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 1 6443020 61416443184 (fax) www.epa.ohio.govRevised 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 ex press its appreciation for the effort, expertise, and directi on provided by the staff of t he Midwest Regional Planning Organization (MRPO). The assistance they have given in terms of development of modeling protocols, processing of meteor ological data, and overall technical guidance has been invaluable and essential to the successful completion of this project.Table of Contents

1. Backgroun d .............................................................................................................. 1
1.1 States and Tribes Class I Ar eas ......................................................................... 2

2. Regional Pl anning .................................................................................................... 3

3. State and Federal Land M anager Coordi nation ........................................................ 4

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

5. Monitoring St rategy .................................................................................................. 6

6. Emissions In ventory ................................................................................................ 7 6.1 Nonpoint Sources ............................................................................................. 10 6.2 Construction Ac tivities ...................................................................................... 13 6.3 Fires ................................................................................................................. 14

7. Modeling Asse ssment ............................................................................................ 16

8. BART Analysis ........................................................................................................ 18 8.1 BART Eligible Sources in Ohio ......................................................................... 18 8.2 Determination of Source s Subject to BART ..................................................... 19 8.2.1 Individual Source Attribution Ap proach (Dispersi on Modelin g) ................. 19 8.2.2 Use of Model Plants ................................................................................. 20 8.2.3 Cumulative Modelin g ................................................................................ 20 8.2.4 EGUs ........................................................................................................ 22 8.2.5 Detailed Analysis of Potent ial BART-Subjec t Source s ............................. 23 8.3 Determination of BART Requirements for Subject-to-B ART Sources .............. 24 8.4 Projected Emissions Reductions Resulting fr om Installation of BART Controls . ......................................................................................................................... 26 8.5 Enforceability of BAR T Requirem ents .............................................................. 26 8.6 Monitoring, Recordkeeping, and R eporting of BART Re quirements ................ 26

9. Areas of Influence ................................................................................................... 27 9.1 MRPO Back Trajecto ry Anal yses ..................................................................... 29 9.2 MRPO Powertrain System Anal ysis Toolkit (PSAT ) Modeling ......................... 29 9.3 MANE-VU Contributio n Assessm ent ................................................................ 29 9.4 Missouri-Arkansas Cont ribution Asse ssment ................................................... 30 9.5 VISTAS Area of Infl uence Analys is .................................................................. 30

10. Long-Term Strategy and R easonable Pr ogress ..................................................... 30 10.1 Consultati on .................................................................................................. 34 10.2 Share of Emissions Reducti ons .................................................................... 34 10.2.1 MRPO ........................................................................................................ 35 10.2.2 MANE-VU ................................................................................................. 3510.2.3 Missouri-Arkansas (CENR AP) ................................................................... 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 Complianc e) .................................................................. 59 10.3.2 Factor 2 (Time Necessa ry for Comp liance) .............................................. 59 10.3.3 Factor 3 (Energy and Non-Air Q uality Environmental Impacts) ................ 60 10.3.4 Factor 4 (Remaini ng Useful Life) .............................................................. 60 10.3.5 Factor 5 (Visibility Impacts) ....................................................................... 60 10.4 Baseline Inv entory ........................................................................................ 60 10.5 Anthropogenic Sources of Vi sibility Im pairment ............................................ 60 10.6 Factors the State Must Cons ider................................................................... 61 10.6.1 Emissions Reductions Due to On going Air Pollution Programs ................ 61 10.6.2 Measures to Mitigate the Impacts of Construction Activities ..................... 61 10.6.4 Emissions Limitations and Sc hedules of Co mpliance ............................... 62 10.6.5 Source Retirement and Replacement Schedules ..................................... 62 10.6.6 Agricultural and Forestry Smoke Management Practice s ......................... 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 Progre ss Reports ..................................... 69

13. Adequac y ............................................................................................................... 70Appendices

A. Preliminary Draft Comment s from Federal Land Managers.

B. Regional Air Quality Analyses for Oz one, 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 BAR T-Eligible Sources on the Regional Scale Technical Support Document.

E. MANE-VU consultation su mmary, 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 USE PA to reduce emissions from EGUs, ICI boilers, mobile sources and area sources, September 2, 2009.

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

G. Public notice, public hearing docum ents, 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 comm ent 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 wilder ness areas to the “pristine” condition of atmospheric clarity that would prev ail in the absence of hum an impacts. In 1999 the U.S Environmental Protection Agency (USEPA) issu ed 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 futu re, 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 address ed 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 74 92) was incorporated. This section provided for further resear ch and regular assessments of the progress made to date. In 1993, the Na tional 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, Wash ington, DC: 1993) . In addition to authorizing creation of vi sibility 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 submi tted its report to USEPA in June 1996. The Commission report, as well as the m any 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 we nt into effect on August 30, 1999. The Regional Haze Rule aims at achieving national visibility goals by 2064. This rulemaking addressed the combined visi bility effects of various pollution sources over a wide geographic region. This wide-r eaching effort means that many states, including those without Class I areas, must par ticipate 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, Mi chigan, 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 Amer ican Corn Growers Association. The Court remanded to the USEPA the “Best Available Retrofit Technology,” or “BART,” provis ions 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 Appeal s, DC Circuit Court issued a ruling based on a second suit brought by the Center for Energy and Ec onomic Development (CEED) challenging an optional emissions trading program (the WRAP A nnex 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 st ate implementation plan (SIP) and subsequent revisions to that first SIP, recognizing achieving natura l 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 fo r 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 toward s 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, wi th 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 nonatta inment 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 addres ses the first planning period (i.e., reasonable progress by the year 2018) and is submitted pursuan t to 40 CFR 51.308(a) and (b). This SIP fulfills the requirements of:

• 40 CFR 51.308(d) which includes esta blishing reasonable progress goals, determining baseline condition s, 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 es tablishing BART requirements.

1.1 States and Tribes Class I Areas

Ohio does not contain any Class I areas subjec t 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 affect ed by emissions from within the state. Class I areas which may be affected by emissi ons 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 cons ultation 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 emissi ons from Ohio (see Section 9).Page 3 of 70 2. Regional Planning

Since the atmospheric cont aminants degrading the atmos phere 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 r egional planning organi zations (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 (MR PO). Tribal leaders from Michigan and Wisconsin, USEPA Region V, and F ederal Land Managers (F LMs) 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 stakehol ders, was issued in March 2001.

Since the emissions of the MR PO 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 resu lts, and other technical support documents prepared by the MRPO for its members. The MRPO has established an active committee structure to address both technica l and nontechnical issues related to regional haze. The Policy Steering Committ ee provides policy direction for regional planning. The Technical Steering Committee m anages the technical portion of regional planning. The Project Team carries out the orders of t he 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 Illinoi s, Indiana, Michigan, and Wisconsin. Ohio later joined as the fifth state member. LADCO provides supportive activities for the thr ee teams/committees.

MRPO works cooperatively with the RPOs r epresenting other parts of the country. The other RPOs are Mid-Atlantic / Northeast Vi sibility Union (MANE-VU), Central Regional Air Planning Association (CENRAP), VISTAS, and Western Region al Air Partnership (WRAP). The following is a map of t he regional planning organization boundaries:Page 4 of 70 The RPOs sponsored several joint proj ects 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 reas onable 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 t heir assessments of visibility conditions, analyses of visibility impacts, and possible meas ures that could be taken for reasonable progress for the first planning period (20 18). Section 9 and 10 of this document provides more detailed information regardi ng Ohio’s long-term strategy to address visibility impacts and obtain Ohio’s fair shar e of emissions reductions. Summaries of the calls and meetings held wi th states and RPOs with Cla ss 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 hasPage 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 CF R 51.308(i)(2).

Ohio provides FLMs an opportunity for consulta tion, in person and at least 60 days prior to holding a public hearing on this plan submi ttal. During the consultation process, the FLMs are given the opportuni ty to address their:

• Assessment of the impai rment of visibility in any Class I areas;

• Recommendations on the development of reasonable progress goals; and

• Recommendations on the devel opment and implementation of strategies to address visibility impairment.

Ohio sent the draft plan to the FLMs on S eptember 9, 2008. On October 16, 2008, Ohio received preliminary draft comments back fr om the FLMs (Appendi x A) and addressed those comments in this final document. Ohio provided the revise d 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 t he 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 Be st Available Retrofit Technolog y (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 (A ppendix H). The final federally enforceable BART per mit was issued on March 7, 2011 after comments into consideration (A ppendix H).

Ohio will continue to coordinate and consul t with the FLMs duri ng 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 wit h the FLMs during new source review (NSR) of sources that may impact Class I areas.

4. Baseline, Current and Es timated Natural Conditions

The goal of the Regional Haze Rule is to re store natural visibility conditions to the 156 Class I areas identified in the 1977 Clean Air Act Am endments. Section 51.301(q) defines natural conditions: “Natural cond itions include natura lly occurring phenomena that reduce visibility as measur ed in terms of light extinction 1 , 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. Fi rst, states are to compare bas eline visibility conditions in the years 2000 to 2004 (in deciview 2 ) for the most impaired days 3 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 "glide path." The glidepath is a straight line drawn from the baseline level of vi sibility 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. Stat es identify the amount of progress needed during the first planning period consistent with the uniform ra te of progress (third step). And lastly, fourth, states identify and analyze the emi ssions 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 per formed 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 R egional Haze: Final Technical Support Document, April 25, 2008” (herein referr ed 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 meas uring, 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 determi ning the contribution of emissions from within Ohio to visibility impairment at Class I areas in other states.

The monitoring strategy relies in part upon parti cipation in the Interagency Monitoring of Protected Visual Environment s (IMPROVE) network. The IM PROVE 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 devel opment. 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 wh ich is equivalent to the 20 percent best visibility days.Page 7 of 70 For regional haze, monitoring data we re analyzed to produce a conceptual understanding of the air qualit y 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 reas onably anticipated to cause or contribute to visibility impairment in any mandatory Cl ass I area(s). Emissions data are derived from MRPO and the National Emissions In ventory (NEI) (Appendix C).

Emissions 4

The following is Ohio’s baseline year, 2002, inventory 5 :

Data sources: All data: 2002 Nati onal 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 non point 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 v ehicle emission modelin g software, and the Integrated Planning Model (IP M) version 3.0 for electric generating units (EGUs). Additional details are prov ided 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 60,752 133,842 441,584Page 9 of 70 The following table represent s the percent changes in the inventory based on the emissions in the previous tables. Discussi ons of the projected changes for different source categories follows.

Percent Changes in Ohio Emissions, by S ource 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 -71.3NonEGU 2.0 24.4 135.8 0.7 -36.3 18.7 -55.8 21.0 -51.3 35.4 20.2 1.3NonRoad -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 -46.8OnRoad -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 sour ce 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 y ear. 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 la rgest source of NOx emissions in 2005 was from mo bile 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 sh ow 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 great er detail in Section 10. Emissions of NOx and SO2, considering CAIR, are ex pected to decline betwe en 2002 and 2018 byPage 10 of 70 about 63 percent and 62 percen t, 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 fr om 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 exce ption of NH3, PM10 and PM2. 5 which are projected to increase slightly.

2002 Total Emissions (TPY) of Pollutants C ontributing 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 identifi ed in the bar chart above and discussed below.

PM10 accounts for the largest nonpoint source ca tegory, and can be attributed primarily to agriculture tillage, unpaved and paved r oad dust, and industrial road construction activities. The following tables provide the re lative 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 Till age 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 (Industria l Processes) 17,882 3.87%

VOC emissions are the second largest source of Ohio’s n onpoint emissions. A large portion of these emissions result from indus trial and consumer product utilization (nearly 25 percent). Ohio promulgated a consumer products rule on September 15, 2007. Effective January 1, 2009, consumer products t hat are sold in the State of Ohio will have to meet stringent VOC content limitations 6 . 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 rule 7 and Portable Fuel Container rule 8 , both of which were recently promulgated.

Top VOC Emissions from Ohio Nonpoint Sources During 2002

Source classification tons/yr % of Nonpoint VOC
Miscellaneous Non-indus trial: Consumer Solvent Utilization 41,688 14.50%

Miscellaneous Industrial Solv ent 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 agricul ture production activities: crops, cattle, swine, and poultry production mainly. Howeve r, Ohio EPA’s Division of Air Pollution Control has a very limited authority under the Ohio Re vised 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/porta ls/27/regs/3745-21/21_17.pdfPage 12 of 70 Top NH3 Emissions from Ohio Nonpoint Sources During 2002

Source classification tons/yr % of Nonpoint NH3 Urea from Fertilizer A pplication 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 perc ent of the PM2.5 emissions for nonpoint sources in Ohio. Paved and unpaved roadwa ys contribute a combined 21.6 percent. These sources are also significant contri butors 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 Re sidential 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 emissi ons 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 Bo ilers and IC Engines Combustion 7,547 18.16% Commercial and Institutional Natural Gas Boilers and IC Engine s 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 Engine s Combustion 1,682 8.43% Residential Bituminous/ Subbituminous Coal Combustion 1,263 6.33%

The Regional Haze SIP requirements include assessing the contributi on of construction activities and fire s from Ohio.

6.2 Construction Activities

The following table identifies emissions from the 2002 NEI attributed to construction activities. Additional info rmation on construction activities is discussed under Section 10.

Emissions from Ohio Nonpoint Constr uction 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 identifie s emissions from the 2002 NEI contributed from fire activities. In Ohio, open burning represents t he majority of emissions from fire/burning activities. Wildfires and prescribed burning are not significant emission sources for Ohio. Fires are not a significant contribut ion to emissions in Ohio. Ohio EPA’s regulations for open and prescribed bur ning 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 prescri bed 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 prescri bed 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 guideli nes for conducting regionalscale visibility modeling. USEPA provides recommendations on appropriate models and MRPO chose the Comprehensive Air Qua lity Model with extensions (CAMx) with emissions and meteorology generated using EMS (a nd CONCEPT) and MM5, respectively. The selection of CAMx as the primary model is based on several factors: performance, operator consid erations (e.g., ease of application and resource requirements), technical support and document ation, model extensions (e.g., 2-way nested grids, process analysis, source apportionment, and plume-ingrid), and model science. This is the same m odel used for ozone and PM2.5 SIPs.Page 17 of 70 The air quality analysis conducted by MR PO includes weight-of- evidence approaches which rely on extensive qualit ative and quantitativ e data analysis and modeling. Given uncertainties in emissions inventories and modeling, these data analyses are a necessary part of the overall technical sup port. The analyses are as follows: emissions analyses, meteorological analyses, time seri es (hour of day/day of week/seasonal) patterns, trajectory analyses, source apporti onment, 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 acco rdance with USEPA’s modeling guidelines 9 . The modeling covers each full calendar year (2 002 and 2005) for an ea stern U.S. 36 km domain. Emission inventories were prepar ed 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 proj ect 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 inventor ies. Further details of the emission inventories are provided in two summary reports 10 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 s ources, emissions were estimated by models. For the other sector s (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 EG Us were predicted based on USEPA’s IPM (version 2.1.9 for 2002 and version 3.0 for 2005).

Section 10 and the TSD (Appendi x B) identify the “on-the-books” controls used to prepare the future year projections.

For regional haze, the ca lculation of future y ear conditions assumed:

• baseline concentrations based on 2000- 2004 IMPROVE data , with updated (substituted) data for Mingo, Boundary Wa ters, 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-45 4/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/repo rts/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 natura l 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 visibilit y days) based on a st raight 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 modelin g results and a summary of measured baseline and modeled future year dec iview values for these Class I areas are discussed in Section 10.6.8.

The haze results show that several Class I ar eas in the eastern U.S. are expected to be greater than (less improved than) the uniform ra te of visibility impr ovement 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. ar e 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 informa tion on the other four factors, in setting reasonable progress goals.

Full details of the modeling pr otocol and performance can be found in Section 3 of the TSD (Appendix B).

8. BART Analysis

USEPA’s 1999 Regional Haze Rule requires Oh io to have additional controls for certain sources that contribute to visibility impairment in Class I areas (Best Available Retrofit Technology (BART)) or implem ent an emissions trading or other alternative program that will achieve greater reasonable progre ss than would be achieved through the installation and operation of BAR T. 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,” (hereafte r referred to as “BART Guidelines”).

8.1 BART Eligible Sources in Ohio

A preliminary list of Ohio BA RT-eligible sources were i dentified using the methodology in the BART Guidelines. For an emission source to be identif ied as BART eligible, Ohio used these criteria from the BART Guidelines:Page 19 of 70 • One or more emissions units at the fa cility 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 y ear of any of these visibility-impairing pollutants: SO2, NOx, or PM.

To identify the prelimi nary list of sources that meet th e criteria above, Ohio performed the following activities:

• Reviewed the Ohio EPA/Division of Air Pollution Control (OEPA/DAPC) emissions inventory files, to identify c andidate 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 a ffected non-EGU facilities identified in the review of the inventor y files. A sample questionna ire is provided as Appendix B of the attached BART Technical Suppor t 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 a ll sources, or (b) consider exempting some sources from BART because they do not cause or contribute to visibi lity 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 det ermining that certain sources need not be subject to BART:

• Individual source attributi on approach (dispersion modeling).

• Use of model plants to exempt so urces with common characteristics.

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

8.2.1 Individual Source Attributi on Approach (Dispersion Modeling)

Under this option, CALPUFF (or other appropr iate 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 (“SinglePage 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-eligib le non-EGU sources in the 5-state region. CALPUFF modeling for all these sources was not considered necessary. This is because previous CA LPUFF modeling (conducted in response to USEPA’s proposed BART rule) i ndicated that only sources with a Q/D value > 10 – 20 had more than a 0.5 deciview visibility im pact in a nearby Class I area (MRPO’s “Determining Which BART-Eligible Sources ar e 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 repres entative plume characteristi cs 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 est ablishes 0.5 deciview as a cont ribution 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 co nsistent 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 co llectively do not cause or contribute to visibility impairment in a Class I area. Th is approach was used to assess the likelihood that VOC and PM emissions wil l not cause or contribute to visibility impairment. Specifically, CAMx was run with all point source VOC and PM em issions eliminated (“zeroed-out”) to assess the contri bution of these species to visibility impairment. The model results shown below demonstrate t hat these emissions do not contribute to visibility impairment (i.e., less than a 0.5 dec iview impact in any Class I area). Because the VOC and PM emissions fr om 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 subjec t 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 t hese 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, give n 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 dec ision that CAIR would suffi ce for their control, as discussed below. The following 18 generating st ations include an aggregate of 37 BART-eligible units (from A ppendix 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 51.30 8(e)(2). This provision provi des 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 pr ovisions of the CAIR under 40 CFR Part 96 AAA-EEE do est ablish such a program in relation to emissions of NOx a nd SO2 from EGUs, and this det ermination that CAIR is an acceptable alternative to BART for EGUs ha s been codified in 40 CFR 51.308(e)(4). The CAIR program and implicat ions 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, demons trates that these emissions do notPage 23 of 70 contribute to visibility impairment (i.e., le ss 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 i dentified as needing a detaile d analysis using the CALPUFF computer model. This includes one facilit y (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 facilit ies. Appendix D of the BART TSD co ntains 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 impa irment and, therefore, are subject to BART. The CALPUFF modeling protocol used to det ermine which BART-eligible facilities are subject to BART (developed by MRPO) is in cluded as Appendix F -m in the BART TSD. The procedure involves modeling visibility im pacts 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. CarolinaPage 24 of 70 Lye Brook Wilderness Vermont Mammoth Cave National Park Kentucky Mingo Wilderness Area Missouri Seney Wilderness Area Michigan Shenandoah National Pa rk Virginia Sipsey Wilderness Alabama Voyageurs National Park Minnesota

A source is considered subject-to-BART i f, for any of the years 2002, 2003, and 2004, it causes eight or more days of visibility degr adation exceeding 0.5 dec iview at any one of the above-listed Class I areas. The pollutants modeled are SO2, NO x, primary PM2.5, HNO 3 , and SO 4 . Generally no data were available for the latter two pollutants.

The operation of the model was consist ent with MRPO’s protocol document and employed run scripts and postprocessor routi nes 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 restrict ed 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 inve ntory) to arrive at the pounds per hour to be used for modeling. This approach was judged to be sa tisfactory for facilities with impacts well below the eight days/year exceedance leve l, but inadequate for the one source, P. H. Glatfelter Company (“Glatfelter”) , with larger impacts. For Gla tfelter, three years of daily emission data were reviewed, to identify t he 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 allowabl es 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 belo w. Accordingly, this study finds that Glatfelter’s two large coal-f ired boilers are the only non-EGU “subject-toBART” sources in Ohio. Glatfelter has wo rked cooperatively with Ohio EPA to identify potential emission controls and anal yze all the site-specific fa ctors that are required as part of a BART determination. The BART dete rmination for Glatfelter is summarized in the BART TSD, and the full document is c ontained 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 Requirem ents for Subject-to-BART Sources

The one non-EGU subject-to-BART facility in Oh io, Glatfelter in Chillicothe, hired the BE & K Engineering consulting firm to perform a BART analysis according to applicablePage 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 c ontinuous emissions co ntrol available and reductions achievable, and the following fact ors must be considered in making the source-specific BART determination:

• Technology available;

• Costs of compliance;

• Energy and non-air quality environm ental impacts of compliance;

• Existing pollution control technology in use at the source;

• Remaining useful lif e 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 f easibility and negligible visibility impacts as demonstrated by CALPUFF model ing, NOx and primary parti culate 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 te chnologies 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 Carl o financial analysis including cost of construction, and operating costs such as those of electric ity, reagents and waste disposal. Taking this analysis into consideration in conjunction with the CALPU FF modeling results, Ohio determined that a process c apable of 90 percent SO2 removal was approp riate. Upon further discussions with Glatfelter it was decided that Glatfelter would implement an alternative program to BART as allowed un der 40 CFR 51.308(e)(2). An alternative BART measure must achieve greater reasonable progre ss than would be achieved through the installation and oper ation of BART. If the alternative measure results in greater emission reductions, t hen 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 alternativ e approach that will achieve greater emission reductions than the 90 percent SO2 removal projected under traditional BART. This approach includes installing contro l technology sufficient toPage 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 Result ing from Installation of BART Controls

The application of alternative BART to th e subject-to-BART source, Glatfelter, will provide an estimated reducti on 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 alternativ e 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 in to a federally enforceable permit with a compliance date of December 31, 2014 12 . (Appendix H 13 )

Under the alternative, control may incl ude an add-on control device, use of an alternative fuel, use of low sulf ur fuel, or a combination of these measures. In addition, Glatfelter may choose to shut down the boile r(s). By no later than December 31, 2013, Glatfelter shall submit to Ohio EPA an app lication 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 appropri ate monitoring, recordkeeping, and reporting requirements, shall be incorporated into the federally enforceab le permit by no later than December 31, 2014. A continuous emission m onitoring system (CEMS) will al so be installed prior to December 31, 2014 to measure and re cord the daily SO2 emissions. The requirements will be incorporated into the facility’s Titl e V operating permit according to Title V revision procedures.

8.6 Monitoring, Recordkeeping, and Reporting of BART Requirements

Monitoring, recordkeeping, and reporting re quirements 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 in corporating all necessary requirements into the federally enforceable permit to ensure compliance with BART.

12 All necessary emission reductions must take place du ring the period of the first long-term strategy (40 CFR 51.308(e)(2)(iii)).

13 This permit contains all requirements, includ ing those unrelated to BART, for these two boilers. Incorporating this permit as an appendix to this SI P is not a request to incorporate all of the permit requirements into Ohio’s SIP. Rather, Ohio EPA re cognizes 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 require d by 40 CFR 51.308(d) to address regional haze in each mandatory Class I federal area located within the st ate and in each mandatory Class I federal area located outside the state which may be affected by emissions from within the stat e. Although there are no Class I areas located within Ohio, the state is still required to address region al haze by determining any Class I area(s) that may be impacted by emissi ons from sources within Ohio.

Technical analyses conducted by the RPOs were consulted to obtain information on Ohio’s areas of influence and culpabilit y for Class I areas in the eastern U.S. 14 A summary of Class I areas determined to be impac ted by Ohio is provided in the table below. An explanation of the assessments us ed 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 su lfates and nitrates in western Class I areas (Cite: “Attribution of Haze Phase I Report, Geographic Attr ibution 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 lik ely 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 Ye s: (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) MR PO PSAT Modeling, (3) MANE-VU Contribution Assessment, (4) Missouri-Arkansas Contributi on 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 exti nction. This criterion was selected based on a review of the back traj ectory and modeling results which showed that states contributin g 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 analysis 15 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 wa s 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 prov ide source contribution information for 2018 conditions. Specifically, the model estimated the impact of 18 geographic source regi ons and 6 source sectors (EGU point, non-EGU point, on-road, off-road, area, and ammonia s ources) at Class I areas in the eastern U.S. Example results for four Class I areas (Seney, Ma mmoth Cave, Mingo, and Shenandoah) are provided in the TSD (A ppendix 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 report 16 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 impairme nt at Class I areas in the northeastern and mid-Atlantic portions of the U.S. The r eport 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 monitori ng data. Sulfate im pacts were quantified using five analytical techniques based on 2002 conditions: Regional Modeling System for Aerosols and Deposition (REMSAD), Q/D, CALPUFF (wit h National Weather Service data), CALPUFF (with MM5 data), and percent time upwind (based on trajectory analyses). Additional details, including the percent contribution re sults, for MANE-VU Class I areas is provided in the TSD (Appendix B).

Although no specific criteria were identif ied 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/m 3 sulfate contribution to

15 “Quantifying Transboundary Transport of PM2.5: A GIS Analysis”, May 2003, LADCO

16 “Contributions to Regional Haze in the Northea st and Mid-Atlantic Unit ed States”, August 2006Page 30 of 70 the 20 percent worst days as their signif icance 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 Plan 17 for the two Missouri and tw o Arkansas Class I areas provides information on source regions affect ing 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 thes e Class I areas was based on the combined results of three approaches: areas of in fluence, PSAT modeling (based on 2018 conditions), and monitoring data analyses (Posit ive 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 st ate 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 ident ified 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 extincti on by ammonium sulfate, amm onium nitrate, or elemental carbon). 18

These extinction-weighted residence time analyses were ov erlayed 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 Cl ass 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 i dentified under Section 9 as being impacted by emissions from Ohio sources. Informa tion provided by MRPO, technical documents from the other RPOs, other st ates’ Regional Haze SIPs or communications indicating their decisions regarding reason able further progress goals were used as part of this evaluation.

Section 169A of the Clean Air Act and USEPA’s vi sibility rule requires states to consider five factors:

17 “Central Class I Areas Consultation Plan”, St ates of Missouri and Arkansas, February 2007

18 “VISTAS Areas of Influence Analysis”, Draft, February 28, 2007Page 31 of 70 • Costs of compliance;

• Time necessary for compliance;

• Energy and non-air quality environ mental impacts of compliance;

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

• Uniform rate of visibility improvement (needed to attain natural visibility conditions by 2064).

However, USEPA provides for flexibilit y in consideration of these factors:

“...the factors could be used to select wh ich sources or activities should or should not be regulated, or they coul d be used to determine the level or stringency of control, if any, for sele cted sources or activities, or some combination of both. The fa ctors may be considered bot h individually and/or in combination. As noted in se ction 4.1, given t he significant emissions reductions that we anticipate to result from BAR T, the CAIR, and t he implementation of other CAA programs, these reductions ma y be all that is necessary to achieve reasonable progress in the first planning peri od 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 fo r which you have already completed a BART analysis.” (USEPA’s “Guidance fo r 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 establishmen t of their reasonable progress goals and consideration of the factor s above while Ohio partici pated 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 eac h 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 sc hedules and other measures necessary to achieve the reasonable progre ss 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 Cont rol Program, low-sulfur gasoline and ultra-low sulfur diesel fuel

• Inspection - maintenance programs, in cluding Ohio’s E-check program in northeast Ohio (note: a special emissions modelin g 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 di esel rule), plus the evaporative Large Spark Ignition and Recr eational 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 in terstate transport of air pollution to downwind states. On Febr uary 1, 2008, USEPA approved Ohio’s CAIR program. Revisions to the CAIR SIP were again subm itted 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. C ourt 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, wh ich assumed implementation of Phases I and II of CAIR. MRPO conducted additional m odeling where alternative EGU emission projections were developed, wh ich did not rely on CAIR (o r IPM). In summary, the results show, with respect to regional ha ze, there is a significant change from the previous MRPO modeling (with CAIR). The modeling shows hi gher visibility levels in 2018 for the 20 percent worst visibility days (average about 0.5 deciview for thePage 33 of 70 northern Class I areas). The resulting visibi lity 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 wi thout vacatur. This decision allows implementation of CAIR, and the benefit of CAIR emission reductions, while USEPA works to address the Court’s prior opinions c ontained in the original vacatur. To address the D.C. Circuit Court’s conc erns in the remand, USEPA pr oposed a replacement to the CAIR program, the Transport Rule on July 6, 2010. [75 FR 45 210] Upon finalization, it will further assist states in addressing their obligations r egarding regionally transported pollution by providing reductions in NOx and SO2 emissions in 2012 and 2014. Therefore, Ohio is basing its results with CAIR, or it s replacement, in place.

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

• Controlling EGUs beyond CAIR control le vels 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 eval uating control options for meeting the new PM2.5 24-hour standard a nd the new 8-hour ozone standard. Such controls are likely to be implemented in a timefr ame close to the 2018 haze progress date and will, therefore, resu lt in additional improvements to visibility.

• Industrial, commercial and inst itutional (ICI) boiler contro ls 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 t he Northeast states to develop recommendations for a federal ICI boiler ru le. 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 source s and area sources (Appendix E).

• Requiring controls on other source sectors, such as reciprocatin g engines and turbines, and some mobile measures, may be cost effective, but they provide very little visibility improvement. Costs fo r 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. Furt her, 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 plann ing periods. It is reasonable for you to defer reductions to later planning periods in order to maintain a consistent glidepathPage 34 of 70 toward the long-term goal” (USE PA’s “Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program,” June 1, 2007). Notwithstanding the reasons described above for not pursuin g additional controls, Ohio has pursued BART controls on the BART-eligible source(s) discussed in Se ction 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 m eets the long-term strate gy 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 requi rement applies both w here emissions from the state are reasonably anticip ated to contribute to visibility impairment in Class I areas outside the state and when em issions from other states/tribes are reasonably anticipated to contribute to visibility impai rment 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 in formation 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 discu ssions 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 (A ppendix 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 it s 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-t he-books controls. The following details Ohio’s determination of its fa ir share of emission reductions for each Class I area which Ohio was determined to have emissions impacti ng 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 si gnificantly to its Class I areas as those with more than a 5 percent contri bution to visibility impairment. Ohio’s contribution, as identifi ed under Section 10.6.8, was found to be 4 percent and, therefore, Ohio was not ident ified by Michigan as a cont ributing state. Contributing states included: Michigan ( 18 percent), Illinois (14 percent), Indiana (12 percent) and Wisconsin (11 percent). Michigan determi ned that reasonable controls are on-thebooks controls. Ohio supports Michigan’s dete rmination of reasonable progress for this first planning period for the Seney Wilderne ss 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, Gr eat Gulf/President ial 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/m 3 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 wo rst visibility days fo r the first planning period (2018):

MANE-VU Class I Area % Contribution

New Hampshire – Great Gu lf 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 2007 19 ” 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) r eduction in SO2 emissions fr om 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 (poi nt, area, on-road, and off-road) SO2 emissions relative to on-the- books, on-the-way 2018 projections.

• Continued evaluation of ot her measures, including meas ures to reduce SO2 and NO x emissions from coal-burning fac ilities 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. Sammi s facility began cont inuous 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 thir d 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 oper ate a scrubber by 2016.

• The four units (573 MW each) at the Da yton P&L JM Stuart facility have installed and operated scrubbers continuous ly since spring of 2008.

• The unit (587 MW) at Dayton P&L Killen facility has instal led 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 construc tion 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, tw o 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 installe d and operating by mid-2012.

Therefore, Ohio’s utilities have made signific ant progress in installing SO2 controls as requested under MANE-VU’s Ask.

The following chart from MRPO modeling shows the culpabil ity of geographic areas to visibility conditions in the Arcadia Class I ar ea 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 ModelingPage 38 of 70 The following table, based on MRPO modeli ng, identifies the perc ent 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 in significant 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 exce eded at all MANE-VU Class I sites."Page 39 of 70 The document further states:

“MANE-VU received comments from se veral stakeholders and another RPO related to the fact that the modeling described in this report included control measures and emission reductions th at went beyond currently existing regulations. Commenters suggested that since the CAIR program and other “on the books” or “on the way” measures ar e projected to achieve uniform rates of progress as previously modeled, additi onal reductions to both EGU and nonEGU sectors were unnece ssary.... there are ..r easons why MANE-VU has chosen to include these measures in this modeling analysis....wh ile the results of the modeling described in this report sugg est 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 appr oach 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 add itional federal acti on to control EGU emissions (e.g., a third phase of CAIR), but MANE-VU does not believe that these reductions are likely to o ccur absent additional regulation.”

MRPO used USEPA’s approved IPM mode ling and projections to project EGU emissions for 2018. Ohio EPA does not agr ee 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 dec iview, or 19 percent, reducti on is predicted based on onthe-book controls and restrict ions on fuel sulfur content in the MANE-VU region. Adding additional controls in corporated into MANE-VU’s A sk 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 continui ng work with MANE-VU states but continues to believe that on-the-books controls, for this first planni ng period, represent reas onable progress. However, Ohio, along with the other MR PO 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 boile r workgroup (with participation by the Southeastern states and USEPA) to re-e xamine 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, m any states, including Ohio and MANE-VU states, sent letters to USEPA requesting a cooperative e ffort between states a nd USEPA to reduce emissions from EGUs, ICI boilers, mobile sources and area sources (Appendix E).

If a contributing state cannot agree with the st ate establishing the reasonable progress goal, “the state setting the goal must de scribe the actions taken to resolve the disagreement.” [64 FR 35714] Oh io does not believe at this time that it can commit to any particular course of action beyond the co llaboration that occurr ed in 2009 until it is determined, through the above work and furt her 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 Ar ea and Upper Buffalo Wilderness Area

The CENRAP modeling shows t hat 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 visi bility projections are available from the CENRAP, VISTAS and MRPO RPOs. MRPO proj ections showed Ohio’s contribution at 3 percent for both of these Clas s I areas. However, the TSD 20 prepared by Environ for CENRAP states acknowledges “the MRPO 2018 vi sibility projections are approximately 12 to 25 percentage points lowe r than the CENRAP and VIST AS projections at these three Class I areas, with values of 97 per cent 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 visib ility projections at their northern Class I areas and likely did not use the latest CE NRAP emission estimates. In addition, the CENRAP 2018 visibility projecti ons included BART controls on several sources in CENRAP states not included in the MRPO projections. Su ch BART controls are even more important in those stat es not covered by CAIR.”

Arkansas’ Regional Haze SIP stat es that by 2018, Arkansas is the largest contributor to extinction at Caney Creek fo r the 20 percent worst days fo llowed 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 Implementati on Plans,” September 12, 2007.Page 43 of 70Page 44 of 70 And:Page 45 of 70 Arkansas’ SIP states the c ontributions to extinction on the worst 20 percent days at Upper Buffalo is similar to Caney Creek onl y with less contributions from East Texas and more from Missouri, Illinoi s and Indiana. Ohio’s contribut ion 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 co ntributor for NO3 in the right graph.Page 47 of 70 Arkansas’ SIP demonstrates th at on-the-books controls are sufficient to meet the uniform rate of progress needed during this firs t planning period (2018), as depicted in the glide paths below:

Ohio supports Arkansas’ determination of r easonable 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 Wilder ness Area and Mingo Wilderness Area

For the two Missouri Class I areas, 2018 visib ility projections are available from the CENRAP, VISTAS and MRPO RPOs. MRPO proj ections showed Ohio’s contribution at 6 percent for Mingo and 4 percent for He rcules-Glades. However, the TSD 21 prepared by Environ for CENRAP states acknowledge s “the MRPO 2018 visibility projections are approximately 12 to 25 per centage points lower than the CENRAP and VISTAS projections at these three Class I areas, wi th values of 97 percent to 100 percent. The reasons why the MRPO 2018 visi bility projections are less optimistic than CENRAP and VISTAS are unclear. However, the MRPO fo cused on visibility projections at their northern Class I areas and likely did not use t he latest CENRAP emission estimates. In addition, the CENRAP 2018 visibility projecti ons included BART controls on several sources in CENRAP states not included in the MR PO projections. Su ch 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, Oh io, Oklahoma, Tennessee and Texas, were identified as contributing to visibility in Mingo and/or He rcules Glades Class I areas. Missouri’s SIP states the modeling demonstration has shown that the emission reductions from these contri buting states are sufficient to achieve reasonable progress goals in Missouri’s Class I areas. They al so 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 Implementati on Plans,” September 12, 2007.Page 49 of 70 Missouri is the largest contri butor as demonstrated above and Mi ssouri states in its SIP that existing programs are sufficient for its state and the other cont ributing states. AsPage 50 of 70 further support, the largest contributions from Ohio for SO2 are ident ified in its SIP as: Conesville, Cinergy Beckjord and Killen. As stated above, tw o of these three facilities have already installed SO2 controls.

Missouri’s SIP demonstrates th at on-the-books controls are sufficient to meet the uniform rate of progress needed during this firs t 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 achi eve reasonable progress goals in Missouri’s Class I areas.” Ohio supports Missouri’s de termination 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 follo wing 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: Kentu cky (54 percent), Indi ana (22 percent) and Tennessee (13 percent). Kentucky det ermined the VISTAS baseline modeling demonstrated that the 2018 base control sc enario (existing and planned (i.e., on-the-Page 52 of 70 books)) provides for an improvement in visibi lity 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 l east impaired days over the same period, as depicted in the glide path below:

Ohio supports Kentucky’s determination of r easonable 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 ident ified states that are expec ted 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 MRP O, 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 Ha ze SIPs identifies Ohio’s percent contribution to SO2 emissions at 0.9 percent. More significant contributing states identified by North Carolina and Tennessee included: Tenne ssee (75 percent), Georgia (8 percent) and North Caroli na (7 percent). North Ca rolina and Tennessee determined the VISTAS baseline modeling demonstrated that the 2018 base control scenario (onthe-books) provides for an impr ovement 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 degr adation in visibility for the leas t impaired days over the same period, as depicted in the glide path below:Page 54 of 70 Ohio supports Tennessee and North Carolin a’s determination of reasonable progress for this first planning period for Great Smok y Mountains and that on- the-book controls by Ohio constitutes Ohio’s fair share of emission reductions.

Virginia – James River Face W ilderness 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 followi ng 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 per cent at Shenandoah. Virginia’s Regional Haze SIP identifies Ohio’s per cent contribution to SO2 em issions at 3.6 percent at James River and 4.6 percent at Shenandoah. More signifi cant 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 identifiedPage 56 of 70 by Virginia for Shenandoah inclu ded: Virginia (38 percent), Maryland (24 percent), and West Virginia (20 percent).

Virginia’s Regional Haze SIP id entified 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 demonstr ated 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 vi sibility for the least impaired days over the same period, as depi cted 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 perc ent 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 SI P identifies Ohio’s percent contribution to SO2 emissions at 7 percent. More significant contributing states identified by West Virginia included: We st 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 ment ioned above, unit B006 at Mu skingum 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 baselin e modeling demonstrate d 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 determinat ion of reasonable progress for this first planning period for Dolly S ods/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 emi ssions 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 coordinat ed 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 de scribed throughout this document.

An assessment of the five factors descr ibed 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 c an be applied to other Class I areas.Page 59 of 70 Specifically, EC/R examined reductions in SO2 and NOx em issions from EGUs and ICI boilers; NOx emissions from mobile source s and reciprocating engines and turbines; and ammonia emissions from agricultural oper ations. 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 t he five factors ar e 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 in clude (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/millio n-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 (E GU1 and EGU2) cost $1540 to $3,016/ton. These costs would be in addit ion to the $700 to $2,600/t on costs for CAIR and other cap-and-trade programs. Therefor e, if the additio nal EGU strategies were added to the on-the-books controls, EGUs would incur a to tal cost of $2,260 to $5,616/ton. For ICI boilers, costs were slightly higher compar ed 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. Fo r 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 a nd 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 co sts 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 im plemented by 2018.Page 60 of 70 10.3.3 Factor 3 (Energy and Non-Ai r 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 treat ment costs are less than 5 pe rcent of the total operating costs of the polluti on 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 (Rem aining Useful Life)

The additional control measur es are intended to be market -based strategies applied over a broad geographic region. It is not ex pected that the cont rol 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 sign ificant beyond-CAIR reducti ons from EGUs (EGU1 or EGU2), especially for SO2, w ould be the most effective cont rol 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 contro ls would have a small effect on visibility improvement. The last two sour ce categories, reciprocating engines and turbines and mobile sources, show ve ry 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 baseli ne 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 it s long-term strategy. Section 6 contains a discussion of anthropogenic sources and includes references where details on the baseline and current emissions invent ories 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 program s. Ohio considered “on-the-books” controls, as identified at the beg inning 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 Im pacts 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 constructi on activities in Ohio are a significant contributor to visibility impairment in Class I areas.

When USEPA first promulgated t he Regional Haze Rule in 1999, emissions related to construction activities such as windblown du st and nonroad diesel eng ines were a major concern. This was especially a problem in rapidly growin g metropolitan areas such as Los Angeles and Phoenix. Construction activi ties are directly related to population growth. Ohio has not experienced rapid grow th 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 pr ojected to grow to 12,005, 733 by 2020, a 4.5 percent increase over 2007.

Construction projects in Ohio that distur b 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 entitie s to develop a storm water pollution prevention plan containing best management pr actices to control erosion and runoff. Many of the best management practices employed to prevent erosion and runoff are also effective at preventing windblown du st. 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 no t sufficient to meet the goals.

Ohio believes that on-the-boo ks controls provide sufficient measures to achieve reasonable progress goals, recogn izing that there wil l 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 reduct ions to meet the 1997 ozone NAAQs and expects to make additional r eductions 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 vi sibility 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 consi der source retirement and replacement schedules in developing it s long term strategy. Retirement and replacement will be managed in conformance with existing SI P requirements pertaining to New Source Review (NSR), both during Pr evention 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 agricultura l 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 visibili ty 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 t he Ohio Department of Natural Resources (ODNR) Division of Forest ry the authority to ban outdoor burning statewide in unincorporated areas during the m onths of March, April, May, October, andPage 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 po licy 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 St andards”, regulates the types of materials that can be burned, locations where they can be burned and determines that no open burni ng shall be conducted in an area where an air alert, warning, or emergency is in effect. Further more, to open burn in many areas, advanced approval from Ohio EPA is required. O pen burning is defined as the burning of any material wherein air contaminants resulting fr om combustion are emitted directly into the ambient air without passing th rough a stack or chimney.

OAC Chapter 3745-19 allows spec ific open burning activities such as prescribed fires, for recognized horticultural, silvicultural, ra nge, or wildfire manag ement practices. An application for permission to open burn shall be submitted in wr iting 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 ta ken 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 W ildland and Prescribed Fires recommendations, and will certify in a letter to the USEPA Administrator t hat a basic program has been adopted and implemented in the future.

The Ohio SMP will establis h a basic framework of pr ocedures and requirements for managing smoke from fires managed for resour ce benefits and will be developed by the Ohio EPA with the cooperation and participa tion 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 assess ing and authorizing prescribed burns. The following describes the minimal requirem ents the Ohio Basic Smoke Management Program would consider, complementing Oh io’s existing open burn ing 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 sm oke 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 enfo rceable. Ohio will ensure that all BART emi ssion limitations and control measures used to meet reasonable progress goals and as a part of t he long term strategy are enforceable by embodying these in rules, federally enfor ceable permit documents or orders of the director.

10.6.8 Anticipated Net Effect on Visib ility Resulting from Projected Changes to Emissions

Ohio is required by 40 CFR 51 .308(d)(3)(v)(G) to address t he net effect on visibility resulting from changes projected in point, ar ea 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 implem entation period resulting from population growth; industrial, energy and natural re sources 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 offe rs the conclusion, supported by MRPO’s technical analysis, that year 2064 attainm ent and intermediate ra te-of-progress goals are projected to be achieved at all but a small number of th e national parks and wilderness areas in the study area. However, when com paring the rate-of-progress glide path analysis performed by MRPO fo r both the 2002 (Base K) and 2005 (Base M) base years, the extent of t he areas where the rate-of-progr ess 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 Minnesota 22 and Northern Michigan.

The difference in the two modeling analysis is due primarily to differences in future year emission projections, especially for EGUs wh ich are based upon US EPA’s results using IPM2.1.9 for 2002 and IPM3.0 for 2005. For Ohio ’s Regional Haze SI P, more weight is given to the 2005 base year; however, the resu lts of the 2002 base year analysis should also be weighed.

Recall, as discussed in Section 10.2.2, mo re 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 wo rk with states regardi ng 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 AcadiaPage 67 of 70 The following tables, based upo n 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-th e-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 8.82Page 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 th at 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 cont ribution levels (see table be low). 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 Se ction 10.2. Substantial SO2 and NOxPage 69 of 70 emission reductions are expected in Ohio pursuant to existing and new control programs. These emission reductions will dec rease Ohio's contribution to visibility impairment on the 20 percent worst visib ility 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 othe r 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/r eports/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 accordanc e with the requirement s listed in 40 CFR 51.308(f), Ohio commits to revising and submitting this Regi onal Haze SIP by July 31, 2018 and every ten years thereafter.Page 70 of 70 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 (CER R). 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 r equirements 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 periodi c reports evaluating progress towards the reasonable progress goals established for each mandatory Class I area. In accordance with the requirements lis ted in 40 CFR 51.308(g), Ohio co mmits to submitting a report on reasonable progress to USEPA every five y ears following the initia l 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 reas onable progress goal for each mandatory Class I area located outside Ohio, which ma y be affected by em issions from within Ohio

. All requirements listed in 40 CFR 51.308(g) shall be addre ssed in the SIP revision for reasonable progress.

13. Adequacy

Depending on the findings of t he five-year progress report, Ohio commits to taking one of the actions listed in 40 CF R 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 existi ng SIP required no further substantive revision in order to achi eve established goals. Ohio would provide to the Administrator a declaration that further re vision of the SIP wi ll not be needed at that time.

2) Ohio would determine that the exis ting SIP may be inadequate to ensure reasonable progress due to emissions from other states which participated in the regional planning process. Oh io would provide notificat ion to the Administrator and the states that participat ed 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 exis ting SIP may be inadequate to ensure reasonable progress due to emissions from another country. Ohio would provide notification, along with av ailable information, to the Administrator.

4) Ohio would determine that the existi ng SIP is inadequate to ensure reasonable progress due to emissions within Ohio. Ohio would revise its SIP to address the plan’s deficiencies withi n one year thereafter.