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 Employer 
U.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 2009
 

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 i 

TABLE OF CONTENTS 

Chapter One 

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

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

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

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

Chapter Two 

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

Chapter Three 

Ozone monitoring .......................................................................................................................... 7 

Ozone NAAQS .............................................................................................................................. 7 

Ambient data quality assured ........................................................................................................ 8 

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

Commitment to continue monitoring ........................................................................................... 11 

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 NOx sources...................................................................................................... 47 

Chapter Seven 

Public participation ...................................................................................................................... 48 

Chapter Eight 

Conclusions ................................................................................................................................ 49 
 ii 

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 .................. 36 

 
 iii 

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 Documentation 
 iv 

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 1 

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 ozone to develop State Implementation 

Plans (SIP’s) to expeditiously attain and maintain the standard. In 1997, the 

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

quality 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 designated 134 nonattainment areas for the 

eight-hour ozone standard. 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 eight-hour 

ozone 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. 

 

Background

The current Cincinnati-Hamilton nonattainment 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-evaluation, the following Counties 

within the Cincinnati-Hamilton area were designated as moderate 

nonattainment for the one-hour ozone standard pursuant to the CAA and, 
 2 

therefore, were subject to nonattainment area rulemakings: Butler, Clermont, 

Hamilton, and Warren Counties in Ohio and Boone, Campbell and Kenton 

Counties in Kentucky. The Ohio portion of the Cincinnati-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 designations, U.S. EPA designated the 

Cincinnati-Hamilton area basic nonattainment for the eight-hour standard, and 

Ohio EPA was required to develop a plan to reduce volatile organic 

compounds (VOCs) and nitrogen oxides (NOx) 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 redesignated from nonattainment to 

attainment for the eight-hour ozone standard. In addition, the States of 

Kentucky and Indiana also intend to submit requests for their respective 

portions of the Cincinnati-Hamilton area. The Cincinnati-Hamilton area has 

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

monitoring data for the years 2007 – 2009 demonstrating attainment of the 

eight-hour ozone standard. 

 Geographical Description

 The Cincinnati-Hamilton eight-hour ozone nonattainment area is located in 

southwest Ohio and includes the following 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 recent three (3) years, 2007 through 

2009, demonstrate that the air quality has met the NAAQS for ozone in this 

basic nonattainment area. The NAAQS attainment, accompanied by 

decreases in emission levels discussed in Chapter Four, supports a 

redesignation to attainment for the 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 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 V. 

Below is a summary of each redesignation 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 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. The supplemental modeling is 

not required for ozone nonattainment areas seeking 

redesignation; however, in Appendix C and Appendix D the 

most recent modeling results showing future attainment and 

maintenance are provided. Chapter Three discusses this 

requirement in more detail and provides the attainment 

demonstration. 

ii.) SIP approval

 The SIP for the area must be fully approved under Section 

110(k) and must satisfy all the requirements that apply to the 

area. Ohio’s SIP was approved 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 improvement in air quality

 The state must be able to reasonably attribute the improvement 

in air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures 

that have been adopted and implemented by the state. 
 4 

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 measures for these Counties 

in that area beyond the federal measures 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) 

• NOx Sip Call Rules 

 Chapters Four and Five discuss this requirement in more detail. 

iv.) Section 110 and Part D requirements

 For purposes of redesignation, a state must meet all 

requirements of Section 110 and Part D that were applicable 

prior to submittal of the complete redesignation request. 

 Part D consists of general requirements applicable to all areas 

which are designated nonattainment based on a violation of the 

NAAQS. 

 i.) Section 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 
 5 

measures, monitoring, and reporting; include provisions 

for air quality modeling; and provides 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 

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, 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. 

 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 procedures, if the state already 

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

conformity procedures in place at the time that it submits 

a redesignation request, the state must commit to follow 

U.S. EPA’s conformity regulation upon issuance, as 

applicable. 

v.) Maintenance plans

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

redesignated, U.S. EPA must fully approve a maintenance plan 

that meets the requirements of Section 175(A). The 

maintenance plan must 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 
 6 

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. 
 7 

CHAPTER THREE 

OZONE MONITORING1

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

Requirement 1 of 4 

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

been attained. 

Background

 There are eleven monitors measuring 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 Services. 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 sites 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 assured in accordance with 40 CFR 58.10, 

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

public view. 

Demonstration

The Ohio Environmental Protection Agency (Ohio EPA) has quality 

assured all data shown in Appendix A in accordance with 40 CFR 

58.10 and the Ohio Quality Assurance Manual. Ohio EPA has recorded 

the data in the AQS database and, therefore, 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 taken from U.S. EPA's "Guideline 

on Data Handling Conventions for the eight-hour ozone National 

Ambient Air Quality Standard (NAAQS)," U.S. EPA-454/R-98-

017, December 1998. 

Three complete years of ozone monitoring data are required to 

demonstrate attainment at a monitoring site. The eight-hour 

primary and secondary ozone ambient air quality standards are 

met at an ambient air quality monitoring site when the 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 digit, in ppm, is rounded, 0.084 ppm 

is the largest concentration that is less than or equal to 0.08 

ppm. Therefore, for the purposes of this request, the eight-hour 

standard is considered to be 0.085 ppm. Values 

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

than 0.085 ppm exceed the standard. These data handling 

procedures are applied on an individual basis at each monitor in 

the area. An area is in compliance with the eight-hour ozone 

NAAQS if, and only if, every monitoring site in the area meets 

the NAAQS. An individual site's three-year average of the 

annual fourth highest daily maximum 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 design value among all sites in the 

area. Please note that the 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

    1st 2nd 3rd 4th 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 80 
 11 

    1st 2nd 3rd 4th 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 trended 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 requirements of 40 CFR 58 and all other 

federal requirements. Connection to a central station and 
 12 

updates to the Ohio EPA web site2 will provide real time 

availability of the data and knowledge of any exceedances. Ohio 

EPA will enter all data into AQS on a timely basis in accordance 

with federal guidelines. 

 

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 precursor emissions (VOC and NOx) representative of the 

year when the area achieves attainment of the ozone air quality standard. 

Ohio also must demonstrate that the improvement in air quality between the 

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

based on permanent and enforceable emission reductions. Other 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 used by Ohio EPA and the Lake Michigan 

Air Directors Consortium (LADCO) regarding emissions from Ohio’s portion of 

the Counties in the Cincinnati-Hamilton area. Specific emissions data are 

provided for all Counties, including those in Ohio, Kentucky and Indiana. 

Indiana and Kentucky emissions data were obtained directly from Indiana and 

Kentucky, respectively. 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 Indiana 

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 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 taken from Ohio's annual emissions 

reporting program. The 2005 periodic inventory has been 

identified as one of the preferred databases for SIP 

development and coincides with nonattainment air quality in the 

Cincinnati-Hamilton area. 

Periodic inventories, which include emissions from all sectors - 

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

three years. 
 14 

Demonstration

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

this submittal and was submitted to U.S. EPA on June 15, 2007 

along with the attainment demonstration for this area. The 

detailed emission inventory information for the Ohio portion of 

the Cincinnati-Hamilton 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 emission inventory to a year at least 10 years following 

redesignation. 

Background

Ohio EPA prepared a comprehensive inventory for the Ohio portion of 

the Cincinnati-Hamilton area including area, mobile, and point sources 

for precursors of ozone (VOCs and NOx) for base year 2005. The 2005 

inventory was submitted to U.S. EPA on June 15, 2007 as part of the 

attainment demonstration 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 Report3

). 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 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/reports/LADCO%202005%20Base%20Yr%20Growth%20and%

20Controls%20Report_Final.pdf 
 15 

• Point source information was compiled from Ohio EPA’s 

2005 annual emissions inventory database and the 2005 

U.S. EPA Air Markets acid rain database4. 

• 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. 

 

Demonstration

On-Road Emission Estimations

In coordination with the Ohio Department of Transportation 

(Ohio DOT), OKI utilizes a regional 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 the 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 travel capacity may be needed and to 

determine the infrastructure requirements necessary to meet 

that need. It is also used as a tool for air quality purposes to 

estimate the total emissions of pollution caused by vehicles in 

the area. The travel demand forecasting model is used to 

predict the total daily vehicle miles traveled (VMT), and a U.S. 

EPA computer program called MOBILE6.2 is used to calculate 

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

pollution emitted by the on-road vehicles for the area. Clinton 

County is outside the area covered 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/acidrain 
 16 

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 generate VMT by hour, VMT by 

speed distribution, and VMT by facility type. These tables are 

then included as input into MOBILE6.2. The VMT by hour 

tables utilize hourly traffic distribution 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” conditions (with traffic volumes) 

are estimated using techniques 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 post-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 volumes to summer conditions. The 

factors were derived from local 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 emissions model MOBILE6.2 to 

develop emission factors for VOC’s and NOX. The MOBILE6.2 

input file contains local parameters, developed through 

consultation with the Ohio DOT and Ohio EPA, for temperature, 

fuel programs and fuel characteristics. 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 parameters are combined with the VMT 

tables from the OKI Travel Demand Model to produce one set of 

emission factors measured in grams 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 were guided by the U.S.EPA’s 
 17 

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 NOx 

emission factors and lower VOC emission factors than gasoline 

vehicles, and higher average speeds have lower emission 

factors except for diesel vehicles which have higher NOx at 

higher speeds. MOBILE6.2 input and output files are provided 

in Appendix C. 

Best Available Data 

Most current vehicle age distribution data, temperature data, 

and fuel properties data provided by Ohio EPA were used by 

OKI and the Ohio DOT for generating emission factors. 

Likewise, the most current transportation planning data 

available from OKI and most current Ohio DOT count data were 

used by Ohio DOT for the emissions estimates. Details about 

each data set and how it was used is documented in OKI’s 

“Mobile Source Emissions Inventory for the Cincinnati Ozone 

Nonattainment Area” document dated October, 2009 (revised). 

See Appendix C. 

Analysis Years

Analysis years for this redesignation 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 transportation 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 subdivision streets are not explicitly 

modeled in a travel demand model. These local roads are 

represented as fictitious roadways called centroid connectors. 

Local road VMT is included in the OKI post process by including 

the traffic loaded on centroid connectors. In addition, some 

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

demand models usually do not assign to roadway segments. 

The 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 emissions 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 8,209,236
 19 

Table 7 – Dearborn County, Indiana 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 4,998,184
 20 

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 the 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 interagency 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 future variations in travel demand 

models and VMT forecast when no change to the network is 

planned, Ohio EPA consulted with 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 emissions estimates for the 

Ohio and Indiana portions of this nonattainment area. 

The above budget for the Kentucky 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 calculated for 2015 and 2020 (from Table 

12). 

The emission estimates are derived from the travel demand 

model and MOBILE6.2 as described 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 variation in VMT forecast and 

potential estimated mobile source emissions due to expected 

modifications to TDM and mobile emissions models; and 2) the 

total decrease in emissions from all sources is sufficient to 
 22 

accommodate this 15 percent allocation of safety margin to 

mobile sources while still continuing to maintain the total 

emissions in the Cincinnati-Hamilton 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 conformity 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 states 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 safety margin, as defined in 40 

CFR 93.1015

, discussed under “Requirement 3 of 5” below, it is 

evident this allocation is significantly below the total safety 

margin for this area (see Table 36). 

The current one-hour budgets will no longer be applicable either after 

the effective date of the approved redesignation or after the effective 

date of any U.S. EPA action approving 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 the projected level of emissions is sufficient to maintain 

the ozone standard. 

Background

In consultation with U.S. EPA, Ohio EPA selected the year 2020 

as the maintenance year for this 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 requirement 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 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 M6

). 

• For the Ohio portion of the Cincinnati-Hamilton 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 2020 maintenance year is based on 

emissions estimates from the 2018 LADCO modeling. 

The detailed inventory information for the Ohio portion of the 

Cincinnati-Hamilton area for 2005 is in Appendix B. Emission 

trends are an important gauge for continued compliance with 

the ozone standard. Therefore, Ohio EPA performed an initial 

comparison of the inventories for the base year and 

maintenance years. Mobile source emission inventories are 

described in Section 5 of Appendix B. 

 

6

 http://www.ladco.org/tech/emis/current/index.php 
 24 

Sectors included in the following tables are: Electrical 

Generating Unit (EGU-Point); Non-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 when the future-year (2020) 

projected emission totals are below the 2008 attainment year 

totals. 

The emissions data in the tables below are based on the 

following data sources: 

Demonstration

NOx

Table 16 - Butler County, Ohio NOx Emission Inventory 

Totals (TSD)

Sector 2005 

Base 

2008 

Attainment

2015 

Interim 

2020 

Maintenance

Safety 

Margin 

EGU 

Point 3.88 2.87 2.86 2.95 

NonEGU 12.03 10.53 11.98 11.91 

Nonroad 7.76 6.55 4.06 3.01 

Other 2.15 2.18 2.19 2.19 

MAR 2.49 2.34 1.85 1.63 

Onroad 18.88 16.05 7.55 5.37 

TOTAL 47.19 40.52 30.49 27.06 13.46
 25 

Table 17 - Clermont County, Ohio NOx Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim

2020 

Maintenance

Safety 

Margin 

EGU 

Point 42.96 22.61 50.07 51.49 

NonEGU 0.15 0.18 0.16 0.16 

Nonroad 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 NOx 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 0.00 0.00 0.00 0.00 

Nonroad 2.21 1.96 1.34 1.07 

Other 0.42 0.43 0.43 0.43 

MAR 0.05 0.05 0.05 0.06 

Onroad 5.07 3.87 2.02 1.41 

TOTAL 7.75 6.31 3.84 2.97 3.34
 26 

Table 19 - Hamilton County, Ohio NOx Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim

2020 

Maintenance

Safety 

Margin 

EGU 

Point 15.23 12.92 28.32 29.13 

NonEGU 6.72 6.17 7.39 7.56 

Nonroad 16.08 13.28 8.04 5.89 

Other 5.19 5.27 5.30 5.30 

MAR 4.49 3.93 3.14 2.84 

Onroad 56.51 46.80 21.11 14.44 

TOTAL 104.22 88.37 73.30 65.16 23.21

 

 

Table 20 - Warren County, Ohio NOx 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 2.68 3.14 2.70 2.70 

Nonroad 5.84 4.94 3.01 2.19 

Other 1.15 1.17 1.17 1.17 

MAR 0.26 0.25 0.21 0.19 

Onroad 15.15 12.76 6.23 4.63 

TOTAL 25.08 22.26 13.32 10.88 11.38
 27 

Table 21 - Dearborn County, Indiana NOx Emission Inventory 

(TSD) 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim

2020 

Maintenance

Safety 

Margin 

EGU 

Point 25.31 27.34 25.30 26.03 

NonEGU 5.09 3.21 5.12 5.19 

Nonroad * 1.26 1.14 0.78 0.65 

Other 0.26 0.26 0.27 0.27 

Onroad 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 NOx 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 0.12 

Nonroad * 12.96 11.02 9.77 9.48 

Other 4.99 5.02 5.03 5.03 

Onroad 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 emissions
 28 

Table 23 - Campbell County, Kentucky NOx 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 0.03 

Nonroad* 6.33 5.34 4.57 4.34 

Other 1.41 1.32 1.30 1.30 

Onroad 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 NOx 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 0.03 

Nonroad* 8.43 7.33 6.15 5.75 

Other 4.17 4.06 4.02 4.02 

Onroad 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 emissions
 29 

Table 25 - Cincinnati-Hamilton Area NOx 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 0.02 

NonEGU 3.64 2.77 4.25 4.56 

Nonroad 6.73 5.54 4.85 4.71 

Other 11.96 10.31 9.76 9.76 

MAR 0.15 0.14 0.10 0.09 

Onroad 9.94 7.87 4.87 4.50 

TOTAL 32.45 26.66 23.85 23.64 3.02
 30 

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 0.53 

NonEGU 0.24 0.09 0.26 0.27 

Nonroad 4.31 3.66 3.11 2.95 

Other 6.98 6.05 5.74 5.74 

MAR 0.02 0.02 0.02 0.01 

Onroad 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 0.00 

NonEGU 0.00 0.00 0.00 0.00 

Nonroad 1.73 1.60 1.20 1.02 

Other 3.24 2.85 2.72 2.72 

MAR 0.04 0.05 0.06 0.06 

Onroad 3.02 2.33 1.47 1.22 

TOTAL 8.03 6.83 5.45 5.02 1.81

 
 31 

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 0.31 

NonEGU 2.66 2.85 2.97 3.12 

Nonroad 17.25 14.47 12.55 12.06 

Other 33.04 28.80 27.38 27.38 

MAR 0.20 0.19 0.15 0.13 

Onroad 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 0.00 

NonEGU 0.53 0.82 0.57 0.57 

Nonroad 4.78 4.09 3.38 3.14 

Other 8.40 7.30 6.94 6.94 

MAR 0.01 0.01 0.01 0.01 

Onroad 7.97 6.26 4.02 3.88 

TOTAL 21.69 18.48 14.92 14.54 3.94
 32 

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 0.46 

NonEGU 2.91 3.23 3.51 3.69 

Nonroad 0.82 0.74 0.62 0.60 

Other 2.07 2.42 1.79 1.79 

Onroad 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 3.01 

Nonroad* 1.71 5.07 4.55 4.36 

Other 8.13 8.41 8.50 8.50 

Onroad 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 emissions 
 33 

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 0.00 

NonEGU 0. 25 0.28 0.30 0.31 

Nonroad* 1.76 1.51 1.29 1.22 

Other 4.77 4.34 4.20 4.20 

Onroad 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 0.00 

NonEGU 1.20 1.17 1.31 1.42 

Nonroad* 2.33 1.95 1.76 1.73 

Other 8.53 7.88 7.66 7.66 

Onroad 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 emissions 
 34 

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 

NOx 309.47 280.15 29.32 262.47 47.00 

As shown in the table above, 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. 

NOx emissions in the nonattainment 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. Decreases from U.S. EPA rules covering 

Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur 
 35 

Control Requirements7, Highway Heavy-Duty Engine Rule8, and 

the Non-Road Diesel Engine Rule9

 are factored into the 

changes. 

All projections do not take into account reductions expected 

from the Clean Air Interstate Rule10. In many cases, Ohio 

utilities subject to CAIR have already, or will be installing 

controls and reducing NOx emissions 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 year 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 overall area’s safety margin (emission 

reductions from 2008 to 2020) to the mobile emissions budgets 

for future conformity. As identified in Table 14 and Table 15 

above, the mobile budget margin of safety allocation and the 

total budget is distributed separately between Kentucky (alone) 

and Ohio/Indiana (combined). For 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-AIR/2005/May/Day-12/a5723a.pdf 
 36 

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 ozone in 2007-2009. 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 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 NOx 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 information annually, in accordance with 

U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). 

Ohio EPA prepares a new periodic inventory for all ozone 

precursor emission sectors every three years. These ozone 

precursor inventories will be prepared for future years as 
 37 

necessary to comply with the inventory reporting requirements 

established in the CFR. Emissions information will be 

compared to the 2005 base year and the 2020 projected 

maintenance year inventories to assess emission trends, as 

necessary, and to assure continued 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 implement 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 requirements 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 which U.S. EPA approved on April 

25, 1996 (61 FR 18255) and September 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 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. The Ohio RACT rules 

are found in OAC Chapter 3745-2111. 

Requirement 2 of 5

Section 182(a)(3)(B) requires states to submit emissions statements. 

Background

Section 182(a)(3)(B) requires states 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.html 
 39 

Requirement 3 of 5

Evidence that control measures required 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 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. 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). 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 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 

 

12 http://www.epa.gov/cair/pdfs/0053-2228.pdf 
 40 

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 modeling that indicated this 

area would attain the eight-hour ozone standard with the 

implementation of the NOx SIP Call. Controls for EGUs formally 

commenced May 31, 2004. Emissions covered by this program 

have been generally trending downward since 1998 with larger 

reductions occurring in 2002 and 2003. Data taken from 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 3745-1413 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 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 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. 

The 2007 controlled NOx emissions are 599 tons statewide for 

the ozone season. 

 

13 http://www.epa.state.oh.us/dapc/regs/3745-14/3745_14.html 
 41 

Section 182(b)(3) requires states to submit Stage II vapor 

recovery rules no later than November 15, 1992. The U.S. EPA 

partially approved and partially disapproved Ohio's SIP revision 

for implementation of Stage II on October, 20, 1994 (59 FR 

52911). As stated in that rulemaking 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." Furthermore, the September 17, 

1993, guidance memorandum states that once onboard vapor 

recovery regulations are promulgated, the Stage II regulations 

are no longer applicable for moderate ozone nonattainment 

areas. The U.S. EPA promulgated onboard vapor recovery rules 

in February 1994. Therefore, pursuant to Section 202(a)(6) of 

the CAA, Stage II would no longer be required. Stage I and 

Stage II requirements are still being implemented in the original 

one-hour attainment area (excludes Clinton County). 

The U.S. EPA's final I/M regulations 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-Check program in 

this area. In order to transfer the E-Check program from the 

active maintenance plan to a contingency plan, alternative 

emission reduction programs were adopted to replace the 

benefits associated with the E-Check program in the one-hour 

maintenance plan approved at that time. The following 

programs were implemented in place of the E-Check program 

and are still being implemented 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 operations. 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 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. VOC emission reductions will be 

approximately 12 percent for passenger cars, 18 percent for 

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

larger SUVs, vans, and heavier trucks. 

Heavy-Duty Diesel Engines

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

Duty Engines, a program which includes low-sulfur diesel fuel 

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

This rule applies to heavy-duty gasoline and diesel trucks and 

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

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

sources NOx inventory. 

Clean Air Non-road Diesel Rule

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

Rule. This rule applies to diesel engines used in industries such 

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

cleaner fuel standard similar to the highway diesel program. 

The new standards will cut emissions from non-road diesel 

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

as described in this rule, currently accounts for 47 percent of 

diesel particulate matter (PM) and 25 percent of NOx from 

mobile sources nationwide. Sulfur levels will be reduced in nonroad 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 ozone precursors. 

Requirement 4 of 5
 43 

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 

3745-3114. 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 5 of 5

Assure that all existing control measures will remain in effect after 

redesignation unless the State demonstrates through photochemical modeling 

that the standard can be maintained without one (1) 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 VOC and/or 

NOx sources, as required for maintenance of the ozone 

standard in the Cincinnati-Hamilton area, will be submitted to 

U.S. EPA for approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal section, has the legal authority 

and necessary resources to actively enforce any violations of its 

rules or permit provisions. After redesignation, it intends to 

continue enforcing all rules that relate to the emission of ozone 

precursors in the Cincinnati-Hamilton area. 

 

14 http://www.epa.state.oh.us/dapc/regs/3745-31/3745_31.html 
 44 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4

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

Demonstration

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

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

CAA. 

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

(triggers) or in the event that future violations of the ambient 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 an 

annual (1-year) fourth high monitored value of 88 ppb occurs in 

a single ozone season within the maintenance area. A warning 

level response will consist of a study to determine whether the 

ozone value indicates a trend toward higher ozone values or 

whether emissions appear to be increasing. The study will 

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

the control measures necessary to reverse the trend taking into 

consideration ease and timing for implementation as well as 

economic and social considerations. Implementation of 

necessary controls in response to a warning level response 

trigger will take place as expeditiously as possible, but in no 

event later than 12 months from the conclusion of the most 

recent ozone season (October 31). 

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. 
 45 

Action Level Response: 

An action level response shall be prompted whenever a twoyear average fourth high monitored value of 85 parts per billion 

(ppb) or greater occurs within the 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 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 ozone. 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 ozone season 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 
 46 

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. 

1) Implementation of an enhanced I/M program (E-Check) 

in Butler, Clermont, Hamilton and Warren Counties. 

2) Tighten or adopt VOC RACT on existing sources 

covered by U.S. EPA Control Technique Guidelines

issued after the 1990 CAA. 

3) Apply VOC RACT to smaller existing sources. 

4) One or more transportation control measures sufficient to 

achieve at least half a percent reduction in actual 

areawide VOC emissions. Transportation measures will 

be selected from the following, based upon the factors 

listed above after consultation with affected local 

governments: 

a) trip reduction programs, including, but not limited 

to, employer-based transportation management 

plans, areawide rideshare programs, work 

schedule changes, and telecommuting; 

b) traffic flow and transit improvements; and 

c) other new or innovative 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 NOx emission offsets for new and 

modified major sources. 

7) Increase the ratio of emission offsets required for new 

sources. 
 47 

8) Require VOC or NOx controls on new minor sources 

(less than 100 tons). 

9) Adopt NOx RACT for existing combustion sources. 

No contingency measure shall be implemented without 

providing the opportunity for full public participation during which 

the relative costs and benefits of individual measures, at the 

time they are under consideration, can be fully evaluated. 

Requirement 4 of 4

A list of VOC and NOx sources potentially subject to future additional 

control requirements. 

Demonstration

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

future controls. 

NOx RACT 

• EGUs 

• asphalt batching plants 

• industrial/commercial and institutional boilers 

• process heaters 

• internal combustion engines 

• combustion turbines 

• other sources greater than 100 tons per year 

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 year 
 48 

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 November 4, 2009. 

The public hearing to receive comments on the redesignation request was 

held on December 9, 2009, at the 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 notice from the public hearing and comment 

period. 
 49 

CHAPTER EIGHT 

CONCLUSIONS

The Cincinnati-Hamilton ozone nonattainment area has attained the 1997 

NAAQS for ozone and complied with the applicable provisions of the 1990 

Amendments to the CAA regarding redesignations of ozone 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 Cincinnati-Hamilton ozone 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 NOx 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 attainment simultaneously with U.S. 

EPA approval of the maintenance plan provisions contained herein. In 

addition, the State of Ohio requests that 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. 
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