Environmental

Protection Agency

John R. Kasich, Governor

Mary Taylor, Lt. Governor

Scott J. Nally, Director

March ~1, 2011

Ms. Susan Hedman

Regional Administrator

U.S. EPA, Region 5

77 West Jackson Blvd. R-19J

Chicago, Illinois 60604-3507

Re: Ohio's Revised State Implementation Plan (SIP) for Regional Haze

Dear Administrator Hedman:

I am submitting for your review and approval a revised SIP package.

demonstrating satisfactory progress toward the long-term visibility goals

contained in the Regional Haze Rule of 1999 and the Clean Air Act. Ohio

EPA has addressed all required elements of 40 CFR 51.308 in this Plan;

including public participation and incorporation of federally enforceable Best

Available Retrofit Technology (BART) requirements for Ohio's BART source.

The original Ohio Regional Haze SIP was submitted to U.S. EPA on

December 31, 2008. Ohio EPA .acknowledged in our original submittal letter

that the original SIP submittal would necessitate revision in order to complete

a public participation process and issue a federally enforceable BART permit.

In turn, on January 19, 2009, U.S. EPA notified Ohio EPA of its finding of

failure to submit due to these two omissions.

Following the original submittal, Ohio EPA held a public hearing on February

26, 2009 and accepted written comments through that date. Several

comments were received and Ohio has addressed those comments in this

revised document. This includes revising the original BART determination for

Ohio's only BART source, P.H. Glatfelter. As a result of the revised BART,

significant reductions in sulfur dioxide emissions will be achieved through an

alternative BART strategy that achieves greater than ninety percent reduction.

The BART strategy was incorporated into a federallycenforceable permit that

50 West Town Street. Suite 700

P.O. Box 1049

CoIumbus,OH 43216-1049

614 16443020

61416443184 (fax)

www.epa.ohio.gov
Revised Regional Haze SIP

Page 2of2

was issued final on March 7, 2011 after a public participation process and

consideration of comments received on the revised BART strategy.

We appreciate the help and gUidance provided by U.S. EPA throughout the

development of this SIP. Ohio EPA wishes to continue to work with you and

your staff as they review this submittal. If you have any questions concerning

this submittal, please feel free to contact Jennifer Hunter of the Division of Air

Pollution Control at 614-644-3696 or jennifer.hunter@epa.state.oh.us.

Sincerely,

UNallY

Director

xc: Bob Hodanbosi, Ohio EPA, DAPC

John Summerhays, USEPA
Regional Haze State Implementation Plan for Ohio 

Prepared by: 

The Ohio Environmental Protection Agency 

Division of Air Pollution Control 

December 2008 

Revised 

March 2011 

________________________________________________________________ 
Acknowledgement 

The Ohio EPA Division of Air Pollution Control wishes to express its appreciation for the 

effort, expertise, and direction provided by the staff of the Midwest Regional Planning 

Organization (MRPO). The assistance they have given in terms of development of 

modeling protocols, processing of meteorological data, and overall technical guidance 

has been invaluable and essential to the successful completion of this project. 
Table of Contents 

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

1.1 States and Tribes Class I Areas ......................................................................... 2

2. Regional Planning .................................................................................................... 3

3. State and Federal Land Manager Coordination ........................................................ 4

4. Baseline, Current and Estimated Natural Conditions ................................................ 5

5. Monitoring Strategy .................................................................................................. 6

6. Emissions Inventory ................................................................................................ 7

6.1 Nonpoint Sources ............................................................................................. 10

6.2 Construction Activities ...................................................................................... 13

6.3 Fires ................................................................................................................. 14

7. Modeling Assessment ............................................................................................ 16

8. BART Analysis ........................................................................................................ 18

8.1 BART Eligible Sources in Ohio ......................................................................... 18

8.2 Determination of Sources Subject to BART ..................................................... 19

8.2.1 Individual Source Attribution Approach (Dispersion Modeling) ................. 19

8.2.2 Use of Model Plants ................................................................................. 20

8.2.3 Cumulative Modeling ................................................................................ 20

8.2.4 EGUs ........................................................................................................ 22

8.2.5 Detailed Analysis of Potential BART-Subject Sources ............................. 23

8.3 Determination of BART Requirements for Subject-to-BART Sources .............. 24

8.4 Projected Emissions Reductions Resulting from Installation of BART Controls . 

 ......................................................................................................................... 26

8.5 Enforceability of BART Requirements .............................................................. 26

8.6 Monitoring, Recordkeeping, and Reporting of BART Requirements ................ 26

9. Areas of Influence ................................................................................................... 27

9.1 MRPO Back Trajectory Analyses ..................................................................... 29

9.2 MRPO Powertrain System Analysis Toolkit (PSAT) Modeling ......................... 29

9.3 MANE-VU Contribution Assessment ................................................................ 29

9.4 Missouri-Arkansas Contribution Assessment ................................................... 30

9.5 VISTAS Area of Influence Analysis .................................................................. 30

10. Long-Term Strategy and Reasonable Progress ..................................................... 30

10.1 Consultation .................................................................................................. 34

10.2 Share of Emissions Reductions .................................................................... 34

10.2.1 MRPO ........................................................................................................ 35

10.2.2 MANE-VU ................................................................................................. 35
10.2.3 Missouri-Arkansas (CENRAP) ................................................................... 42

10.2.4 VISTAS ..................................................................................................... 51

10.3 Technical Basis for Achieving Fair Share of Emissions Reductions ............. 58

10.3.1 Factor 1 (Cost of Compliance) .................................................................. 59

10.3.2 Factor 2 (Time Necessary for Compliance) .............................................. 59

10.3.3 Factor 3 (Energy and Non-Air Quality Environmental Impacts) ................ 60

10.3.4 Factor 4 (Remaining Useful Life) .............................................................. 60

10.3.5 Factor 5 (Visibility Impacts) ....................................................................... 60

10.4 Baseline Inventory ........................................................................................ 60

10.5 Anthropogenic Sources of Visibility Impairment ............................................ 60

10.6 Factors the State Must Consider................................................................... 61

10.6.1 Emissions Reductions Due to Ongoing Air Pollution Programs ................ 61

10.6.2 Measures to Mitigate the Impacts of Construction Activities ..................... 61

10.6.4 Emissions Limitations and Schedules of Compliance ............................... 62

10.6.5 Source Retirement and Replacement Schedules ..................................... 62

10.6.6 Agricultural and Forestry Smoke Management Practices ......................... 62

10.6.7 Enforceability of Emissions Limitations and Control Measures ................. 64

10.6.8 Anticipated Net Effect on Visibility Resulting from Projected Changes to 

Emissions................................................................. .................... 64

11. Consultation ............................................................................................................ 69

12. Inventory Updates, Plan Revisions and Progress Reports ..................................... 69

13. Adequacy ............................................................................................................... 70
Appendices 

A. Preliminary Draft Comments from Federal Land Managers. 

B. Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Final 

Technical Support Document, April 25, 2008. Supplemented September 12, 2008. 

C. Emissions Inventories and Projections. 

D. Analysis of Visibility Impacts of BART-Eligible Sources on the Regional Scale 

Technical Support Document. 

E. MANE-VU consultation summary, August 6, 2007. Ohio EPA response, October 3, 

2007. Ohio Stacks from MANE-VU Ask, June 2007. Letter to USEPA requesting a 

cooperative effort between states and USEPA to reduce emissions from EGUs, ICI 

boilers, mobile sources and area sources, September 2, 2009. 

F. EC/R, Reasonable Progress for Class I Areas in the Northern Midwest—Factor 

Analysis. 

G. Public notice, public hearing documents, comments received and Responsive 

Summary to Comments from the public comment period on the draft Regional Haze 

SIP. 

H. Public notice, public hearing documents, comments received and Responsive 

Summary to Comments from the public comment period on the draft P.H. Glatfelter 

federally enforceable BART permit. 
Page 1 of 70 

1. Background 

In the 1977 amendments to the Clean Air Act (CAA), Congress established the goal of 

restoring national parks and wilderness areas to the “pristine” condition of atmospheric 

clarity that would prevail in the absence of human impacts. In 1999 the U.S 

Environmental Protection Agency (USEPA) issued a final version of a Regional Haze 

Rule having the purpose of achieving those pristine conditions by the year 2064. 

Section 169 of the Act calls for the prevention of any future, and the remedying of any 

existing, human-made visibility impairment in Class I areas. Over the following years 

modest steps were taken to address the visibility problems in Class I areas; however, 

these measures mainly addressed plume blight from specific sources and did little to 

address regional haze issues in the Eastern United States (U.S.). 

When the CAA was amended in 1990, Section 169B (42 USC 7492) was incorporated. 

This section provided for further research and regular assessments of the progress 

made to date. In 1993, the National Academy of Sciences concluded that “current 

scientific knowledge is adequate and control technologies are available for taking 

regulatory action to improve and protect visibility” (Protecting Visibility in National Parks 

and Wilderness Areas; National Research Council, Washington, DC: 1993). In addition 

to authorizing creation of visibility transport commissions and setting forth their duties, 

Section 169B(f) of the CAA mandated creation of the Grand Canyon Visibility Transport 

Commission (Commission) to make recommendations to the USEPA for the region 

affecting the visibility of the Grand Canyon National Park. After four years of research 

and policy development, the Commission submitted its report to USEPA in June 1996. 

The Commission report, as well as the many research reports prepared by the 

Commission, contributed invaluable information to the USEPA in its development of the 

federal Regional Haze Rule. 

USEPA’s Regional Haze Rule was adopted July 1, 1999, and went into effect on August 

30, 1999. The Regional Haze Rule aims at achieving national visibility goals by 2064. 

This rulemaking addressed the combined visibility effects of various pollution sources 

over a wide geographic region. This wide-reaching effort means that many states, 

including those without Class I areas, must participate in haze reduction efforts. USEPA 

designated five Regional Planning Organizations (RPOs) to assist with the coordination 

and cooperation needed to address the haze issue. Ohio participates in the Midwest 

Regional Planning Organization (MRPO) which is comprised of the northern Midwest 

states of Indiana, Illinois, Michigan, Ohio, and Wisconsin. 

After adoption of the Regional Haze Rule, on May 24, 2002, the US Court of Appeals, 

DC District Court ruled on a challenge brought by the American Corn Growers 

Association. The Court remanded to the USEPA the “Best Available Retrofit 

Technology,” or “BART,” provisions of the rule, and denied industry’s challenge to the 

haze rule goals of natural visibility and no degradation requirements. USEPA has 

revised the Regional Haze Rule pursuant to the remand and on July 6, 2005, finalized 

its guideline for determining BART. 
Page 2 of 70 

On February 18, 2005, the US Court of Appeals, DC Circuit Court issued a ruling based 

on a second suit brought by the Center for Energy and Economic Development (CEED) 

challenging an optional emissions trading program (the WRAP Annex Rule). USEPA 

finalized revisions to the alternative trading programs on December 12, 2006. 

This federal Regional Haze Rule establishes a schedule by which states must submit 

their first Regional Haze state implementation plan (SIP) and subsequent revisions to 

that first SIP, recognizing achieving natural visibility conditions will require long-term 

planning and review. USEPA was mindful of the “balance that must be maintained 

between the need for strategies that will achieve meaningful improvements in air quality 

and the need to provide appropriate flexibility for states in designing strategies that are 

responsive to both air quality and economic concerns.” [64 FR 35731] Reasonable 

progress goals must be set for each Class I area and states must include a long-term 

strategy for making reasonable progress towards meeting the national goal in their first 

Regional Haze SIP. USEPA interprets “long-term strategy” as the control measures 

needed (and a demonstration of their effectiveness) to ensure reasonable progress 

during the first 10 to 15 year period of planning. USEPA selected the first planning 

period to extend to 2018, with a reassessment and revision of strategies as needed 

every 10 years. All Regional Haze SIPs are due three years after USEPA designates 

PM2.5 attainment and nonattainment areas. USEPA approved PM2.5 designations for 

all areas of each state on December 17, 2004, and determined that the Regional Haze 

SIPs were due by December 17, 2007. 

This Regional Haze SIP addresses the first planning period (i.e., reasonable progress 

by the year 2018) and is submitted pursuant to 40 CFR 51.308(a) and (b). This SIP 

fulfills the requirements of: 

• 40 CFR 51.308(d) which includes establishing reasonable progress goals, 

determining baseline conditions, determining natural conditions, providing a longterm strategy, providing an air quality monitoring strategy, and providing an 

emissions monitoring strategy; and 

• 40 CFR 50.308(e) which includes establishing BART requirements. 

1.1 States and Tribes Class I Areas 

Ohio does not contain any Class I areas subject to the Regional Haze Rule. Ohio is 

required by 40 CFR 51.308(d) to address regional haze in each mandatory Class I area 

located outside the state which may be affected by emissions from within the state. 

Class I areas which may be affected by emissions from Ohio are discussed in Section 

9. Ohio consulted with states and tribes in the MRPO region as outlined in Section 3 

and Section 11. As a result of this consultation and the analyses performed, Ohio 

developed a long-term strategy for the first planning period (see Section 10) based upon 

the Class I areas affected by emissions from Ohio (see Section 9). 
Page 3 of 70 

2. Regional Planning 

Since the atmospheric contaminants degrading the atmosphere in a given park or 

wilderness area may have been transported by winds over a great distance, USEPA 

determined that control strategies to reduce those contaminants must involve 

participation by responsible parties on a region-wide basis, over a large area. 

Accordingly, USEPA has designated five regional planning organizations (RPOs) to 

cover the entire country. In October 2000, the States of Illinois, Indiana, Michigan, 

Ohio, and Wisconsin signed a memorandum of agreement that established the Midwest 

Regional Planning Organization (MRPO). Tribal leaders from Michigan and Wisconsin, 

USEPA Region V, and Federal Land Managers (FLMs) are also members of the MRPO. 

An operating principles document for the MRPO, which describes the roles and 

responsibilities of states, tribes, federal agencies, and stakeholders, was issued in 

March 2001. 

Since the emissions of the MRPO region travel far outside the boundaries of those five 

states, MRPOs activities have included mutual consultation and sharing of information 

with other RPOs such as the Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS). 

This SIP utilizes data analysis, modeling results, and other technical support documents 

prepared by the MRPO for its members. The MRPO has established an active 

committee structure to address both technical and nontechnical issues related to 

regional haze. The Policy Steering Committee provides policy direction for regional 

planning. The Technical Steering Committee manages the technical portion of regional 

planning. The Project Team carries out the orders of the Technical Steering Committee 

and guides the development of the regional planning effort. Staff of the Lake Michigan 

Air Director’s Consortium (LADCO) provided much of the technical resources for the 

MRPO. LADCO was started in 1989 by the States of Illinois, Indiana, Michigan, and 

Wisconsin. Ohio later joined as the fifth state member. LADCO provides supportive 

activities for the three teams/committees. 

MRPO works cooperatively with the RPOs representing other parts of the country. The 

other RPOs are Mid-Atlantic / Northeast Visibility Union (MANE-VU), Central Regional 

Air Planning Association (CENRAP), VISTAS, and Western Regional Air Partnership 

(WRAP). The following is a map of the regional planning organization boundaries: 
Page 4 of 70 

The RPOs sponsored several joint projects with assistance by USEPA. MRPO 

maintains regular contact with the RPOs on technical and policy matters. By 

coordinating with MRPO and other RPOs, Ohio has worked to ensure that its long-term 

strategy and BART determinations provide reasonable reductions to mitigate impacts of 

sources from Ohio on affected Class I areas. 

3. State and Federal Land Manager Coordination 

Ohio has participated in meetings and conference calls with states within the MRPO 

and the RPOs outside the MRPO to discuss their assessments of visibility conditions, 

analyses of visibility impacts, and possible measures that could be taken for reasonable 

progress for the first planning period (2018). Section 9 and 10 of this document 

provides more detailed information regarding Ohio’s long-term strategy to address 

visibility impacts and obtain Ohio’s fair share of emissions reductions. Summaries of 

the calls and meetings held with states and RPOs with Class I areas in which Ohio 

participated can be found at: http://www.ladco.org/reports/rpo/consultation/index.php. 

Coordination between states and FLMs is required by 40 CFR 51.308(i). Opportunities 

have been provided by MRPO for FLMs to review and comment on each of the 

technical documents developed by MRPO and referenced in this submittal. Ohio has 
Page 5 of 70 

provided agency contacts to the FLMs as required. In development of this plan 

submittal, the FLMs were consulted as required under 40 CFR 51.308(i)(2). 

Ohio provides FLMs an opportunity for consultation, in person and at least 60 days prior 

to holding a public hearing on this plan submittal. During the consultation process, the 

FLMs are given the opportunity to address their: 

• Assessment of the impairment of visibility in any Class I areas; 

• Recommendations on the development of reasonable progress goals; and 

• Recommendations on the development and implementation of strategies to address 

visibility impairment. 

Ohio sent the draft plan to the FLMs on September 9, 2008. On October 16, 2008, Ohio 

received preliminary draft comments back from the FLMs (Appendix A) and addressed 

those comments in this final document. Ohio provided the revised document, based on 

comments, to the FLMs on December 29, 2008 and then submitted the document to 

USEPA on December 31, 2008. A public hearing was held on February 26, 2009 where 

additional comments were received from the public and the FLMs (Appendix G). This 

final document is the result of taking FLM, and other stakeholder, comments into 

consideration. On January 5, 2011, Ohio provided a draft federally enforceable permit 

that implements the Best Available Retrofit Technology (BART) requirements for P.H. 

Glatfelter to the public and FLMs. BART is discussed further in Section 8. Comments 

were accepted through February 11, 2011 and there was no request to hold a public 

hearing. Comments were received only from P.H. Glatfelter (Appendix H). The final 

federally enforceable BART permit was issued on March 7, 2011 after comments into 

consideration (Appendix H). 

Ohio will continue to coordinate and consult with the FLMs during the development of 

future progress reports and revisions of this plan, as well as during the implementation 

of programs having the potential to contribute to visibility impairment in the mandatory 

Class I areas. This includes coordination with the FLMs during new source review 

(NSR) of sources that may impact Class I areas. 

4. Baseline, Current and Estimated Natural Conditions 

The goal of the Regional Haze Rule is to restore natural visibility conditions to the 156 

Class I areas identified in the 1977 Clean Air Act Amendments. Section 51.301(q) 

defines natural conditions: “Natural conditions include naturally occurring phenomena 

that reduce visibility as measured in terms of light extinction1

, visual range, contrast, or 

 

1

 Visibility impairment is caused by particles and gases in the atmosphere. Some particles and gases 

scatter light, while others absorb light. The net effect is called ‘‘light extinction.’’ The result of these 

processes is a reduction of the amount of light from a scene that is returned to the observer, creating a 

hazy condition. 
Page 6 of 70 

coloration.” Regional Haze SIPs must contain measures that make “reasonable 

progress” toward this goal by reducing anthropogenic emissions that cause haze. 

40 CFR 51.308(d)(2) requires states with a mandatory Class I area to determine 

baseline and natural visibility conditions. Ohio does not have any Class I areas 

requiring this determination. First, states are to compare baseline visibility conditions in 

the years 2000 to 2004 (in deciview2

) for the most impaired days3 with the natural 

background conditions. Second, states identify a "uniform rate of progress" over a 60-

year period that would be needed to achieve natural conditions by 2064. The uniform 

rate of progress is also known as the "glidepath." The glidepath is a straight line drawn 

from the baseline level of visibility impairment for 2000 to 2004 to the level representing 

natural conditions in 2064. The glidepath is one of the indicators used in setting 

reasonable progress goals. States identify the amount of progress needed during the 

first planning period consistent with the uniform rate of progress (third step). And lastly, 

fourth, states identify and analyze the emissions measures that would be needed to 

achieve this amount of progress during the first planning period. 

Glidepaths were developed by the states and RPOs for their own Class I areas using 

their available information. MRPO also performed an analysis of these conditions for 

MRPO states, which Ohio accepts. This analysis is contained in the “Regional Air 

Quality Analyses for Ozone, PM2.5, and Regional Haze: Final Technical Support 

Document, April 25, 2008” (herein referred to as “TSD”) (Appendix B) and is discussed 

further in Sections 7 and 10. 

5. Monitoring Strategy 

40 CFR 51.308(d)(4) requires a monitoring strategy for measuring, characterizing, and 

reporting regional haze visibility impairment that is representative of all mandatory Class 

I areas within the state. Ohio does not have any mandatory Class I areas. 

Ohio is required by 40 CFR 51.308(d)(4)(iiii) to identify procedures by which monitoring 

data and other information are used in determining the contribution of emissions from 

within Ohio to visibility impairment at Class I areas in other states. 

The monitoring strategy relies in part upon participation in the Interagency Monitoring of 

Protected Visual Environments (IMPROVE) network. The IMPROVE website is located 

at http://vista.cira.colostate.edu/improve/. Ohio also runs a large monitoring network of 

USEPA-approved monitors for ozone and PM2.5. Data from these monitors is used for 

a variety of reasons, including SIP development. Ohio is continually reviewing 

monitoring data as part of the SIP process. 

 

2

 ‘‘Deciview’’ is a visibility metric defined in 40 CFR 51.301(bb). Higher deciview values indicate greater 

levels of visibility impairment. 

3

 “Most impaired days” is equivalent to the 20 percent worst visibility days. States also must ensure no 

degradation in visibility for the least impaired days which is equivalent to the 20 percent best visibility 

days. 
Page 7 of 70 

For regional haze, monitoring data were analyzed to produce a conceptual 

understanding of the air quality problems. Additional discussions on the use of 

monitoring data can be found under Section 9 and in the TSD document (Appendix B). 

6. Emissions Inventory 

Ohio is required by 40 CFR 51.308(d)(4)(v) to provide a statewide emissions inventory 

of pollutants that are reasonably anticipated to cause or contribute to visibility 

impairment in any mandatory Class I area(s). Emissions data are derived from MRPO 

and the National Emissions Inventory (NEI) (Appendix C). 

Emissions4 

The following is Ohio’s baseline year, 2002, inventory5: 

Data sources: All data: 2002 National Emissions Inventory System 

http://www.epa.gov/air/data/neidb.html

Ohio 2002 Emissions Summary, by Source Category and Pollutant 

Source category 

VOC NOx PM2.5 PM10 NH3 SO2 

tons/yr 

EGU Point 1,706 360,551 54,722 60,019 80 1,012,132

Non-EGU 27,292 28,089 15,581 33,976 6,524 96,143 

Non-Road 90,447 91,256 8,234 8,942 74 6,792 

Other 287,487 78,029 17,169 23,268 107,425 8,350 

MAR* 3,632 96,728 3,113 3,393 32 11,191 

On-Road 184,072 327,337 5,933 8,049 10,987 12,682 

Totals 594,636 981,990 104,752 137,647 125,121 1,147,290

*Marine, Airplane and Railroad 

 

4

 Agricultural NH3 emissions are included in the “other” category in the tables. 5

 The 2002 inventory does not include fugitive dust and specifically road dust nonpoint sources, which are 

discussed in the nonpoint summaries below. 
Page 8 of 70 

The following is Ohio’s current year, 2005, inventory: 

Data sources: On-Road data: 2005 National Emissions Inventory System 

http://www.epa.gov/air/data/neidb.html

All other data: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/round5/index.php

Ohio 2005 Emissions Summary, by Source Category and Pollutant 

Source category 

VOC NOx PM2.5 PM10 NH3 SO2 

tons/yr 

EGU Point 1,354 255,556 9,158 17,324 107 1,100,511

Non-EGU 27,848 66,229 9,920 15,012 3,175 115,547 

Non-Road 89,584 85,887 7,384 7,719 77 8,747 

Other 226,910 39,582 16,708 16,764 109,047 5,632 

MAR 2,706 47,021 1,452 1,634 27 4,687 

On-Road 171,331 259,299 4,735 6,797 11,381 6,290 

Totals 519,734 753,573 49,357 65,249 123,813 1,241,414

These 2005 emissions were grown to year 2018, primarily using the Economic Growth 

Analysis System (EGAS5), MOBILE 6.2 vehicle emission modeling software, and the 

Integrated Planning Model (IPM) version 3.0 for electric generating units (EGUs). 

Additional details are provided in the TSD (Appendix B). The following is Ohio’s 

projected 2018 inventory: 

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

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/round5/index.php

Ohio 2018 Emissions Summary, by Source Category and Pollutant 

Source category 

VOC NOx PM2.5 PM10 NH3 SO2 

tons/yr 

EGU Point 

1,352 95,678 9,154 17,311 107 315,560 

Non-EGU 34,651 66,696 11,776 18,161 4,300 117,018 

Non-Road 60,461 37,691 3,526 3,728 86 100 

Other 182,075 38,441 18,359 18,409 117,264 4,957 

MAR 1,146 22,018 538 615 18 2,494 

On-Road 88,526 100,056 2,483 2,529 12,067 1,455 

Totals 368,211 360,579 45,836 60,752 133,842 441,584 
Page 9 of 70 

The following table represents the percent changes in the inventory based on the 

emissions in the previous tables. Discussions of the projected changes for different 

source categories follows. 

Percent Changes in Ohio Emissions, by Source Category and Pollutant, from 2002 to 

2005 to 2018 

Source 

category 

VOC NOx PM2.5 PM10 NH3 SO2 

’02 -

‘05 

’05 ’02 -

‘05 

’05 ’02 -

‘05 

’05 ’02 -

‘05 

’05 ’02 -

‘05 

’05 ’02 -

‘05 

’05 

-‘18 -‘18 -‘18 -‘18 -‘18 -‘18 

EGU 

Point -20.6 -0.1 -29.1 -62.6 -83.3 0.0 -71.1 -0.1 33.7 0.1 8.7 -71.3 

NonEGU 2.0 24.4 135.8 0.7 -36.3 18.7 -55.8 21.0 -51.3 35.4 20.2 1.3 

NonRoad -1.0 -32.5 -5.9 -56.1 -10.3 -52.2 -13.7 -51.7 4.1 12.4 28.8 -98.9 

Other -21.1 -19.8 -49.3 -2.9 -2.7 9.9 -28.0 9.8 1.5 7.5 -32.5 -12.0 

MAR -25.5 -57.7 -51.4 -53.2 -53.4 -63.0 -51.8 -62.3 -15.0 -31.9 -58.1 -46.8 

OnRoad -6.9 -48.3 -20.8 -61.4 -20.2 -47.6 -15.6 -62.8 3.6 6.0 -50.4 -76.9 

Totals -12.6 -29.2 -23.3 -52.2 -52.9 -7.1 -52.6 -6.9 -1.0 8.1 8.2 -64.4 

Total 

Change 

From 

2002 to 

2018 

-38.08% -63.28% -56.24% -55.86% 6.97% -61.51% 

The majority of visibility-impairing point source emissions in Ohio currently comes from 

EGUs. This source category represented 88 percent of the reported SO2 emissions and 

37 percent of the NOx emissions for the 2002 inventory year. For 2002, mobile source 

emissions is the second largest source of NOx and VOC emissions, 31 percent and 33 

percent, respectively. The largest source of VOC emissions in 2002, 48 percent, is from 

other, or area, sources. 

This pattern remained fairly consistent in 2005. However, the largest source of NOx 

emissions in 2005 was from mobile sources, 34.4 percent, rather than EGU sources, 

33.9 percent. Emissions of NOx from EGUs is steadily declining primarily due to the 

NOx SIP call. 

Projected emissions for 2018 show dramatic reductions due to the Clean Air Interstate 

Rule (CAIR) program. The CAIR program and implications regarding its vacatur, 

remand, and replacement are discussed in greater detail in Section 10. Emissions of 

NOx and SO2, considering CAIR, are expected to decline between 2002 and 2018 by 
Page 10 of 70 

about 63 percent and 62 percent, respectively. As seen in the percent change table 

above, emissions of all pollutants, except NH3, are expected to decline by 2018. 

6.1 Nonpoint Sources 

Nonpoint source emissions were compiled from the 2002 NEI database. As indicated in 

the percent change table above, all area, or nonpoint, source emissions are projected to 

decline by 2018 with the exception of NH3, PM10 and PM2.5 which are projected to 

increase slightly. 

2002 Total Emissions (TPY) of Pollutants Contributing to Regional Haze from Ohio 

Nonpoint Sources 

* Recall, the 2002 inventory identified in the table above does not include fugitive dust and specifically 

road dust nonpoint sources, which are identified in the bar chart above and discussed below. 

PM10 accounts for the largest nonpoint source category, and can be attributed primarily 

to agriculture tillage, unpaved and paved road dust, and industrial road construction 

activities. The following tables provide the relative contributions from the top sources of 

nonpoint emissions for the state for each of the above pollutants. These values are 

based on the 2002 NEI. 
Page 11 of 70 

Top PM10 Emissions from Ohio Nonpoint Sources During 2002 

Source classification tons/yr % of Nonpoint PM10 

Agriculture Tillage 149,656 32.36% 

Unpaved Roads 100,824 21.80% 

Paved Roads 89,467 19.35% 

Road Construction (Industrial Processes) 48,771 10.55% 

Industrial/Commercial/Institutional 

Construction (Industrial Processes) 25,294 5.47% 

Mining and Quarrying (Industrial Processes) 17,882 3.87% 

VOC emissions are the second largest source of Ohio’s nonpoint emissions. A large 

portion of these emissions result from industrial and consumer product utilization (nearly 

25 percent). Ohio promulgated a consumer products rule on September 15, 2007. 

Effective January 1, 2009, consumer products that are sold in the State of Ohio will 

have to meet stringent VOC content limitations6

. This will help to reduce VOC 

emissions for this nonpoint source category in the future. In addition, VOC reductions 

from nonpoint sources will be achieved by Ohio’s Architectural and Industrial 

Maintenance (AIM) Coatings rule7 and Portable Fuel Container rule8, both of which were 

recently promulgated. 

Top VOC Emissions from Ohio Nonpoint Sources During 2002 

Source classification tons/yr % of Nonpoint VOC 

Miscellaneous Non-industrial: Consumer 

Solvent Utilization 

41,688 14.50% 

Miscellaneous Industrial Solvent Utilization 29,937 10.41% 

Degreasing Solvent Utilization 17,877 6.22% 

Residential Wood Stoves and Fireplaces 14,962 5.20% 

Ammonia is the third largest source of Ohio’s nonpoint emissions. The majority of these 

emissions, 98.0 percent, result from agriculture production activities: crops, cattle, 

swine, and poultry production mainly. However, Ohio EPA’s Division of Air Pollution 

Control has a very limited authority under the Ohio Revised Code to regulate 

agricultural activities. 

 

6

 http://www.epa.ohio.gov/dapc/regs/3745_112.aspx 7

 http://www.epa.ohio.gov/dapc/regs/3745_113.aspx 8

 http://www.epa.ohio.gov/portals/27/regs/3745-21/21_17.pdf 
Page 12 of 70 

Top NH3 Emissions from Ohio Nonpoint Sources During 2002 

Source classification tons/yr % of Nonpoint NH3 

Urea from Fertilizer Application of Crops 17,008 15.81% 

Nitrogen Solutions from Fertilizer Application 

of Crops 16,348 15.20% 

Confined Poultry Production - layers with dry 

manure manage 11,165 10.38% 

Poultry Waste Emissions 9,719 9.03% 

Agriculture tilling contributes over 30 percent of the PM2.5 emissions for nonpoint 

sources in Ohio. Paved and unpaved roadways contribute a combined 21.6 percent. 

These sources are also significant contributors of PM10 emissions as demonstrated 

above. 

Top PM2.5 Emissions from Ohio Nonpoint Sources During 2002 

Source classification tons/yr % of Nonpoint PM2.5

Agriculture Tillage 22,448 30.16% 

Unpaved Roads 10,086 13.55% 

Residential Woodstoves and Fireplaces 8,937 12.00% 

Open Burning of Residential Household 

Waste 6,763 9.09% 

Paved Roads 5,978 8.03% 

Road Construction (Industrial Processes) 4,901 6.58% 

Mining and Quarrying (Industrial Processes) 3,576 4.80% 

Open Burning of Land Clearing Debris 3,494 4.69% 

The majority of nonpoint source NOx emissions results from natural gas combustion, 

whether from residential, industrial, or commercial and institutional sources. 

Top NOx Emissions from Ohio Nonpoint Sources During 2002 

Source classification tons/yr % of Nonpoint NOx 

Residential Natural Gas Combustion 15,100 36.33% 

Industrial Natural Gas Boilers and IC Engines 

Combustion 7,547 18.16% 

Commercial and Institutional Natural Gas 

Boilers and IC Engines Combustion 7,163 17.24% 

Residential Liquid Petroleum Gas 

Combustion 3,121 7.51% 

The majority of nonpoint source SO2 emissions results from oil and coal combustion, 

whether from residential, industrial or commercial and institutional sources. 
Page 13 of 70 

Top SO2 Emissions from Ohio Nonpoint Sources During 2002 

Source classification tons/yr % of Nonpoint SO2 

Industrial Residual Oil Boiler Combustion 7,539 37.81% 

Commercial and Institutional 

Bituminous/Subbituminous Coal Boiler 

Combustion 6,324 31.71% 

Industrial Distillate Oil Boilers and IC Engines 

Combustion 1,977 9.92% 

Commercial and Institutional Distillate Oil 

Boilers and IC Engines Combustion 1,682 8.43% 

Residential Bituminous/ Subbituminous Coal 

Combustion 1,263 6.33% 

The Regional Haze SIP requirements include assessing the contribution of construction 

activities and fires from Ohio. 

6.2 Construction Activities

The following table identifies emissions from the 2002 NEI attributed to construction 

activities. Additional information on construction activities is discussed under Section 

10. 

Emissions from Ohio Nonpoint Construction Activities Sources During 2002 

2002 TPY 

NOx % Total NOx

Off-Highway Non-Road Diesel 32,431 3.3% 

Off-Highway Non-Road Gasoline 889 0.09% 

PM10 % Total PM10 

Miscellaneous Other Fugitive Dust 77,713 16.8% 

Industrial 

Processes (area 

source) Road Construction 48,771 10.5% 

Industrial 

Processes (area 

source) 

Industrial/Commercial/Instituti

onal 25,294 5.5% 

Industrial 

Processes (area 

source) Residential 3,647 0.8% 
Page 14 of 70 

Off-Highway Non-Road Diesel 2,775 0.6% 

Off-Highway Non-Road Gasoline 130 0.03% 

PM2.5 % Total PM2.5 

Miscellaneous Other Fugitive Dust 7,809 10.5% 

Industrial 

Processes (area 

source) Road Construction 4,901 6.6% 

Off-Highway Non-Road Diesel 2,692 3.6% 

Industrial 

Processes (area 

source) 

Industrial/Commercial/Instituti

onal 2,542 3.4% 

Industrial 

Processes (area 

source) Residential 366 0.5% 

Off-Highway Non-Road Gasoline 120 0.2% 

VOC % Total VOC 

Off-Highway Non-Road Gasoline 3,310 0.6% 

Off-Highway Non-Road Diesel 3,058 0.5% 

SO2 % Total SO2 

Off-Highway Non-Road Diesel 4,141 0.4% 

Off-Highway Non-Road Gasoline 24 0.002% 

6.3 Fires

The following table identifies emissions from the 2002 NEI contributed from fire 

activities. In Ohio, open burning represents the majority of emissions from fire/burning 

activities. Wildfires and prescribed burning are not significant emission sources for 

Ohio. Fires are not a significant contribution to emissions in Ohio. Ohio EPA’s 

regulations for open and prescribed burning are discussed under Section 10. 
Page 15 of 70 

Emissions from Ohio Nonpoint Fire Sources During 2002 

 2002 TPY 

NOx 

% Total 

NOx 

Waste Disposal & 

Recycling Open Burning residential 1,166 0.1% 

Waste Disposal & 

Recycling Open Burning land clearing debris 1,028 0.1% 

Miscellaneous 

Other 

Combustion prescribed burning 85 0.009% 

Miscellaneous 

Other 

Combustion structural fires 18 0.002% 

Miscellaneous 

Other 

Combustion forest wildfires 9 0.001% 

PM10 

% Total 

PM10 

Waste Disposal & 

Recycling Open Burning residential 7,385 1.6% 

Waste Disposal & 

Recycling Open Burning land clearing debris 3,494 0.8% 

Miscellaneous 

Other 

Combustion prescribed burning 767 0.2% 

Waste Disposal & 

Recycling Open Burning yard waste 360 0.08% 

Miscellaneous 

Other 

Combustion structural fires 137 0.03% 

Miscellaneous 

Other 

Combustion forest wildfires 87 0.02% 

PM2.5 

% Total 

PM2.5 

Waste Disposal & 

Recycling Open Burning residential 6,763 9.1% 

Waste Disposal & 

Recycling Open Burning land clearing debris 3,494 4.7% 

Miscellaneous 

Other 

Combustion prescribed burning 650 0.9% 

Waste Disposal & 

Recycling Open Burning yard waste 360 0.5% 

Miscellaneous 

Other 

Combustion structural fires 125 0.2% 

Miscellaneous 

Other 

Combustion forest wildfires 74 0.1% 

 
Page 16 of 70 

VOC % Total 

VOC 

Waste Disposal & 

Recycling Open Burning residential 5,830 1.0% 

Waste Disposal & 

Recycling Open Burning land clearing debris 2,384 0.4% 

Miscellaneous 

Area Sources 

Other 

Combustion 

prescribed burning 

for forest 

management 1,748 0.3% 

Waste Disposal & 

Recycling Open Burning yard waste 307 0.05% 

Miscellaneous 

Area Sources 

Other 

Combustion forest wildfires 207 0.03% 

Miscellaneous 

Other 

Combustion structural fires 140 0.02% 

SO2 % Total SO2

Waste Disposal & 

Recycling Open Burning residential 194 0.02% 

Miscellaneous 

Other 

Combustion prescribed burning 1264 0.01% 

Miscellaneous 

Other 

Combustion forest wildfires 6 0.0005% 

PM N/AP 

Miscellaneous 

Area Sources 

Other 

Combustion forest wildfires 125 

NH3 % Total NH3

Miscellaneous 

Area Sources 

Other 

Combustion 

prescribed burning 

for forest 

management 1265 0.1% 

Miscellaneous 

Area Sources 

Other 

Combustion forest wildfires 145 0.01% 

7. Modeling Assessment 

Appendix W of 40 CFR Part 51 contains modeling guidelines for conducting regionalscale visibility modeling. USEPA provides recommendations on appropriate models 

and MRPO chose the Comprehensive Air Quality Model with extensions (CAMx) with 

emissions and meteorology generated using EMS (and CONCEPT) and MM5, 

respectively. The selection of CAMx as the primary model is based on several factors: 

performance, operator considerations (e.g., ease of application and resource 

requirements), technical support and documentation, model extensions (e.g., 2-way 

nested grids, process analysis, source apportionment, and plume-ingrid), and model 

science. This is the same model used for ozone and PM2.5 SIPs. 
Page 17 of 70 

The air quality analysis conducted by MRPO includes weight-of-evidence approaches 

which rely on extensive qualitative and quantitative data analysis and modeling. Given 

uncertainties in emissions inventories and modeling, these data analyses are a 

necessary part of the overall technical support. The analyses are as follows: emissions 

analyses, meteorological analyses, time series (hour of day/day of week/seasonal) 

patterns, trajectory analyses, source apportionment, spatial pattern analyses, episodic 

analyses, data analysis infrastructure, and modeling analyses. Trajectory analyses are 

used as the primary method to determine which Class I areas are affected by emissions 

from Ohio, as discussed in Section 9.1. Results from a source apportionment analysis 

were also considered. CAMx was applied to provide source contribution information for 

the first planning period (2018 conditions) and those results are discussed in Section 

9.2. 

Modeling includes base year analyses for 2002 and 2005 to evaluate model 

performance and future year strategy analyses to assess candidate control strategies. 

The analyses were conducted in accordance with USEPA’s modeling guidelines9

. The 

modeling covers each full calendar year (2002 and 2005) for an eastern U.S. 36 km 

domain. Emission inventories were prepared for the two base years: 2002 (Base K) 

and 2005 (Base M), and several future years: 2008, 2009, 2012, and 2018. The Base M 

-2005 emissions inventory was used to project the 2018 emissions inventory results 

used as part of this SIP. However, portions of this document will refer to the modeling 

results predicted by both the 2002 and 2005 inventories. Further details of the emission 

inventories are provided in two summary reports10 and the following pages of the 

LADCO web site: 

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

http://www.ladco.org/tech/emis/round5/index.php 

For on-road, nonroad, ammonia, and biogenic sources, emissions were estimated by 

models. For the other sectors (point sources, area sources, and MAR (commercial 

marine, aircraft, and railroads)), emissions were prepared using data supplied by the 

states and other RPOs. Emissions from EGUs were predicted based on USEPA’s IPM 

(version 2.1.9 for 2002 and version 3.0 for 2005). 

Section 10 and the TSD (Appendix B) identify the “on-the-books” controls used to 

prepare the future year projections. 

For regional haze, the calculation of future year conditions assumed: 

• baseline concentrations based on 2000-2004 IMPROVE data, with updated 

(substituted) data for Mingo, Boundary Waters, Voyageurs, Isle Royale, and 

 

9

 "Guidance for on the Use of Models and Other Analyses for Demonstrating 

Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze”, EPA-454/B07-002, April 2007. 10 “Base K/Round 4 Strategy Modeling” Emissions”, May 16, 2006; “Base M Strategy Modeling: Emissions 

(Revised)”, February 27, 2008. Available at: http://www.ladco.org/reports/general/ 
Page 18 of 70 

Seney (see “Impact of Missing Data on Worst Days at Midwest Northern Class I 

Areas”, March 12, 2007 (revised 6/19/07)); 

• use of the new IMPROVE light extinction equation; and 

• use of EPA default values for natural conditions, based on the new IMPROVE 

light extinction equation. 

The uniform rate of visibility improvement values for the 2018 planning year were 

derived (for the 20 percent worst visibility days) based on a straight line between 

baseline concentration values (plotted in the end year of the 5-year baseline period 

(2004)) and natural condition value (plotted in the year for achieving natural conditions 

(2064)). Plots of these “glide paths” with the Base M modeling results and a summary of 

measured baseline and modeled future year deciview values for these Class I areas are 

discussed in Section 10.6.8. 

The haze results show that several Class I areas in the eastern U.S. are expected to be 

greater than (less improved than) the uniform rate of visibility improvement values (in 

2018), including those in northern Michigan and several in the northeastern U.S. Many 

other Class I areas in the eastern U.S. are expected to be less than (more improved 

than) the uniform rate of visibility improvement values (in 2018). As noted above, states 

should consider these results, along with information on the other four factors, in setting 

reasonable progress goals. 

Full details of the modeling protocol and performance can be found in Section 3 of the 

TSD (Appendix B). 

8. BART Analysis 

USEPA’s 1999 Regional Haze Rule requires Ohio to have additional controls for certain 

sources that contribute to visibility impairment in Class I areas (Best Available Retrofit 

Technology (BART)) or implement an emissions trading or other alternative program 

that will achieve greater reasonable progress than would be achieved through the 

installation and operation of BART. On July 6, 2005, USEPA published a revised final 

rule, including Appendix Y to 40 CFR part 51 “Guidelines for BART Determinations 

under the Regional Haze Rule,” (hereafter referred to as “BART Guidelines”). 

8.1 BART Eligible Sources in Ohio

A preliminary list of Ohio BART-eligible sources were identified using the methodology 

in the BART Guidelines. For an emission source to be identified as BART eligible, Ohio 

used these criteria from the BART Guidelines: 
Page 19 of 70 

• One or more emissions units at the facility fit within one of the 26 categories 

listed in the BART Guidelines. 

• The emission unit was in existence on August 7, 1977 and began operation at 

some point on or after August 7, 1962. 

• The limited potential emissions from all emission units identified in the previous 

two bullets were 250 tons or more per year of any of these visibility-impairing 

pollutants: SO2, NOx, or PM. 

To identify the preliminary list of sources that meet the criteria above, Ohio performed 

the following activities: 

• Reviewed the Ohio EPA/Division of Air Pollution Control (OEPA/DAPC) 

emissions inventory files, to identify candidate sources for BART eligibility, based 

on SIC code and installation date. This review turned up 35 candidate facilities, 

including 14 EGUs; and 

• Sent questionnaires to the 21 potentially affected non-EGU facilities identified in 

the review of the inventory files. A sample questionnaire is provided as Appendix 

B of the attached BART Technical Support Document (herein referred to as 

BART TSD) (the BART TSD is contained in Appendix D).

8.2 Determination of Sources Subject to BART

Under the BART Guidelines, states have the following options regarding BART-eligible 

sources: (a) make BART determinations for all sources, or (b) consider exempting some 

sources from BART because they do not cause or contribute to visibility impairment in a 

Class I area. Ohio chose option (b). If a state chooses that option, then the BART 

Guidelines suggest three sub-options for determining that certain sources need not be 

subject to BART: 

• Individual source attribution approach (dispersion modeling). 

• Use of model plants to exempt sources with common characteristics. 

• Cumulative modeling to show that no sources in a state are subject to BART. 

8.2.1 Individual Source Attribution Approach (Dispersion Modeling) 

Under this option, CALPUFF (or other appropriate models) can be used to show that 

SO2, NOx, and direct PM emissions from an individual source do not cause or 

contribute to visibility impairment in a Class I area. The first step in this approach is to 

prepare a modeling protocol. MRPO drafted a CALPUFF modeling protocol (“Single 
Page 20 of 70 

Source Modeling to Support Regional Haze BART” contained in Appendix F-m of the 

BART TSD)11. For the purposes of this analysis, the threshold value used to determine 

whether a source causes or contributes to visibility impairment is 0.5 deciview. 

Analysis by MRPO showed there were more than 100 BART-eligible non-EGU sources 

in the 5-state region. CALPUFF modeling for all these sources was not considered 

necessary. This is because previous CALPUFF modeling (conducted in response to 

USEPA’s proposed BART rule) indicated that only sources with a Q/D value > 10 – 20 

had more than a 0.5 deciview visibility impact in a nearby Class I area (MRPO’s 

“Determining Which BART-Eligible Sources are Subject to BART: Summary”, December 

21, 2004.) Consequently, new CALPUFF runs were performed with those sources with 

a Q/D value > 5. (The Q/D values were calculated using the minimum distance to a 

Class I area and potential emissions, if available, or actual emissions, if potential 

emissions were not available.) 

8.2.2 Use of Model Plants 

Under this option, analyses of model plants can be used to exempt sources that share 

specific characteristics. CALPUFF modeling was performed by USEPA of model plants 

(EGUs and non-EGUs) with representative plume characteristics to assess the visibility 

impact from emission sources of difference sizes and distances from two hypothetical 

Class I areas (one in the East and one in the West). Based on these analyses, USEPA 

concluded that if a state establishes 0.5 deciview as a contribution threshold, then the 

state could exempt sources with combined SO2 and NOx emissions of less than 500 

TPY located more than 50 km from a Class I area, or less than 1000 TPY located more 

than 100 km from a Class I area. (Note, in “Q&A’s for Source by Source BART rule” of 

July 6, 2005” (Revision 1, October 31, 2005), USEPA approved the use of these 

emissions-distance criteria by states to exempt sources from BART review.) These 

emissions-distance criteria are consistent with a Q/D value < 10. 

8.2.3 Cumulative Modeling 

Under this option, modeling of total visibility impacts from all BART-eligible sources in a 

given state can be used to show that they collectively do not cause or contribute to 

visibility impairment in a Class I area. This approach was used to assess the likelihood 

that VOC and PM emissions will not cause or contribute to visibility impairment. 

Specifically, CAMx was run with all point source VOC and PM emissions eliminated 

(“zeroed-out”) to assess the contribution of these species to visibility impairment. The 

model results shown below demonstrate that these emissions do not contribute to 

visibility impairment (i.e., less than a 0.5 deciview impact in any Class I area). Because 

the VOC and PM emissions from just the BART-eligible sources are much less than 

 

11 The procedures and assumptions in this CALPUFF modeling are specific to the BART analysis (i.e., to 

help determine which BART-eligible sources are subject to BART), and may not necessarily be applicable 

to CALPUFF modeling performed for other purposes, including new source review analyses. 
Page 21 of 70 

those from all point sources, the visibility impact of these emissions from the BARTeligible sources will be much less than 0.5 deciview in any Class I area. Thus, these 

emissions can be excluded from BART review. In addition, ammonia emissions can be 

excluded from BART review, given that these emissions from the BART-eligible sources 

are relatively small (i.e., ammonia emissions from all point sources make up only 1 

percent of the total ammonia emissions in the region). 
Page 22 of 70 

8.2.4 EGUs 

The BART-eligible EGUs in Ohio were not subjected to Q/D analysis or dispersion 

modeling because of Ohio’s decision that CAIR would suffice for their control, as 

discussed below. The following 18 generating stations include an aggregate of 37 

BART-eligible units (from Appendix H of the BART TSD): 

 

 No. of BART- 

 Station County eligible units 

 J. M. Stuart Adams 4 

 Ashtabula Ashtabula 4 

 City of St. Mary’s Auglaize 1 

 City of Hamilton Butler 2 

 W. C. Beckjord Clermont 2 

 Conesville Coshocton 3 

 Gen. J. M. Gavin Gallia 2 

 Miami Fort Hamilton 1 

 Cardinal Jefferson 3 

 W. H. Sammis Jefferson 4 

 Eastlake Lake 2 

 City of Painesville Lake 2 

 Avon Lake Lorain 1 

 Bay Shore Lucas 1 

 Muskingum River Morgan 1 

 City of Shelby Richland 2 

 City of Dover Tuscarawas 1 

 City of Orrville Wayne 1 

With respect to emissions of NOx and SO2 from EGUs, Ohio chooses the option 

allowed under 40 CFR 51.308(e)(2). This provision provides that a state may impose a 

cap-and-trade emissions program in lieu of BART requirements, if it can be shown that 

the program will provide a greater rate of progress toward visibility improvement goals 

than would BART. USEPA has determined that the cap-and-trade provisions of the 

CAIR under 40 CFR Part 96 AAA-EEE do establish such a program in relation to 

emissions of NOx and SO2 from EGUs, and this determination that CAIR is an 

acceptable alternative to BART for EGUs has been codified in 40 CFR 51.308(e)(4). 

The CAIR program and implications regarding its vacatur and remand are discussed in 

greater detail in Section 10. 

With respect to emissions of VOC and PM from EGUs, the cumulative modeling, as 

discussed above under Section 8.2.3, demonstrates that these emissions do not 
Page 23 of 70 

contribute to visibility impairment (i.e., less than a 0.5 deciview impact in any Class I 

area). 

Thus, Ohio EPA has determined EGUs do not have to conduct BART control analyses 

as a requirement for this SIP. 

8.2.5 Detailed Analysis of Potential BART-Subject Sources 

The result of the preliminary review discussed under Sections 8.1 and 8.2 was that 

twelve facilities were identified as needing a detailed analysis using the CALPUFF 

computer model. This includes one facility (Degussa) which was overlooked at the 

outset, and several that were provided a Q/D analysis based on faulty source locations. 

Ohio determined CALPUFF modeling would be conducted rather than reanalyzing the 

Q/D calculation for those facilities. Appendix D of the BART TSD contains the results 

of the analysis along with the Q/D values. Those twelve include the following: 

 City County 

 Cemex Xenia Greene 

 Chemtrade Logistics Cairo Allen 

 Cinergy Solutions St. Bernard Hamilton 

 Cognis Cincinnati Hamilton 

 Degussa Belpre Washington 

 P. H. Glatfelter Chillicothe Ross 

 Martin Marietta Woodville Sandusky 

 Ormet Hannibal Monroe 

 Owens Corning Newark Licking 

 Premcor Lima Allen 

 Sun Oregon Lucas 

WCI Steel Warren Trumbull 

Ohio chose individual source attribution by dispersion modeling to determine which 

sources cause or contribute to visibility impairment and, therefore, are subject to BART. 

The CALPUFF modeling protocol used to determine which BART-eligible facilities are 

subject to BART (developed by MRPO) is included as Appendix F-m in the BART TSD. 

The procedure involves modeling visibility impacts at the following sixteen Class I areas: 

Class I Area State(s) 

 Boundary Waters Canoe Area Minnesota 

 Brigantine National Wildlife Refuge New Jersey 

 Dolly Sods/Otter Creek Wilderness W. Virginia 

 Great Gulf Wilderness New Hampshire 

 Great Smoky Mountains National Park Tennessee, N. Carolina 

 Hercules-Glades Missouri 

 Isle Royale National Park Michigan 

 James River Face Virginia 

 Linville Gorge N. Carolina 
Page 24 of 70 

 Lye Brook Wilderness Vermont 

 Mammoth Cave National Park Kentucky 

 Mingo Wilderness Area Missouri 

 Seney Wilderness Area Michigan 

 Shenandoah National Park Virginia 

 Sipsey Wilderness Alabama 

 Voyageurs National Park Minnesota 

A source is considered subject-to-BART if, for any of the years 2002, 2003, and 2004, it 

causes eight or more days of visibility degradation exceeding 0.5 deciview at any one of 

the above-listed Class I areas. The pollutants modeled are SO2, NOx, primary PM2.5, 

HNO3, and SO4. Generally no data were available for the latter two pollutants. 

The operation of the model was consistent with MRPO’s protocol document and 

employed run scripts and postprocessor routines supplied by MRPO. The basis for the 

mass rates of emission varied from source to source. Generally, permit allowables were 

used, but where emissions were not restricted by permit, actual values were found in 

Ohio EPA’s emission inventory or in data supplied by the company. If the data were 

taken from the annual inventory, the annual release was divided by actual hours of 

operation (also found in the inventory) to arrive at the pounds per hour to be used for 

modeling. This approach was judged to be satisfactory for facilities with impacts well 

below the eight days/year exceedance level, but inadequate for the one source, P. H. 

Glatfelter Company (“Glatfelter”), with larger impacts. For Glatfelter, three years of daily 

emission data were reviewed, to identify the single day of highest combined emission of 

all BART-eligible sources. This gave rise to a modeled emission rate higher than would 

have been used if permit allowables had served as the basis. (This does not indicate a 

violation by Glatfelter, since the permit allowable is based on a 30-day averaging 

period.) Notes on the model inputs for each facility appear in Appendix F-l of the BART 

TSD. 

The CALPUFF modeling shows one facility (Glatfelter) with visibility impacts above the 

eight days per year threshold, and all other facilities well below. Accordingly, this study 

finds that Glatfelter’s two large coal-fired boilers are the only non-EGU “subject-toBART” sources in Ohio. Glatfelter has worked cooperatively with Ohio EPA to identify 

potential emission controls and analyze all the site-specific factors that are required as 

part of a BART determination. The BART determination for Glatfelter is summarized in 

the BART TSD, and the full document is contained in Appendix G of the BART TSD. 

The attached BART TSD also contains details of the Q/D analysis and the dispersion 

modeling. 

8.3 Determination of BART Requirements for Subject-to-BART Sources

The one non-EGU subject-to-BART facility in Ohio, Glatfelter in Chillicothe, hired the BE 

& K Engineering consulting firm to perform a BART analysis according to applicable 
Page 25 of 70 

guidelines. The consultant’s report, attached as Appendix G to the BART TSD, includes 

an analysis of the requirements of 40 CFR 51.308(e)(1)(iii) which states BART must be 

based on analysis of the best system of continuous emissions control available and 

reductions achievable, and the following factors must be considered in making the 

source-specific BART determination: 

• Technology available; 

• Costs of compliance; 

• Energy and non-air quality environmental impacts of compliance; 

• Existing pollution control technology in use at the source; 

• Remaining useful life of the source; and 

• Degree of improvement in visibility that may reasonably be anticipated to result 

from the use of such technology. 

On a variety of grounds, including technical feasibility and negligible visibility impacts as 

demonstrated by CALPUFF modeling, NOx and primary particulate emissions were 

determined to require no control beyond what is currently provided. The analysis 

conducted by BE & K Engineering narrowed the full range of possibilities for SO2 

control down to three specific technologies meriting detailed study: 

• Wet Flue Gas Desulfurization (FGD) 

• Semi-Dry FGD 

• Overfire Air and Sorbent Injection System (OASIS) 

The three technologies are targeted toward SO2 reduction. They are capable of 90 

percent, 90 percent, and 60 percent removal of SO2, respectively. The company 

performed a detailed Monte Carlo financial analysis including cost of construction, and 

operating costs such as those of electricity, reagents and waste disposal. Taking this 

analysis into consideration in conjunction with the CALPUFF modeling results, Ohio 

determined that a process capable of 90 percent SO2 removal was appropriate. Upon 

further discussions with Glatfelter it was decided that Glatfelter would implement an 

alternative program to BART as allowed under 40 CFR 51.308(e)(2). An alternative 

BART measure must achieve greater reasonable progress than would be achieved 

through the installation and operation of BART. If the alternative measure results in 

greater emission reductions, then the alternative measure is deemed to achieve greater 

reasonable progress. As part of a broader business strategy to improve energy 

efficiency, Glatfelter will be implementing an alternative approach that will achieve 

greater emission reductions than the 90 percent SO2 removal projected under 

traditional BART. This approach includes installing control technology sufficient to 
Page 26 of 70 

achieve greater than BART SO2 removal on boiler numbers B002 and B003 or 

permanently shutting down the boiler(s). 

8.4 Projected Emissions Reductions Resulting from Installation of BART Controls

The application of alternative BART to the subject-to-BART source, Glatfelter, will 

provide an estimated reduction of 20,515 TPY of SO2 emissions below current levels. 

Controlling both boilers at 90 percent would have resulted in limiting SO2 emissions to 

24,931 pounds per day. Under this alternative the boilers will be limited to emitting 

24,930 pounds per day. There is also the co-benefit of additional reductions of NOx 

and PM2.5 if Glatfelter chooses to permanently shut down a boiler. 

8.5 Enforceability of BART Requirements

This requirement has been incorporated into a federally enforceable permit with a 

compliance date of December 31, 201412. (Appendix H13) 

Under the alternative, control may include an add-on control device, use of an 

alternative fuel, use of low sulfur fuel, or a combination of these measures. In addition, 

Glatfelter may choose to shut down the boiler(s). By no later than December 31, 2013, 

Glatfelter shall submit to Ohio EPA an application for modification of the federally 

enforceable permit that includes a compliance plan outlining, at a minimum, the specific, 

selected control technologies and methods of compliance; and these requirements, 

along with any appropriate monitoring, recordkeeping, and reporting requirements, shall 

be incorporated into the federally enforceable permit by no later than December 31, 

2014. A continuous emission monitoring system (CEMS) will also be installed prior to 

December 31, 2014 to measure and record the daily SO2 emissions. The requirements 

will be incorporated into the facility’s Title V operating permit according to Title V 

revision procedures. 

8.6 Monitoring, Recordkeeping, and Reporting of BART Requirements

Monitoring, recordkeeping, and reporting requirements to ensure compliance with the 

terms and conditions of 40 CFR Part 51 Appendix Y are required for all units subject to 

BART. As discussed above, Ohio will be incorporating all necessary requirements into 

the federally enforceable permit to ensure compliance with BART. 

 

12 All necessary emission reductions must take place during the period of the first long-term strategy (40 

CFR 51.308(e)(2)(iii)). 

13 This permit contains all requirements, including those unrelated to BART, for these two boilers. 

Incorporating this permit as an appendix to this SIP is not a request to incorporate all of the permit 

requirements into Ohio’s SIP. Rather, Ohio EPA recognizes only the BART requirements are a part of 

this SIP. 
Page 27 of 70 

9. Areas of Influence 

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

Consortium (LADCO): Draft List of Class I Areas Located Within (or Impacted by) 

Midwest RPO States, June 26, 2007. (TSD (Appendix B)) 

 

Each state with a Class I area is required by 40 CFR 51.308(d) to address regional 

haze in each mandatory Class I federal area located within the state and in each 

mandatory Class I federal area located outside the state which may be affected by 

emissions from within the state. Although there are no Class I areas located within Ohio, 

the state is still required to address regional haze by determining any Class I area(s) 

that may be impacted by emissions from sources within Ohio. 

Technical analyses conducted by the RPOs were consulted to obtain information on 

Ohio’s areas of influence and culpability for Class I areas in the eastern U.S.14 A 

summary of Class I areas determined to be impacted by Ohio is provided in the table 

below. An explanation of the assessments used to determine Ohio’s areas of influence 

follows the table. 

List of Class I Areas Assessed and Determined to be Impacted by Ohio 

Class I Area Name Impacted? Class I Area Name Impacted? 

81.401 Alabama. 81.419 New 

Hampshire. 

Sipsey Wilderness Area No Great Gulf Wilderness 

Area Yes: (1), (3) 

81.404 Arkansas. 

Pres. Range-Dry River 

Wilderness Area. Yes: (1), (3) 

Caney Creek 

Wilderness Area Yes: (2), (4) 81.42 New Jersey. 

Upper Buffalo 

Wilderness Area Yes: (2), (4) Brigantine Wilderness Area Yes: (1), (3) 

81.408 Georgia. 81.422 North Carolina. 

Cohotta Wilderness 

Area No Great Smoky Mountains NP{1} Yes: (1) 

Okefenokee Wilderness 

Area No Joyce Kilmer-Slickrock Wilderness Area{2} No 

 

14 Back trajectories and modeling conducted by the WRAP indicate that the MRPO States are not 

important contributors to visibility impairment due to sulfates and nitrates in western Class I areas (Cite: 

“Attribution of Haze Phase I Report, Geographic Attribution for the Implementation of the Regional Haze 

Rule”, March 14, 2005). The analyses show only five groups of western Class I areas with at least 5 

percent contribution from states outside the WRAP. The outside-WRAP contribution is generally small 

(on the order of 0-15 percent), and is likely due mostly to nearby CENRAP states. 
Page 28 of 70 

Class I Area Name Impacted? Class I Area Name Impacted? 

Wolf Island Wilderness 

Area No Linville Gorge Wilderness Area. No 

81.411 Kentucky. 

Shining Rock 

Wilderness Area. No 

Mammoth Cave NP Yes: (1), (2), (5) Swanquarter 

Wilderness Area No 

81.412 Louisiana. 81.426 South Carolina. 

Breton Wilderness Area No Cape Romain 

Wilderness No 

81.413 Maine. 81.428 Tennessee. 

Acadia National Park Yes: (3) Great Smoky 

Mountains NP{1}. Yes: (1) 

Moosehorn Wilderness 

Area. Yes: (3) Joyce Kilmer-Slickrock Wilderness{2} No 

81.414 Michigan. 81.431 Vermont. 

Isle Royale NP. No Lye Brook Wilderness Yes: (1), (2), (3)

Seney Wilderness Area Yes: (1), (2) 81.433 Virginia. 

81.415 Minnesota. 

James River Face 

Wilderness. Yes: (2), (5) 

Boundary Waters 

Canoe Area Wilderness No Shenandoah NP Yes: (1),(2),(3),(5) 

Voyageurs NP No 81.435 West Virginia. 

81.416 Missouri. 

Dolly Sods/Otter Creek 

Wilderness. 

Yes: 

(1),(2),(3),(5) 

Hercules-Glades 

Wilderness Area Yes: (2), (4) 

Mingo Wilderness Area Yes: (2), (4) 

Key: (1) MRPO Back Trajectory Analyses, (2) MRPO PSAT Modeling, (3) MANE-VU Contribution 

Assessment, (4) Missouri-Arkansas Contribution Assessment, (5) VISTAS Areas of Influence 

For the MRPO analyses, Ohio was assumed to affect visibility impairment in a Class I 

area if it contributes 2 percent (or more) to total light extinction. This criterion was 

selected based on a review of the back trajectory and modeling results which showed 

that states contributing 2 percent (or more) make up about 90 to 95 percent of total light 

extinction, whereas states contributing 5 percent (or more) make up about 75-80 

percent of total light extinction. For the other RPO analyses, deference was given to the 

criteria established by each group to identify contributing states. 
Page 29 of 70 

9.1 MRPO Back Trajectory Analyses

An initial trajectory analysis15 was conducted using data for 1997-2001 (all sampling 

days), a start height of 200 meters, and a 72-hour (3-day) trajectory period. By 

combining trajectory frequencies with concentration information, the average 

contribution to PM2.5 mass and individual PM2.5 species was estimated (which, in turn, 

was used to estimate the average contribution to light extinction). The results for 17 

Class I areas in eastern U.S. were examined to identify those Class I areas where Ohio 

had at least a 2 percent contribution to total light extinction (based on all days). 

Additional details on the back trajectory analyses are provided in the TSD (Appendix B). 

9.2 MRPO Powertrain System Analysis Toolkit (PSAT) Modeling

A photochemical grid model (CAMx) was applied to provide source contribution 

information for 2018 conditions. Specifically, the model estimated the impact of 18 

geographic source regions and 6 source sectors (EGU point, non-EGU point, on-road, 

off-road, area, and ammonia sources) at Class I areas in the eastern U.S. Example 

results for four Class I areas (Seney, Mammoth Cave, Mingo, and Shenandoah) are 

provided in the TSD (Appendix B). The results for 13 Class I areas in eastern U.S. were 

examined to identify those Class I areas where Ohio had at least a 2 percent 

contribution to total light extinction. 

9.3 MANE-VU Contribution Assessment

A weight-of-evidence report16 was prepared by the Northeast States for Coordinated Air 

Use Management (NESCAUM) (on behalf of MANE-VU) to understand the causes of 

sulfate-driven visibility impairment at Class I areas in the northeastern and mid-Atlantic 

portions of the U.S. The report provides information on the relative contribution of 

various emissions sources and geographic source regions. The analytical and 

assessment tools considered include Eulerian and Lagrangian air quality models, and 

data analysis techniques, such as source apportionment analyses, back trajectories, 

and examination of emissions and monitoring data. Sulfate impacts were quantified 

using five analytical techniques based on 2002 conditions: Regional Modeling System 

for Aerosols and Deposition (REMSAD), Q/D, CALPUFF (with National Weather Service 

data), CALPUFF (with MM5 data), and percent time upwind (based on trajectory 

analyses). Additional details, including the percent contribution results, for MANE-VU 

Class I areas is provided in the TSD (Appendix B). 

Although no specific criteria were identified in the report to determine a significant 

contribution, the States of Vermont, New Hampshire, Maine, and New Jersey used a 

very low threshold of 2 percent sulfate contribution or 0.1 ug/m3 sulfate contribution to 

 

15 “Quantifying Transboundary Transport of PM2.5: A GIS Analysis”, May 2003, LADCO 16 “Contributions to Regional Haze in the Northeast and Mid-Atlantic United States”, August 2006 
Page 30 of 70 

the 20 percent worst days as their significance level. Ohio was an MRPO state 

identified as contributing to a MANE-VU Class I area. 

9.4 Missouri-Arkansas Contribution Assessment

The draft Consultation Plan17 for the two Missouri and two Arkansas Class I areas 

provides information on source regions affecting these Class I areas (i.e., areas of 

influence) using a variety of data and analyses. A decision on whether a given state is 

a contributor to visibility impairment in these Class I areas was based on the combined 

results of three approaches: areas of influence, PSAT modeling (based on 2018 

conditions), and monitoring data analyses (Positive Matrix Factorization (PMF) and back 

trajectories). According to the draft plan, if a state was a major contributor for at least 

two of the three approaches (for either sulfate or nitrate), then it was determined to be a 

significant contributor. Ohio was an MRPO state identified as contributing to a central 

CENRAP Class I area. Additional details on this assessment are provided in the TSD 

(Appendix B). 

9.5 VISTAS Area of Influence Analysis

Areas of influence were identified for Class I areas in the southeastern U.S. using 

residence time plots based on wind trajectory direction and frequency, and weighted by 

visibility impact (light extinction by ammonium sulfate, ammonium nitrate, or elemental 

carbon).18

These extinction-weighted residence time analyses were overlayed on gridded 

emissions (for both 2002 and 2018) to define emission sources in the areas of greatest 

influence for each Class I area. Areas of influence were defined on the basis of 

residence times greater than 10 percent. Ohio was an MRPO state identified as 

contributing to a VISTAS Class I area. Additional details on this assessment are 

provided in the TSD (Appendix B). 

10. Long-Term Strategy and Reasonable Progress 

Ohio evaluated each of the Class I areas identified under Section 9 as being impacted 

by emissions from Ohio sources. Information provided by MRPO, technical documents 

from the other RPOs, other states’ Regional Haze SIPs or communications indicating 

their decisions regarding reasonable further progress goals were used as part of this 

evaluation. 

Section 169A of the Clean Air Act and USEPA’s visibility rule requires states to consider 

five factors: 

 

17 “Central Class I Areas Consultation Plan”, States of Missouri and Arkansas, February 2007 18 “VISTAS Areas of Influence Analysis”, Draft, February 28, 2007 
Page 31 of 70 

• Costs of compliance; 

• Time necessary for compliance; 

• Energy and non-air quality environmental impacts of compliance; 

• Remaining useful life of any existing source subject to such requirements; and 

• Uniform rate of visibility improvement (needed to attain natural visibility 

conditions by 2064). 

However, USEPA provides for flexibility in consideration of these factors: 

“...the factors could be used to select which sources or activities should or 

should not be regulated, or they could be used to determine the level or 

stringency of control, if any, for selected sources or activities, or some 

combination of both. The factors may be considered both individually and/or in 

combination. As noted in section 4.1, given the significant emissions reductions 

that we anticipate to result from BART, the CAIR, and the implementation of 

other CAA programs, these reductions may be all that is necessary to achieve 

reasonable progress in the first planning period for some states. Also, as noted in 

section 4.2, it is not necessary for you to reassess the reasonable progress 

factors for sources subject to BART for which you have already completed a 

BART analysis.” (USEPA’s “Guidance for Setting Reasonable Progress Goals 

Under the Regional Haze Program,” June 1, 2007) 

In the following sections, these analyses are summarized. A detailed analysis of each 

area is included. In the previous section, MRPO modeling was used to identify areas 

possibly impacted by Ohio sources. 

Ohio has no Class I areas and is not required to set reasonable progress goals. States 

with Class I areas lead the establishment of their reasonable progress goals and 

consideration of the factors above while Ohio participated in the discussions and 

provided information to assist in setting the goals. 

Ohio is required by 40 CFR 51.308(d)(3) to submit a long-term strategy that addresses 

regional haze visibility impairment for each mandatory Class I area located outside Ohio 

that may be affected by emissions from within Ohio. The long-term strategy must 

include enforceable emissions limitations, compliance schedules and other measures 

necessary to achieve the reasonable progress goals established by states where the 

Class I areas are located. 

In summary, Ohio believes that the current “on-the-books” controls address Ohio’s 

impact on Class I areas and is therefore Ohio’s long-term strategy. The “on-the-books” 

control programs include: 
Page 32 of 70 

On-Highway Mobile Sources 

• Federal Motor Vehicle Emission Control Program, low-sulfur gasoline and 

ultra-low sulfur diesel fuel 

• Inspection - maintenance programs, including Ohio’s E-check program in 

northeast Ohio (note: a special emissions modeling run was done for the 

Cincinnati/Dayton area to reflect the removal of the state’s E-check 

program and inclusion of low RVP gasoline) 

Off-Highway Mobile Sources 

• Federal control programs (e.g., nonroad diesel rule), plus the evaporative 

Large Spark Ignition and Recreational Vehicle standards 

• Heavy-duty diesel (2007) engine standard/Low sulfur fuel 

• Federal railroad/locomotive standards 

• Federal commercial marine vessel engine standards 

Area Sources 

• Consumer solvents 

• AIM coatings 

• Aerosol coatings 

• Portable fuel containers 

Power Plants 

• Title IV (Phases I and II) 

• NOx SIP Call 

• Clean Air Interstate Rule, or its replacement 

Other Point Sources 

• VOC 2-, 4-, 7-, and 10-year MACT standards 

• Combustion turbine MACT 

One “on-the-book” control includes the CAIR. On March 10, 2005, the USEPA 

announced CAIR, a rule that addresses the interstate transport of air pollution to 

downwind states. On February 1, 2008, USEPA approved Ohio’s CAIR program. 

Revisions to the CAIR SIP were again submitted by Ohio EPA on July 15, 2009. The 

revised CAIR SIP was approved as a direct final action on September 25, 2009 (74 FR 

48857). 

On July 11, 2008, the U.S. Court of Appeals for the D.C. Circuit vacated USEPA’s CAIR 

rule. MRPO’s modeling used as part of this submittal relied on EGU emission 

projections from USEPA’s IPM3.0 analysis, which assumed implementation of Phases I 

and II of CAIR. MRPO conducted additional modeling where alternative EGU emission 

projections were developed, which did not rely on CAIR (or IPM). In summary, the 

results show, with respect to regional haze, there is a significant change from the 

previous MRPO modeling (with CAIR). The modeling shows higher visibility levels in 

2018 for the 20 percent worst visibility days (average about 0.5 deciview for the 
Page 33 of 70 

northern Class I areas). The resulting visibility levels in the northern Class I areas 

(except Voyageurs) are above the glide path. 

On December 23, 2008, the U.S. Court of Appeals for D.C. Circuit issued its mandate 

deciding to remand CAIR back to USEPA without vacatur. This decision allows 

implementation of CAIR, and the benefit of CAIR emission reductions, while USEPA 

works to address the Court’s prior opinions contained in the original vacatur. To address 

the D.C. Circuit Court’s concerns in the remand, USEPA proposed a replacement to the 

CAIR program, the Transport Rule on July 6, 2010. [75 FR 45210] Upon finalization, it 

will further assist states in addressing their obligations regarding regionally transported 

pollution by providing reductions in NOx and SO2 emissions in 2012 and 2014. 

Therefore, Ohio is basing its results with CAIR, or its replacement, in place. 

Beyond “on-the-books” controls were considered. In summary: 

• Controlling EGUs beyond CAIR control levels would have the most effect on 

visibility improvement. Beyond-CAIR controls are likely to be considered by Ohio 

and other states in the region when evaluating control options for meeting the 

new PM2.5 24-hour standard and the new 8-hour ozone standard. Such controls 

are likely to be implemented in a timeframe close to the 2018 haze progress date 

and will, therefore, result in additional improvements to visibility. 

• Industrial, commercial and institutional (ICI) boiler controls are estimated to be a 

little more expensive per ton of SO2 or NOx removed than EGU controls and 

have much less overall impact on visibility improvement (in deciview) than EGUs. 

Ohio EPA worked with MRPO and the Northeast states to develop 

recommendations for a federal ICI boiler rule. Many states, including Ohio, have 

sent letters to USEPA requesting a cooperative effort between states and 

USEPA to reduce emissions from EGUs, ICI boilers, mobile sources and area 

sources (Appendix E). 

• Requiring controls on other source sectors, such as reciprocating engines and 

turbines, and some mobile measures, may be cost effective, but they provide 

very little visibility improvement. Costs for mobile sources varied widely, but all 

programs had very little impact on visibility as discussed below. 

• For agricultural sources, modeling is very uncertain and reducing ammonia may 

increase acid deposition, which could do more harm than the current visibility 

impacts. 

With the current bleak economic condition in Ohio, pursuing controls on these other 

sectors for visibility reduction cannot be justified. Further, USEPA acknowledges that 

“in deciding what amount of emissions reduction is appropriate in setting the reasonable 

progress goals, you should take into account the fact that the long-term goal of no 

manmade impairment encompasses several planning periods. It is reasonable for you 

to defer reductions to later planning periods in order to maintain a consistent glidepath 
Page 34 of 70 

toward the long-term goal” (USEPA’s “Guidance for Setting Reasonable Progress Goals 

Under the Regional Haze Program,” June 1, 2007). Notwithstanding the reasons 

described above for not pursuing additional controls, Ohio has pursued BART controls 

on the BART-eligible source(s) discussed in Section 8. Ohio does intend to revisit and 

review its decision during the progress review period and future planning periods. 

The following subsections detail how Ohio meets the long-term strategy requirements. 

10.1 Consultation

Ohio is required by 40 CFR 51.308(d)(3)(i) to consult with other states/tribes to develop 

coordinated emission strategies. This requirement applies both where emissions from 

the state are reasonably anticipated to contribute to visibility impairment in Class I areas 

outside the state and when emissions from other states/tribes are reasonably 

anticipated to contribute to visibility impairment in Class I areas within the state. 

Ohio consulted with other states and tribes by participation in the MRPO and inter-RPO 

processes that developed technical information necessary for development of 

coordinated strategies (see Section 11). 

Ohio received a letter from the MANE-VU on July 30, 2007 requesting a course of 

action for reasonable progress at their Class I areas. Ohio participated, along with other 

MRPO states, in consultations and discussions with MANE-VU and was provided a 

consultation summary by MANE-VU on August 6, 2007 (Appendix E). Ohio EPA 

provided a response on October 3, 2007 (Appendix E). In this response, Ohio 

requested additional information and work to be done before Ohio could properly 

respond to MANE-VU’s request. MANE-VU’s request is discussed in greater detail 

under Section 10.2. 

The state coordination with FLMs on long-term strategy development is described in 

Section 3. 

10.2 Share of Emissions Reductions 

Ohio is required by 40 CFR 51.308(d)(3)(ii) to demonstrate that its implementation plan 

includes all measures necessary to obtain its fair share of emission reductions needed 

to meet reasonable progress goals. 

In summary, Ohio has determined that its fair share of emission reductions needed to 

meet reasonable progress constitutes on-the-books controls. The following details 

Ohio’s determination of its fair share of emission reductions for each Class I area which 

Ohio was determined to have emissions impacting visibility, as discussed under Section 

9. 
Page 35 of 70 

10.2.1 MRPO 

Michigan - Seney Wilderness Area

Michigan identified states that are expected to contribute significantly to its Class I areas 

as those with more than a 5 percent contribution to visibility impairment. Ohio’s 

contribution, as identified under Section 10.6.8, was found to be 4 percent and, 

therefore, Ohio was not identified by Michigan as a contributing state. Contributing 

states included: Michigan (18 percent), Illinois (14 percent), Indiana (12 percent) and 

Wisconsin (11 percent). Michigan determined that reasonable controls are on-thebooks controls. Ohio supports Michigan’s determination of reasonable progress for this 

first planning period for the Seney Wilderness Area and that on-the-book controls by 

Ohio constitutes Ohio’s fair share of emission reductions. 

10.2.2 MANE-VU 

Four states in the MANE-VU region indicated that Ohio contributed to their Class I 

areas: Acadia and Moosehorn in Maine, Great Gulf/Presidential Range in New 

Hampshire, Brigantine in New Jersey, and Lye Brook in Vermont. MANE-VU used a 

very low threshold of two percent sulfate contribution or 0.1 ug/m3 sulfate contribution to 

the 20 percent worst days in 2002 as their significance level. 

The following summarizes the analysis by MRPO regarding Ohio’s contribution to the 

MANE-VU Class I areas on the 20 percent worst visibility days for the first planning 

period (2018): 

 

MANE-VU Class I Area % Contribution 

New Hampshire – Great Gulf Wilderness Area and 

Presidential Range-Dry River Wilderness Area 

<2% 

New Jersey – Brigantine Wilderness Area 3% 

Vermont – Lye Brook Wilderness Area 3% 

Maine – Acadia National Park 4% 

Maine – Moosehorn Wilderness Area <2% 

 

MANE-VU’s document entitled “Assessment of Reasonable Progress for Regional Haze 

in MANE-VU Class I Areas - Methodology for Source Selection, Evaluation of Control 

Options, and Four Factor Analysis, July 200719” requests states outside of the MANEVU area to examine controls for specific types of sources (i.e., “MANE-VU Ask”). 

MANE-VU suggested the following control strategies be adopted and implemented: 

 

19 http://www.marama.org/technical-center/regional-haze-planning/reasonable-progress-analysis, under 

“Work Products.” The resulting request is referred to as the “MANE-VU Ask.” 
Page 36 of 70 

• Application of BART. 

• 90 percent (or greater) reduction in SO2 emissions from each of the EGU stacks 

on MANE-VU’s list of 167 stacks (located in 19 states), which reflect those stacks 

determined to be reasonably anticipated to cause or contribute to visibility 

impairment in the MANE-VU Class I areas. 

• 28 percent reduction in non-EGU (point, area, on-road, and off-road) SO2 

emissions relative to on-the-books, on-the-way 2018 projections. 

• Continued evaluation of other measures, including measures to reduce SO2 and 

NOx emissions from coal-burning facilities and promulgation of new source 

performance standards for wood combustion. 

• Further reduction in power plant SO2 (and NOx) emissions beyond CAIR 

Of the 167 stacks identified by MANE-VU based on 2002 emissions, 28 are from 14 

sources in Ohio (Appendix E). Most of these stacks have or will have post-combustion 

emission controls for SO2 emissions (i.e., scrubbers). This will provide for further 

reductions in emissions from these Ohio sources compared to the 2002 emissions used 

by MANE-VU to develop this list. 

Since 2002 the following sources from the MANE-VU list are implementing SO2 

controls: 

• The seven units (4 -185 MW; 300 MW; 2-600 MW) (identified as five stacks by 

MANE-VU) at First Energy W. H. Sammis facility began continuous operation of 

scrubbers in 2010. 

• Two (600 MW each) of the three units at AEP Cardinal were operating scrubbers 

by the end of 2007 or early 2008. The third unit’s (630 MW) scrubber is currently 

under construction but required by Consent Decree to continuously operate by 

2012. 

• AEP Muskingum currently has five units identified as two stacks by MANE-VU. 

The largest of five units (2-205 MW; 2-250 MW; 600 MW) at AEP Muskingum is 

required by Consent Decree to install and continuously operate a scrubber by 

2016. 

• The four units (573 MW each) at the Dayton P&L JM Stuart facility have installed 

and operated scrubbers continuously since spring of 2008. 

• The unit (587 MW) at Dayton P&L Killen facility has installed and operated its 

scrubber since June 2007. 
Page 37 of 70 

• In 2006, two of the units (each 125 MW) at AEP Conesville, and identified on 

MANE-VU’s list, shut down (they comprised one stack). The second stack, 

comprised of one unit (800 MW), completed construction and began operating its 

scrubber in June 2009. 

• Duke Miami Fort had five units in operation. In 2007, two of these units shut 

down. Of the remaining three units, two units (490 MW each) began operating 

scrubbers in 2007; and for the third (smallest at163 MW), Duke has indicated no 

immediate plans to install a scrubber. 

• First Energy Burger has three units. Two units (156 MW each) will shut down by 

no later than 2012. For the third (smallest at 94 MW), First Energy has indicated 

no immediate plans to install a scrubber. 

• OVEC Kyger Creek has five units (217 MW each)(identified as one stack by 

MANE-VU). All units are planned to have scrubbers installed and operating by 

mid-2012. 

Therefore, Ohio’s utilities have made significant progress in installing SO2 controls as 

requested under MANE-VU’s Ask. 

The following chart from MRPO modeling shows the culpability of geographic areas to 

visibility conditions in the Arcadia Class I area for which MRPO modeling indicated Ohio 

as the highest contribution in 2018 compared to all Class I areas in the northeast for 

which Ohio is a contributor (circled in red): 

Acadia Visibility Impact Modeling 
Page 38 of 70 

The following table, based on MRPO modeling, identifies the percent contributions in 

2018 from various states and regions to three Class I areas, including Arcadia, in the 

northeast: 

The chart and table demonstrate that Ohio sources have insignificant impacts on these 

areas compared to other states and regions. 

More recent modeling has been done for MANE-VU (www.nescaum.org/topics/regionalhaze/regional-haze-documents) for projecting visibility in 2018 (“2018 Visibility 

Projections,” May 13, 2018). Based on this more recent modeling, MANE-VU found 

“the uniform rate is achieved and exceeded at all MANE-VU Class I sites." 
Page 39 of 70 

The document further states: 

“MANE-VU received comments from several stakeholders and another RPO 

related to the fact that the modeling described in this report included control 

measures and emission reductions that went beyond currently existing 

regulations. Commenters suggested that since the CAIR program and other “on 

the books” or “on the way” measures are projected to achieve uniform rates of 

progress as previously modeled, additional reductions to both EGU and nonEGU sectors were unnecessary.... there are ..reasons why MANE-VU has 

chosen to include these measures in this modeling analysis....while the results of 

the modeling described in this report suggest individual MANE-VU Class I areas 

will be able to meet or exceed uniform rates of progress by 2018, our current 

analysis also suggests that this would be difficult without including additional 

measures beyond implementation of CAIR. This result is due, in part, to our 

assumptions about the effectiveness of CAIR. We believe that it is appropriate for 

MANE-VU to take a conservative approach to estimating the potential for 

emissions reductions under the CAIR program. Therefore MANE-VU added EGU 

emissions to estimate the impact of banking and trading under CAIR. Additional 

EGU reductions would be feasible with additional federal action to control EGU 

emissions (e.g., a third phase of CAIR), but MANE-VU does not believe that 

these reductions are likely to occur absent additional regulation.” 

MRPO used USEPA’s approved IPM modeling and projections to project EGU 

emissions for 2018. Ohio EPA does not agree with MANE-VU’s “add back” due to the 

uncertainty of CAIR. 

Further details are found in MANE-VU’s February 7, 2008 document entitled “MANE-VU 

Modeling for Reasonable Progress Goals” regarding the following projections for 2018: 
Page 40 of 70 

As seen above, for Arcadia (the Class I area for which Ohio has the highest contribution 

in 2018 (4 percent)), a 4.39 deciview, or 19 percent, reduction is predicted based on onthe-book controls and restrictions on fuel sulfur content in the MANE-VU region. 

Adding additional controls incorporated into MANE-VU’s Ask results in an additional 

0.55 deciview, or 2 percent, change. Important to note, in all cases, including on-thebooks control, the uniform rate of improvement is met at Arcadia as depicted graphically 

below in MANE-VU’s document: 
Page 41 of 70 

The same results are seen in this document for all MANE-VU Class I areas. 

Ohio EPA committed to continuing work with MANE-VU states but continues to believe 

that on-the-books controls, for this first planning period, represent reasonable progress. 

However, Ohio, along with the other MRPO states, has committed to continue 

consultation with MANE-VU. Specifically, Ohio has agreed to support additional work 

and discussion to accomplish the following: 

Establish a clear understanding of the MANE-VU Ask by agreeing on base emissions 

inventories and control assumptions; 

Draft language on a national "Ask" based on the multi-pollutant needs of the states, 

including potential controls for EGUs and ICI boilers; and 

Reconvene the MANE-VU/MRPO ICI boiler workgroup (with participation by the 

Southeastern states and USEPA) to re-examine the workgroup’s January 2007 straw 

proposal. 

In addition, as discussed above, in 2009 after a six-month collaborative effort among 

MRPO and northeast states, many states, including Ohio and MANE-VU states, sent 

letters to USEPA requesting a cooperative effort between states and USEPA to reduce 

emissions from EGUs, ICI boilers, mobile sources and area sources (Appendix E). 

If a contributing state cannot agree with the state establishing the reasonable progress 

goal, “the state setting the goal must describe the actions taken to resolve the 

disagreement.” [64 FR 35714] Ohio does not believe at this time that it can commit to 

any particular course of action beyond the collaboration that occurred in 2009 until it is 

determined, through the above work and further discussions, what actions may be 

appropriate to meet reasonable progress goals given Ohio’s marginal impact on those 

areas. 
Page 42 of 70 

10.2.3 Missouri-Arkansas (CENRAP) 

Arkansas- Caney Creek Wilderness Area and Upper Buffalo Wilderness Area 

The CENRAP modeling shows that Arkansas’s Class I areas can achieve the 2018 

reasonable progress goals without additional control measures (above on-the-books). 

For the two Arkansas Class I areas, 2018 visibility projections are available from the 

CENRAP, VISTAS and MRPO RPOs. MRPO projections showed Ohio’s contribution at 

3 percent for both of these Class I areas. However, the TSD20 prepared by Environ for 

CENRAP states acknowledges “the MRPO 2018 visibility projections are approximately 

12 to 25 percentage points lower than the CENRAP and VISTAS projections at these 

three Class I areas, with values of 97 percent to 100 percent. The reasons why the 

MRPO 2018 visibility projections are less optimistic than CENRAP and VISTAS are 

unclear. However, the MRPO focused on visibility projections at their northern Class I 

areas and likely did not use the latest CENRAP emission estimates. In addition, the 

CENRAP 2018 visibility projections included BART controls on several sources in 

CENRAP states not included in the MRPO projections. Such BART controls are even 

more important in those states not covered by CAIR.” 

Arkansas’ Regional Haze SIP states that by 2018, Arkansas is the largest contributor to 

extinction at Caney Creek for the 20 percent worst days followed by East Texas, the 

large Eastern U.S. region and then secondary organic aerosols (SOA) due to biogenic 

sources. Ohio’s contribution to the worst 20 percent days as identified in Arkansas’ SIP 

is depicted below (circled in red): 

 

20 ENVIRON’s “Technical Support Document for CENRAP Emissions and Air Quality Modeling to Support 

Regional Haze State Implementation Plans,” September 12, 2007. 
Page 43 of 70 
Page 44 of 70 

And: 
Page 45 of 70 

Arkansas’ SIP states the contributions to extinction on the worst 20 percent days at 

Upper Buffalo is similar to Caney Creek only with less contributions from East Texas 

and more from Missouri, Illinois and Indiana. Ohio’s contribution to the worst 20 percent 

days as identified in Arkansas’ SIP is depicted below (circled in red): 
Page 46 of 70 

And: 

*note: Ohio is not identified as a contributor for NO3 in the right graph. 
Page 47 of 70 

Arkansas’ SIP demonstrates that on-the-books controls are sufficient to meet the 

uniform rate of progress needed during this first planning period (2018), as depicted in 

the glide paths below: 

Ohio supports Arkansas’ determination of reasonable progress for this first planning 

period for the two Class I areas and that on-the-book controls by Ohio constitutes 

Ohio’s fair share of emission reductions. 
Page 48 of 70 

Missouri – Hercules-Glades Wilderness Area and Mingo Wilderness Area

For the two Missouri Class I areas, 2018 visibility projections are available from the 

CENRAP, VISTAS and MRPO RPOs. MRPO projections showed Ohio’s contribution at 

6 percent for Mingo and 4 percent for Hercules-Glades. However, the TSD21 prepared 

by Environ for CENRAP states acknowledges “the MRPO 2018 visibility projections are 

approximately 12 to 25 percentage points lower than the CENRAP and VISTAS 

projections at these three Class I areas, with values of 97 percent to 100 percent. The 

reasons why the MRPO 2018 visibility projections are less optimistic than CENRAP and 

VISTAS are unclear. However, the MRPO focused on visibility projections at their 

northern Class I areas and likely did not use the latest CENRAP emission estimates. In 

addition, the CENRAP 2018 visibility projections included BART controls on several 

sources in CENRAP states not included in the MRPO projections. Such BART controls 

are even more important in those states not covered by CAIR.” 

Missouri states in their Regional Haze SIP that nine states, including Missouri, 

Arkansas, Kentucky, Illinois, Indiana, Ohio, Oklahoma, Tennessee and Texas, were 

identified as contributing to visibility in Mingo and/or Hercules Glades Class I areas. 

Missouri’s SIP states the modeling demonstration has shown that the emission 

reductions from these contributing states are sufficient to achieve reasonable progress 

goals in Missouri’s Class I areas. They also state that “ongoing air pollution control 

programs ... are sufficient to meet the 2018 Uniform Rate of Progress for the Mingo and 

Hercules Glades Class I areas. These ongoing programs such as CAIR, BACT, or 

BART have been demonstrated to be very cost-effective in reducing the visibility in 

Missouri’s Class I areas.” 

Appendix E of Missouri’s SIP identifies Ohio contributing to Mingo and Hercules Glades 

with respect to sulfate but not nitrate. 

 

21 ENVIRON’s “Technical Support Document for CENRAP Emissions and Air Quality Modeling to Support 

Regional Haze State Implementation Plans,” September 12, 2007. 
Page 49 of 70 

 

Missouri is the largest contributor as demonstrated above and Missouri states in its SIP 

that existing programs are sufficient for its state and the other contributing states. As 
Page 50 of 70 

further support, the largest contributions from Ohio for SO2 are identified in its SIP as: 

Conesville, Cinergy Beckjord and Killen. As stated above, two of these three facilities 

have already installed SO2 controls. 

Missouri’s SIP demonstrates that on-the-books controls are sufficient to meet the 

uniform rate of progress needed during this first planning period (2018), as depicted in 

the glide paths below: 
Page 51 of 70 

Missouri’s SIP, as stated above, determined the “emission reductions from these 

contributing states are sufficient to achieve reasonable progress goals in Missouri’s 

Class I areas.” Ohio supports Missouri’s determination of reasonable progress for this 

first planning period for the two Class I areas and that on-the-book controls by Ohio 

constitutes Ohio’s fair share of emission reductions. 

 

10.2.4 VISTAS 

Ohio was an MRPO state identified as contributing to a VISTAS Class I area. 

Kentucky – Mammoth Cave National Park 

Kentucky identified states that are expected to contribute to its Class I areas as those in 

an area of influence defined by 5 percent or greater sulfate extinction-weighted 

residence time. The following depicts Mammoth Cave’s area of influence: 

Ohio’s contribution, as analyzed by MRPO and identified under Section 10.6.8, was 

found to be 8 percent. Kentucky’s Regional Haze SIP identifies Ohio’s percent 

contribution to SO2 emissions at 4 percent. More significant contributing states 

identified by Kentucky included: Kentucky (54 percent), Indiana (22 percent) and 

Tennessee (13 percent). Kentucky determined the VISTAS baseline modeling 

demonstrated that the 2018 base control scenario (existing and planned (i.e., on-the-
Page 52 of 70 

books)) provides for an improvement in visibility better than the uniform rate of progress 

for Mammoth Cave for the most impaired days over the first planning period and 

ensures no degradation in visibility for the least impaired days over the same period, as 

depicted in the glide path below: 

Ohio supports Kentucky’s determination of reasonable progress for this first planning 

period for Mammoth Cave and that on-the-book controls by Ohio constitutes Ohio’s fair 

share of emission reductions. 

North Carolina and Tennessee– Great Smoky Mountains National Park

North Carolina and Tennessee identified states that are expected to contribute to their 

Class I areas as those in an area of influence defined by 5 percent or greater sulfate 

extinction-weighted residence time. The following depicts Great Smoky Mountain’s 

area of influence: 
Page 53 of 70 

Ohio’s contribution, as analyzed by MRPO, was found to be less than 2 percent; 

however, MRPO back trajectory analysis did determine Ohio was a contributor. 

Tennessee and North Carolina’s Regional Haze SIPs identifies Ohio’s percent 

contribution to SO2 emissions at 0.9 percent. More significant contributing states 

identified by North Carolina and Tennessee included: Tennessee (75 percent), Georgia 

(8 percent) and North Carolina (7 percent). North Carolina and Tennessee determined 

the VISTAS baseline modeling demonstrated that the 2018 base control scenario (onthe-books) provides for an improvement in visibility better than the uniform rate of 

progress for Great Smoky Mountains for the most impaired days over the first planning 

period and ensures no degradation in visibility for the least impaired days over the same 

period, as depicted in the glide path below: 
Page 54 of 70 

Ohio supports Tennessee and North Carolina’s determination of reasonable progress 

for this first planning period for Great Smoky Mountains and that on-the-book controls 

by Ohio constitutes Ohio’s fair share of emission reductions. 

Virginia – James River Face Wilderness Area and Shenandoah National Park

Virginia identified states that are expected to contribute to its Class I areas as those in 

an area of influence defined by 5 percent or greater sulfate extinction-weighted 

residence time. The following depicts Virginia’s Class I area’s area of influence: 
Page 55 of 70 

Ohio’s contribution, as analyzed by MRPO and identified under Section 10.6.8, was 

found to be 9 percent at James River and 8 percent at Shenandoah. Virginia’s Regional 

Haze SIP identifies Ohio’s percent contribution to SO2 emissions at 3.6 percent at 

James River and 4.6 percent at Shenandoah. More significant contributing states 

identified by Virginia for James River included: Virginia (62 percent), West Virginia (15 

percent) and North Carolina (9 percent). More significant contributing states identified 
Page 56 of 70 

by Virginia for Shenandoah included: Virginia (38 percent), Maryland (24 percent), and 

West Virginia (20 percent). 

Virginia’s Regional Haze SIP identified specific sources (units) in other states calculated 

to have at least a 1 percent calculated impact on James River Face and Shenandoah. 

No Ohio sources (units) were identified on the list. 

Virginia determined the VISTAS baseline modeling demonstrated that the 2018 base 

control scenario (on-the-books) provides for an improvement in visibility better than the 

uniform rate of progress for Virginia’s Class I areas for the most impaired days over the 

first planning period and ensures no degradation in visibility for the least impaired days 

over the same period, as depicted in the glide path below: 
Page 57 of 70 

Ohio supports Virginia’s determination of reasonable progress for this first planning 

period for these Class I areas and that on-the-book controls by Ohio constitutes Ohio’s 

fair share of emission reductions. 

West Virginia – Dolly Sods/Otter Creek Wilderness Area

West Virginia identified states that are expected to contribute to its Class I areas as 

those in an area of influence defined by 5 percent or greater sulfate extinction-weighted 

residence time. The following depicts Dolly Sods/Otter Creek Wilderness’ area of 

influence: 

Ohio’s contribution, as analyzed by MRPO and identified under Section 10.6.8, was 

found to be 13 percent. West Virginia’s Regional Haze SIP identifies Ohio’s percent 

contribution to SO2 emissions at 7 percent. More significant contributing states 

identified by West Virginia included: West Virginia (66 percent) and Maryland (12 

percent). 

West Virginia’s Regional Haze SIP identified specific sources (units) in other states 

calculated to have at least a 0.5 percent calculated impact on Dolly Sods/Otter Creek 

Wilderness Area. The following Ohio sources (units) were identified on the list: B006 at 

Muskingum River Power Plant (0.82 percent), and B003 and B004 at Gavin Power Plant 

(0.52 percent each). As mentioned above, unit B006 at Muskingum River is planning 

SO2 control to begin in 2015. Both units at the Gavin Power Plant installed and began 

operating SO2 control (i.e., scrubbers) in 1994 and 1995. 
Page 58 of 70 

West Virginia determined the VISTAS baseline modeling demonstrated that the 2018 

base control scenario (on-the-books) provides for an improvement in visibility better 

than the uniform rate of progress for Dolly Sods/Otter Creek Wilderness Area for the 

most impaired days over the first planning period and ensures no degradation in 

visibility for the least impaired days over the same period, as depicted in the glide path 

below: 

Ohio supports West Virginia’s determination of reasonable progress for this first 

planning period for Dolly Sods/Otter Creek Wilderness Area and that on-the-book 

controls by Ohio constitutes Ohio’s fair share of emission reductions. 

10.3 Technical Basis for Achieving Fair Share of Emissions Reductions

Ohio is required by 40 CFR 51.308(d)(3)(iii) to document the technical basis, including 

modeling, monitoring and emissions information, on which Ohio is relying to determine 

the apportionment of emissions reduction obligations for achieving reasonable progress 

in each Class I area it affects. Ohio relied on the TSD developed by MRPO and 

analyses by states, and their RPOs, affected by Ohio’s emissions to demonstrate that 

the Ohio’s emission reductions, when coordinated with those of other states/tribes, are 

sufficient to achieve reasonable progress goals in Class I areas affected by the states. 

The technical basis has been described throughout this document. 

An assessment of the five factors described at the beginning of Section 10 was 

performed for MRPO by the contractor EC/R Incorporated, “Reasonable Progress for 

Class I Areas in the Northern Midwest—Factor Analysis” (herein referred to as “Factor 

Analysis”) (Appendix F). While this analysis was targeted at Class I areas in the MRPO 

region, much of the information can be applied to other Class I areas. 
Page 59 of 70 

Specifically, EC/R examined reductions in SO2 and NOx emissions from EGUs and ICI 

boilers; NOx emissions from mobile sources and reciprocating engines and turbines; 

and ammonia emissions from agricultural operations. The impacts of “on-the-books” 

controls were also examined to provide a frame of reference for assessing the impacts 

of the additional control measures. 

The results of EC/R’s analysis of the five factors are summarized below: 

10.3.1 Factor 1 (Cost of Compliance) 

The average cost-effectiveness values are provided in Table 17 of the TSD. For 

comparison, cost-effectiveness estimates previously provided for “on-the-books” 

controls for EGUs and ICI boilers include (cost per ton removed basis): 

• CAIR - SO2: $700 - $1,200, NOx: $1,400 – $2,600 

• BART - SO2: $300 - $963, NOx: $248 - $1,770 

• MACT - SO2: $1,500, NOx: $7,600 

Additional EGU controls (0.15 lb/million-BTU SO2 and 0.10 lb/million-BTU NOx for 

EGU1 strategy and 0.10 lb/million BTU SO2 and 0.07 lb/million-BTU for NOx for EGU2 

strategy) would double the cost of CAIR and other cap-and-trade programs, on a cost 

per ton ($/ton) basis as indicated in Tables 4-2 and 6.5-3 of the Factor Analysis. For 

example, the proposed EGU strategies (EGU1 and EGU2) cost $1540 to $3,016/ton. 

These costs would be in addition to the $700 to $2,600/ton costs for CAIR and other 

cap-and-trade programs. Therefore, if the additional EGU strategies were added to the 

on-the-books controls, EGUs would incur a total cost of $2,260 to $5,616/ton. For ICI 

boilers, costs were slightly higher compared to EGU costs on a $/ton basis. However, 

ICI controls were slightly less expensive than controls for EGUs on a $/deciview basis, 

as indicated in Table 6.5-3 of the Factor Analysis. For reciprocating engines and 

turbines, the $/ton and $/deciview were less expensive than for EGUs. For agricultural 

sources (ammonia sources), the $/ton and $/deciview costs had a very wide range, 

partly due to uncertainty of the emissions and modeling of ammonia sources. However, 

the lower end of the range was much less than for EGUs, as indicated in Table 6.5-3 of 

the Factor Analysis. Finally costs for mobile sources vary widely, from potential savings 

to excessively expensive, as indicated in Table 6.5-3 of the Factor Analysis. 

10.3.2 Factor 2 (Time Necessary for Compliance) 

EC/R found that all of the control measures could be implemented by 2018. 
Page 60 of 70 

10.3.3 Factor 3 (Energy and Non-Air Quality Environmental Impacts) 

The energy and other environmental impacts are believed to be manageable. For 

example, the increased energy demand from add-on control equipment is less than 1 

percent of the total electricity and steam production in the region, and solid waste 

disposal and wastewater treatment costs are less than 5 percent of the total operating 

costs of the pollution control equipment. There would also be health and environmental 

benefits due to reduced acid deposition, nitrogen deposition, PM2.5 and ozone.

10.3.4 Factor 4 (Remaining Useful Life) 

The additional control measures are intended to be market-based strategies applied 

over a broad geographic region. It is not expected that the control requirements will be 

applied to units that will be retired prior to the amortization period for the control 

equipment. 

10.3.5 Factor 5 (Visibility Impacts) 

Modeling indicated that significant beyond-CAIR reductions from EGUs (EGU1 or 

EGU2), especially for SO2, would be the most effective control for improving visibility, 

as indicated in Table 6.5-2 of the Factor Analysis. Ohio has found that analysis by many 

other states arrived at a similar conclusion. For other sectors, the Factor Analysis shows 

very limited impact on improving visibility. Agricultural sources would be the next most 

effective control for visibility improvements. ICI boiler controls would have a small effect 

on visibility improvement. The last two source categories, reciprocating engines and 

turbines and mobile sources, show very minor improvements for visibility. 

10.4 Baseline Inventory 

Ohio is required by 40 CFR 51.308(d)(3)(iii) to identify the baseline inventory on which 

the long-term strategy is based. Ohio will use 2002 as the baseline inventory and 2005 

as the current inventory, as identified in Section 6. 

10.5 Anthropogenic Sources of Visibility Impairment 

Ohio is required by 40 CFR 51.308(d)(3)(iv) to identify all anthropogenic sources of 

visibility impairment considered by the state in developing its long-term strategy. Section 

6 contains a discussion of anthropogenic sources and includes references where details 

on the baseline and current emissions inventories can be found. Ohio also analyzed 

the 2002 NEI (Appendix C). 
Page 61 of 70 

10.6 Factors the State Must Consider 

Ohio is required by 40 CFR 51.308(d)(3)(v) to consider several factors in developing the 

long-term strategy. 

10.6.1 Emissions Reductions Due to Ongoing Air Pollution Programs 

Ohio is required by 40 CFR 51.308(d)(3)(v)(A) to consider emission reductions from 

ongoing pollution control programs. Ohio considered “on-the-books” controls, as 

identified at the beginning of Section 10, in developing its long-term strategy along with 

strategies identified in the Factor Analysis as discussed above. 

10.6.2 Measures to Mitigate the Impacts of Construction Activities 

Ohio is required by 40 CFR 51.308(d)(3)(v)(B) to consider measures to mitigate the 

impacts of construction activities. Based on baseline emission information supplied in 

Section 6, Ohio does not believe construction activities in Ohio are a significant 

contributor to visibility impairment in Class I areas. 

When USEPA first promulgated the Regional Haze Rule in 1999, emissions related to 

construction activities such as windblown dust and nonroad diesel engines were a major 

concern. This was especially a problem in rapidly growing metropolitan areas such as 

Los Angeles and Phoenix. Construction activities are directly related to population 

growth. Ohio has not experienced rapid growth and is not forecasted to in the future 

(http://www.odod.state.oh.us/Research/files/s101.pdf): 

• Ohio’s population grew 5.7 percent between 1990 and 2007. 

• The 2007 population for Ohio was 11,466,917. 

• Ohio’s population is projected to grow to 12,005,733 by 2020, a 4.5 percent 

increase over 2007. 

Construction projects in Ohio that disturb one acre or more are required to obtain a 

general permit under the National Pollutant Discharge Elimination System (NPDES). 

The permitting program was implemented to protect the waters of the state from 

sediment and other contaminants, and may also reduce the amount of particulate 

matter emissions from these activities. 

The NPDES permits require permitted entities to develop a storm water pollution 

prevention plan containing best management practices to control erosion and runoff. 

Many of the best management practices employed to prevent erosion and runoff are 

also effective at preventing windblown dust. For example, the use of wind fences, 

sprinkling, or using vegetative cover such as geotextiles can reduce the amount of 

airborne particles. 
Page 62 of 70 

Emissions from diesel engines in the construction industry are expected to decline with 

the implementation of new federal standards for both on-road and nonroad engines. 

Additionally, the use of ultra-low sulfur diesel fuel, which is now mandatory for on-road 

use and is scheduled for all nonroad use in 2010, will achieve reductions in the future. 

10.6.4 Emissions Limitations and Schedules of Compliance 

Ohio is required by 40 CFR 51.308(d)(3)(v)(C) to identify additional measures to meet 

reasonable progress goals when ongoing programs alone are not sufficient to meet the 

goals. 

Ohio believes that on-the-books controls provide sufficient measures to achieve 

reasonable progress goals, recognizing that there will be new additional reductions that 

will be occurring within and outside of Ohio in response to BART and other states’ 

programs. Ohio has also been implementing additional reductions to meet the 1997 

ozone NAAQs and expects to make additional reductions to meet the new 2008 ozone 

NAAQS, since many counties will likely be nonattainment for the new standard. These 

reductions, that are still to be determined, will likely reduce visibility impairment at other 

states’ Class I areas. 

10.6.5 Source Retirement and Replacement Schedules 

Ohio is required by 40 CFR 51.308(d)(3)(v)(D) to consider source retirement and 

replacement schedules in developing its long term strategy. Retirement and 

replacement will be managed in conformance with existing SIP requirements pertaining 

to New Source Review (NSR), both during Prevention of Significant Deterioration and 

nonattainment NSR permitting. 

10.6.6 Agricultural and Forestry Smoke Management Practices 

Ohio is required by 40 CFR 51.308(d)(3)(v)(E) to consider smoke management 

techniques for the purposes of agricultural and forestry management in developing 

reasonable progress goals. The major pollutant of concern in smoke from wildland fire 

is fine particulate matter, both PM10 and PM2.5. Based on baseline emission 

information supplied in Section 6, Ohio does not believe smoke activities in Ohio are a 

significant contributor to visibility impairment in Class I areas. 

In Ohio, emissions from prescribed fires are managed and regulated through 

interrelated laws and regulations. 

Chapter 1503.18 of the Ohio Revised Code (ORC) gives the Ohio Department of 

Natural Resources (ODNR) Division of Forestry the authority to ban outdoor burning 

statewide in unincorporated areas during the months of March, April, May, October, and 
Page 63 of 70 

November in any year, between 6 A.M. and 6 P.M. ORC 1503.18 (C) allows the Chief of 

the ODNR Division of Forestry to waive the ban expanding the times and places for 

kindling fires. The Division of Forestry’s policy waives the ban only for individuals that 

have been certified by the Division as a Certified Prescribed Fire Manager. 

Ohio Administrative Code (OAC) Chapter 3745-19 “Open Burning Standards”, regulates 

the types of materials that can be burned, locations where they can be burned and 

determines that no open burning shall be conducted in an area where an air alert, 

warning, or emergency is in effect. Furthermore, to open burn in many areas, advanced 

approval from Ohio EPA is required. Open burning is defined as the burning of any 

material wherein air contaminants resulting from combustion are emitted directly into the 

ambient air without passing through a stack or chimney. 

OAC Chapter 3745-19 allows specific open burning activities such as prescribed fires, 

for recognized horticultural, silvicultural, range, or wildfire management practices. An 

application for permission to open burn shall be submitted in writing to the Ohio EPA at 

least 10 working days before the fire is to be set. OAC Chapter 3745-19 determines 

that the application for permission to open burn must contain the following minimal 

information: 

• Purpose of the proposed burning; 

• Nature of quantities of material to be burned; 

• Date or dates when such burning will take place; 

• Location of the burning site, including a map showing distances to residences, 

populated areas, roadways, air fields, and other pertinent landmarks; and 

• Methods or actions which will be taken to reduce the emissions of air 

contaminants. 

Ohio is currently developing a Basic Smoke Management Program (SMP) based on 

USEPA’s Interim Air Quality Policy on Wildland and Prescribed Fires recommendations, 

and will certify in a letter to the USEPA Administrator that a basic program has been 

adopted and implemented in the future. 

The Ohio SMP will establish a basic framework of procedures and requirements for 

managing smoke from fires managed for resource benefits and will be developed by the 

Ohio EPA with the cooperation and participation of wildland owners and managers. The 

purposes of this SMP will be to mitigate the nuisance and public safety hazards (e.g., on 

roadways, at airports, etc.) posed by smoke intrusions into populated areas and to 

minimize impacts on air quality. 
Page 64 of 70 

The SMP will include a process for assessing and authorizing prescribed burns. The 

following describes the minimal requirements the Ohio Basic Smoke Management 

Program would consider, complementing Ohio’s existing open burning requirements: 

• Type of vegetation to be burned. 

• Acres to be burned. 

• Amount of fuel to be consumed (ton/acre). 

• Criteria for making burn/no burn decision. 

• Safety and contingency plans addressing smoke intrusions. 

• Evaluation of smoke dispersion. 

• Public notification. 

• Air quality monitoring. 

• Public education and awareness. 

• Surveillance and enforcement. 

10.6.7 Enforceability of Emissions Limitations and Control Measures 

Ohio is required by 40 CFR 51.308(d)(3)(v)(F) to ensure that emission limitations and 

control measures used as part of the long term strategy are enforceable. Ohio will 

ensure that all BART emission limitations and control measures used to meet 

reasonable progress goals and as a part of the long term strategy are enforceable by 

embodying these in rules, federally enforceable permit documents or orders of the 

director. 

10.6.8 Anticipated Net Effect on Visibility Resulting from Projected Changes 

to Emissions 

Ohio is required by 40 CFR 51.308(d)(3)(v)(G) to address the net effect on visibility 

resulting from changes projected in point, area and mobile source emissions by 2018. 

The emission inventory for Ohio projects changes to point, area and mobile source 

inventories by the end of the first implementation period resulting from population 

growth; industrial, energy and natural resources development; land management; and 

air pollution control. The 2002, 2005 and 2018 emissions inventories are contained, and 

discussed, in Section 4. 
Page 65 of 70 

In summary, Ohio’s Regional Haze SIP offers the conclusion, supported by MRPO’s 

technical analysis, that year 2064 attainment and intermediate rate-of-progress goals 

are projected to be achieved at all but a small number of the national parks and 

wilderness areas in the study area. However, when comparing the rate-of-progress 

glide path analysis performed by MRPO for both the 2002 (Base K) and 2005 (Base M) 

base years, the extent of the areas where the rate-of-progress glide path does not show 

adequate visibility improvement varies as follows: 

• Based upon the 2005 base year: Northern Michigan, New Jersey, Maine, and 

Missouri. 

• Based upon the 2002 base year: Northern Minnesota22 and Northern Michigan. 

The difference in the two modeling analysis is due primarily to differences in future year 

emission projections, especially for EGUs which are based upon USEPA’s results using 

IPM2.1.9 for 2002 and IPM3.0 for 2005. For Ohio’s Regional Haze SIP, more weight is 

given to the 2005 base year; however, the results of the 2002 base year analysis should 

also be weighed. 

Recall, as discussed in Section 10.2.2, more recent modeling by MANE-VU states 

indicates “the uniform rate is achieved and exceeded at all MANE-VU Class I sites." 

Again, Ohio has committed to continue to work with states regarding the MANE-VU Ask. 

The following, based upon MRPO modeling, depicts the glide paths for several Class I 

areas in the Eastern U.S.: 

 Voyageurs Boundary Waters Isle Royale 

 

22 Ohio was not found to be a contributing State to visibility in Minnesota’s Class I areas. 
Page 66 of 70 

 Seney Mammoth Cave Upper Buffalo 

 

 Mingo Shenandoah Dolly Sods 

 Brigantine Lye Brook Acadia 
Page 67 of 70 

The following tables, based upon MRPO modeling, provide a summary of measured 

baseline and modeled future year deciview values for several Eastern U.S. Class I 

areas: 

*URP - uniform rate of progress, OTB - on-the-books controls, OTB+Will Do - on-the-books 

controls plus adjustments for controls from states commitments 

Visibility Modeling (2005 Base M) Results (Deciview) (Worst 20%) 

Site 2000-2004 

Baseline 

2018 

URP 

2009 

OTB 

2012 

OTB 

2018 

OTB 

2018 

OTB+Will Do 

Boundary Waters 19.86 17.94 18.45 18.33 17.94 17.92 

Voyageurs 19.48 17.75 18.2 18.07 17.63 17.66 

Seney 24.38 21.64 23.1 23.04 22.59 22.42 

Isle Royale 1 21.59 19.43 20.52 20.43 20.09 20.13 

Isle Royale 9 21.59 19.43 20.33 20.22 19.84 19.82 

Hercules-Glades 26.75 23.13 24.72 24.69 24.22 24.17 

Mingo 28.15 24.27 25.88 25.68 24.74 24.83 

Caney Creek 26.36 22.91 23.39 23.29 22.44 22.4 

Upper Buffalo 26.27 22.82 23.34 23.27 22.59 22.55 

Mammoth Cave 31.37 26.64 27.11 27.01 26.1 26.15 

Dolly Sods 29.05 24.69 24 23.9 23 23.04 

Shenandoah 29.31 25.12 24.99 24.87 23.92 23.95 

James River Face 29.12 24.91 25.17 25.01 24.06 24.12 

Brigantine 29.01 25.05 25.79 25.72 25.21 25.22 

Lye Brook 24.45 21.48 22.04 21.86 21.14 21.14 

Acadia 22.89 20.45 21.72 21.72 21.49 21.49 

Visibility Modeling Results (2005 Base M) (Deciview) (Best 20%) 

Site 2000-2004 

Baseline 

2018 

URP 

2009 

OTB 

2012 

OTB 

2018 

OTB 

2018 

OTB+Will Do 

Boundary Waters 6.42 6.42 6.21 6.19 6.14 6.12 

Voyageurs 7.09 7.09 6.86 6.83 6.75 6.76 

Seney 7.14 7.14 7.57 7.58 7.71 7.78 

Isle Royale 1 6.75 6.75 6.62 6.59 6.6 6.62 

Isle Royale 9 6.75 6.75 6.56 6.55 6.52 6.5 

Hercules-Glades 12.84 12.84 12.51 12.32 11.66 11.64 

Mingo 14.46 14.46 14.07 13.89 13.28 13.29 

Caney Creek 11.24 11.24 10.88 10.85 10.52 10.52 

Upper Buffalo 11.71 11.71 11.13 11.08 10.73 10.74 

Mammoth Cave 16.51 16.51 15.76 15.69 15.25 15.25 

Dolly Sods 12.28 12.28 11.25 11.23 11 11.01 

Shenandoah 10.93 10.93 10.13 10.11 9.91 9.91 

James River Face 14.21 14.21 13.38 13.38 13.14 13.14 

Brigantine 14.33 14.33 14.15 14.08 13.92 13.92 

Lye Brook 6.37 6.37 6.25 6.23 6.14 6.15 

Acadia 8.78 8.78 8.86 8.86 8.82 8.82 
Page 68 of 70 

Visibility Modeling (2002 Base K) Results (Deciview) (Worst 20%) 

Site 2000-2004 

Baseline 

2018 

URP 

2009 

OTB 

2012 

OTB 

2018 

OTB 

Boundary Waters 19.86 17.70 19.05 19.01 18.94 

Voyageurs 19.48 17.56 19.14 19.19 19.18 

Seney 24.38 21.35 22.98 22.71 22.38 

Isle Royale 1 21.59 19.21 20.46 20.28 20.04 

Hercules-Glades 26.75 22.76 24.73 24.34 23.85 

Mingo 28.15 24.08 25.18 24.67 24.01 

Caney Creek 26.36 22.55 24.01 23.55 22.99 

Upper Buffalo 26.27 22.47 24.02 23.58 23.06 

Mammoth Cave 31.37 26.14 28.06 27.03 25.52 

Dolly Sods 29.04 24.23 24.86 23.59 22.42 

Shenandoah 29.31 24.67 24.06 22.79 21.57 

James River Face 29.12 24.48 24.81 23.79 22.42 

Brigantine 29.01 24.68 25.87 25.25 24.39 

Lye Brook 24.45 21.16 21.80 21.32 20.69 

Visibility Modeling Results (2002 Base K) (Deciview) (Best 20%) 

Site 2000-2004 

Baseline 

2018 

URP 

2009 

OTB 

2012 

OTB 

2018 

OTB 

Boundary Waters 6.42 6.42 6.71 6.73 6.87 

Voyageurs 7.09 7.09 7.21 7.25 7.34 

Seney 7.14 7.14 7.19 7.19 7.23 

Isle Royale 1 6.75 6.75 6.57 6.51 6.47 

Hercules-Glades 12.84 12.84 12.61 12.62 12.61 

Mingo 14.46 14.46 13.96 13.93 13.94 

Caney Creek 11.24 11.24 10.91 10.92 10.90 

Upper Buffalo 11.71 11.71 11.47 11.46 11.42 

Mammoth Cave 16.51 16.51 16.06 15.91 15.54 

Dolly Sods 12.28 12.28 11.72 11.45 11.19 

Shenandoah 10.93 10.93 9.73 9.53 9.17 

James River Face 14.21 14.21 13.56 13.33 12.97 

Brigantine 14.33 14.33 13.74 13.69 13.47 

Lye Brook 6.36 6.36 6.12 6.05 5.96 

MRPO’s documentation includes culpability studies showing that Ohio’s contribution is 

small. Source apportionment conducted by the MRPO indicates that Ohio's contribution 

(in 2018) in these Eastern Class I areas is generally less than 5 – 10 percent and all 

show a decline from 2005 contribution levels (see table below). The locations most 

highly impacted by Ohio sources, such as Dolly Sods in West Virginia, Mammoth Cave 

in Kentucky, and Shenandoah Valley and James River in Virginia, show satisfactory 

progress as discussed and agreed upon in Section 10.2. Substantial SO2 and NOx 
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emission reductions are expected in Ohio pursuant to existing and new control 

programs. These emission reductions will decrease Ohio's contribution to visibility 

impairment on the 20 percent worst visibility days in these Eastern Class I areas. 

11. Consultation 

Ohio does not contain any Class I areas. Ohio, through MRPO, has consulted with the 

other states/tribes of which Ohio may reasonably be anticipated to cause or contribute 

to visibility impairment in a Class I area. Ohio is involved with monthly consultation calls 

with MRPO states, several other CENRAP states, tribes, FLMs, the Ontario Ministry of 

Environment, and Region 5 EPA. Minutes from these calls can be found on the MRPO 

website: http://www.ladco.org/reports/rpo/consultation/index.php 

12. Inventory Updates, Plan Revisions and Progress Reports 

Ohio is required by 40 CFR 51.308(f) to revise its 

Regional Haze SIP and submit a revised SIP to USEPA by July 31, 2018, and every ten 

years thereafter. In accordance with the requirements listed in 40 CFR 51.308(f), Ohio 

commits to revising and submitting this Regional Haze SIP by July 31, 2018 and every 

ten years thereafter. 
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Ohio is required by 40 CFR 51.308(d)(4)(v) to include a commitment to update the 

inventory periodically. In Ohio, major point sources in all counties are required to 

submit air emissions information annually, in accordance with USEPA’s Consolidated 

Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic inventory for all 

sectors every three (3) years. These inventories will be prepared for future years as 

necessary to comply with the inventory reporting requirements established in the CFR. 

Emissions information will be compared to the 2002 base year and the future projected 

year inventories to assess emission trends. 

In addition, 40 CFR 51.308(g) requires periodic reports evaluating progress towards the 

reasonable progress goals established for each mandatory Class I area. In accordance 

with the requirements listed in 40 CFR 51.308(g), Ohio commits to submitting a report 

on reasonable progress to USEPA every five years following the initial submittal of the 

SIP. The report will be in the form of a SIP revision. The reasonable progress report will 

evaluate the progress made towards the reasonable progress goal for each mandatory 

Class I area located outside Ohio, which may be affected by emissions from within 

Ohio. All requirements listed in 40 CFR 51.308(g) shall be addressed in the SIP revision 

for reasonable progress. 

13. Adequacy 

Depending on the findings of the five-year progress report, Ohio commits to taking one 

of the actions listed in 40 CFR 51.308(h). The findings of the five-year progress report 

will determine which action is appropriate and necessary. 

List of Possible Actions – 40 CFR 51.308(h) 

1) Ohio would determine that the existing SIP required no further substantive 

revision in order to achieve established goals. Ohio would provide to the 

Administrator a declaration that further revision of the SIP will not be needed at 

that time. 

2) Ohio would determine that the existing SIP may be inadequate to ensure 

reasonable progress due to emissions from other states which participated in the 

regional planning process. Ohio would provide notification to the Administrator 

and the states that participated in regional planning. Ohio would collaborate with 

states through the regional planning process to address the SIP’s deficiencies. 

3) Ohio would determine that the existing SIP may be inadequate to ensure 

reasonable progress due to emissions from another country. Ohio would provide 

notification, along with available information, to the Administrator. 

4) Ohio would determine that the existing SIP is inadequate to ensure reasonable 

progress due to emissions within Ohio. Ohio would revise its SIP to address the 

plan’s deficiencies within one year thereafter.