State Implementation Plan

2008 Eight-Hour Ozone National Ambient Air Quality 

Standard Emissions Inventory & Emissions Statement 

The Ohio Environmental Protection Agency 

Division of Air Pollution Control 

July 2014 
State Implementation Plan 

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

Acknowledgement 

The Ohio EPA, Division of Air Pollution Control would like to express appreciation for the extensive efforts 

and expertise providing onroad data by the Ohio Department of Transportation and the nonattainment 

area Metropolitan Planning Organizations inlcuding the Ohio-Kentucky-Indiana Regional Council of 

Governments (OKI), the Northeast Ohio Areawide Coordinating Agency (NOACA), and the Mid-Ohio 

Regional Planning Commission (MORPC). Appreciation is also extended to Mark Janssen of the Lake 

Michigan Air Directors Consortium (LADCO) for the emissions inventory data included in this submittal. 
State Implementation Plan 

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

Table of Contents 

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

2 Nonattainment Areas ............................................................................................... 3

2.1 Cincinnati ........................................................................................................... 3

2.2 Cleveland-Akron-Lorain ..................................................................................... 3

2.3 Columbus ........................................................................................................... 3

3 Emission Inventory Summary .................................................................................. 5

3.1 Point Source Emissions ..................................................................................... 6

3.1.1 Non-Electric Generating Units ..................................................................... 6

3.1.2 Electric Generating Units ............................................................................. 6

3.2 Area Source Emissions ...................................................................................... 7

3.3 Mobile Source Emissions ................................................................................... 8

3.3.1 Onroad Mobile Emissions ............................................................................ 8

3.3.2 Nonroad Mobile Emissions .......................................................................... 9

3.4 Emission Inventory Quality Assurance ............................................................. 10

4 Source Emission Statement ................................................................................... 16

5 Projected Emissions Modeling ............................................................................... 17

6 References ............................................................................................................. 18

Figures 

Figure 1. Ohio 2008 Eight-Hour Ozone (0.075 ppm) Nonattainment Areas .................... 4

Tables 

Table 1. 2008 VOC Typical Summer Day Emissions .................................................... 12

Table 2. 2008 NOx Typical Summer Day Emissions ..................................................... 13

Table 3. 2008 VOC Total Annual Emissions ................................................................. 14

Table 4. 2008 NOx Total Annual Emissions ................................................................... 15

Table 5. US EPA Projected 2015 Ozone Design Values............................................... 17

Appendices 

Appendix A ConCEPT – Consolidated Community Emissions Processing Tool An OpenSource Tool for the Emissions Modeling Community 

Appendix B State of Ohio 2008 Base Year Emissions Inventory Report 

Appendix C EGU Point Source Emission Units in the 2008 Base Year Emissions Inventory 
State Implementation Plan 

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

Appendix D Non-EGU Point Source Emission Units in the 2008 Base Year Emissions 

Inventory 

Appendix E Temporally Allocating Emission with CEM Data for Chemical Transport and SIP 

Modeling 

Appendix F 2008 Base Year Emissions Inventory Area (nonpoint) Sources by County and 

SCC 

Appendix G 2008 Ozone Mobile Sources Emissions Inventory for Ohio Portion of the 

Cincinnati Ozone Nonattainment Area 

Appendix H Central Ohio On-Road Mobile Emission Estimates 

Appendix I Technical Memorandum Northeast Ohio (AMATS, ERPC, NOACA, Ashtabula) 

2008 Base Year Inventories for Ozone NAAQS Mobile Source Emission (VOC 

and NOx) 

Appendix J 2008 Base Year Emissions Inventory Onroad Emissions by County and Road 

Type 

Appendix K 2008 Base Year Emissions Inventory Nonroad Sources by County and SCC 

Appendix L 2008 Base Year Emissions Inventory MAR Sources by County and SCC 

Appendix M Spreadsheet estimates 2015 design values for hypothetical 8-hour ozone 

nonattainment areas for the 75 ppb NAAQS for the purpose of estimating the 

number of marginal nonattainment areas that are expected to attain the NAAQS 

by their attainment date (2015) 

Appendix N Public Notice, Public Hearing and Comment Period Documents 

 
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2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

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1 Introduction 

The 1990 Clean Air Act Amendments (CAAA) requires the United States Environmental 

Protection Agency (US EPA) to set National Ambient Air Quality Standard (NAAQS) for 

pollutants considered harmful to public health and the environment. In 2008, the US EPA 

established revisions to the primary and secondary National Ambient Air Quality Standards for 

ozone thereby replacing the 1997 ozone standards. The 2008 NAAQS for Ozone established a 

primary and secondary 8-hour ozone standard of 0.075 parts per million (ppm) (73 FR 16436). 

Ground level ozone is not directly emitted into the air. It is formed as a product of chemical 

reactions between nitrogen oxides (NOx) and volatile organic compounds (VOCs), referred to as

ozone precursors, in the presence of sunlight. Industrial facilities, motor vehicle exhaust, 

gasoline vapors and chemical solvents are a few examples of emission sources contributing to 

these ozone precursors. Ozone is a harmful pollutant at ground level and is of particular 

concern during the summer months when sunlight and hot weather can form harmful ozone 

concentrations which can trigger a variety of chest, throat and lung related health problems. 

The CAAA defines five ozone nonattainment area classifications based on severity for areas 

that exceed the NAAQS. The nonattainment area classifications are as follows (in order of 

increasing severity): marginal, moderate, serious, severe and extreme. The US EPA “Air Quality 

Designations for the 2008 Ozone NAAQS” rule designated nonattainment and 

unclassifiable/attainment areas nationwide effective July 2012 (77 FR 30088). These 

designations were published concurrently with the “Implementation of the 2008 NAAQS for 

Ozone: Nonattainment Area Classifications Approach, Attainment Deadlines and Revocation of 

the 1997 Ozone Standards for Transportation Conformity Purposes” rule which established the 

air quality thresholds for classification categories that are assigned to all areas designated 

nonattainment for the 2008 Ozone NAAQS according to the ‘‘percent-above-the-standard’’ 

methodology (77 FR 30160). 

In Ohio, three nonattainment areas (NAAs) have been designated for the 2008 NAAQS for 

Ozone including Cincinnati, Cleveland-Akron-Lorain and Columbus. These nonattainment 

areas, comprised of multiple counties, have each been classified as Marginal nonattainment 

based on an area design value criteria. The Cincinnati nonattainment area is a multi-state 

nonattainment area which includes partial nonattainment areas in counties located outside of 

Ohio in Kentucky and Indiana (77 FR 30088). The nonattainment areas are discussed in further 

detail in the following section. 

Outside of the Marginal nonattainment designation areas, all other counties in the State of Ohio 

have been designated as unclassifiable/attainment (77 FR 30088). US EPA has historically 

used the “unclassifiable/attainment” category for areas that either have air quality monitors that 

demonstrate attainment and for areas that do not have monitors and for which there is no 

reason to believe they are not in attainment or are contributing to nearby violations. 

Attainment dates and State Implementation Plan (SIP) submission requirements are dependent 

upon area classification designations. Under section 182(a) of the CAAA, Marginal areas have 

up to 3 years from designation to attain the NAAQS, and are not required to submit an 

attainment demonstration. When Congress amended the CAA in 1990, it anticipated that 

nonattainment areas with ozone concentrations close to the NAAQS would likely come into 

attainment within 3 years of designation without any additional local planning (78 FR 34184). 
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2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

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July 2014 

This SIP submittal is intended to satisfy the requirements for the designated Ohio Marginal 

nonattainment areas established in the proposed “Implementation of the 2008 NAAQS for 

Ozone: SIP Requirements” (78 FR 34178) including the emissions inventory and emissions 

statement requirements. The 2008 emission inventory has been selected as the appropriate 

inventory for SIP development. The 2008 base year ozone emissions inventory presented in this 

document is an inventory of the actual reported, estimated or calculated typical summer day and 

annual VOC and NOx emissions for Ohio sources. Ohio EPA has prepared an inventory for 

each nonattainment area including the point, area, onroad and nonroad sectors. Typical 

summer day emissions were evaluated for summer weekdays in the months of June, July and 

August. 
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2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

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July 2014 

2 Nonattainment Areas 

The US EPA “Air Quality Designations for the 2008 Ozone NAAQS” rule designated three 

nonattainment areas in Ohio (77 FR 30088). The design value for an individual monitoring site is 

the three-year average of the annual fourth highest daily maximum eight-hour average ozone 

concentration. An area meets the standard if, and only if, every monitoring site in the area 

meets the NAAQS. The designated nonattainment areas in Ohio have each been classified as 

Marginal nonattainment based on an area design value criteria above the NAAQS of 0.075 ppm. 

Each of the three nonattainment areas is comprised of a subset of several counties. Figure 1 

shows the location of the counties included in each designated nonattainment area discussed 

below. 

2.1 Cincinnati 

The Cincinnati nonattainment area is a multi-state nonattainment area which includes partial 

nonattainment areas in counties located outside of Ohio in Kentucky and Indiana. The 

Cincinnati nonattainment area includes the following counties: Butler, Clermont, Clinton, 

Hamilton and Warren Counties in Ohio; portions of Boone, Kenton and Campbell Counties in 

Kentucky; and portions of Dearborn County in Indiana. The typical summer day emissions 

inventory and emission statement information presented in this report is only representative of 

the nonattainment counties located in Ohio. The Ohio-Kentucky-Indiana Regional Council of 

Governments (OKI) is the designated metropolitan planning organization (MPO) for all of the 

Cincinnati ozone nonattainment area with the exception of Clinton County, Ohio. 

2.2 Cleveland-Akron-Lorain 

The Cleveland-Akron-Lorain nonattainment area includes the following counties: Ashtabula, 

Cuyahoga, Geauga, Lake, Lorain, Medina, Portage and Summit. The Northeast Ohio Areawide 

Coordinating Agency (NOACA) is the MPO that covers Cuyahoga, Geauga, Lake, Lorain and 

Medina. The Akron Metropolitan Area Tranportation Study (AMATS) is the MPO that covers 

Summit and Portage counties. 

2.3 Columbus 

The Columbus nonattainment area includes the following counties: Delaware, Fairfield, Franklin, 

Knox, Licking and Madison. The six county Columbus nonattainment area includes two MPOs, 

the Mid-Ohio Regional Planning Commission (MORPC) and the Licking County Area 

Tranportation Study (LCATS). MORPC covers Franklin County, Delaware County, Pataskala 

and Etna Township in Licking County, and Violet and Bloom Townships in Fairfield County. 

LCATS covers the ramainder of Licking county. Madison County, Delaware County and the 

remainder of Fairfield County are located outside of the MPO area coverage. 
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2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

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Figure 1. Ohio 2008 Eight-Hour Ozone (0.075 ppm) Nonattainment Areas 
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3 Emission Inventory Summary 

This section presents a summary of the 2008 Base Year Emissions Inventory for Ohio. Marginal 

nonattainment areas are required to submit an emission inventory summary (EIS) for the 

nonattainment area within 2 years of nonattainment designation (CAA Section 182(a)(1)). 

“Emission inventories are critical for the efforts of state, local and federal agencies to attain and 

maintain the NAAQS that the US EPA has established for criteria pollutants, including ozone. 

The CAA section 182(a)(3)(A) requires that states submit periodic emission inventories every 3 

years after the initial base year inventory for Marginal and above ozone nonattainment areas. 

The periodic inventory must include emissions of VOC and NOx for point, area, and mobile 

sources (onroad and nonroad). On December 4, 2008, the US EPA promulgated the AERR rule 

(40 CFR 51, subpart A). The AERR requires states to submit comprehensive statewide 3-year 

cycle emission inventories (2008, 2011, 2014, etc.) regardless of an area’s attainment status. 

The Proposed Implementation Rule US EPA has suggested for states with periodic inventory 

obligations under 182(a)(3)(A) to rely on their 3-year cycle inventory as described in the AERR 

to satisfy their 182(a)(3)(A) periodic inventory obligation.” (78 FR 34201) 

At the time the 2008 emission inventory was evaluated, permitted Ohio facilities classified as 

Title V were required to file a complete EIS. The EIS includes detailed emissions information as 

well as data about the egress points where pollutants are released into the air including NOx

and VOCs. Ohio EPA has the authority under Ohio Administrative Code (OAC) rule 3745-15-

03 to request and receive this information from regulated entities. 

A typical permitted facility may have multiple source types. For example, a refinery with 

numerous industrial processes would itself be a point source, the leaks from valves and the 

switch engine that moves tank cars on the railroad siding would be a nonroad mobile source. A 

typical permitted facility may also have more than one industrial classification. The refinery in 

the previous example is in one industrial category while the tank farm is in another. Quantities 

of emissions may be measured directly (at the stack); they may be calculated from engineering 

principles (e.g., mass balance); or they may be estimated (e.g., by assuming reasonable 

emission rates, times, etc.). Emissions can be expressed in terms of annual emissions, 

seasonal emissions or daily emissions. For the purpose of this submittal, the data presented 

has been quantified as typical summer day emissions in tons per day. 

Ohio EPA prepared a comprehensive emissions inventory including point, area and mobile 

sources for precursors of ozone (VOCs and NOx) for base year 2008. The point sources were 

divided into two categories, electric generating units (EGUs) and non-EGUs. Four basic steps 

were involved in the preparation of the emission inventory including planning, data collection, 

data analysis and emission estimation and reporting. 

Emission estimates generally followed the methodologies outlined in US EPA’s emission 

inventory preparation guidance document, Volumes I-IV and US EPA’s “Reporting Guidance for 

1996 Periodic Emissions Inventories and National Emission Trends (NET) Inventories.” The 

Lake Michigan Air Directors Consortium (LADCO) spatially and temporally processed the 

emissions data in accordance with US EPA guidance: “Guidelines on the Use of Models and 

Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and 

Regional Haze”, EPA-454/B07-002, April 2007. To ensure the EIS is of the highest quality, 

Ohio EPA implemented quality assurance (QA) procedures and quality control (QC) checks 

throughout the inventory development process. Ohio EPA specifically followed the procedures 

outlined in US EPA’s guidance documents pertaining to inventory quality assurance and 
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believes the inventory to be complete, accurate and of high quality. 

In the case of the pollutant ozone, precursor emissions are expressed in terms of typical daily 

emissions representative of the peak ozone season, or tons per day. LADCO has processed 

annual emissions data files for the 2008 base year inventory using the Consolidated Community 

Emissions Processing Tool (CONCEPT) model and calculated daily emissions in a robust, 

consistent and transparent manner (Appendix A). The information below describes the 

procedures Ohio EPA used to generate the 2008 base year ozone emissions inventory. A 

detailed description of the development of the 2008 base year emissions inventory estimates in 

its entirety is available in Appendix B. More information on the development and results of the 

2008 base year emissions inventory is available on the LADCO website at: 

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

3.1 Point Source Emissions 

Emissions from point sources are defined as those whose emissions are usually fairly well 

characterized, are generally discharged through stacks and which are required to possess an 

Ohio EPA issued permit. The final point source inventory is divided into two categories: EGUs 

and non-EGUs. The majority of the point source EGU inventory is comprised of the US EPA 

Clean Air Markets Division (CAMD) inventory. The non-EGU inventory, and several EGUs not 

required to submit data to CAMD, are comprised of point source facility data submitted to Ohio 

EPA. Typical summer day and total annual emissions of NOx and VOCs for Ohio point sources 

are presented by county in Tables 1-4. Based on the typical summer day emissions presented 

in Tables 1 and 2 the EGU NOx emissions were the second largest emission sector in the 

Cincinnati NAA. Appendices C and D contain a detailed list of the EGU and non-EGU point 

sources included in the 2008 base year inventory by facility and unit ID, with their respective 

VOC and NOx emissions. 

3.1.1 Non-Electric Generating Units 

The primary source of data for non-EGU point sources was the facility reported 2008 annual 

emission data. Ohio Title V facilities are required to submit annual emissions reports through 

the Ohio EPA web interface, Air Services. Under Title V, major sources are those with the 

potential to emit 100 tons per year or more of any one regulated pollutant (PM10; nitrogen 

oxides; sulfur dioxide; carbon monoxide; volatile organic compounds; and lead); 10 tons per 

year or more of any one hazardous air pollutant (HAP); or 25 tons per year or more of any two 

or more hazardous air pollutants. The emissions data are reported by the sources annually as 

part of the inventory process conducted by Ohio EPA and include emissions, process rates, 

operating schedules, and other relevant facility information. The data are stored in Ohio EPA’s 

internal data management system called STARS2. The data were converted from Air Services 

into the EIS XML file format via a tool developed by Ohio EPA’s contractor, UNICON. The data 

were submitted to US EPA and LADCO. LADCO used the data to spatially and temporally 

allocate typical summer daily emissions. 

3.1.2 Electric Generating Units 

40 CFR Part 75 includes requirements for Ohio EGU units to report emissions and activity data 

to the US EPA CAMD database. This data is referred to as continuous emission monitoring 

(CEM) data. For these units, temporal allocation of VOC and NOx annual emissions to typical 
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summer day emissions was accomplished utilizing a 3-tier approach. The total annual 

emissions are based on the emissions reported in the CAMD database. For all other EGU units, 

the Ohio EPA facility reported 2008 annual emission data was used as described in section 

3.1.1 above. 

The Tier 1 approach to the temporal allocation of the CEM data was adapted from the 

methodology presented in ‘Temporally Allocating Emission with CEM Data for Chemical 

Transport and SIP Modeling’ (S. Edick, M. Janssen, n.d.). That methodology used CEM data 

from 2001 through 2003 to temporally allocate 2002 emissions data. For the 2008 inventory 

presented in this document, 2008 CEM data was used to temporally allocate the 2008 typical 

summer day emissions. Ohio EPA also deviated from the described methodology by using 

annual unit emission values from the CEM data rather than integrating the NIF inventory annual 

unit emission values. A detailed description of the methodology used for the temporal allocation 

of the CAMD EGU unit emissions is available in Appendix E. 

 

The results of the Tier 1 approach were reviewed and any suspected anomalies or zero values 

were further analyzed using the Tier 2 approach. The Tier 2 analysis was completed by finding 

the average NOx emission rate of each unit for every weekday hour during summer 2008 (June 

- August ). The resulting average hourly weekday NOx emission rate was multiplied by 24 hours 

to calculate the typical summer day (ozone season) emission rate in tons per day. 

The results of the Tier 2 approach were reviewed and any anomalies or zero values were 

further analyzed using the Tier 3 approach. In the Tier 3 analysis the total annual EGU unit NOx

emissions were divided by 366 days (2008 was a leap year) to produce a typical day emission 

assuming each day of the year produced an equivalent NOx emission in tons per day. 

3.2 Area Source Emissions 

Area sources (also referred to as nonpoint sources) are usually spread over wide areas with no 

distinct discharge points or are comprised of a large number of small point sources that are 

difficult to describe separately and whose emissions are not well characterized (e.g., heating 

furnaces in individual homes, architectural surface coating, automobile refueling, dry cleaning, 

etc.). Area emissions are typically estimated by multiplying an emission factor by a known 

indicator of activity (e.g., population, employment, etc.) for a source classification code (SCC). 

For the 2008 inventory, States and US EPA formed the Eastern Regional Technical Advisory 

Committee (ERTAC). The committee defined the inventory categories, emissions factors and 

sources of activity data and contracted with Transystems to develop draft emissions estimates. 

County level activity data were provided to all States. When available, 2008 activity data was 

used to perform calculations of emissions for area sources and Ohio EPA accepted the majority 

of the estimates. In some cases Ohio developed a more refined methodology, produced more 

accurate activity data, or applied a necessary point source subtraction to the ERTAC or US EPA 

estimate. In a number of cases, data was provided from national estimates and allocated to the 

State and county levels. In a few cases projections from a previous inventory were used. 

Appendix F contains a list of the area sources included in the 2008 base year inventory by SCC 

and County, with their respective VOC and NOx emissions 

The area source data were processed in Microsoft Excel and Access applications, converted 

into the EIS XML file format via US EPA’s EIS Bridge Application and provided to US EPA and 

LADCO. The area source emissions files provided to LADCO were used to create spatial and 

temporal allocation of emissions and typical summer day estimates using the LADCO 
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CONCEPT emissions model. The CONCEPT model produced typical summer day emissions 

estimates which were aggregated for each nonattainment county. Typical summer day and total 

annual emissions for Ohio area sources are presented in Table 1-4, respectively. The area 

source VOC emissions were the second largest sector contribution in the Columbus and 

Cincinnati NAAs. 

3.3 Mobile Source Emissions 

Mobile sources are divided into two major categories – onroad and nonroad. Onroad mobile 

sources include cars, trucks, buses and motorcycles used for transportation of goods and 

passengers on roads and streets. Nonroad mobile sources include other modes of powered 

transportation such as aircraft, locomotives, ships and motor vehicles not associated with 

highway vehicles. This classification protocol has been utilized throughout this document. 

“For all inventories that are used in developing RFP plans or attainment demonstrations, mobile 

source emissions should be estimated using the latest emissions models, data and planning 

assumptions. The latest approved models should be used to estimate emissions from onroad 

and nonroad sources, in combination with the latest available estimates of [vehicle miles 

traveled] VMT, vehicle population, and/or equipment activity. States are advised to check the 

US EPA Web pages for the mobile source models and to consult with the US EPA Office of 

Transportation and Air Quality and their regional office to determine the versions of models to 

use for their SIPs for the 2008 ozone NAAQS. Currently, the most recently approved model for 

estimating onroad emissions in states outside of California is MOVES2010 which initially was 

approved for use in SIPs on March 2, 2010 (75 FR 9411). The US EPA has subsequently 

released two minor updates to MOVES2010, MOVES2010a and MOVES2010b that are also 

approved for use in SIPs” (78 FR 34202). Typical summer day and total annual emissions for 

Ohio mobile sources are presented in Tables 1-4. 

3.3.1 Onroad Mobile Emissions 

Onroad mobile source emissions were calculated by running US EPA Motor Vehicle Emission 

Simulator version 2010b (MOVES2010b). MOVES2010b provides emissions estimates for 

pollutants including VOCs and NOx from mobile sources under a wide range of user-defined 

conditions. Ohio EPA relied on VMT data generated by the Ohio DOT Office of Planning and 

Programming and Metropolitan Planning Organizations (MPOs). Ohio DOT and MPOs used 

urban transportation planning methodologies approved by the Federal Highway Administration 

to generate the necessary VMT estimates. MOVES2010b was run using area-specific input 

values where available and national average defaults in other cases. The nonattainment areas 

MPOs provided the nonattainment area county emissions for a typical summer day as shown in 

Tables 1 and 2. Detailed reports and information on the development of these emission 

estimates are available from the developing MPO in Appendices G-I. Appendix J contains a list 

of the 2008 base year inventory onroad emissions by county and road type, with their respective 

VOC and NOx emissions. 

Based on the estimated typical summer day emission presented in Tables 1 and 2, onroad 

mobile emissions are the largest contributing sector of NOx emissions in all three Ohio NAAs. 

Onroad mobile emissions are also the largest contributing sector of VOC emissions in the 

Columbus and Cincinnati NAAs and the second largest contributing sector of VOC emissions in 

the Cleveland-Akron-Lorain NAA based on typical summer day emissions. 
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3.3.2 Nonroad Mobile Emissions 

Nonroad mobile source emissions were calculated using the Nonroad National Mobile Inventory 

Mode (NMIM) computer model and CONCEPT. Ohio EPA prepared the inputs to the NMIM 

model and provided them to LADCO and US EPA. LADCO performed analysis using NMIM to 

generate emission rates for various off road equipment. LADCO had previously contracted 

consultants to develop local data used in NMIM 2008 for agricultural equipment, construction 

equipment, commercial marine, recreational marine, and railroads (Environ, 2004, E.H. Pechan, 

2004, and Environ, 2007a, 2007b). The emissions rates were processed in CONCEPT and 

spatially/temporally allocated in specified grid cells. The NMIM model does not include 

emission estimates for aircraft, locomotives and commercial marine vessels. 

The typical summer day emissions presented in Tables 1 and 2 show nonroad emissions are 

the largest contributing sector of VOC emissions and the second largest contributing sector of 

NOx in the Cleveland-Akron-Lorain NAA. Nonroad emissions are also the second largest 

contributing sector of NOx emissions in the Columbus NAA. Appendix K contains a list of the 

nonroad sources included in the 2008 base year inventory by SCC and county, with their 

respective VOC and NOx emissions. 

Ohio EPA and LADCO prepared emission estimates for railroad locomotives; commercial, 

military and civil aircraft; and commercial vessels using state- and county-specific activity factors 

and US EPA approved emission factors and data. The aircraft, locomotives and commercial 

marine vessels inventories are also processed in CONCEPT by LADCO. The typical summer 

day emission inventories for marine, aircraft and rail (MAR) are further described below. 

Appendix L contains a list of the MAR sources included in the 2008 base year inventory by SCC 

and County, with their respective VOC and NOx emissions. 

3.3.2.1 Marine 

Marine fuel consumption in the LADCO region remained fairly consistent between 2005 and 

2008 (EERA et al., 2007). Therefore, the 2008 marine emissions are based on the 2005 LADCO 

Base M inventory which was developed utilizing data previously prepared by a LADCO 

contractor (Environ, 2007a). The data was then spatially and temporally allocated using the 

LADCO CONCEPT model. 

3.3.2.2 Aircraft 

For inventory year 2008, US EPA contracted with the Eastern Research Group (ERG) and 

generated a detailed aircraft inventory for the entire nation. Ohio EPA provided the statespecific aircraft emission data (where available) for the 2008 aircraft inventory. The Ohio airport 

inventory accounted for 724 Airports, including, for the first time, emissions from gliderports, 

heliports, sea plane bases, STOLports and ultra-light fields. However, airport specific 

landing/take off (LTO) and engine type information necessary for calculating specific aircraft 

emissions was only available for the large airports. Therefore, two methods were used to 

calculate the Ohio aircraft emissions inventory. 

The ODOT tracks operations for towered and non-towered airports in Ohio. A landing or a takeoff is considered an operation. Two operations make up one landing/take-off (LTO). Where 

there was specific aircraft model data available emission factors were derived using the Federal 

Aviation Administration (FAA) Emission Dispersion Modeling System (EDMS). EDMS is a 

combined emissions and dispersion model for assessing air quality at civilian airports and 

military air bases. This portion of the aircraft emissions inventory was calculated by multiplying 
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the number of LTOs per year by the EDMS emission factor. More information on the ODOT 

tracking operations is available at: 

www.dot.state.oh.us/aviation

For the majority of the remaining airports where airport specific LTO and aircraft engine type 

information was not available, ERG used either regression equations to calculate the LTOs or 

other documented procedures as explained in the following report: 

http://www.epa.gov/ttn/chief/net/2008_nei/aircraft_report_final.pdf

Ohio EPA thoroughly reviewed the 2008 ERG aircraft inventory and it was considered 

representative for Ohio. Emissions data was temporally and spatially allocated by LADCO 

using CONCEPT to generate typical summer day emissions. 

3.3.2.3 Rail 

Rail emissions for the 2008 inventory were developed by ERTAC. Previous inventory 

development indicates that locomotives are the most important source of NOX emissions from 

nonroad engines. Ohio is an important rail center in the nation and ranking second in 

Midwestern rail activity after the State of Illinois. The objective of developing an inventory 

through ERTAC was to standardize and improve data quality calculations of railroad 

locomotives by creating a link-level, spatially and temporally allocated emission inventory. 

The calculation of emissions for locomotives is similar to that of on-road mobile sources. Each 

railroad company operates on certain rail lines. Each company has a set of locomotives each 

with a different emission factor. Based upon the mix of locomotives a company has, a weighted 

emission factor for that company can be obtained. The fuel used by each company can then be 

multiplied by the appropriate emission factor to obtain an emission rate. 

The ERTAC Rail group used annual gross ton miles (GTM) and total amount of fuel used for 

each railroad to calculate a railroad fuel consumption index for each railroad in terms of 

GTM/gallon fuel. The GTM for a given link was then divided by the average fuel consumption 

index for all railroads on that link to obtain the fuel consumption for the link. In cases where 

more than one railroad operated on the link, the resulting average fuel consumption index was 

the straight average of the number of railroads operating on the link. The fuel use was then 

multiplied by the emission factor to obtain emissions for the link. Using a GIS, the links were 

summed to the appropriate counties to obtain county level emissions. Daily emissions were 

calculated by dividing the annual emissions by 365. More information regarding the ERTAC Rail 

methodology is available at: 

http://www.ertac.us/rail/index.html

Typical summer day emissions were provided by LADCO assuming typical day and typical 

summer day emissions are equivalent. 

3.4 Emission Inventory Quality Assurance 

Standardized procedures were utilized for emissions calculations. Emission estimates generally 

followed the methodologies outlined in US EPA’s emission inventory preparation guidance 

document, Volumes I-IV and US EPA’s “Reporting Guidance for 1996 Periodic Emissions 

Inventories and National Emission Trends (NET) Inventories.” LADCO spatially and temporally 
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processed the emissions data in accordance with US EPA guidance:” Guidelines on the Use of 

Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, 

PM2.5, and Regional Haze”, EPA-454/B07-002, April 2007. 

Starting with the 2008 inventory year, US EPA made significant changes with their repository 

system, National Emissions Inventory (NEI). The new NEI system allows only quality assured 

data to be entered. The Ohio EPA submitted XML files were quality assured in US EPA’s QA 

environment and a number of corrections were needed to satisfy US EPA’s QA checks. US 

EPA performs format and content checks on State files prior to accepting the files. Corrections 

were made to Ohio’s data to meet US EPA’s strict reporting requirements and data files were 

submitted to US EPA by the deadline. A complex Java application was developed to convert 

Ohio data form STARS2 into US EPA’s NEI XML files. The State relies on this program to meet 

future reporting requirements and any minor change with NEI requires a significant State 

investment to modify the program to satisfy the change. 

The same quality assured data was also submitted to LADCO for emissions processing through 

CONCEPT. There was an exception for the Electric Generating Units (EGUs). The EGU 

inventory is submitted by facilities to US EPA and it is compiled in US EPA’s Acid Rain Program 

application. The EGU inventory is based on an analysis performed by Ohio EPA on facility 

reported emissions as measured by continuous emissions monitors. In conclusion, the final 

point source inventory is a hybrid of the federal EGU inventory and the state provided non-EGU 

units. Throughout the development of the 2008 base year emissions inventory technical reviews 

and accuracy checks were performed. 

 
State Implementation Plan Page 12 

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

Table 1. 2008 VOC Typical Summer Day Emissions 

This table includes VOC emissions estimates developed for a typical summer day in tons 

per day from all sectors in Ohio counties designated nonattainment under the 2008 NAAQS 

for Ozone. 

2008 LADCO TYPICAL SUMMER DAY EMISSIONS FROM NON ATTAINMENT COUNTY SECTORS 

VOC (tpd) 

NAA County/Area NON-EGU EGU AREA ONROAD NONROAD MAR TOTAL VOC 

Ashtabula 12.41 0.00 2.74 3.67 15.03 0.22 34.07 

Cuyahoga 2.44 0.00 42.59 41.99 54.35 0.41 141.78 

Geauga 0.00 0.00 4.53 4.15 5.45 0.00 14.13 

Lake 0.82 0.02 8.95 9.22 19.62 0.14 38.77 

Lorain 2.21 0.18 8.76 11.71 20.08 0.21 43.15 

Medina 0.61 0.00 6.22 7.86 5.88 0.05 20.62 

Portage 0.70 0.00 4.50 6.72 8.64 0.11 20.67 

Summit 0.78 0.00 18.52 21.23 13.35 0.10 53.98 

Cleveland-AkronLorain NAA 19.97 0.20 96.81 106.55 142.40 1.24 367.17 

Delaware 0.43 0.00 5.35 8.74 6.04 0.11 20.67 

Fairfield 0.26 0.00 4.95 5.12 2.40 0.01 12.74 

Franklin 1.67 0.00 35.49 94.25 22.53 0.22 154.16 

Knox 0.00 0.00 3.01 1.76 1.72 0.00 6.49 

Licking 0.30 0.00 6.86 10.03 3.85 0.01 21.05 

Madison 0.07 0.00 2.12 3.51 1.52 0.02 7.24 

Columbus NAA 2.73 0.00 57.78 123.41 38.06 0.37 222.35 

Butler 2.87 0.03 11.61 10.32 6.66 0.13 31.62 

Clermont 0.09 0.51 6.63 6.88 4.42 0.02 18.55 

Clinton 0.00 0.00 2.33 2.51 1.73 0.00 6.57 

Hamilton 1.91 0.27 28.14 30.30 16.86 0.26 77.74 

Warren 0.89 0.00 5.54 7.78 4.92 0.01 19.14 

Cincinnati NAA* 5.76 0.81 54.25 57.79 34.59 0.42 153.62 

Notes: 

tpd tons per day 

NAA nonattainment 

* Cincinnati NAA does not include emissions from partial non-attainment counties 

located outside of Ohio 

 
State Implementation Plan Page 13 

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

Table 2. 2008 NOx Typical Summer Day Emissions 

This table includes NOx emissions estimates developed for a typical summer day in tons 

per day from all sectors in Ohio counties designated nonattainment under the 2008 NAAQS 

for Ozone. 

2008 LADCO TYPICAL SUMMER DAY EMISSIONS FROM NON ATTAINMENT COUNTY SECTORS 

NOX (tpd) 

NAA County/Area NON-EGU EGU AREA ONROAD NONROAD MAR TOTAL NOX

Ashtabula 0.70 5.63 0.35 7.93 4.25 4.70 23.56 

Cuyahoga 8.74 5.41 5.14 78.39 29.41 8.27 135.36 

Geauga 0.00 0.00 0.75 8.14 2.61 0.00 11.50 

Lake 2.05 32.74 1.18 19.01 7.66 2.94 65.58 

Lorain 2.31 21.69 0.94 21.31 9.44 4.48 60.17 

Medina 0.29 0.00 0.90 21.84 4.18 1.05 28.26 

Portage 0.27 0.00 0.86 13.16 3.93 2.14 20.36 

Summit 1.95 0.00 2.59 39.90 9.38 2.08 55.90 

Cleveland-AkronLorain NAA 16.31 65.47 12.71 209.68 70.86 25.66 400.69 

Delaware 0.05 0.00 0.63 19.00 6.01 2.12 27.81 

Fairfield 4.21 0.00 0.51 11.52 3.86 0.12 20.22 

Franklin 1.67 0.00 3.78 168.46 22.93 3.99 200.83 

Knox 0.10 0.00 0.24 3.94 1.95 0.03 6.26 

Licking 1.52 0.00 0.62 20.84 3.67 0.17 26.82 

Madison 0.01 0.00 0.24 7.96 2.30 0.36 10.87 

Columbus NAA 7.56 0.00 6.02 231.72 40.72 6.79 292.81 

Butler 12.53 3.17 0.99 18.76 7.47 2.51 45.43 

Clermont 0.17 65.54 0.76 12.50 3.95 0.87 83.79 

Clinton 0.00 0.00 0.36 5.50 2.00 0.10 7.96 

Hamilton 7.83 30.64 4.19 55.08 15.25 5.53 118.52 

Warren 3.80 0.00 0.87 14.14 5.67 0.28 24.76 

Cincinnati NAA* 24.33 99.35 7.17 105.98 34.34 9.29 280.46 

Notes: 

tpd tons per day 

NAA nonattainment area 

* Cincinnati NAA does not include emissions from partial non-attainment counties 

located outside of Ohio 

 
State Implementation Plan Page 14 

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

Table 3. 2008 VOC Total Annual Emissions 

This table includes VOC emissions estimates developed for a typical summer day in tons 

per day from all sectors in Ohio counties designated nonattainment under the 2008 NAAQS 

for Ozone. 

2008 LADCO TOTAL ANNUAL EMISSIONS FROM NON ATTAINMENT COUNTY SECTORS 

VOC (tpy) 

NAA County/Area NON-EGU EGU AREA ONROAD NONROAD MAR TOTAL VOC 

Ashtabula 4470.93 0.20 1343.60 1327.34 2704.97 70.51 9917.55 

Cuyahoga 873.80 0.17 16798.79 13544.41 11062.21 138.18 42417.56 

Geauga 0.00 0.00 1721.91 891.38 1339.58 0.03 3952.90 

Lake 290.41 4.79 3462.76 2130.40 3406.21 48.09 9342.66 

Lorain 752.12 51.69 3445.68 2759.07 3681.89 72.74 10763.19 

Medina 215.67 0.00 2401.78 1793.48 1389.98 17.94 5818.85 

Portage 253.12 0.00 1784.73 1835.85 1800.31 40.51 5714.52 

Summit 279.96 0.00 7292.82 5420.09 3055.54 37.48 16085.89 

Cleveland-AkronLorain NAA 7136.01 56.85 38252.07 29702.02 28440.69 425.48 104013.12 

Delaware 142.44 0.00 2084.80 1369.67 1346.76 40.45 4984.12 

Fairfield 92.04 0.00 1931.29 1324.74 572.66 1.96 3922.69 

Franklin 598.93 0.00 14157.34 12668.64 5410.72 81.02 32916.65 

Knox 0.00 0.00 1278.75 577.20 372.10 0.35 2228.40 

Licking 108.95 0.00 2645.67 1833.66 853.92 2.34 5444.54 

Madison 24.02 0.00 805.07 803.65 345.70 7.26 1985.70 

Columbus NAA 966.38 0.00 22902.92 18577.56 8901.86 133.38 51482.10

Butler 1018.67 5.69 4527.08 2689.85 1605.05 48.43 9894.77 

Clermont 32.44 168.12 2575.10 1699.44 1005.48 5.18 5485.76 

Clinton 0.00 0.00 993.27 559.80 381.95 1.33 1936.35 

Hamilton 671.93 98.30 11064.69 9001.36 4063.79 91.42 24991.49 

Warren 292.79 0.00 2178.41 1403.74 1133.26 4.81 5013.01 

Cincinnati NAA* 2015.83 272.11 21338.55 15354.19 8189.53 151.17 47321.38

Notes: 

tpy tons per year 

NAA nonattainment area 

* Cincinnati NAA does not include emissions from partial non-attainment counties 

located outside of Ohio 

 
State Implementation Plan Page 15 

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

Table 4. 2008 NOx Total Annual Emissions 

This table includes NOx emissions estimates developed for a typical summer day in tons 

per day from all sectors in Ohio counties designated nonattainment under the 2008 NAAQS 

for Ozone. 

2008 LADCO TOTAL ANNUAL EMISSIONS FROM NON ATTAINMENT COUNTY SECTORS 

NOX (tpy) 

NAA County/Area NON-EGU EGU AREA ONROAD NONROAD MAR TOTAL NOX

Ashtabula 258.95 1463.15 306.68 3788.98 1055.91 1513.24 8386.91 

Cuyahoga 3106.53 1674.57 4438.42 31729.66 8136.17 2747.63 51832.98 

Geauga 0.00 0.00 384.30 2346.92 759.51 0.88 3491.61 

Lake 722.68 10425.10 805.18 5442.55 1870.59 999.07 20265.17 

Lorain 817.83 5577.70 745.02 6523.05 2503.32 1513.69 17680.61 

Medina 100.33 0.00 539.28 5460.96 1292.43 380.91 7773.91 

Portage 87.24 0.00 510.12 5709.05 1182.19 773.11 8261.71 

Summit 674.73 0.00 1919.64 13277.01 2947.01 754.03 19572.42 

Cleveland-AkronLorain NAA 5768.29 19140.52 9648.64 74278.18 19747.13 8682.56 137265.32

Delaware 19.03 0.00 395.05 3490.70 1872.05 767.70 6544.53 

Fairfield 1526.01 0.00 335.34 2842.30 1190.18 41.71 5935.54 

Franklin 582.10 0.00 3225.28 26113.38 7306.02 1443.55 38670.33 

Knox 35.05 0.00 168.31 1266.97 565.91 9.36 2045.60 

Licking 542.86 0.00 411.61 4752.48 1104.17 63.26 6874.38 

Madison 4.99 0.00 128.74 2644.50 635.85 130.91 3544.99 

Columbus NAA 2710.04 0.00 4664.33 41110.33 12674.18 2456.49 63615.37

Butler 4108.89 838.17 703.08 6070.45 2343.53 909.45 14973.57 

Clermont 61.78 24110.39 450.23 4124.55 1215.80 232.43 30195.18 

Clinton 0.00 0.00 196.32 1700.00 551.97 36.12 2484.41 

Hamilton 2803.80 12376.78 2909.18 21335.17 4835.11 1828.87 46088.91 

Warren 1077.03 0.00 493.53 3905.97 1786.32 101.02 7363.87 

Cincinnati NAA* 8051.50 37325.34 4752.34 37136.14 10732.73 3107.89 101105.94

Notes: 

tpy tons per year 

NAA nonattainment area 

* Cincinnati NAA does not include emissions from partial non-attainment counties 

located outside of Ohio 

 
State Implementation Plan Page 16

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

4 Source Emission Statement 

Marginal areas are required to submit an emissions statement under Section 182(a)(3)(B) of the 

CAA (78 FR 34202). The emission statement must: ‘‘. . . require that the owner or operator of 

each stationary source of oxides of nitrogen or volatile organic compounds provide the state 

with a statement, in such form as the Administrator may prescribe (or an equivalent alternative 

developed by the state), for classes or categories of sources, showing the actual emissions of 

oxides of nitrogen and volatile organic compounds from that source. The first such statement 

shall be submitted within 3 years after the date of the enactment of the CAA Amendments of 

1990. Subsequent statements shall be submitted at least every year thereafter. The statement 

shall contain a certification that the information contained in the statement is accurate to the 

best knowledge of the individual certifying the statement” (78 FR 34202). The US EPA has 

proposed that this SIP submittal of the emissions statement program be due 2 years after the 

effective date of designations (78 FR 34203). 

In July 1992, US EPA published a guidance memorandum on source emission statements titled, 

‘Guidance on the Implementation of an Emission Statement Program.’ Further guidance was 

provided to clarify the source emission statement requirements were applicable to all areas 

designated nonattainment for the 1997 ozone NAAQS and classified as Marginal or higher 

under subpart 2, part D, title I of the CAAA. The Proposed Implementation Rule similarly applies 

the memorandum ‘‘Emission Statement Requirements Under 8-hour Ozone NAAQS 

Implementation,’’ dated March 14, 2006, to all areas designated nonattainment for the 2008 

ozone NAAQS and classified as Marginal or higher under subpart 2 (78 FR 34202). 

All of the Ohio 2008 Ozone NAAQS nonattainment areas have an emissions statement program 

in place due to historic nonattainment designations for an earlier ozone NAAQS. The Proposed 

Implementation Rule indicates that “if an area has a previously approved emission statement 

rule in force for the 1997 ozone NAAQS or the 1-hour ozone NAAQS that covers all portions of 

the nonattainment area for the 2008 ozone NAAQS, such rule should be sufficient for purposes 

of the emissions statement requirement for the 2008 ozone NAAQS. The state should review 

the existing rule to ensure it is adequate and, if it is, may rely on it to meet the emission 

statement requirement for the 2008 ozone NAAQS” (78 FR 34203). 

Ohio EPA has the authority under OAC Chapter 3745-24 to request NOx and VOC Emission 

Statements, which applies to any facility located in a county that is out of attainment for the 

NAAQS for ozone and emits greater than or equal to 25 tons per year of VOC or NOx during the 

reporting year. In general, facilities subject to this requirement must submit actual emissions 

data for NOx and VOC. OAC Chapter 3745-24 is available at: 

http://www.epa.ohio.gov/dapc/regs/3745_24.aspx. 

Ohio’s current emission statement program was approved by US EPA into Ohio’s SIP on 

September 27, 2007 (72 FR 54844). 
State Implementation Plan Page 17

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

5 Projected Emissions Modeling 

US EPA provided 2015 design value estimates for hypothetical 8-hour ozone 

nonattainment areas for the 2008 Ozone NAAQS. The projected 2015 design values 

were presented as supporting material for the rules to implement the 8-hour Ozone 

NAAQS. The projections were developed using measured 2008-2010 design value 

information from the Cross State Air Pollution Rule (CSAPR) final rule modeling. The 

original CSAPR modeling made projections for 2014 using a base year of 2005 (a 9-

year projection). The percentage change of ozone over the modeled 9 year period was 

apportioned to develop estimates for the projected change in ozone between the 

measured 2008-2010 period and the 2015 Marginal attainment demonstration year. The 

results of this analysis are presented in Table 5. The highest design value for each 

nonattainment area based on actual measured data is presented for the 2008-2010 

period. The highest projected values for the year 2015 are also presented for each of 

the three Ohio designated NAAs. All three Ohio areas are projected to attain the 2008 

Ozone NAAQS by the year 2015. The spreadsheets and methodology for these 

projections are included in Appendix M (US EPA, 2012). 

Table 5. US EPA Projected 2015 Ozone Design Values 

This table shows the projected ozone design values in the three Ohio 2008 NAAQS 

nonattainment areas. All three nonattainment areas are projected to be in attainment by 

2015. 

State 2008 Ozone NAAQS Nonattainment 

Area Name 

Area 

Classification 

Highest 

Measured 

2008-2010 

Ozone Design 

Value 

Highest 

Projected 

2015 Ozone 

Design 

Value 

Projected 

to Attain 

by 2015? 

Ohio CincinnatiǦHamilton, OH-KY-IN Marginal 79 74 Yes 

Ohio ClevelandǦAkronǦLorain, OH Marginal 77 72.2 Yes 

Ohio Columbus, OH Marginal 77 71.3 Yes 

Adapted from "Spreadsheet estimates 2015 design values for hypothetical 8-hour ozone nonattainment 

areas for the 75 ppb NAAQS for the purpose of estimating the number of marginal nonattainment areas 

that are expected to attain the NAAQS by their attainment date (2015)" EPA-HQ-OAR-2010-0885-0011
State Implementation Plan Page 18

2008 Eight-Hour Ozone NAAQS Emissions Inventory & Emissions Statement 

Ohio Environmental Protection Agency 

July 2014 

6 References 

Energy and Environmental Research Associates (EERA), LLC, Comer, B., Corbett. J., 

Silberman, J., Alpine Geophysics, Stella, G., 2011. “Commercial Marine Emissions in the 

LADCO Region Final Report”. Final. September 2011. 

E.H. Pechan, 2004. “LADCO Nonroad Emissions Inventory Project – Development of Local 

Data for Construction and Agricultural Equipment”, Final Report. September 10, 2004 

 

Environ, 2004. “LADCO Nonroad Emissions Inventory Project for Locomotive, Commercial 

Marine, and Recreational Marine Emission Sources”, Final Report. December 2004. 

 

Environ, 2007a. “LADCO 2005 Locomotive Emissions”, Draft. February 2007. 

 

Environ, 2007b. “LADCO 2005 Commercial Marine Emissions”, Draft. March 2, 2007. 

US EPA, 2012. “Spreadsheet estimates 2015 design values for hypothetical 8-hour ozone 

nonattainment areas for the 75 ppb NAAQS for the purpose of estimating the number of 

marginal nonattainment areas that are expected to attain the NAAQS by their attainment 

date (2015)". February 14, 2012.