quality System (AQS) in order for it to be available to the public for review.

The second component relie s upon supplemental U.S. EPAapproved air quality modeling. The supplemental modeling is not required for ozone nonatta inment areas seeking redesignation ; however, in Appendix C and Appendix D the most recent modeling results showing future attainment and maintenance are provided. C hapter Three discusses this requirement in more detail and provides the attainment demonstration.

ii.) SIP approval The SIP for the area must be fully approved under Section 110(k) and must satisfy all the requirements that apply to the area. Ohio’s SIP was appr oved on May 9, 1994 (59FR23799) and March 23, 1995 (60FR15235) and includes the CincinnatiHamilton area. Chapter Five discusses this requirement in more detail.

iii.) Permanent and enforceable im provement in air quality The state must be able to reas onably attribute the improvement in air quality to emission r eductions which are permanent and enforceable. The state should es timate the percent reduction achieved from federal measures as well as control measures that have been adopted and impl emented by the state.4 The Ohio Counties portion of the Cincinnati-Hamilton area was designated moderate nonattainment for ozone as part of the 1990 CAA Amendments re-evaluation. As a result, Ohio has adopted and implemented control meas ures for these Counties in that area beyond the federal measur es and the initial 1979/1981 Statewide rules. In addition, Ohio EPA has adopted several rules recently that will have an impact Statewide on ozone emissions in the future:

• Portable Fuel Containers requirements

• Architectural and Industrial Maintenance (AIM) Coatings rules

• Consumer Products rules

• Clean Air Interstate Rule (CAIR)

• NO x Sip Call Rules

Chapters Four and Five discuss this requirement in more detail.

iv.) Section 110 and Part D requirements For purposes of redesignati on, a state must meet all requirements of Section 110 and Part D that were applicable prior to submittal of the complete redesignation request.

Part D consists of general r equirements applicable to all areas which are designated nonattainment based on a violation of the NAAQS.

i.) Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Sect ion 110(a)(2) provides that the implementation plan submi tted by a state must have been adopted by the state afte r reasonable public notice and hearing, and that, among ot her things, it must include enforceable emissi on 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 stationar y source within the areas covered by the plan; in clude provisions for the implementation of Part C, prevention of significant deterioration (PSD) and Part D, NSR permit programs; include criteria for stationar y source emission control5 measures, monitoring, and r eporting; include provisions for air quality modeling; and pr ovides for public and local agency participation in planning and emission control rule development. In Ohio’s December 5, 2007 and September 4, 2009 infrastructu re SIP submissions, Ohio verified that the State fulfills the requirements of Section 110(a)(2) of the Act.

ii.) Section 172(c) requirements This Section contains general requirements for nonattainment plans. The requirements for reasonable further progress, identificat ion of certain emissions increases, and other measur es needed for attainment will not apply for redesignati ons because they only have meaning for areas not atta ining 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.

ii.) 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 proce dures, if the state already has these procedures in plac e. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the st ate must commit to follow U.S. EPA’s conformity r egulation upon issuance, as applicable.

v.) Maintenance plans Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fu lly approve a maintenance plan that meets the requirement s of Section 175(A). The maintenance plan must constitute a SIP revision and must provide for maintenance of the re levant NAAQS in the area for at least 10 years after redesignat ion. 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 Ad ministrator deems necessary to ensure prompt correction of any vi olation of the NAAQS. At a minimum, the contingency measures must include a6 requirement that the state will implem ent 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.7 

### CHAPTER THREE

OZONE MONITORING 1 CAA Section107 (d)(3)(E)(i)

Requirement 1 of 4 A demonstration that the NAAQS for oz one, as published in 40 CFR 50.4, has been attained.

Background There are eleven monitors m easuring ozone concentrations in this nonattainment area. Eight of the eleven monitors, located in Ohio, are operated by Ohio EPA Division of Air Pollution Control, Southwest District Office and the Hamilton County Division of Environmental Serv ices. A listing of the design values based on the three-year average of the annual fourth highest daily maximum eight-hour average ozone concentrations from 2007 through 2009 is shown in Table 1. The locations of the monitoring site s for this nonattainment area are shown on Figure 1.

1 The draft version of this redesignation request primarily contains data through the end of August and has not been fully quality assured. However, all data will be incorporated and quality assured, as described in the text of this document, prior to official submittal to U.S. EPA. Ohio EPA does not believe the data as provided in this draft will change appreciably.8 Demonstration

Figure 1 Map of the Cincinnati-Hamilton, OH nonattainment area and monitor locations

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

Demonstration The Ohio Environmental Protec tion Agency (Ohio EPA) has quality assured all data shown in Appendi x A in accordance with 40 CFR 58.10 and the Ohio Quality Assur ance Manual. Ohio EPA has recorded the data in the AQS databas e and, therefore, the data are available to the public.9 Requirement 3 of 4 A showing that the three-year average of the fourth highest values, based on data from all monitoring sites in the area or its affected downwind environs, are below 85 parts per billion (ppb). (This showing must rely on three complete, consecutive calendar years of quality assured data.)

Background The following information is ta ken from U.S. EPA's "Guideline on Data Handling Conventions fo r the eight-hour ozone National Ambient Air Quality Standard (NAAQS)," U.S. EPA-454/R-98- 017, December 1998.

Three complete years of ozone monitoring data are required to demonstrate attainment at a m onitoring site. The eight-hour primary and secondary ozone ambi ent air quality standards aremet at an ambient air quality monitoring site when the threeyear average of the annual fourth -highest daily maximum eighthour average ozone concentrations is less than or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. Three significant digits must be carried in the computations. Because the third decimal digi t, in ppm, is rounded, 0.084 ppm is the largest concentration that is less than or equal to 0.08 ppm. Therefore, for the purposes of this request, the eight-hour standard is considered to be 0.085 ppm. Values below 0.085 ppm meet the standard, values equal to or greater than 0.085 ppm exceed the standar d. These data handling procedures are applied on an indivi dual basis at each monitor in the area. An area is in co mpliance with the eight-hour ozone NAAQS if, and only if, every moni toring site in the area meets the NAAQS. An individual site 's three-year average of the annual fourth highest daily maxi mum eight-hour average ozone concentrations is also called the site's design value.

Table 1 shows the monitoring data for 2007 – 2009 that were retrieved from the U.S. EPA AQS. The air quality design value for the area is the highest desi gn value among all sites in the

area. Please note that t he standard is measured in ppm while the commonly used unit is ppb. For the remainder of this document, ppb will be used.10 Demonstration

Table 1 Monitoring Data for the Cincinnati-Hamilton, OH area for 2007 – 2009

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

1 st 2 nd 3 rd 4 th 2007-2009

SITE

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

39-017-

0004 Butler Hamilton 2007 100 97 96 91 91 78 39-017-

0004 Butler Hamilton 2008 99 89 75 72 71 39-017-

0004 Butler Hamilton 2009 98 79 78 74 73 39-017-

1004 Butler Middletown 2007 100 104 97 95 91 82 39-017-

1004 Butler Middletown 2008 96 91 87 82 79 39-017-

1004 Butler Middletown 2009 100 78 76 76 76 39-025-

0022 Clermont Batavia 2007 98 93 92 90 86 75 39-025-

0022 Clermont Batavia 2008 97 72 71 71 71 39-025-

0022 Clermont Batavia 2009 99 71 71 69 69 39-027-

1002 Clinton Wilmington 2007 99 91 89 85 82 76 39-027-

1002 Clinton Wilmington 2008 96 87 80 77 76 39-027-

1002 Clinton Wilmington 2009 96 73 72 71 70 39-061-

0006 Hamilton Cincinnati 2007 96 100 92 91 89 82 39-061-

0006 Hamilton Cincinnati 2008 96 93 89 87 86 39-061-

0006 Hamilton Cincinnati 2009 98 80 76 75 72 39-061-

0010 Hamilton Cleves 2007 99 93 91 88 86 76 39-061-

0010 Hamilton Cleves 2008 96 85 79 78 77 39-061-

0010 Hamilton Cleves 2009 80 69 66 65 65 39-061-

0040 Hamilton Cincinnati 2007 99 97 93 88 86 80 39-061-

0040 Hamilton Cincinnati 2008 100 86 83 81 8011 1 st 2 nd 3 rd 4 th 2007-2009

SITE

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

39-061-

0040 Hamilton Cincinnati 2009 99 77 76 74 74 39-165-

0007 Warren Lebanon 2007 100 103 89 88 88 82 39-165-

0007 Warren Lebanon 2008 95 92 87 84 82 39-165-

0007 Warren Lebanon 2009 100 80 80 78 77 21-015-

0003 Boone Not in City 2007 100 81 79 78 78 68 21-015-

0003 Boone Not in City 2008 98 65 64 64 64 21-015-

0003 Boone Not in City 2009 98 69 67 65 64 21-037-

3002 Campbell Highland Heights 2007 100 95 92 88 86 76 21-037-

3002 Campbell Highland Heights 2008 99 84 83 75 75 21-037-

3002 Campbell Highland Heights 2009 100 75 72 70 68
21-117-

0007 Kenton Covington 2007 100 93 89 85 85 77
21-117-

0007 Kenton Covington 2008 99 80 77 74 73
21-117-

0007 Kenton Covington 2009 99 76 75 75 74
Highest Average 82 ppb

The area's design values have tr ended downward as emissions have declined due to such factors as cleaner automobiles and fuels, and controls for EGUs, both regionally and locally.

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 ozone levels at the Ohio sites indicated in Figure 1. Ohio EPA will consult with U.S. EPA Region V 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 requirement s of 40 CFR 58 and all other federal requirements. Connec tion to a central station and12 updates to the Ohio EPA web site 2 will provide real time availability of the data and kno wledge of any exceedances. Ohio EPA will enter all data into AQS on a timely basis in accordance with federal guidelines.

2 www.epa.state.oh.us/dapc/13 

### CHAPTER FOUR

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

U.S. EPA’s redesignation guidance requires the submittal of a comprehensive inventory of ozone precur sor emissions (VOC and NO x ) representative of the year when the area achieves attainment of the ozone air quality standard. Ohio also must demonstrat e that the improvement in air quality between the year that violations occurred and the y ear that attainment was achieved is based on permanent and enforceable emi ssion 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 ozone 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 us ed by Ohio EPA and the Lake Michigan Air Directors Consortium (LADCO) regardi ng emissions from Ohio’s portion of the Counties in the Cinci nnati-Hamilton area. Spec ific emissions data are provided for all Counties, including t hose in Ohio, Kentucky and Indiana. Indiana and Kentucky emissions data were obtained directly from Indiana and Kentucky, respectively. All of thes e inventories and emi ssions projections were prepared using similar methodologies. Ohio recognizes that revisions to the emissions data below may be necessary once Kentucky and Indiana prepare a redesignation request and maint enance plan for their portion of the nonattainment area. Mobile emissions inventories and projections for all Counties were prepared by the Ohio , Kentucky, Indiana Council of Governments (OKI).

Requirement 1 of 5 A comprehensive emission inventory of the precursors of ozone completed for the base year.

Background The point source data are tak en from Ohio's annual emissions reporting program. The 2005 periodic inventory has been identified as one of the pr eferred databases for SIP development and coincides with nona ttainment air quality in the Cincinnati-Hamilton area.

Periodic inventories, which incl ude emissions from all sectors - mobile, area, non-road, and point sources - are prepared every three years.14 Demonstration The 2005 inventory is used as t he base year for the purpose of this submittal and was submitt ed to U.S. EPA on June 15, 2007 along with the attainment demons tration for this area. The detailed emission inventory info rmation for the Ohio portion of the Cincinnati-Hamilt on area is provided in Appendix B. Emissions of VOC and NOx for 2005 are identified under Requirement Three of this Chapter.

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

Background Ohio EPA prepared a comprehensive inv entory for the Ohio portion of the Cincinnati-Hamilton area including area, mobile, and point sources for precursors of ozone (VOCs and NO x ) for base year 2005. The 2005 inventory was submitted to U.S. EPA on June 15, 2007 as part of the attainment demonstration for th is area. The information below describes the procedures Ohio EPA used to generate the 2005 base year inventory and to develop SI P-ready modeling inventories and future year projections (Pechan Report 3 ). The report by Pechan generated future year estimates of annual emissions for each source sector using accepted growth surr ogates. These inventories were provided to the LADCO and have b een processed to develop summerday 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, the on-road mobile source sector was addressed by specific modeling as discussed below.

• Area sources were taken from the Ohio 2005 periodic inventory submitted to U.S. EPA. These projections were made from the U.S. Department of Commerce Bureau of Economic Analysis ( BEA) growth factors, with some updated local information.

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

3 http://www.ladco.org/tech/emis/r5/re ports/LADCO%202005%20Base%20Yr%20Growth%20and% 20Controls%20Report_Final.pdf15 • Point source information wa s compiled from Ohio EPA’s 2005 annual emissions inventor y database and the 2005 U.S. EPA Air Markets acid rain database 4

.

• 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 conc erns about the accuracy of some of the categorie s 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 fo r agricultural sources also was updated.

Demonstration

On-Road Emission Estimations In coordination with the Ohio Department of Transportation (Ohio DOT), OKI utilizes a r egional travel demand forecast model to simulate traffic in the area and to forecast traffic flows for given growth expectations. The model has been validated to observed traffic volumes for t he model base year 2005. The model is primarily used as a long range planning tool to evaluate the transportation system including determination of locations where additional trav el capacity ma y be needed and to determine the infrastructure requirements necessary to meet that need. It is also used as a tool for air quality purposes to estimate the total emissions of pollution caused by vehicles in the area. The travel demand forecasting model is used to predict the total daily vehicle miles traveled (VMT), and a U.S. EPA computer program called MOBI LE6.2 is used to calculate emissions per mile. The product of these is the total amount of pollution emitted by the on-road v ehicles for the area. Clinton County is outside the area cove red by the regional travel demand model. The Ohio DOT uses traffic counts and local traffic growth rates for the VMT estimates.

4 http://www.epa.gov/airmarkets/acidrain16 Overview OKI incorporates a variety of sources of local data to both improve and confirm the accuracy of VMT, as well as other travel-related parameters. Free flow speeds used on the highway and transit networks are based on travel time studies performed locally. An OKI post- processing program uses the loaded highway network to gener ate VMT by hour, VMT by speed distribution, and VMT by fac ility type. These tables are then included as input into MO BILE6.2. The VMT by hour tables utilize hourly traffic di stribution and directional split factors for different roadway types as developed by OKI. The main source of the data was the permanent traffic counting stations located throughout the OKI region. These data were supplemented with data collected at coverage count stations (locations with counts taken on only one-two days). The stations were classified by area type(urban and rural) and functional classification (freeway , arterial and collector). Speeds representing various “loaded” condi tions (with traffic volumes) are estimated using techni ques from the 1997 Highway Capacity Manual. This permits the estimation of speeds as conditions vary from hour to hour on the different facility types throughout the region. The pos t-processing program performs the appropriate summation by area and roadway type as well as regional totals. OKI has also developed seasonal conversion factors to adjust traffic volu mes to summer conditions. The factors were derived from lo cal data collected at permanent traffic counting stations utilizing the average daily traffic monthly conversion factors for June, July and August.

OKI’s utilized U.S.EPA’s emissi ons model MOBILE6.2 to develop emission factors for VOC’s and NO X . The MOBILE6.2 input file contains loca l parameters, developed through consultation with the Ohio DOT and Ohio EPA, for temperature, fuel programs and fuel characteri stics. Low RVP (Reid Vapor Pressure) gasoline is the summer fuel program in OKI’s Ohio counties. Low RVP fuel results in lower evaporative emissions and is a key component of the region’s strategy for ozone attainment. The local paramet ers are combined with the VMT tables from the OKI Travel De mand Model to produce one set of emission factors measured in gram s per mile for the appropriate calendar year (from 1952 to 2050). These emission factors are then multiplied by VMT. The methodologies incorporated into MOBILE6.2 for estimating emissions are based on methods and research conducted by U.S. EPA. OKI’s development of MOBILE6.2 input values we re guided by the U.S.EPA’s17 document “Technical Guidance on the Use of MOBILE6 for Emission Inventory Preparation”, January 2002

. Some of the assumptions built into MOBILE6.2 include the following: older vehicles have much higher emission factors than newer vehicles, diesel vehicles have much higher NO x emission factors and lower VOC em ission factors than gasoline vehicles, and higher average speeds have lower emission factors except for diesel v ehicles which have higher NO x at higher speeds. MOBILE6.2 input and output file s are provided in Appendix C.

Best Available Data Most current vehicle age distri bution data, tem perature data, and fuel properties data provided by Ohio EPA were used by OKI and the Ohio DOT for gener ating emission factors. Likewise, the most current transportation planning data available from OKI and most curr ent Ohio DOT count data were used by Ohio DOT for the emissi ons estimates. Details about each data set and how it was us ed is documented in OKI’s “Mobile Source Emissions In ventory for the Cincinnati Ozone Nonattainment Area” document dated October, 2009 (revised). See Appendix C.

Analysis Years Analysis years for this redes ignation request include 2005, 2008 (attainment year), 2015 (interim year), and 2020 to meet the requirements specified by the CAA and U.S. EPA. The travel demand model presents the trans portation system conditions for each of these years. Model runs for each future analysis year contain the road network OKI and Ohio DOT expect to exist in July of that year with corresponding socioeconomic forecasts for that year.

Local Road VMT Most local roads such as subdivi sion streets are not explicitly modeled in a travel demand model . These local roads are represented as fictitious roadwa ys called centroid connectors. Local road VMT is included in t he OKI post process by including the traffic loaded on centroid c onnectors. In addition, some local road traffic is captured as intra-zonal trips which travel demand models usually do not assi gn to roadway segments. The OKI post process includes these trips as local road VMT.18 On-Road Mobile Emission Estimations Tables 2 through 13 contain the results of the emissions analysis for the appropriate years. All emissi ons estimations are expressed in tons per summer day (TSD).

Table 2 - Butler County, Ohio Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 9.94 7.87 4.87 4.50
NOx (TSD) 18.88 16.05 7.55 5.37 VMT (miles/day) 7,804,476 8,133,554 8,869,806 9,520,999

Table 3 - Clermont County, Ohio Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 6.86 5.42 3.29 3.04
NOx (TSD) 13.04 11.05 5.10 3.63 VMT (miles/day) 5,391,578 5,599,530 5,995,538 6,434,554

Table 4 - Clinton County, Ohio Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 3.02 2.33 1.47 1.22
NOx (TSD) 5.07 3.87 2.02 1.41 VMT (miles/day) 1,809,600 1,793,580 2,049,496 2,172,899

Table 5 - Hamilton County, Ohio Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 29.47 22.70 13.44 12.00
NOx (TSD) 56.51 46.80 21.11 14.44 VMT (miles/day) 23,170,766 23,481,421 24,516,538 25,407,972

Table 6 - Warren County, Ohio Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 7.97 6.26 4.02 3.88
NOx (TSD) 15.15 12.76 6.23 4.63 VMT (miles/day) 6,263,010 6,464,217 7,324,104 8,209,23619 Table 7 – Dearborn County, Indi ana Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 1.00 0.75 0.50 0.42
NOx (TSD) 1.44 1.14 0.60 0.42
VMT (miles/day) 599,761 613,027 673,632 715,923

Table 8 – Summary of Ohio and Indiana Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 58.26 45.33 27.59 25.06
NOx (TSD) 110.09 91.67 42.61 29.90 VMT (miles/day) 45,039,191 46,085,329 49,429,114 52,461,583

Table 9 - Boone County, Kentucky Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 4.33 4.00 3.17 2.96
NOx (TSD) 10.27 8.53 4.63 3.45 VMT (miles/day) 4,186,006 4,355,527 5,133,456 5,790,231

Table 10 - Campbell County, Kentucky Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 2.52 2.29 1.74 1.55
NOx (TSD) 5.98 4.88 2.54 1.81 VMT (miles/day) 2,437,698 2,495,174 2,809,926 3,039,274

Table 11 - Kenton County, Kentucky Emission Estimations for On-Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 4.32 3.85 2.85 2.56
NOx (TSD) 10.39 8.37 4.23 3.01 VMT (miles/day) 4,182,042 4,197,027 4,623,038 4,998,18420 Table 12 – Summary of Kentucky Emission Estimations for On- Road Mobile Sources

2005 2008 2015 2020 VOC (TSD) 11.17 10.14 7.76 7.07
NOx (TSD) 26.64 21.78 11.40 8.27 VMT (miles/day) 10,805,746 11,047,728 12,566,420 13,827,689

Table 13 - Emission Estimation Totals for On-Road Mobile Sources for the Cincinnati-Hamilton Area

2005 2008 2015 2020 VOC (TSD) 69.43 55.47 35.35 32.14
NOx (TSD) 136.73 113.45 54.01 38.17 VMT (miles/day) 55,844,937 57,133,057 61,995,534 66,289,272

Motor Vehicle Emission Budget

Table 14 and Table 15 contain the motor vehicle emissions budgets for the Cincinnati-Hamilton area. For planning purposes, budgets are established for t he combined Ohio and Indiana portions and for the separate Kentucky portion.

Table 14 - Mobile Vehicle Emissions Budget for Ohio and Indiana
2015 Estimated Emissions 2015 Mobile Safety Margin Allocation* 2015 Total Mobile Budget 2020 Estimated Emissions 2020 Mobile Safety Margin Allocation* 2020 Total Mobile Budget

VOC (TSD) 27.59 4.14 31.73 25.06 3.76 28.82 NOx (TSD) 42.61 6.39 49.00 29.90 4.49 34.39 VMT (miles/day) 56,843,481 - - 60,330,820 - - *The 15 percent margin of safety was calculated by taking 15 percent of the mobile source emission estimates.21 Table 15 - Mobile Vehicle Emissions Budget for Kentucky

2015 Estimated Emissions 2015 Mobile Safety Margin Allocation 2015 Total Mobile Budget 2020 Estimated Emissions 2020 Mobile Safety Margin Allocation 2020 Total Mobile Budget

VOC (TSD) 7.76 2.00 9.76 7.07 3.00 10.07 NOx (TSD) 11.40 3.00 14.40 8.27 5.00 13.27 VMT (miles/day) 14,451,383 - - 15,901,842 - -

The above budgets for the Ohio and Indiana portion of the area, agreed upon as part of the inter agency consultation process, include the emission estimates calculated for 2015 and 2020 (from Table 8) with an additional 15 percent margin of safety allocated to those estimates.

In an effort to accommodate futu re variations in travel demand models and VMT forecast when no change to the network is planned, Ohio EPA consulted wit h U.S. EPA to determine a reasonable approach to address this variation. Based on this discussion, a 15 percent margin of safety allocation was agreed upon and has been added to the emi ssions estimates for the Ohio and Indiana portions of this nonattainment area.

The above budget for the Kentu cky portion of the area was provided directly by Kentucky as part of the consultation process and also includes a margin of safety allocated to the emission estimates calculat ed for 2015 and 2020 (from Table 12).

The emission estimates are der ived from the travel demand model and MOBILE6.2 as descr ibed above under the expected OKI 2030 Long Range Plan. All methodologies, the latest planning assumptions, and the safety margins allocations were determined through the interagency consultation process described in the Transportation Conformity Memorandum of Understanding (MOU) among OKI, Ohio DOT, and Ohio EPA.

A 15 percent margin of safety is appropriate because: 1) there is an acknowledged potential vari ation in VMT forecast and potential estimated mobile sour ce emissions due to expected modifications to TDM and mobile emissions models; and 2) the total decrease in emissions from all sources is sufficient to22 accommodate this 15 percent allocation of safety margin to mobile sources while still cont inuing to maintain the total emissions in the Cincinnati-Ha milton area well below the 2006 attainment level of emissions.

The 15 percent margin of safety was calculated by taking 15 percent of the mobile source emission estimates. Safety margin, as defined by the confo rmity rule, looks at the total emissions from all sources in the nonattainment area. The actual allocation is less than 15 percent of the total emission reduction from all sources as can be seen from Table 36.

In summary, for all three stat es combined, the mobile budget safety margin allocation translates into:

--An allocation of 6.14 TSD for VOC and 9.39 TSD for NOx for 2015; and -An allocation of 6.76 TSD for VOC and 9.49 TSD for NOx for 2020.

When compared to the overall sa fety margin, as defined in 40 CFR 93.101 5 , discussed under “Requirement 3 of 5” below, it is evident this allocation is signifi cantly below the total safety margin for this area (see Table 36).

The current one-hour budget s will no longer be applicable either after the effective date of t he approved redesignation or after the effective date of any U.S. EPA action approvi ng a finding that the eight-hour conformity budget included in this submittal is adequate for transportation conformity purposes, whichever date comes first.

Requirement 3 of 5 A demonstration that t he projected level of emissions is sufficient to maintain the ozone standard.

Background In consultation with U.S. EPA, Oh io EPA selected the year 2020 as the maintenance year for th is redesignation request. This document contains projected emissions inventories for 2015 and 2020.

5 "safety margin" means the amount by which the total projected emissions from all sources of a given pollutant are less than the total emissions that would satisfy the applicable requirem ent for reasonable further progress, attainment, or maintenance.23 Emission projections for the Cincinnati-Hamilton area were performed using the following approaches:

• As performed by OKI, mobile source emission projections are based on the U.S. EPA MOBILE6.2 model. The analysis is described in more detail in Appendix C. All projections were made in accordance with “Procedures for Preparing Emissions Projections” U.S. EPA-45/4-91-019.

• Emissions inventories are required to be projected to future dates to assess the influence growth and future controls will have. 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 us ed for redesignation are consistent with modeling performed in the future. Appendix D contains LADCO’s technical support document detailing the anal ysis used to project emissions (Base M 6 ).

• For the Ohio portion of t he Cincinnati-Hamilton area, for the 2008 attainment year, em issions were grown from the 2005 LADCO modeling inv entory, using LADCO’s growth factors, for all se ctors except point sources (electrical generating units and non-electrical generating units). Point source emi ssions for 2008 were compiled from Ohio EPA’s 2008 annual emissions inventory database. The 2015 interi m year emissions were estimated based on the 2009 and 2018 LADCO modeling inventory, using LA DCO’s growth factors, for all sectors. The 2020 ma intenance year is based on emissions estimates from the 2018 LADCO modeling.

The detailed inventory informati on for the Ohio portion of the Cincinnati-Hamilton area for 2005 is in Appendix B. Emission trends are an important gauge fo r continued compliance with the ozone standard. T herefore, Ohio EPA performed an initial comparison of the inventor ies for the base year and maintenance years. Mobile s ource emission inventories are described in Section 5 of Appendix B.

6 http://www.ladco.org/tech/emis/current/index.php24 Sectors included in the followi ng tables are: Electrical Generating Unit (EGU-Point); N on-Electrical Generating Unit (Non-EGU); Non-road Mobile (Non -road); Other Area (Other); Marine; Aircraft; Rail (MAR); and On-road Mobile (On-road).

Maintenance is demonstrated w hen the future-year (2020) projected emission totals are below the 2008 attainment year totals.

The emissions data in the t ables below are based on the following data sources:

Demonstration

NO x
Table 16 - Butler County, Ohio NO x Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 3.88 2.87 2.86 2.95NonEGU 12.03 10.53 11.98 11.91Nonroad 7.76 6.55 4.06 3.01 Other 2.15 2.18 2.19 2.19 MAR 2.49 2.34 1.85 1.63Onroad 18.88 16.05 7.55 5.37 TOTAL 47.19 40.52 30.49 27.06 13.4625 Table 17 - Clermont County, Ohio NO x Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 42.96 22.61 50.07 51.49NonEGU 0.15 0.18 0.16 0.16Nonroad 4.07 3.48 2.21 1.67 Other 1.65 1.67 1.67 1.67 MAR 0.96 0.74 0.55 0.50 On-road 13.04 11.05 5.10 3.63 TOTAL 62.83 39.73 59.76 59.12 -19.39

Table 18 - Clinton County, Ohio NO x Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00NonEGU 0.00 0.00 0.00 0.00Nonroad 2.21 1.96 1.34 1.07 Other 0.42 0.43 0.43 0.43 MAR 0.05 0.05 0.05 0.06Onroad 5.07 3.87 2.02 1.41 TOTAL 7.75 6.31 3.84 2.97 3.3426 Table 19 - Hamilton County, Ohio NO x Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 15.23 12.92 28.32 29.13NonEGU 6.72 6.17 7.39 7.56Nonroad 16.08 13.28 8.04 5.89 Other 5.19 5.27 5.30 5.30 MAR 4.49 3.93 3.14 2.84Onroad 56.51 46.80 21.11 14.44 TOTAL 104.22 88.37 73.30 65.16 23.21

Table 20 - Warren County, Ohio NO x Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00NonEGU 2.68 3.14 2.70 2.70Nonroad 5.84 4.94 3.01 2.19 Other 1.15 1.17 1.17 1.17 MAR 0.26 0.25 0.21 0.19Onroad 15.15 12.76 6.23 4.63 TOTAL 25.08 22.26 13.32 10.88 11.3827 Table 21 - Dearborn County, Indiana NO x Emission Inventory (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 25.31 27.34 25.30 26.03NonEGU 5.09 3.21 5.12 5.19Nonroad * 1.26 1.14 0.78 0.65 Other 0.26 0.26 0.27 0.27Onroad 1.44 1.14 0.60 0.42 TOTAL 33.36 33.09 32.07 32.56 0.41 *MAR emissions are included in the Non-road emissions

Table 22 - Boone County, Kentucky NO x Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 23.80 23.15 24.97 26.35

NonEGU 0.14 0.12 0.11 0.12Nonroad * 12.96 11.02 9.77 9.48 Other 4.99 5.02 5.03 5.03Onroad 10.27 8.53 4.63 3.45 TOTAL 52.16 47.84 44.51 44.43 3.41 *MAR emissions are included in the Non-road emissions28 Table 23 - Campbell County, Kentucky NO x Emission Inventory Total (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00

NonEGU 0.00 0.02 0.02 0.03Nonroad* 6.33 5.34 4.57 4.34 Other 1.41 1.32 1.30 1.30Onroad 5.98 4.88 2.54 1.81 TOTAL 13.72 11.56 8.43 7.48 4.08 *MAR emissions are included in the Non-road emissions

Table 24 - Kenton County, Kentucky NO x Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00

NonEGU 0.04 0.03 0.03 0.03Nonroad* 8.43 7.33 6.15 5.75 Other 4.17 4.06 4.02 4.02Onroad 10.39 8.37 4.23 3.01 TOTAL 23.03 19.79 14.43 12.81 6.98 *MAR emissions are included in the Non-road emissions29 Table 25 - Cincinnati-Hamilton Area NO x Emission Inventory Totals (TSD)
NOx 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

Butler 47.19 40.52 30.49 27.06 Clermont 62.83 39.73 59.76 59.12 Clinton 7.75 6.31 3.84 2.97 Hamilton 104.22 88.37 73.30 65.16 Warren 25.08 22.26 13.32 10.88 Dearborn 33.36 33.09 32.07 32.56 Boone 52.16 47.84 44.51 44.43 Campbell 13.72 11.56 8.43 7.48 Kenton 23.03 19.79 14.43 12.81 COMBINED NOx TOTAL 369.34 309.47 280.15 262.47 47.00

VOC

Table 26 - Butler County, Ohio VOC Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.03 0.03 0.02 0.02NonEGU 3.64 2.77 4.25 4.56Nonroad 6.73 5.54 4.85 4.71 Other 11.96 10.31 9.76 9.76 MAR 0.15 0.14 0.10 0.09Onroad 9.94 7.87 4.87 4.50 TOTAL 32.45 26.66 23.85 23.64 3.0230 Table 27 - Clermont County, Ohio VOC Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.49 0.27 0.52 0.53NonEGU 0.24 0.09 0.26 0.27Nonroad 4.31 3.66 3.11 2.95 Other 6.98 6.05 5.74 5.74 MAR 0.02 0.02 0.02 0.01Onroad 6.86 5.42 3.29 3.04 TOTAL 18.90 15.51 12.94 12.54 2.97

Table 28 - Clinton County, Ohio VOC Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00NonEGU 0.00 0.00 0.00 0.00Nonroad 1.73 1.60 1.20 1.02 Other 3.24 2.85 2.72 2.72 MAR 0.04 0.05 0.06 0.06Onroad 3.02 2.33 1.47 1.22 TOTAL 8.03 6.83 5.45 5.02 1.8131 Table 29 - Hamilton County, Ohio VOC Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.28 0.24 0.31 0.31NonEGU 2.66 2.85 2.97 3.12Nonroad 17.25 14.47 12.55 12.06 Other 33.04 28.80 27.38 27.38 MAR 0.20 0.19 0.15 0.13Onroad 29.47 22.70 13.44 12.00 TOTAL 82.90 69.25 56.80 55.00 14.25

Table 30 - Warren County, Ohio VOC Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00NonEGU 0.53 0.82 0.57 0.57Nonroad 4.78 4.09 3.38 3.14 Other 8.40 7.30 6.94 6.94 MAR 0.01 0.01 0.01 0.01Onroad 7.97 6.26 4.02 3.88 TOTAL 21.69 18.48 14.92 14.54 3.9432 Table 31 - Dearborn County, Indiana VOC Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.33 0.35 0.44 0.46NonEGU 2.91 3.23 3.51 3.69Nonroad 0.82 0.74 0.62 0.60 Other 2.07 2.42 1.79 1.79Onroad 1.00 0.75 0.50 0.42 TOTAL 7.13 7.49 6.86 6.96 0.53 *MAR emissions are included in the Non-road emissions

Table 32 - Boone County, Kentucky VOC Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.17 0.17 0.18 0.19

NonEGU 2.40 2.64 2.86 3.01Nonroad* 1.71 5.07 4.55 4.36 Other 8.13 8.41 8.50 8.50Onroad 4.33 4.00 3.17 2.96 TOTAL 16.74 20.29 19.26 19.02 1.27 *MAR emissions are included in the Non-road emissions33 Table 33 - Campbell County, Kentucky VOC Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00NonEGU 0. 25 0.28 0.30 0.31Nonroad* 1.76 1.51 1.29 1.22 Other 4.77 4.34 4.20 4.20Onroad 2.52 2.29 1.74 1.55 TOTAL 9.30 8.42 7.53 7.28 1.14 *MAR emissions are included in the Non-road emissions

Table 34 - Kenton County, Kentucky VOC Emission Inventory Totals (TSD)
Sector 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin

EGU Point 0.00 0.00 0.00 0.00NonEGU 1.20 1.17 1.31 1.42Nonroad* 2.33 1.95 1.76 1.73 Other 8.53 7.88 7.66 7.66Onroad 4.32 3.85 2.85 2.56 TOTAL 16.38 14.85 13.58 13.37 1.48 *MAR emissions are included in the Non-road emissions34 Table 35 - Cincinnati-Hamilton Area VOC Emission Inventory Totals (TSD)

VOC 2005 Base 2008 Attainment 2015 Interim 2020 Maintenance Safety Margin
Butler 32.45 26.66 23.85 23.64 Clermont 18.90 15.51 12.94 12.54 Clinton 8.03 6.83 5.45 5.02 Hamilton 82.90 69.25 56.80 55.00 Warren 21.69 18.48 14.92 14.54 Dearborn 7.13 7.49 6.86 6.96 Boone 16.74 20.29 19.26 19.02 Campbell 9.30 8.42 7.53 7.28 Kenton 16.38 14.85 13.58 13.37 COMBINED VOC TOTAL 213.52 187.78 161.19 157.37 30.41

VOC and NOx

Table 36 - Cincinnati-Hamilton Area Comparison of 2008 attainment year and projected emission estimates (TSD)

2008 2015 2015 Projected Decrease 2020 2020 Projected Decrease VOC 187.78 161.19 26.59 157.37 30.41

NO x 309.47 280.15 29.32 262.47 47.00

As shown in the table abov e, VOC emissions in the nonattainment area are projected to decrease by 26.59 TSD in 2015 and 30.41 TSD in 2020. Point sources in the Kentucky area show a slight 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 they cause an overall drop in VOC emissions.

NO x emissions in the nonattainm ent area are projected to decrease by 29.32 TSD in 2015 and 47.00 TSD in 2020. Again, area source emissions and, to a lesser extent, point sources show a slight increase due to expectations that the population will grow in this area. Decreas es from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur35 Control Requirements 7 , Highway Heavy-Duty Engine Rule 8 , and the Non-Road Diesel Engine Rule 9 are factored into the changes.

All projections do not take in to account reductions expected from the Clean Air Interstate Rule 10 . In many cases, Ohio utilities subject to CAIR hav e already, or will be installing controls and reducing NOx emi ssions beyond those projected for EGU’s above.

As can be seen from the projected decreases above, even in the absence of consideration of reductions resulting from CAIR, the area will be able to maintain the standard.

As identified in Table 14 and Table 15 above, an additional mobile budget margin of safety allocation is being requested for mobile emissions. The mobile budget margin of safety allocation translates into an additional 6.14 TSD for VOC and 9.39 TSD for NOx in the y ear 2015 and 6.76 TSD for VOC and 9.49 TSD for NOx in the year 2020. U.S. EPA’s conformity regulations allow for allocation, through a revision to the SIP, of all or some portion of the overa ll area’s safety margin (emission reductions from 2008 to 2020) to the mobile emissions budgets for future conformity. As i dentified in Table 14 and Table 15 above, the mobile budget margin of safety allocation and the total budget is distributed separ ately between Kentucky (alone) and Ohio/Indiana (combined). Fo r the entire area, Ohio, Indiana and Kentucky chose to allocate:

- In 2015: 6.14 TSD of the 26. 59 TSD safety margin for VOC and 9.39 TSD of the 29.32 TSD safety margin for NOx as a mobile emissions budget safety margin.

- In 2020: 6.76 TSD of the 30. 41 TSD safety margin for VOC and 9.49 TSD of the 47.00 TSD safety margin for NOx as a mobile emissions budget safety margin.

7 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 8 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 9 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm

10 http://www.epa.gov/fedrgstr/EPA-A IR/2005/May/Day-12/a5723a.pdf36 Requirement 4 of 5 A demonstration that improv ement in air quality betw een the year violations occurred and the year attainment wa s achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background Ambient air quality data from all m onitoring sites indicate that air quality met the NAAQS for oz one in 2007-2009. U.S. EPA’s redesignation guidance (p 9) st ates: “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 inv entory, 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 VOC and NOx emissions have contributed to the attainment of the eight-hour ozone standard. Some of these reductions were due to the application of tighter federal standards on new vehicles. Reductions achieved are discussed in greater detail under Chapter Five.

Table 37 - Cincinnati-Hamilton Area Combined Comparison of 2005 base year and 2008 attainment year on-road reductions

2005 2008

On-road VOC 69.43 55.47

On-road NO x 136.73 113.45

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 informa tion annually, in accordance with U.S. EPA’s Consolidated Emissi ons Reporting Rule (CERR). Ohio EPA prepares a new peri odic inventory for all ozone precursor emission sectors ever y three years. These ozone precursor inventories will be prepared for future years as37 necessary to comply with the inventory reporting requirements established in the CFR. Emissions information will be compared to the 2005 base y ear and the 2020 projected maintenance year inventories to assess emission trends, as necessary, and to assure cont inued compliance with the ozone standard.38 

### CHAPTER FIVE

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

Requirement 1 of 5 Section 182(a) of the 1990 Clean Air Act Amendments requires states with marginal nonattainment areas to im plement RACT under Section 172(b).

Background Section 182(b) of the 1990 Clean Air Act Amendments requires states with moderate nonattainment areas to submit a SIP to correct, or add, RACT requirem ents under Section 172(b) (as in effect immediately before the enactment of the Clean Air Act Amendments of 1990).

Demonstration As required under the 1-hour ozone standard, Ohio EPA submitted VOC RACT rules wh ich U.S. EPA appr oved on April 25, 1996 (61 FR 18255) and Sept ember 7, 1994 (59 FR 46182).

Statewide RACT rules have been applied to all new sources locating in Ohio since that time. RACT requirements are incorporated into permits along wit h monitoring, recordkeeping, and reporting necessary to ensur e ongoing compliance. Ohio EPA also has an active enfor cement program to address violations discovered by field offi ce staff. The Ohio RACT rules are found in OAC Chapter 3745-21 11

. Requirement 2 of 5 Section 182(a)(3)(B) requires states to submit emissions statements.

Background Section 182(a)(3)(B) requires st ates to submit emissions statements within two years of the enactment of the Clean Air Act Amendments and then every three years thereafter.

Demonstration Ohio EPA submitted its 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.

11 http://www.epa.state.oh.us/dapc/regs/3745-21/3745_21.html39 Requirement 3 of 5 Evidence that control measures requi red in past ozone SIP revisions have been fully implemented.

Background In addition to the historic RACT requirements and those mentioned above, the U.S. EPA NO x SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial bo ilers, and cement kilns in the eastern United States. Ohio pass ed this rule in 2001. NOx SIP Call requirements are incorpor ated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations disco vered 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 approximatel y 31 percent of all NO x 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. CAIR replaced the NOx SIP Call for EGUs. National NO x emissions will be cut fr om 4.5 million tons in 2004, to a cap of 1.5 milli on tons by 2009, and 1.3 million tons in 2018 in 28 states. Stat es were required to submit a CAIR SIP as part of this effor t. Ohio submitted a CAIR SIP which was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP we re again submitted on July 15, 2009. The revised CAIR SIP wa s 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 91,000 tons per year within Ohio 12

.
On December 23, 2008, U.S. EPA’s CAIR program was remanded without vacatur by t he 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

12 http://www.epa.gov/cair/pdfs/0053-2228.pdf40 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.

Section 182(b) contains additional provisions applicable to moderate nonattainment areas , for which the CincinnatiHamilton area was under the one-hour standard. Section 182(b)(3) requires gasoline vapor recovery systems for gasoline dispensing stations in the area and section 182(b)(4) requires motor vehicle inspection and maintenance programs.

Demonstration

U.S. EPA and Ohio EPA performed m odeling that indicated this area would attain the eight -hour ozone standard with the implementation of the NO x SIP Call. Controls for EGUs formally commenced May 31, 2004. Emissions covered by this program have been generally trending downw ard since 1998 with larger reductions occurring in 2002 and 2003. Data taken from the U.S. EPA Clean Air Markets w eb site, quantify the gradual NO x reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 13 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 NO x emissions from non-EGUs, compared to historical levels. This cap will stay in place through 2008, at which time the CAIR program will supersede it as discussed above.

On April 21, 2004, U.S. EPA published Phase II of the NO x SIP Call that establishes a budget for large (greater than 1 ton per day emissions) stationary inte rnal combustion engines. Ohio EPA’s OAC rule 3745-14-12 addre sses stationary internal combustion engines, all used in natural gas pipeline transmissions. U.S. EPA approved th is revision to the SIP on April 4, 2008. An 82 percent NO x reduction from 1995 levels is anticipated. Completion of the compliance plan occurred by May 1, 2006, and the compliance demonstration began May 1, 2007. The 2007 controlled NO x emissions are 599 tons statewide for the ozone season.

13 http://www.epa.state.oh.us/dapc/regs/3745-14/3745_14.html41 Section 182(b)(3) requires stat es to submit Stage II vapor recovery rules no later than No vember 15, 1992. The U.S. EPA partially approved and partially di sapproved Ohio's SIP revision for implementation of Stage II on October, 20, 1994 (59 FR 52911). As stated in that rulema king action, with the exception of paragraph 3745-21-09 (DDD)(5), U.S. EPA considers Ohio's Stage II program to fully satisfy the criteria set forth in the September 17, 1993, U.S. EPA guidance document for such programs entitled "Enforcement Guidance for Stage II Vehicle Refueling Control Programs." Fu rthermore, the September 17, 1993, guidance memorandum stat es that once onboard vapor recovery regulations are prom ulgated, the Stage II regulations are no longer applicable for moderate ozone nonattainment areas. The U.S. EPA promulgat ed onboard vapor recovery rules in February 1994. Therefore, pur suant to Section 202(a)(6) of the CAA, Stage II would no l onger be required. Stage I and Stage II requirements ar e still being implemented in the original one-hour attainment area (excludes Clinton County).

The U.S. EPA's final I/M regulati ons in 40 CFR Part 85 require the states to submit a fully adopted I/M program by November 15, 1993. U.S. EPA approved Ohio 's enhanced I/M program (ECheck), on April 4, 1995 ( 60 FR 16989) and January 6, 1997 (62 FR 646). The E-check program is no longer being implemented in this area. On November 3, 2005, Ohio EPA submitted a request for replacement of the E-Che ck program in this area. In order to transfe r the E-Check program from the active maintenance plan to a contingency plan, alternative emission reduction programs we re adopted to replace the benefits associated wit h the E-Check progr am in the one-hour maintenance plan approved at that time. The following programs were implemented in pl ace of the E-Check program and are still being impl emented today in the original one-hour attainment area (excludes Clinton County):

• OAC rule 3745-21-09(O)(2)(e) - Vapor pressure limit for cold cleaning degreasing operati ons. Approved July 28, 2009 (74 FR 37171)

• OAC rule 3745-21-18 - Mobile equipment refinishing emission reduction via high transfer efficiency spray guns. Approved July 28, 2009 (74 FR 37171)

• OAC Chapter 3745-72 - Low Reid Vapor Pressure Fuels

. Approved May 25, 2007 (72 FR 29269)

• OAC rule 3745-21-17 - Portable Fuel Containers

. Approved October 14, 2009 (74 FR 52691)42 Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000, U.S. EPA fi nalized a federal rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (S UVs). Under this proposal, automakers will be required to se ll cleaner cars, and refineries will be required to make cleaner, lo wer sulfur gasoline. This rule will apply nationwide. T he federal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NO x emission reductions will be appr oximately 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. VO C emission reductions will be approximately 12 percent for pa ssenger 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 in cludes 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 NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to dies el 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 emi ssions from non-road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this rule, curr ently accounts for 47 percent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwide. Su lfur levels will be reduced in nonroad diesel fuel by 99 percent from current levels, from approximately 3,000 parts per m illion (ppm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starting in 2008. Together, these rules will substant ially reduce local and regional sources of ozone precursors.

Requirement 4 of 543 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 3745-31 14 . The Chapter includes prov isions 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 J anuary 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 credi t 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 5 of 5 Assure that all existing control m easures will remain in effect after redesignation unless the State demonstr ates through photochemical modeling that the standard can be maintained without one (1) or more control

measures.

Demonstration Ohio commits to maintaini ng the aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emissi on limits applicable to VOC and/or NO x sources, as required fo r maintenance of the ozone standard in the Cinci nnati-Hamilton area, will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal sect ion, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. Afte r redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in the Cin cinnati-Hamilton area.

14 http://www.epa.state.oh.us/dapc/regs/3745-31/3745_31.html44 

### CHAPTER SIX

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

Requirement 1 of 4 A commitment to submit a revised plan eight (8) years after redesignation.

Demonstration Ohio hereby commits to review its maintenance plan eight (8) years after redesignation, as r equired by Secti on 175(A) of the CAA

. Requirement 2 of 4 A commitment to expeditiously enact and implement additional contingency control measures in response to ex ceeding specified predetermined levels (triggers) or in the event t hat 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 s hall be prompted whenever an annual (1-year) fourth high monito red value of 88 ppb occurs in a single ozone season within the maintenance area. A warning level response will consist of a study to determine whether the ozone value indicates a trend towa rd higher ozone values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and timing fo r implementation as well as economic and social considerat ions. Implementation of necessary controls in response to a warning level response trigger will take place as expediti ously as possible, but in no event later than 12 months from the conclusion of the most recent ozone season (October 31).

Should it be determined through t he warning level study that action is necessary to revers e the noted trend, the procedures for control selection and impl ementation outlined under “action level response” shall be followed.45 Action Level Response :

An action level response sha ll be prompted whenever a twoyear average fourth high monitor ed value of 85 parts per billion (ppb) or greater occurs within t he maintenance area. A violation of the standard (three- year average fourth high value of 85 ppb or greater) shall also prompt an action level response. In the event that the action level is tr iggered and is not found to be due to an exceptional event, malfunc tion, or noncompliance with a permit condition or rule require ment, Ohio EPA in conjunction with the metropolitan planning or ganization or regional council of governments, will determine additional control measures needed to assure future attainment of the NAAQS fo r ozone. In this case, measures that can be implemented in a short time will be selected in order to be in pl ace within 18 months from the close of the ozone seas on 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 ma intenance provisions will be implemented in a timely m anner and will constitute our response.

Control Measure Sele ction and Implementation

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

If a new measure/control is already promulgated and scheduled to be implemented at the federal or State le vel, 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 implem ented in such an event.

Demonstration Contingency measures to be c onsidered will be selected from a comprehensive list of meas ures deemed appropriate and effective at the time the select ion is made. The selection of measures will be based on cost-effectiveness, emission46 reduction potential, economic and soci al considerations or other factors that Ohio EPA deems appr opriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to sele cting appropriate contingency measures. Because it is not po ssible 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.

1) Implementation of an enhanc ed I/M program (E-Check) in Butler, Clermont, Hamilton and Warren Counties.

2) Tighten or adopt VOC RA CT on existing sources covered by U.S. EPA Cont rol Technique Guidelines issued after the 1990 CAA.

3) Apply VOC RACT to smaller existing sources.

4) One or more transportation c ontrol measures sufficient to achieve at least half a per cent reduction in actual areawide VOC emissions. Transportation measures will be selected from the follo wing, based upon the factors listed above after consultation with affected local governments:

a) trip reduction programs, including, but not limited to, employer-based transportation management plans, areawide rideshare programs, work schedule changes, and telecommuting;

b) traffic flow and transit improvements; and

c) other new or innovativ e transportation measures not yet in widespread use that affected local governments deem appropriate.

5) Alternative fuel and diesel retrofit programs for fleet vehicle operations.

6) Require VOC or NO x emission offsets for new and modified major sources.

7) Increase the ratio of emi ssion offsets required for new

sources.47 8) Require VOC or NO x controls on new minor sources (less than 100 tons).

9) Adopt NOx RACT for existing combustion sources.

No contingency measure s hall 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 considerat ion, can be fully evaluated.

Requirement 4 of 4 A list of VOC and NO x sources potentially subject to future additional control requirements.

Demonstration The following is a list of VOC and NO x sources potentially subject to future controls.

NO x RACT

• EGUs

• asphalt batching plants

• industrial/commercial and institutional boilers

• process heaters

• internal combustion engines

• combustion turbines

• other sources greater than 100 tons per year

VOC RACT

• synthetic organic compound manufacturing

• organic compound batch processes

• wood manufacturing

• industrial wastewater

• aerospace industry

• bakeries

• plastic parts coating

• volatile organic liquid storage

• industrial solvent cleaning

• offset lithography

• industrial surface coating

• other sources greater than 50 tons per year48 

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesignat ion petition and maintenance plan in the widely distributed county publicat ions on November 4, 2009.

The public hearing to receive comm ents on the redesignation request was held on December 9, 2009, at t he Hamilton County Department of Environmental Services, Cincinnati, Ohio . The public comment period closed on December 11, 2009. No testimony was provided at the public hearing and no comments were received during the public comment period. Appendix E includes a copy of the public notic e from the public hearing and comment period.49 

### CHAPTER EIGHT

CONCLUSIONS

The Cincinnati-Hamilton ozone nonattain ment area has attained the 1997 NAAQS for ozone and complied with the app licable provisions of the 1990 Amendments to the CAA r egarding redesignations of ozone nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepared a redesignation request and ma intenance plan t hat meet the requirements of Section 110 (a)(1) of the 1990 CAA.

Based on this presentation, the Cin cinnati-Hamilton ozone nonattainment area meets the requirements for redes ignation under the CAA and U.S. EPA guidance. Ohio has performed an anal ysis 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 NO x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of Ohio hereby requests that the Cincinnati-Hamilton ozone nonattainment area be redesignated to a ttainment simultaneously with U.S. EPA approval of the maintenance plan pr ovisions contained herein. In addition, the State of Ohio requests t hat this maintenance plan satisfy the requirements of CAA Section 175A (b), for subsequent plan revisions required for areas redesignated for the one-hour ozone standard.This page left intentionally blank