IEnvironmental

I Protection Agency

John Kasich, Governor

Mary Taylor, Lt. Governor

Scott J. Nally, Director

JuN 3 2011

Ms. Susan Hedman

Regional Administrator

U.S. EPA Region 5

77 W. Jackson Blvd.

Chicago, IL 60604

Re: PM2.5 Redesignation Request and Maintenance Plan for the 1997 PM2.5 Annual

Standard for the Columbus Area

Dear Administrator Hedman:

I am writing to formally request a redesignation to attainment of the Columbus area

(Delaware, Licking, Fairfield, and Franklin Counties and Franklin Township in

Coshocton County) with respect to the 1997 PM2.5 annual standard. The enclosed

submittal combines the redesignation request and the required maintenance plan for

this area.

Monitoring of existing air quality indicates that the 1997 National Ambient Air Quality

Standard (NAAQS) for PM2.5 has been attained throughout this area based on" 2008-

2010 air quality data. Emissions projections indicate that current controls, existing State

rules, existing federal rules, and Ohio's PSD program will be more than sufficient to

maintain the NAAQS indefinitely into the future. These programs will, therefore,

constitute the attainment and maintenance plan for the Columbus area. .

The enclo·sed information, compiled by the Ohio Environmental Protection Agency (Ohio

EPA), Ohio Department of Transportation, and the Mid-Ohio Regional Planning

Commission (MORPC), shows significant emission reductions in point and mobile

sources since ambient exceedances have occurred. A significant portion of the

improved air quality can be attributed to federal programs for the mobile source sector,

the regional reductions associated with the NOx Trading Program, and the Clean Air

Interstate Rule (CAIR).

Ohio EPA notified the public of the draft and the opportunity to provide comments on

March 14, 2011. The public hearing for this package was held on April 21, 2011, in

Columbus, Ohio.

50 West Town street, Suite 700

P.O. Box 1049

Columbus,OH 43216-1049

614 I 644 3020

614 I 644 3184 (fax)

www.epa.ohio.gov
If you have questions, please contact Jennifer Hunter in our Division of Air Pollution

Control at (614) 644-3696.

Sincerely,

/~Scott J. Nalty

Director

Enclosure
 

REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR 

THE COLUMBUS 

ANNUAL PM2.5

NONATTAINMENT AREA 

Coshocton, Delaware, Fairfield, Franklin, 

and Licking Counties, Ohio 

Prepared by: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

May 2011 
 

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TABLE OF CONTENTS 

Chapter One 

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

Geographical description and background .................................................................................. 2 

Status of air quality ....................................................................................................................... 3 

Chapter Two 

Requirements for redesignation .................................................................................................... 4 

Chapter Three 

PM2.5 monitoring ............................................................................................................................ 8 

Annual PM2.5 NAAQS .................................................................................................................... 8 

Ambient data quality assured ........................................................................................................ 9 

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

Commitment to continue monitoring ........................................................................................... 12 

Chapter Four 

Emission inventory ...................................................................................................................... 13 

Base year inventory .................................................................................................................... 13 

Emission projections ................................................................................................................... 14 

Demonstration of maintenance ................................................................................................... 21 

Permanent and enforceable emissions reductions ..................................................................... 33 

Provisions for future update ........................................................................................................ 33 

Chapter Five 

Control measures and regulations .............................................................................................. 35 

Marginal nonattainment areas to implement RACM and RACT .................................................. 35 

Show Reasonable Further Progress (RFP) ................................................................................ 37 

Emission inventories ................................................................................................................... 37 

Implementation of past SIP revisions .......................................................................................... 38 

New source review provisions ................................................................................................... 40 

Assurance of continued controls ................................................................................................. 40 

Chapter Six 

Contingency measures ............................................................................................................... 41 

Commitment to revise plan ......................................................................................................... 41 

Commitment for contingency measures ..................................................................................... 41 

Potential contingency measures ................................................................................................. 42 

List of PM2.5, SO2, and NOx sources ........................................................................................... 43 

Chapter Seven 

Public participation ...................................................................................................................... 44 

Chapter Eight 

Conclusions ................................................................................................................................ 45 
FIGURES 

Figure 1 Map of the Columbus nonattainment area and monitor locations ......................... 9 

Figure 2 PM2.5 Annual Mean Trends LADCO States ......................................................... 11 

Figure 3 PM2.5 Annual Mean Trends Midwest States ........................................................ 11 

Figure 4 PM2.5 Annual Mean National Trends .................................................................. 12 

TABLES 

Table 1 Monitoring Data for Columbus area for 2008 - 2010 ........................................... 10 

Table 2 Coshocton County, Emission Estimations for On-road Mobile Sources .............. 18 

Table 3 Delaware County, Emission Estimations for On-road Mobile Sources ................ 18 

Table 4 Fairfield County, Emission Estimations for On-road Mobile Sources .................. 19 

Table 5 Franklin County, Emission Estimations for On-road Mobile Sources .................. 19 

Table 6 Licking County, Emission Estimations for On-road Mobile Sources .................... 19 

Table 7 Emissions Estimations Totals for On-road Mobile Sources for the 

 Columbus Area .................................................................................................... 19 

Table 8 Mobile Vehicle Emission Budget ......................................................................... 20 

Table 9 Reductions in SO2 and NOx EGU Emissions Between 2008 and 2009. ............. 23 

Table 10 Reductions in SO2 and NOx EGU Emissions Between the First Half of 2008 

 and 2010.... ......................................................................................................... 24 

Table 11 Coshocton County, PM2.5 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR ................ 25 

Table 12 Delaware County, PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 26 

Table 13 Fairfield County, PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 26 

Table 14 Franklin County, PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 26 

Table 15 Licking County, PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR ................ 27 

Table 16 Columbus Area PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 27 

Table 17 Coshocton County, NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 27 

Table 18 Delaware County, NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 28 

Table 19 Fairfield County, NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 28 

Table 20 Franklin County, NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 28 

Table 21 Licking County, NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 29 

Table 22 Columbus Area NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 29 

Table 23 Coshocton County, SO2 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 29 

Table 24 Delaware County, SO2 Emission Inventory Totals for Base Year 2005, 
 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 30 

Table 25 Fairfield County, SO2 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 30 

Table 26 Franklin County, SO2 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 30 

Table 27 Licking County, SO2 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 31 

Table 28 Columbus Area SO2 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 31 

Table 29 Columbus Area Comparison of 2008 attainment year and 2015 and 2022 

projected emission estimates (tpy) ...................................................................... 31 

Table 30 Columbus Area Combined Comparison of 2005 base year and 2008 

 attainment year on-road and EGU reductions ..................................................... 33 

APPENDICES 

A Air Quality System (AQS) Data 

B Ohio 2005 SIP Base Year Inventory Discussion 

C Central Ohio On-Road Mobile Emissions Estimates 

D LADCO Technical Support Document 

E Public Participation Documentation 
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1 

REDESIGNATION REQUEST AND MAINTENANCE PLAN 

FOR THE COLUMBUS 

ANNUAL PM2.5 NONATTAINMENT AREA 

Coshocton, Delaware, Fairfield, Franklin and Licking Counties, Ohio 

CHAPTER ONE 

Introduction 

The Clean Air Act (CAA), as amended, requires each State with areas failing to meet the 

annual National Ambient Air Quality Standards (NAAQS) PM2.5

1

 to develop State 

Implementation Plans (SIPs) to expeditiously attain and maintain the standards. The United 

States Environmental Protection Agency (U.S. EPA) revised the NAAQS for particulate 

matter in July 1997. It replaced the existing PM10 standard with a health-based PM2.5 

standard and retained the PM10 standard as a particulate standard protecting welfare. The 

standards include an annual standard set at 15.0 micrograms per cubic meter (μg/m3), 

based on the 3-year average of annual mean PM2.5 concentrations, and a 24-hour standard 

of 65 μg/m3, based on the 3-year average of the 98th percentile of 24-hour concentrations. 

The revised NAAQS was legally challenged in the U.S. Court of Appeals for the District of 

Columbia Circuit (the D.C. Circuit). On May 14, 1999, the D.C. Circuit remanded, without 

vacatur, the standards back to U.S. EPA. The remand did not question the level at which 

U.S. EPA set the standards but rather the constitutionality of the CAA provision that 

authorizes U.S. EPA to set national air quality standards. U.S. EPA requested a rehearing 

which the D.C. Circuit denied. Therefore, in December 1999, U.S. EPA appealed the D.C. 

Circuit decision to the U.S. Supreme Court. The U.S. Supreme Court issued a decision on 

February 27, 2001 that unanimously affirmed the constitutionality of the CAA provision but 

did remand several other issues back to the D.C. Circuit, including the issue of whether 

U.S. EPA acted arbitrarily and capriciously in establishing the specific levels of the 

standards. 

The D.C. Circuit heard arguments in this remanded case in December 2001, and issued its 

decision on March 26, 2002. The D.C. Circuit rejected the claims that the U.S. EPA had 

acted arbitrarily and capriciously in setting the levels of the standards. 

On December 17, 2004, U.S. EPA promulgated the initial PM2.5 nonattainment areas 

designations for the PM2.5 standards across the country. Modifications to those 

 

1 Particle pollution is a mixture of microscopic solids and liquid droplets suspended in air. This pollution, also known 

as particulate matter, is made up of a number of components, including acids (such as nitrates and sulfates), organic 

chemicals, metals, soil or dust particles, and allergens (such as fragments of pollen or mold spores). 

Fine particle pollution or PM2.5 describes particulate matter that is 2.5 micrometers in diameter and smaller - 1/30th 

the diameter of a human hair. Fine particle pollution can be emitted directly or formed secondarily in the atmosphere. 
2 

designations were made and an effective date was set at April 5, 2005. Unlike Subpart 2 of 

the CAA Amendments of 1990 which defined five ozone nonattainment classifications for 

the areas that exceed the NAAQS based on the severity of the ozone levels, PM2.5

nonattainment designations are simply labeled “nonattainment.” The CAA Amendments 

require states with PM2.5 nonattainment areas to submit a plan within three years of the 

effective date of the designations (April 5, 2008) detailing how the PM2.5 standards will be 

attained by April 5, 2010. Ohio EPA submitted its attainment demonstration for the entire 

State of Ohio on July 16, 2008. 

Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas to be 

redesignated to attainment provided certain criteria are met. The following are the criteria 

that must be met in order for an area to be redesignated from nonattainment to attainment: 

i) A determination that the area has attained the PM2.5 standard.

ii) An approved State Implementation Plan (SIP) for the area under Section 110(k).

iii) A determination that the improvement in air quality is due to permanent and 

enforceable reductions in emissions resulting from implementation of the SIP and 

other federal requirements.

iv) A fully approved maintenance plan under Section 175(A).

v) A determination that all Section 110 and Part D requirements have been met. 

This document addresses each of these requirements, and provides additional information 

to support continued compliance with the annual PM2.5 standard. 

 

Geographical Description and Background 

The current Columbus nonattainment area is located in central Ohio and includes the 

following counties: Coshocton (partial nonattainment of Franklin Township only), Delaware, 

Fairfield, Franklin and Licking. This area is shown in Figure 1 under Chapter Three. 

The Columbus area has not previously been subject to nonattainment area rulemakings for 

fine particles. 

As a result of the 2005 PM2.5 designations, U.S. EPA designated the Columbus area 

nonattainment for the 15.0 μg/m3 annual standard2

, and Ohio EPA was required to develop 

a plan to reduce oxides of nitrogen (NOx), sulfur dioxide (SO2) and direct PM2.5 emissions 

and to demonstrate that the area will meet the federal annual air quality standard by April 5, 

2010. Ohio’s main PM2.5 components are primary particles (organic carbon, crustal 

material, and elemental carbon), SO2 and NOx, which were included in the attainment 

demonstration analysis. Volatile organic compounds (VOCs) and ammonia (NH3) were not 

included in the analysis since they were not part of Ohio’s current attainment strategy for 

PM2.5 (although controls for VOCs have been implemented for ozone nonattainment). This 

is consistent with U.S. EPA’s “Clean Air Particle Implementation Rule” [74FR 20856] 

 

2 There were no monitors in Ohio that violated the 1997 24-hour PM2.5 standard of 65 μg/m3. 
3 

(hereafter referred to as “Implementation Rule”). In the Implementation Rule, U.S. EPA 

presumes NH3 emissions are not a PM2.5 attainment plan precursor and that States are not 

required to address VOC unless the State or U.S. EPA makes technical demonstration that 

emissions of VOCs significantly contribute to nonattainment of the annual PM2.5 standard. 

This document is intended to support Ohio’s request that the Columbus area be 

redesignated from nonattainment to attainment for the annual PM2.5 standard. 

Status of Air Quality 

PM2.5 complete quality-assured ambient air quality monitoring data for the most recent 

three (3) years, 2008 through 2010, demonstrate that the air quality has met the NAAQS for 

annual PM2.5 in this nonattainment area. The NAAQS attainment, accompanied by 

decreases in emission levels discussed in Chapter Four, supports a redesignation to 

attainment for the Columbus area based on the requirements in Section 107(d)(3)(E) of the 

CAA as amended. 
4 

CHAPTER TWO 

Requirements for Redesignation 

U.S. EPA has published detailed guidance in a document entitled Procedures for 

Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued 

September 4, 1992, to Regional Air Directors. The redesignation request and maintenance 

plan are based on the redesignation guidance, supplemented with additional guidance 

received from staff of U.S. EPA Region 5. 

Below is a summary of each redesignation criterion as it applies to the Columbus area. 

i.) Attainment of the standard (CAA Section 107(d)(3)(E)(i)) 

There are two components involved in making this demonstration. The first 

component relies on ambient air quality data. The data that are used to 

demonstrate attainment should be the product of ambient monitoring that is 

representative of the area of highest concentration. The data should be 

collected and quality-assured in accordance with 40 CFR 58 and recorded in 

the Air Quality System (AQS) in order for it to be available to the public for 

review. 

The second component relies upon supplemental U.S. EPA-approved air 

quality modeling. While no modeling is required for redesignating 

nonattainment areas, the redesignation guidance states it is “generally 

necessary” for particulate matter redesignations. Appendix C and Appendix 

D contains the most recent modeling results showing future attainment and 

maintenance are provided. Chapter Three discusses this requirement in 

more detail and provides the attainment demonstration. 

ii.) Permanent and enforceable improvement in air quality (CAA Section 

107(d)(3)(E)(iii)) 

The state must be able to reasonably attribute the improvement in air quality 

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

well as control measures that have been adopted and implemented by the 

state. 

It was not necessary for Ohio to adopt or implement control measures for 

these counties beyond the federal measures. 

Ohio EPA has adopted several rules recently that will have an impact 

statewide on PM2.5 emissions in the future: 

• Clean Air Interstate Rule (CAIR) 

• NOx SIP Call Rules 
5 

In addition, since the initial designations were made federally enforceable 

consent decrees have resulted in reductions in emissions from utilities across 

the state. 

Chapters Four and Five discuss this requirement in more detail. 

iii.) Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v)) 

For purposes of redesignation, a state must meet all requirements of Section 

110 and Part D that were applicable prior to submittal of the complete 

redesignation request. 

Subpart 1 of Part D consists of general requirements applicable to all areas 

which are designated nonattainment based on a violation of the NAAQS. 

Subpart 4 of Part D consists of more specific requirements applicable to 

particulate matter (specifically to address PM10). However, for the purpose of 

implementing the 1997 PM2.5 standard, U.S. EPA’s Implementation Rule 

stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of 

implementing PM2.5.[72 FR 20589] 

i.) Section 110(a) requirements 

Section 110(a) of Title I of the CAA contains the general requirements 

for a SIP. Section 110(a)(2) provides that the implementation plan 

submitted by a state must have been adopted by the state after 

reasonable public notice and hearing, and that, among other things, it 

must include enforceable emission limitations and other control 

measures, means or techniques necessary to meet the requirements 

of the CAA; provide for establishment and operation of appropriate 

devices, methods, systems and procedures necessary to monitor 

ambient air quality; provide for implementation of a source permit 

program to regulate the modification and construction of any 

stationary source within the areas covered by the plan; include 

provisions for the implementation of Part C, prevention of significant 

deterioration (PSD) and Part D, NSR permit programs; include criteria 

for stationary source emission control measures, monitoring, and 

reporting; include provisions for air quality modeling; and provides for 

public and local agency participation in planning and emission control 

rule development. In Ohio’s December 5, 2007 and September 4, 

2009 infrastructure SIP submissions, Ohio verified that the State 

fulfills the requirements of Section 110(a)(2) of the Act. 

Section 110(a)(2)(D) also requires State plans to prohibit emissions 

from within the State which contribute significantly to nonattainment or 

maintenance areas in any other State, or which interfere with 
6 

programs under Part C to prevent significant deterioration of air quality 

or to achieve reasonable progress toward the national visibility goal for 

Federal class I areas (national parks and wilderness areas). In order 

to assist States in addressing their obligations regarding regionally 

transported pollution, U.S. EPA finalized CAIR to reduce SO2 and NOx

emissions from large electric generating units (EGU). Ohio has met 

the requirements of the federal CAIR to reduce NOx and SO2

emissions contributing to downwind states. On February 1, 2008, U.S. 

EPA approved Ohio’s CAIR program, which can be found in Ohio 

Administrative Code (OAC) Chapter 3745-1093

. On July 6, 2010, U.S. 

EPA proposed a replacement to the CAIR program, the Transport 

Rule. [75 FR 45210] Upon finalization, it will further assist States in 

addressing their obligations regarding regionally transported pollution 

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

ii.) Section 172(c) requirements 

This Section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for an 

emission inventory will be satisfied by the inventory requirements of 

the maintenance plan. Chapters Four and Five discuss this 

requirement in more detail. 

iii.) Conformity 

The state must work with U.S. EPA to show that its SIP provisions are 

consistent with the Section 176(c)(4) conformity requirements. The 

redesignation request should include conformity procedures, if the 

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

conformity procedures in place at the time that it submits a 

redesignation request, the state must commit to follow U.S. EPA’s 

conformity regulation upon issuance, as applicable. 

iv.) Maintenance plans (CAA Section 107(d)(3)(E)(iv)) 

Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA 

must fully approve a maintenance plan that meets the requirements of 

Section 175(A). The maintenance plan will constitute a SIP revision and must 

provide for maintenance of the relevant NAAQS in the area for at least 10 

years after redesignation. Section 175 (A) further states that the plan shall 

contain such additional measures, if any, as may be necessary to ensure 

such maintenance. 

 

3 http://www.epa.ohio.gov/dapc/regs/regs.aspx#3745-109 
7 

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

violation of the NAAQS. At a minimum, the contingency measures must 

include a requirement that the state will implement all measures contained in 

the nonattainment SIP prior to redesignation. 

States seeking redesignation of a nonattainment area should consider the 

following provisions: 

a.) attainment inventory; 

b.) maintenance demonstration; 

c.) monitoring network; 

d.) verification of continued attainment; and 

e.) contingency plan. 

 Chapter Six discusses this requirement in more detail. 
8 

CHAPTER THREE 

PM2.5 MONITORING 

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

Requirement 1 of 4 

A demonstration that the NAAQS for annual PM2.5, as published in 40 CFR 50.7, has been 

attained. 

Background

There are three monitors measuring PM2.5 concentrations in this nonattainment 

area, all of them in Franklin County. These monitors are operated by Ohio EPA 

Division of Air Pollution Control, Central District Office. A listing of the design 

values based on the three-year average of the annual mean concentrations 

from 2008 through 2010 is shown in Table 1. The locations of the monitoring 

sites for this nonattainment area are shown on Figure 1. 
9 

Demonstration

 

Figure 1 - Map of the Columbus nonattainment area and monitor locations 

Requirement 2 of 4 

Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in the 

U.S. EPA air quality system (AQS) database, and available for public view. 

Demonstration

Ohio EPA has quality assured all data shown in Appendix A in accordance with 40 

CFR 58.10 and all other federal requirements. Ohio EPA has recorded the data in the 

AQS database and, therefore, the data are available to the public. 

Requirement 3 of 4 

A showing that the three-year average of the annual mean values, based on data from all 

monitoring sites in the area or its affected downwind environs, are below 15.0 μg/m3

. (This 

showing must rely on three complete, consecutive calendar years of quality assured data.) 

Background

The following information is taken from U.S. EPA's "Guideline on Data 

Handling Conventions for the PM NAAQS," U.S. EPA-454/R-99-008, April 

1999. 
10 

In accordance with the CAA Amendments, three complete years of monitoring 

data are required to demonstrate attainment at a monitoring site. The annual 

PM2.5 primary and secondary ambient air quality standards are met at an 

ambient air quality monitoring site when the three-year average of the annual 

average is less than 15.0 μg/m3. While calculating design values, three 

significant digits must be carried in the computations, with final values rounded 

to the nearest 0.1 μg/m3

. Decimals 0.05 or greater are rounded up, and those 

less than 0.05 are rounded down, so that 15.049 μg/m3 is the largest 

concentration that is less than, or equal to 15.0 μg/m3. Values at or below 15.0 

μg/m3 meet the standard; values equal to or greater than 15.1 μg/m3 exceed 

the standard. An area is in compliance with the annual PM2.5 NAAQS only if 

every monitoring site in the area meets the NAAQS. An individual site's 3-year 

average of the annual average concentrations is also called the site's design 

value. The air quality design value for the area is the highest design value 

among all sites in the area. 

Table 1 shows the monitoring data for 2008 – 2010 that were retrieved from 

the U.S. EPA AQS. The air quality design value for the area is the highest 

design value among all sites in the area. 

Demonstration

Table 1 - Monitoring Data for the Columbus area for 2008 – 2010 

Average

2008 2009 2010 2008-2010

39-049-0024 12.8 11.5 13.1 12.5

39-049-0025 12.4 11.5 12.6 12.2

39-049-0081 11.1 10.8 11.9 11.3

Less than 75% capture in at least one quarter

Franklin

Annual Standard

Site County Year

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

The design values calculated for the Columbus area demonstrate that the annual 

PM2.5 NAAQS has been attained. The area's design values have trended downward 

as emissions have declined due to such factors as cleaner automobiles and fuels, and 

controls for EGUs, at the national, regional and local level. 

National monitoring for PM2.5 began in 1999. With respect to each of the Lake 

Michigan Air Directors Consortium (LADCO) states, there has been a clear downward 

trend in design values: 
11 

Figure 2 - PM2.5 Annual Mean Trends LADCO States 

Source: LADCO; Recent Ozone and PM2.5 Trends – Aug 26 2010.pptx

The same trend can be seen within the Midwest States as a whole: 

Figure 3 - PM2.5 Annual Mean Trends Midwest States 

Source: LADCO; Recent Ozone and PM25 Trends - Aug 26 2010.pptx 
12 

Design values have also trended downward nationally: 

Figure 4 - PM2.5 Annual Mean National Trends 

Source: http://www.epa.gov/airtrends/pm.html 

Requirement 4 of 4 

A commitment that once redesignated, the state will continue to operate an appropriate 

monitoring network to verify the maintenance of the attainment status. 

Demonstration

Ohio EPA commits to continue monitoring PM2.5 levels at the Ohio sites 

indicated in Figure 1 and Table 1. Ohio EPA will consult with U.S. EPA Region 

5 prior to making changes to the existing monitoring network, should changes 

become necessary in the future. Ohio EPA will continue to quality assure the 

monitoring data to meet the requirements of 40 CFR 58 and all other federal 

requirements. Connection to a central station and updates to the Ohio EPA 

web site4 will provide real time availability of the data and knowledge of any 

exceedances. Ohio EPA will enter all data into AQS on a timely basis in 

accordance with federal guidelines. 

 

4 www.epa.ohio.gov/dapc 
13 

CHAPTER FOUR 

EMISSION INVENTORY

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

U.S. EPA’s redesignation guidance requires the submittal of a comprehensive inventory of 

PM2.5 precursor emissions (primary particles (organic carbon, crustal matter, and elemental 

carbon), SO2 and NOx

5

) representative of the year when the area achieves attainment of 

the annual PM2.5 air quality standard. Ohio also must demonstrate that the improvement in 

air quality between the year that violations occurred and the year that attainment was 

achieved is based on permanent and enforceable emission reductions. Other emission 

inventory related requirements include a projection of the emission inventory to a year at 

least 10 years following redesignation; a demonstration that the projected level of 

emissions is sufficient to maintain the annual PM2.5 standard; and a commitment to provide 

future updates of the inventory to enable tracking of emission levels during the 10-year 

maintenance period. 

The emissions inventory development and emissions projection discussion below, with the 

exception of the mobile (on-road) emissions inventory and projections, identifies 

procedures used by Ohio EPA and the LADCO regarding emissions of all the counties in 

the Columbus area. All of these inventories and emissions projections were prepared using 

similar methodologies. Mobile emissions inventories and projections for all counties were 

prepared by the Mid-Ohio Regional Planning Commission (MORPC) and the Ohio 

Department of Transportation (ODOT). 

Requirement 1 of 5 

A comprehensive emission inventory of PM2.5, SO2 and NOx completed for the base 

year. 

Background

The point source data are taken from Ohio's annual emissions reporting 

program. The 2005 periodic inventory has been identified as one of the 

preferred databases for SIP development and coincides with nonattainment 

air quality in the Columbus area. 

Periodic inventories, which include emissions from all sectors - mobile, area, 

non-road, and point sources - are prepared every three years. 

Demonstration

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

and was submitted to U.S. EPA with Ohio’s PM2.5 attainment demonstration 

SIP submitted on July 18, 2008 and revised on June 7, 2010. The detailed 

 

5 VOC and NH3 are not addressed. 
14 

emission inventory information for the Columbus area is provided in Appendix 

B. Emissions of PM2.5, SO2 and NOx for 2005 are identified under 

Requirement Three of this Chapter. 

Requirement 2 of 5 

A projection of the emission inventory to a year at least 10 years following redesignation. 

Background

Ohio EPA prepared a comprehensive inventory for the Columbus area including 

area, mobile, and point sources for PM2.5, SO2 and NOx for base year 2005. The 

2005 inventory was submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM2.5

attainment demonstration SIP for this area. The information below describes the 

procedures Ohio EPA used to generate the 2005 base year inventory and to 

develop SIP-ready modeling inventories and future year projections (Pechan 

Report6

) based on a 2005 base year inventory. The report by Pechan generated 

future year estimates of annual emissions for each source sector using accepted 

growth surrogates. These inventories were provided to the LADCO and have been 

processed to develop average daily emissions for use in the air quality analyses. 

These processed modeling inventories have been identified as the correct iteration 

of the inventory for use in the redesignation. In this document, references to LADCO 

include the Midwest Regional Planning Organization. Note, the on-road mobile 

source sector was addressed by specific PM2.5 and NOx modeling as discussed 

below. 

• Area sources were taken from the Ohio 2005 periodic inventory 

submitted to U.S. EPA. These projections were made from the U.S. 

Department of Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information. 

• Mobile source emissions were calculated from MOVES2010 -

produced emission factors. Only PM2.5 and NOx necessitate emissions 

inventory analysis. As documented in Ohio EPA’s attainment 

demonstration SIP, Ohio EPA in consultation with U.S. EPA 

determined mobile sources are insignificant contributors for SO2. 

Consistent with Ohio EPA’s attainment demonstration, Ohio EPA 

continues to consider mobile source SO2 to be an insignificant 

contributor to fine particles for this nonattainment area. Based on the 

demonstration below, SO2 constitutes less than one percent (<1%) of 

the area’s total SO2 emissions in 2005, 2008, 2015 and 2022 (ranging 

between 0.28% and 0.76%). 

 

6 

http://www.ladco.org/tech/emis/r5/reports/LADCO%202005%20Base%20Yr%20Growth%20and%20Controls%20Rep

ort_Final.pdf 
15 

• Point source information was compiled from Ohio EPA’s 2005 annual 

emissions inventory database and the 2005 U.S. EPA Air Markets 

acid rain database7. 

• Biogenic emissions are not included in these summaries. 

• Non-road emissions were generated using U.S. EPA’s National Mobile 

Inventory Model (NMIM) 2002 application. To address concerns about 

the accuracy of some of the categories in U.S. EPA’s non-road 

emissions model, LADCO contracted with two (2) companies to 

review the base data and make recommendations. One of the 

contractors also estimated emissions for three (3) non-road categories 

not included in U.S. EPA’s non-road model. Emissions were estimated 

for aircraft, commercial marine vessels, and railroads. Recreational 

motorboat population and spatial surrogates (used to assign 

emissions to each county) were significantly updated. The populations 

for the construction equipment category were reviewed and updated 

based upon surveys completed in the Midwest, and the temporal 

allocation for agricultural sources also was updated. 

 

Demonstration

On-Road Emission Estimations 

The Columbus nonattainment area for the on-road emission estimation 

analysis is divided into a modeled area comprised of Franklin, Delaware, 

Licking Counties and part of Fairfield County, and into the donut area which 

includes the remainder of Fairfield County and Franklin Township in 

Coshocton County. The model coverage area uses the post-processor linklevel procedures to compute the emissions, while the non-modeled donut 

areas will utilize ODOT’s Highway Performance Monitoring Systems (HPMS) 

county level vehicle miles traveled (VMT) by functional class data (see 

Appendix C for further details). The travel demand model provides, among 

other things, daily traffic volumes, congested travel times, speeds, volume to 

capacity ratios, vehicle miles traveled, and vehicle hours traveled. Areas that 

are not within the regional travel demand model boundary utilize HPMS 

based on travel characteristics data. The travel demand model was used in 

evaluating emissions for Franklin, Delaware, and Licking Counties; both the 

travel demand model and the HPMS were used in evaluating emissions for 

Fairfield County, and HPMS alone was used for Franklin Township, 

Coshocton County, in evaluating emissions. 

 

7 http://www.epa.gov/airmarkets/acidrain 
16 

Overview 

U.S.EPA published a Federal Register notice8 of availability on March 2, 

2010, to approve MOVES2010 (Motor Vehicle Emissions Simulator), 

hereafter referred to as MOVES. Upon publication of the Federal Register 

notice, MOVES became U.S. EPA’s approved motor vehicle emission factor 

model for estimating VOCs, NOx, CO, PM10 and PM2.5 and other pollutants 

and precursors from cars, trucks, motorcycles, and buses by state and local 

agencies. MOVES is a computer program designed by the U.S. EPA to 

estimate air pollution emissions from mobile sources. MOVES replaces U.S. 

EPA’s previous emissions model for on-road mobile sources, MOBILE6.2. 

MOVES can be used to estimate exhaust and evaporative emissions as well 

as brake and tire wear emissions from all types of on-road vehicles. 

The CAA requires U.S. EPA to regularly update its mobile source emission 

models. U.S. EPA continuously collects data and measures vehicle emissions to make sure the Agency has the best possible understanding of 

mobile source emissions. This assessment, in turn, informs the development 

of U.S. EPA’s mobile source emission models. MOVES represents the 

Agency’s most up-to-date assessment of on-road mobile source emissions. 

MOVES also incorporates several changes to the U.S. EPA’s approach to 

mobile source emission modeling based upon recommendations made to the 

Agency by the National Academy of Sciences. 

U.S.EPA believes that MOVES should be used in ozone, CO, PM, and 

nitrogen dioxide SIP development as expeditiously as possible. The CAA 

requires that SIP inventories and control measures be based on the most 

current information and applicable models that are available when a SIP is 

developed. 

The MOVES more detailed approach (when compared with the previous 

MOBILE model) to modeling allows U.S. EPA to easily incorporate large 

amounts of in-use data from a wide variety of sources, such as data from 

vehicle inspection and maintenance (I/M) programs, remote sensing device 

(RSD) testing, certification testing, portable emission measurement systems 

(PEMS), etc. This approach also allows users to incorporate a variety of 

activity data to better estimate emission differences such as those resulting 

from changes to vehicle speed and acceleration patterns. MOVES has a 

graphical user interface which allows users to more easily set up and run the 

model. MOVES database-centered design provides users much greater 

flexibility regarding output choices. Unlike earlier models which provided 

emission factors in grams-per-mile in fixed output formats, MOVES output 

can be expressed as total mass (in tons, pounds, kilograms, or grams) or as 

 

8 http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ab1f98 
17 

emission factors (grams-per-mile and in some cases grams-per-vehicle). 

Output can be easily aggregated or disaggregated to examine emissions in a 

range of scales, from national emissions impacts down to the emissions 

impacts of individual transportation projects. The database-centered design 

also allows U.S. EPA to update emissions data incorporated in MOVES more 

easily and will allow users to incorporate a much wider array of activity data to 

improve estimation of local emissions. For example, the improvements in 

MOVES will allow project-level PM2.5 emissions to be estimated. 

The latest planning assumptions available for the Central Ohio area were 

used. For the travel demand model, model validation is a joint process 

between MORPC, LCATS9

, and the ODOT Office of Technical Services. The 

model is a multi-step tour-based model. Nonattainment area within regional 

the model are included (Franklin, Delaware, Licking Counties and part of 

Fairfield County). Areas outside the regional model are remainder of Fairfield 

County and Franklin Township in Coshocton County. Forecasted variables 

such as population, employment, traffic counts, and roadway network, were 

developed by MORPC in coordination with LCATS and used for the analysis. 

Independent variables (land use, socio-economic data, etc.) were developed 

as well as interpolated for intermediate years of analysis. MORPC continually 

monitors land use, population and employment information, and performs 

complete land use inventories every five years. Also, in conjunction with 

LCATS and ODOT, MORPC continuously updates the model networks to 

accurately reflect projects in the current Transportation Improvement Plan 

and Long Range Plan. The model networks developed for this emission 

estimates were for the analysis years 2005, 2008, 2015, and 2022. The 

annual emission inventories used by MORPC were developed for the direct 

PM2.5 pollutants, tail pipe, break and tire wear and the precursors of NOx and 

SO2. 

Areas with Regional Model 

Customs programs developed by ODOT in conjunction with MPO models 

were used in computing total emissions. The process uses data on daily and 

directional traffic distributions as well as more up to date volume /delay 

functions. The process uses codes able to handle the newer model network 

formats and MOVES generated emission factors. 

The steps in the process involve: 1) the calculation of hourly link volumes 

based on the percentage of the daily volume, determined by a link’s facility 

and area type, 2) the calculation of emissions for every network link for each 

hour (this is done using a combination of the MOVES emission factors and 

 

9 Licking County Area Transportation Study
18 

the hourly link volumes in the previous step), 3) the calculation of vehiclebased emissions for each source type for each hour of the day, 4) the 

calculation of intrazonal emissions by combining MOVES generated 

emissions with estimated intrazonal VMT, and 5) summarizing link, vehicle, 

and intrazonal emissions for each county, pollutant, and analyzed year, and 

to multiply annual average daily emissions by 365 to produce an annual 

estimate. 

Areas without Regional Model 

The travel demand forecasting model discussed above does not cover the 

entire nonattainment area. A standard process based on HPMS VMT was 

employed for the rest of the area which includes portions of Fairfield County 

and Franklin Township in Coshocton County. This process requires 

estimating the proportion of county VMT covered and not covered by the 

model, which is accomplished using a GIS procedure and determining the 

proportion of the number of vehicles inside and outside of the model. The 

computed VMT is projected forward based on standard growth rates. 

On-Road Mobile Emission Estimations 

Tables 2 through 7 contain the results of the emissions analysis for the 

appropriate years. All emissions estimations are expressed in tons per year 

(tpy). 

Table 2 - Coshocton County, Emissions Estimations for On-Road Mobile 

Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 2.63 2.15 1.06 0.58 

NOx (tpy) 66.14 49.71 21.10 8.76 

SO2 (tpy) 1.31 0.40 0.15 0.15 

Annual VMT 21,735,020 21,389,730 22,829,655 23,091,360 

Table 3 – Delaware County, Emissions Estimations for On-Road Mobile 

Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 151.99 139.75 78.79 53.78 

NOx (tpy) 5,372.30 4,716.95 2,500.97 1,308.18 

SO2 (tpy) 85.14 29.32 14.35 15.14 

Annual VMT 1,583,202,465 1,783,481,615 2,169,135,870 2,542,369,905 
19 

Table 4 – Fairfield County, Emissions Estimations for On-Road Mobile 

Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 112.09 92.45 47.66 29.22 

NOx (tpy) 3,564.05 2,789.29 1,331.20 624.84 

SO2 (tpy) 62.25 19.00 8.60 8.34 

Annual VMT 1,155,332,310 1,167,404,320 1,313,721,505 1,465,934,900 

Table 5 – Franklin County, Emissions Estimations for On-Road Mobile 

Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 1,232.19 1,076.57 557.77 355.44

NOx (tpy) 38,665.96 32,410.28 15,519.51 7,455.60

SO2 (tpy) 625.30 204.36 90.42 87.07

Annual VMT 10,874,209,575 11,703,950,570 12,815,874,525 13,709,850,410

Table 6 – Licking County, Emissions Estimations for On-Road Mobile 

Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 161.43 140.17 74.25 47.18 

NOx (tpy) 5,722.16 4,859.58 2,439.49 1,200.45 

SO2 (tpy) 90.22 29.97 13.85 13.75 

Annual VMT 1,673,357,830 1,832,011,650 2,102,842,745 2,319,527,550 

Table 7 – Emissions Estimations Totals for On-Road Mobile Sources for the 

Columbus Area 

 2005 2008 2015 2022 

PM2.5 (tpy) 1,660.33 1,451.09 759.53 486.20 

NOx (tpy) 53,390.61 44,825.81 21,812.27 10,597.83 

SO2 (tpy) 864.22 283.05 127.37 124.45 

Annual VMT 15,307,837,200 16,508,237,885 18,424,404,300 20,060,774,125 
20 

Motor Vehicle Emission Budget 

Table 8 contains the motor vehicle emissions budgets for the Columbus area. 

Table 8 - Mobile Vehicle Emissions Budget 

   

2015 

Estimated 

Emissions 

2015 Mobile 

Safety 

Margin 

Allocation 

2015 

Total 

Mobile 

Budget 

2022 

Estimated 

Emissions 

2022 Mobile 

Safety 

Margin 

Allocation 

2022 Total 

Mobile 

Budget 

PM2.5 (tpy) 759.53 113.93 873.46 486.20 72.93 559.13

NOx (tpy) 21,812.27 3,271.84 25,084.11 10,597.83 1,589.67 12,187.50

*The 15 percent margin of safety was calculated by taking 15 percent of the mobile source emission estimates

The above budgets for the Columbus area, agreed upon as part of the 

interagency consultation process, include the emission estimates calculated 

for 2015 and 2022 (from Table 7) with an additional 15 percent margin of 

safety allocated to PM2.5 and NOx in 2015 and 2022. 

In an effort to accommodate future variations in travel demand models and 

VMT forecast when no change to the network is planned, Ohio EPA 

consulted with U.S. EPA to determine a reasonable approach to address this 

variation. Based on this discussion, a 15 percent margin of safety allocation 

was agreed upon and has been added to the emissions estimates for this 

nonattainment area. 

All methodologies, the latest planning assumptions, and the safety margins 

allocations were determined through the interagency consultation process 

described in the Transportation Conformity Memorandum of Understanding 

(MOU) among MORPC, Ohio DOT, and Ohio EPA. 

A 15 percent margin of safety is appropriate because: 1) there is an 

acknowledged potential variation in VMT forecast and potential estimated 

mobile source emissions due to expected modifications to TDM and mobile 

emissions models; and 2) the total decrease in emissions from all sources is 

sufficient to accommodate this 15 percent allocation of safety margin (as 

defined in 40 CFR93.10110) to mobile sources while still continuing to 

maintain the total emissions in the Columbus area well below the 2008 

attainment level of emissions. 

 

The 15 percent margin of safety was calculated by taking 15 percent of the 

mobile source emission estimates. Safety margin, as defined by the 

 

10 "Safety margin" means the amount by which the total projected emissions from all sources of a given pollutant are less 

than the total emissions that would satisfy the applicable requirement for reasonable further progress, attainment, or 

maintenance.
21 

conformity rule, looks at the total emissions from all sources in the 

nonattainment area. The actual allocation is less than 15 percent of the total 

emission reduction from all sources as can be seen from Table 44. 

In summary, the mobile budget safety margin allocation translates into an 

additional 113.93 tpy for PM2.5 and 3,271.84 tpy for NOx for 2015 and an 

additional 72.93 tpy for PM2.5 and 1,589.67 tpy for NOx for 2022. 

When compared to the overall safety margin, as defined in 40 CFR 93.101, 

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

significantly below the total safety margin for this area. 

The current PM2.5 and NOx mobile budgets for the fine particle NAAQS will no 

longer be applicable either after the effective date of the approved 

redesignation or after the effective date of any U.S. EPA action approving a 

finding that the PM2.5 and NOx conformity budgets included in this submittal 

are adequate for transportation conformity purposes, whichever date comes 

first. 

Finally, it is important to underline that all motor vehicle emission budgets in 

this Redesignation submittal, which are based on MOVES2010, will replace 

previous motor vehicle emission budgets on Attainment Demonstration 

submittals based on MOBILE6.2. 

Requirement 3 of 5 

A demonstration that the projected level of emissions is sufficient to maintain the PM2.5

standard. 

Background

In consultation with U.S. EPA, Ohio EPA selected the year 2022 as the 

maintenance year for this redesignation request. This document contains 

projected emissions inventories for 2015 and 2022. 

Emission projections for the Columbus area were performed using the 

following approaches: 

• As performed by MORPC, mobile source emission projections are 

based on the U.S. EPA MOVES model. The analysis is described in 

more detail in Appendix C. All projections were made in accordance 

with “Procedures for Preparing Emissions Projections” U.S. EPA-45/4-

91-019. 
22 

• Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. LADCO has 

developed growth and control files for point, area, and non-road 

categories. These files were used to develop the future-year 

emissions estimates used in this document. This was done so the 

inventories used for redesignation are consistent with modeling 

performed in the future. Appendix D contains LADCO’s technical 

support document detailing the analysis used to project emissions 

(Base M11). 

• For the 2008 attainment year emissions were grown from the 2005 

LADCO modeling inventory, using LADCO’s growth factors, for all 

sectors except point sources (electrical generating units and nonelectrical generating units). Point source emissions for 2008 were 

compiled from Ohio EPA’s 2008 annual emissions inventory database. 

The 2015 interim year emissions were estimated based on the 2009 

and 2018 LADCO modeling inventory, using LADCO’s growth factors, 

for all sectors. The 2022 maintenance year is based on emissions 

estimates from the 2018 LADCO modeling. 

The detailed inventory information for Columbus area for 2005 is in Appendix 

B. Emission trends are an important gauge for continued compliance with the 

PM2.5 standard. Therefore, Ohio EPA performed an initial comparison of the 

inventories for the base year and maintenance years. Mobile source 

emission inventories are described in Section 5 of Appendix B. 

Sectors included in the following tables are: Electrical Generating Unit (EGUPoint); Non-Electrical Generating Unit (Non-EGU); Non-road Mobile (Nonroad); Other Area (Other); Marine; Aircraft; Rail (MAR); and On-road Mobile 

(On-road). 

Ohio EPA is identifying emissions projections for 2015 and 2022 for EGUs 

without the implementation of the CAIR program. U.S. EPA has raised 

concerns regarding the CAIR program and its remand. As discussed below, 

with the proposed CAIR replacement, the Transport Rule, Ohio EPA believes 

additional reductions will be occurring in the future. 

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 

2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the 

District of Columbia to significantly reduce emissions of NOx and SO2. CAIR 

replaced the NOx SIP Call for EGUs. The intent of the CAIR program is for 

national NOx emissions to be cut from 4.5 million tons in 2004, to a cap of 1.5 

 

11 http://www.ladco.org/tech/emis/current/index.php 
23 

million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were 

required to submit a CAIR SIP as part of this effort. Ohio submitted a CAIR 

SIP which was approved by U.S. EPA on February 1, 2007. Revisions to the 

CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP 

was approved as a direct final action on September 25, 2009 (74 FR 48857). 

 As a result of CAIR, U.S. EPA projects that in 2009 emissions of NOx will 

decrease from a baseline of 264,000 tons per year to 93,000 tons per year 

while in 2010 emissions of SO2 will decrease from a baseline of 1,373,000 

tons per year to 298,000 tons per year, within Ohio. And by 2015 U.S. EPA 

projects emissions of NOx will decrease to 83,000 tons per year while 

emissions of SO2 will decrease to 208,000 tons per year, within Ohio12. 

On December 23, 2008, U.S. EPA’s CAIR program was remanded without 

vacatur by the D.C. Circuit Court. As mentioned above, Ohio EPA has not 

incorporated these expected CAIR reductions into this redesignation request. 

 It should also be noted that Ohio’s SIP-approved NOx SIP Call program and 

regulations are still in place. Ohio EPA is currently in the process of revising 

these regulations to provide a “back stop” for the reinstatement of the NOx 

SIP Call program in the event the CAIR program, or an equivalent, is no 

longer implemented by U.S. EPA. 

As can be seen in Table 9 below, Ohio has seen a significant decline in the 

264,000 tons of NOx and 1,373,000 tons of SO2 emitted in 2005. In 2008 

and 2009 facilities began preparing for and implementing control programs to 

address CAIR13 and consent decrees. 

Table 9 - Reductions in SO2 and NOx EGU Emissions Between 2008 and 

2009 

SO2 NOx

2008 2009 Change 2008 2009 Change 

Ohio 709,444 601,101 15% 235,018 96,351 59% 

LADCO States 2,019,036 1,620,071 20% 702,384 393,930 44% 

National 7,616,262 5,747,353 25% 2,996,287 1,990,385 34% 

Source: Clean Air Markets Quarterly Emissions Tracking14

Significant reductions also occurred regionally and nationally as can be seen 

from the above. Data is also available for the first two quarters of 2010, the 

year SO2 reductions are to be implemented under CAIR: 

 

12 http://www.epa.gov/CAIR/oh.html 

13 Under CAIR, NOx reductions are to occur beginning in 2009 while SO2 reductions are to occur beginning in 2010.

14 http://www.epa.gov/airmarkets/quarterlytracking.html
24 

Table 10 – Reductions in SO2 and NOx EGU Emissions Between the 

First Half of 2008 and 2010 

SO2 NOx

2008 

 (1st half) 

2010 

(1st half) Change 2008 (1st half) 

2010 

(1st half) Change 

Ohio 373,798 279,854 25% 130,598 53,187 59% 

LADCO States 1,190,497 854,282 28% 419,114 220,907 47% 

National 3,895,472 2,502,965 36% 1,487,179 930,148 37% 

Source: Clean Air Markets Quarterly Emissions Tracking15

The following was reported by U.S. EPA’s Clean Markets Division: 

“Based on emissions monitoring data, EPA has observed substantial 

reductions in SO2 emissions from 2005 to 2009 and in the first two quarters 

of 2010 as companies installed more controls, electric demand declined, and 

low natural gas prices made combined-cycle gas-fired units more competitive 

in several parts of the country. Thus, even after CAIR's vacatur and 

subsequent remand in late 2008, the controls in place generally have 

continued to operate, helping to drive continued progress in reducing 

emissions.16” 

On July 6, 2010, U.S. EPA proposed a replacement to the CAIR program, the 

Transport Rule. [75 FR 45210] U.S. EPA intends to finalize the Transport 

Rule in time for reductions to begin in 2012. As proposed, the Transport 

Rule will preserve those initial reductions achieved under CAIR and provide 

more reductions in NOx and SO2 emissions in 2012 and 2014, ahead of the 

2015 CAIR Phase 2. 

Ohio EPA is in agreement with the analysis by U.S.EPA that the CAIR 

program is providing real reductions at this time, Ohio believes these 

reductions have assisted with PM2.5 attainment in this nonattainment area 

and throughout Ohio. It is also Ohio EPA’s belief that the Transport Rule, 

when finalized, will continue to provide the necessary reductions, and likely 

even greater reductions, that will be necessary for maintenance of the annual 

PM2.5 standard to occur. As stated by U.S. EPA regarding the proposed 

Transport Rule, “the results of the air quality modeling indicate that all but 

one site17 is projected to be in attainment and only one site18 is projected to 

have a maintenance problem for annual PM2.5 in 2014 with the emissions 

reductions expected from this proposal.” [75 FR 45345]. Furthermore, 

modeling conducted as part of the Transport Rule projects the Counties 

 

15 http://www.epa.gov/airmarkets/quarterlytracking.html

16 http://www.epa.gov/airmarkets/background.htm

17 Allegheny, PA

18 Birmingham, AL
25 

within this area will not have maintenance issues in 2012 or 2014 even 

without the Transport Rule (or CAIR)19

Maintenance is demonstrated when the future-year (2022) projected 

emission totals are below the 2008 attainment year totals. 

The Ohio emissions data in the tables below are based on the following data 

sources: 

- All On-Road data source: MORPC Transportation Modeling Department 

and ODOT’s Division of Transportation System Development-Modeling 

and Forecasting Section. 

- 2008 EGU and non-EGU: Ohio EPA’s 2008 annual emissions inventory 

database. 

- All other data source: Lake Michigan Air Directors Consortium (LADCO). 

Demonstration

PM2.5 

Table 11 - Coshocton County, PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 657.22 656.49 696.46 728.78 ‐72.29

Non-EGU 93.96 91.06 96.01 99.13 ‐8.07

Non-road 23.39 19.89 13.17 6.32 13.57

Area 147.96 190.49 206.13 229.63 ‐39.14

MAR 0.00 0.00 0.00 0.00 0.00

On-road 2.63 2.15 1.06 0.58 1.57

TOTAL 925.16 960.08 1012.83 1064.44 ‐104.36

 

19 See supplemental table “Impacts of the Proposed Transport Rule on Counties with Monitors Projected to have 

Ozone and/or Fine Particle Air Quality Problems.” 
26 

Table 12 - Delaware County, PM2.5 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 0.00 0.00 0.00 0.00 0.00

Non-road 167.23 142.79 94.31 45.03 97.76

Area 156.94 158.37 156.02 154.21 4.16

MAR 25.55 22.06 12.43 2.93 19.13

On-road 151.99 139.75 78.79 53.78 85.97

TOTAL 501.71 462.97 341.55 255.95 207.02

 Table 13 - Fairfield County, PM2.5 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR

 Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 66.92 59.32 59.41 56.23 3.09

Non-road 99.27 83.48 53.80 23.44 60.04

Area 305.67 304.78 297.53 290.77 14.01

MAR 2.57 2.27 1.41 0.57 1.70

On-road 112.09 92.45 47.66 29.22 63.23

TOTAL 586.52 542.30 459.81 400.23 142.07

Table 14 - Franklin County, PM2.5 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 93.93 152.68 103.13 76.09 76.59

Non-road 590.43 506.07 352.28 194.45 311.62

Area 428.69 456.43 466.94 468.41 ‐11.98

MAR 52.56 48.51 31.77 15.71 32.80

On-road 1,232.19 1,076.57 557.77 355.44 721.13

TOTAL 2,397.80 2,240.26 1,511.89 1,110.10 1,130.16
27 

Table 15 - Licking County, PM2.5 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 566.61 594.28 692.98 785.40 ‐191.12

Non-road 96.74 82.50 54.19 25.42 57.08

Area 513.17 509.99 497.17 484.86 25.13

MAR 0.79 0.75 0.59 0.44 0.31

On-road 161.43 140.17 74.25 47.18 92.99

TOTAL 1,338.74 1,327.69 1,319.18 1,343.30 ‐15.61

Table 16 – Columbus Area PM2.5 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and projected 2015 and 2022 (tpy) – 

Without CAIR 

PM2.5 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

Delaware 501.71 462.97 341.55 255.95 207.02

Fairfield 586.52 542.30 459.81 400.23 142.07

Franklin

2,397.8

0 2,240.26 1,511.89 1,110.10 1,130.16

Coshocton 925.16 960.08 1,012.83 1,064.44  ‐104.36

Licking

1,338.7

4 1,327.69 1,319.18 1,343.30  ‐15.61

COMBINED PM2.5

TOTAL 

5,749.9

3 5,533.30 4,645.26 4,174.02 1,359.28

NOx 

Table 17 - Coshocton County, NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 21,465.83 20,449.55 9,379.87 3,837.96 16,611.59

Non-EGU 578.94 647.20 592.43 563.46 83.74

Non-road 262.02 225.90 149.78 72.90 153.00

Area 148.92 154.85 157.50 161.19 ‐6.34

MAR 158.46 161.57 128.74 99.68 61.89

On-road 66.14 49.71 21.10 8.76 40.95
28 

TOTAL 22,680.31 21,688.78 10,429.42 4,743.95 16,944.83

Table 18 - Delaware County, NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 13.89 16.98 14.38 12.95 4.03

Non-road 1,875.66 1,619.90 1,016.83 414.35 1,205.55

Area 457.79 462.93 466.26 470.41 ‐7.48

MAR 815.93 751.99 485.78 230.57 521.42

On-road 5,372.30 4,716.95 2,500.97 1,308.18 3,408.77

TOTAL 8,535.57 7,568.75 4,484.22 2,436.46 5,132.29

Table 19 - Fairfield County, NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 1,318.66 1,465.80 1,289.27 1,159.51 306.29

Non-road 1,192.44 1,029.77 646.11 262.83 766.94

Area 329.99 335.35 338.88 343.25 ‐7.90

MAR 91.25 86.90 60.58 35.77 51.13

On-road 3,564.05 2,789.29 1,331.20 624.84 2,164.45

TOTAL 6,496.39 5,707.11 3,666.04 2,426.20 3,280.91

Table 20 - Franklin County, NOx Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 842.40 797.78 811.33 835.71  ‐37.93

Non-road 7,321.50 6,209.36 3,845.20 1,459.36 4,750.00

Area 3,945.51 3,989.72 4,019.37 4,055.92  ‐66.20

MAR 1,751.39 1,657.67 1,149.43 668.41 989.26

On-road 38,665.96 32,410.28 15,519.51 7,455.60 24,954.68
29 

TOTAL 52,526.76 45,064.81 25,344.84 14,475.00 30,589.81

Table 21 - Licking County, NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 969.15 996.65 1,071.92 1,217.92 ‐221.27

Non-road 1,106.27 949.96 602.90 254.19 695.77

Area 584.99 591.47 595.76 601.07 ‐9.60

MAR 34.77 35.45 28.25 21.87 13.58

On-road 5,722.16 4,859.58 2,439.49 1,200.45 3,659.13

TOTAL 8,417.34 7,433.11 4,738.32 3,295.50 4,137.61

Table 22 - Columbus Area NOx Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

NOx 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

Delaware 8,535.57 7,568.75 4,484.22 2,436.46 5,132.29

Fairfield 6,496.39 5,707.11 3,666.04 2,426.20 3,280.91

Franklin 52,526.76 45,064.81 25,344.84 14,475.00 30,589.81

Coshocton 22,680.31 21,688.78 10,429.42 4,743.95 16,944.83

Licking 8,417.34 7,433.11 4,738.32 3,295.50 4,137.61

COMBINED 

NOx TOTAL 98,656.37 87,462.56 48,662.84 27,377.11 60,085.45

SO2

Table 23 - Coshocton County, SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 109,750.80 93,358.73 43,384.63 21,967.16 71,391.57

Non-EGU 12.45 14.79 12.46 11.06 3.73

Non-road 25.31 9.34 1.52 0.27 9.07

Area 30.47 30.59 28.97 27.52 3.07

MAR 9.97 10.16 8.23 6.53 3.63

On-road 1.31 0.40 0.15 0.15 0.25
30 

TOTAL 109,830.31 93,424.01 43,435.96 22,012.69 71,411.32

Table 24 - Delaware County, SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 0.13 0.22 0.21 0.23 ‐0.01

Non-road 233.51 85.35 13.21 1.83 83.52

Area 73.14 72.15 69.17 66.25 5.90

MAR 70.99 69.39 54.94 41.51 27.88

On-road 85.14 29.32 14.35 15.14 14.18

TOTAL 462.91 256.43 151.88 124.96 131.47

Table 25 - Fairfield County, SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 212.97 183.31 191.64 195.21 ‐11.90

Non-road 145.86 53.34 8.21 1.06 52.28

Area 73.56 72.60 69.65 66.76 5.84

MAR 7.14 7.06 5.62 4.30 2.76

On-road 62.25 19.00 8.60 8.34 10.66

TOTAL 501.78 335.31 283.72 275.67 59.64

Table 26 - Franklin County, SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 867.35 569.01 588.78 597.25 ‐28.24

Non-road 841.63 307.64 48.51 7.94 299.70

Area 302.03 301.68 297.31 293.27 8.41

MAR 141.84 139.56 110.37 83.43 56.13

On-road 625.30 204.36 90.42 87.07 117.29

TOTAL 2,778.15 1,522.25 1,135.39 1,068.96 453.29
31 

Table 27 - Licking County, SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 422.83 427.42 458.60 487.65 ‐60.23

Non-road 124.74 45.73 7.21 1.12 44.61

Area 87.75 86.66 83.29 80.00 6.66

MAR 2.19 2.23 1.81 1.43 0.80

On-road 90.22 29.97 13.85 13.75 16.22

TOTAL 727.73 592.01 564.76 583.95 8.06

 Table 28 - Columbus Area SO2 Emission Inventory Totals for Base Year 

2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – 

Without CAIR 

SO2 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

Delaware 462.91 256.43 151.88 124.96 131.47

Fairfield 501.78 335.31 283.72 275.67 59.64

Franklin 2,778.15 1,522.25 1,135.39 1,068.96 453.29

Coshocton 109,830.31 93,424.01 43,435.96 22,012.69 71411.32

Licking 727.73 592.01 564.76 583.95 8.06

COMBINED 

SO2 TOTAL 114,300.88 96,130.01 45,571.71 24,066.23 72,063.78

PM2.5, NOx, and SO2

Table 29 - Columbus Area Comparison of 2008 attainment year and 2015 

and 2022 projected emission estimates (tpy) 

  

2008 Base 2015

Interim

2015

Projected

Decrease

2022

Maintenance

2022

Projected

Decrease

PM2.5 5,533.30 4,645.26 888.04 4,174.02 1,359.28

NOx 87,462.56 48,662.84 38,799.72 27,377.11 60,085.45

SO2 96,130.01 45,571.71 50,558.30 24,066.23 72,063.78

 

As shown in the table above (Table 29), PM2.5 emissions in the 

nonattainment area are projected to decrease by 888.04 tpy in 2015 and 

1,359.28 tpy in 2022. NOx emissions in the nonattainment area are projected 
32 

to decrease by 38,799.72 tpy in 2015 and 60,085.45 tpy in 2022. SO2

emissions in the nonattainment area are projected to decline by 50,558.30 

tpy in 2015 and 72,063.78 tpy in 2022. 

In some cases, area source emissions and, point sources show an increase 

due to expectations that the population will grow in this area; however, 

cleaner vehicles and fuels are expected to be in place in 2009 and 2018, and 

the Transport Rule will be implemented in 2012 and 2014 and these 

programs should cause an overall drop in all three pollutants emissions. 

Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions 

Standards and Gasoline Sulfur Control Requirements20, Highway Heavy-Duty 

Engine Rule21, and the Non-Road Diesel Engine Rule22 are factored into the 

changes. 

In addition to the above, the Cardinal AEP Station in Coshocton County Two 

largest coal-fired units (each 600 megawatts) began operating advanced 

SO2 controls in late 2007 and early 2008 per a consent decree. The third 

Cardinal unit (630 megawatts) has plans for advanced SO2 control to comply 

with a December 2012 deadline within the same consent decree. The 

Conesville AEP Station, also in Coshocton County, permanently shut down 

two coal-fired boilers in 2006 (each 125 megawatts). Conesville also has 

implemented important changes in 2009 to two 425 megawatt coal-fired 

units, as required through a consent decree, by continuously operating their 

existing advanced SO2 controls and accepting a restricted SO2 allowable 

emissions rate that will not cause or contribute to a violation of the NAAQS 

(the consent decree required their FGD be updated to meet 95% control 

efficiency by 12/31/2009). The largest coal-fired unit (800 megawatts) at 

Conesville also started operating advanced NOx and SO2 controls in June 

2009, as required by their consent decree. 

All projections (PM2.5, SO2, and NOx) do not take into account reductions 

expected from the CAIR. In many cases, Ohio utilities subject to CAIR have 

already, or will be installing controls and reducing NOx and SO2 emissions 

beyond those projected for EGUs above. 

As can be seen from the projected decreases above, even in the absence of 

consideration of reductions resulting from CAIR, and its future replacement, 

the Transport Rule, the area will be able to maintain the standard. 

Requirement 4 of 5 

 

20 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 

21 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 

22 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 
33 

A demonstration that improvement in air quality between the year violations occurred and 

the year attainment was achieved is based on permanent and enforceable emission 

reductions and not on temporary adverse economic conditions or unusually favorable 

meteorology. 

Background 

Ambient air quality data from all monitoring sites indicate that air quality met the 

NAAQS for PM2.5 in 2008-2010. U.S. EPA’s redesignation guidance (p 9) states: “A 

state may generally demonstrate maintenance of the NAAQS by either showing that 

future emissions of a pollutant or its precursors will not exceed the level of the 

attainment inventory, or by modeling to show that the future mix of sources and 

emissions rates will not cause a violation of the NAAQS.” 

Demonstration 

Permanent and enforceable reductions of PM2.5, NOx, and SO2 emissions have 

contributed to the attainment of the annual PM2.5 standard. Some of these 

reductions were due to the application of tighter federal standards on new vehicles. 

Also Title IV of the CAA, the NOx SIP Call, CAIR, and federal consent decrees 

required the reductions of SO2 and NOx emissions from utility sources. Reductions 

achieved are discussed in greater detail under Chapter Five. 

Table 30 - Columbus Area Comparison of 2005 base year and 2008 

attainment year on-road and EGU reductions 

2005 2008 

On-road PM2.5 1,660.33 1,451.09 

On-road NOx 53,390.61 44,825.81 

On-road SO2 864.22 283.05 

EGU PM2.5 657.22 656.49 

EGU NOx 21,465.83 20,449.55 

EGU SO2 109,750.80 93,358.73 

Requirement 5 of 5 

Provisions for future annual updates of the inventory to enable tracking of the emission 

levels, including an annual emission statement from major sources. 

Demonstration

In Ohio, major point sources in all counties are required to submit air 

emissions information annually, in accordance with U.S. EPA’s Consolidated 

Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic 

inventory for all PM2.5 precursor emission sectors every three years. These 

PM2.5 precursor inventories will be prepared for future years as necessary to 

comply with the inventory reporting requirements established in the CFR. 

Emissions information will be compared to the 2005 base year and the 2022 
34 

projected maintenance year inventories to assess emission trends, as 

necessary, and to assure continued compliance with the annual PM2.5

standard. 
35 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

CAA Section107 (d)(3)(E)(ii), 107(d)(3)(iv), and 107(d)(3)(E)(v) 

Requirement 1 of 6

Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with 

nonattainment areas to implement RACM and RACT. 

Background

Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with 

nonattainment areas to submit a SIP providing for implementation of all 

reasonably available control measures and expeditiously as practicable 

(including such reductions in emissions from existing sources in the area as 

may be obtained through the adoption, at a minimum, of reasonable available 

control technology). 

U.S. EPA’s Implementation Rule interprets this requirement in great detail. 

Under U.S. EPA’s approach, RACT is determined as part of the broader 

RACM analysis and identification of all measures (for stationary, mobile, and 

area sources) that are technically and economically feasible, and that would 

collectively contribute to advancing the attainment date (i.e., by one year or 

more). States are required to use a combined approach to RACT and RACM, 

that (1) identifies potential measures that are reasonable, (2) uses modeling 

to identify the attainment date that is as expeditious as practicable, and (3) 

selects the appropriate RACT and RACM. 

The Implementation Rule also provides for a presumption that in States that 

fulfill their CAIR emission reduction requirements, EGU compliance with 

CAIR is equivalent to RACM/RACT. 

Demonstration

In 1972, 1980, and 1991, Ohio promulgated rules requiring reasonably 

available control measures for particulate emissions from stationary sources. 

 

Statewide RACT rules have been applied to all new sources locating in Ohio 

since that time. RACT requirements are incorporated into permits along with 

monitoring, recordkeeping, and reporting necessary to ensure ongoing 

compliance. Ohio EPA also has an active enforcement program to address 

violations discovered by field office staff. The Ohio RACT rules are found in 

OAC Chapter 3745-1723. 

 

23 http://www.epa.ohio.gov/dapc/regs/3745_17.aspx 
36 

In addition, Ohio EPA promulgated NOx SIP Call rules (OAC Chapter 3745-

1424), CAIR (OAC Chapter 3745-10925), and NOx Reasonably Available 

Control Technology rules (OAC Chapter 3745-11026) over the past five years. 

Emissions from EGUs make up a significant contribution to Ohio’s inventory. 

Beginning in 2009, Ohio implemented CAIR which has, and will, provide for 

significant reductions in NOx, PM2.5, and SO2 until such time it is replaced by 

U.S. EPA’s proposed Transport Rule. Then the Transport Rule will provide 

for even greater reductions. 

As part of a larger initiative, LADCO, in consultation with two contractors, 

performed a series of studies exploring control measures for reducing both 

ozone precursors and PM2.5 precursors in Ohio, Illinois, Indiana, Michigan, 

and Wisconsin area. The first consultant, MACTEC, prepared a series of 

white papers27 researching different stationary source categories. The results 

were compiled into two reports28. The second consultant, Environ, 

investigated control options for mobile sources. The results were compiled 

into two reports29. The stationary and mobile source sectors (and associated 

control measures) were selected by the LADCO States based on several 

factors presented in the report (See Chapter 2). 

Photochemical modeling was then conducted (as part of LADCO Round 4 

modeling) to assess the air quality benefit of the candidate control measures 

and a modeling report was developed30. Based on the results, the LADCO 

project team felt it would not be possible to advance the attainment date for 

PM2.5. Ohio EPA, in its attainment demonstration submitted on July 18, 

2008, demonstrated (using a weight of evidence approach) that attainment 

would be achieved in this area by 2009. Because of a projected 2009 

attainment date, it would not have been reasonably possible or practicable 

for Ohio to develop RACT/RACM requirements, promulgate regulations and 

implement a control program prior to the projected attainment date. 

 

24 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 

25 http://www.epa.ohio.gov/dapc/regs/3745_109.aspx 

26 http://www.epa.ohio.gov/dapc/regs/3745_110.aspx 

27 http://www.ladco.org/reports/control/white_papers 

28 

http://www.ladco.org/reports/control/final_reports/identification_and_evaluation_of_candidate_control_measures_i_april_2

005.pdf; 

http://www.ladco.org/reports/control/final_reports/identification_and_evaluation_of_candidate_control_measures_ii_june_2

006.pdf 

29 

http://www.ladco.org/reports/control/final_reports/final_report_evaluation_of_candidate_mobile_source_control_measures

_february_2006.pdf; 

http://www.ladco.org/reports/control/final_reports/final_report_evaluation_of_candidate_mobile_source_control_measures

_for_ladco_states_in_2009_and_2012_march_2007.pdf 

30 http://www.ladco.org/reports/control/modeling/round4_modeling.pdf 
37 

Requirement 2 of 6

Section 172(c)(2) of the 1990 CAA Amendments requires attainment demonstration SIPs 

for nonattainment areas to show reasonable further progress (RFP). 

Background

U.S. EPA’s Implementation Rule requires RFP only for any area which a 

State projects an attainment date beyond 2010. The RFP would provide 

emission reductions showing linear progress between 2002 and 2009. If a 

State demonstrates attainment will occur by 2010 or earlier, U.S. EPA 

considers the attainment demonstration to demonstrate achievement of RFP. 

Demonstration

In Ohio’s attainment demonstration submitted on July 18, 2008, Ohio 

demonstrated (using a weight of evidence approach) that attainment would 

be achieved in this area by 2009; and therefore, it was not necessary to 

submit a separate RFP plan. 

Requirement 3 of 6

Section 172(c)(3) requires states to submit a comprehensive inventory of actual emissions. 

Background

Section 172(c)(3) requires states to submit a comprehensive inventory of 

actual emissions in the area, including the requirement for periodic revisions 

as determined necessary. 40 CFR 51.1008 requires such inventory to be 

submitted within three years of designation and requires a baseline emission 

inventory for calendar year 2002 or other suitable year to be used for 

attainment planning. 

Demonstration

The 2005 comprehensive inventory was submitted to U.S. EPA with Ohio’s 

PM2.5 attainment demonstration SIP submitted on July 18, 2008. It was then 

subsequently revised and resubmitted on June 7, 2010. 

Ohio also updates its inventory in accordance with U.S. EPA’s CERR rule 

(i.e. emissions statements). Ohio EPA submitted its emissions statement SIP 

on March 18, 1994 which was approved by U.S. EPA on October 13, 1995 

(59 FR 51863). As discussed in Chapter 4 (Requirement 4), Ohio EPA 

submits, and commits to submit, emission inventories (statements) every 

three years. 

Requirement 4 of 6
38 

Evidence that control measures required in past PM2.5 SIP revisions have been fully 

implemented. 

Background

In addition to the historic RACT requirements for PM, the U.S. EPA NOx SIP 

Call required 22 states to pass rules that would result in significant emission 

reductions from large EGUs, industrial boilers, and cement kilns in the 

eastern United States. Ohio passed this rule in 2001. NOx SIP Call 

requirements are incorporated into permits along with monitoring, 

recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio 

EPA also has an active enforcement program to address violations 

discovered by field office staff. Compliance is tracked through the Clean Air 

Markets data monitoring program. Beginning in 2004, this rule accounts for a 

reduction of approximately 31 percent of all NOx emissions statewide 

compared to previous uncontrolled years. The other 21 states also have 

adopted these rules. 

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 

2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the 

District of Columbia to significantly reduce emissions of NOx and SO2. CAIR 

replaced the NOx SIP Call for EGUs. National NOx emissions will be cut 

from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 

million tons in 2018 in 28 states. States were required to submit a CAIR SIP 

as part of this effort. Ohio submitted a CAIR SIP which was approved by 

U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again 

submitted on July 15, 2009. The revised CAIR SIP was approved as a direct 

final action on September 25, 2009 (74 FR 48857). 

Demonstration

Controls for EGUs under the NOx SIP Call formally commenced May 31, 

2004. Emissions covered by this program have been generally trending 

downward since 1998 with larger reductions occurring in 2002 and 2003. 

Data taken from the U.S. EPA Clean Air Markets web site, quantify the 

gradual NOx reductions that have occurred in Ohio as a result of Title IV of 

the 1990 CAA Amendments and the beginning of the NOx SIP Call Rule. 

Ohio developed the NOx Budget Trading Program rules in OAC Chapter 

3745-1431 in response to the SIP Call. OAC Chapter 3745-14 regulates 

EGUs and certain non-EGUs under a cap and trade program based on an 85 

percent reduction of NOx emissions from EGUs and a 60 percent reduction 

of NOx emissions from non-EGUs, compared to historical levels. This cap 

was in place through 2008, at which time the CAIR program superseded it as 

 

31 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 
39 

discussed above. Requirement 3 of 5 under Chapter 4 above discussed the 

reductions Ohio has seen as a result of CAIR. 

On April 21, 2004, U.S. EPA published Phase II of the NOx SIP Call that 

establishes a budget for large (greater than 1 ton per day emissions) 

stationary internal combustion engines. Ohio EPA’s OAC rule 3745-14-12 

addresses stationary internal combustion engines, all used in natural gas 

pipeline transmissions. U.S. EPA approved this revision to the SIP on April 4, 

2008. An 82 percent NOx reduction from 1995 levels is anticipated. 

Completion of the compliance plan occurred by May 1, 2006, and the 

compliance demonstration began May 1, 2007. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards 

In February 2000, U.S. EPA finalized a federal rule to significantly reduce 

emissions from cars and light trucks, including sport utility vehicles (SUVs). 

Under this proposal, automakers will be required to sell cleaner cars, and 

refineries will be required to make cleaner, lower sulfur gasoline. This rule 

will apply nationwide. The federal rules will phase in between 2004 and 2009. 

U.S. EPA has estimated that NOx emission reductions will be approximately 

77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and 

minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier 

trucks. The sulfur content of gasoline is estimated to be reduced by up to 90 

percent. VOC emission reductions will be approximately 12 percent for 

passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 

15 percent for larger SUVs, vans, and heavier trucks. 

Heavy-Duty Diesel Engines 

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

program which includes low-sulfur diesel fuel standards, which will be phased 

in from 2004 through 2007. This rule applies to heavy-duty gasoline and 

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

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

inventory. It also estimated the level of sulfur in highway diesel fuel will be 

reduced by 97 percent by mid-2006. 

Clean Air Non-road Diesel Rule 

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

applies to diesel engines used in industries such as construction, agriculture, 

and mining. It also contains a cleaner fuel standard similar to the highway 

diesel program. The new standards will cut emissions from non-road diesel 

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

in this rule, currently accounts for 47 percent of diesel particulate matter (PM) 

and 25 percent of NOx from mobile sources nationwide. Sulfur levels will be 

reduced in non-road diesel fuel by 99 percent from current levels, from 
40 

approximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New 

engine standards take effect, based on engine horsepower, starting in 2008. 

Together, these rules will substantially reduce local and regional sources of 

PM2.5 precursors. 

Requirement 5 of 6

Acceptable provisions to provide for new source review. 

Background

Ohio has a longstanding and fully implemented New Source Review (NSR) 

program. This is addressed in OAC Chapter 3745-3132. The Chapter includes 

provisions for the Prevention of Significant Deterioration (PSD) permitting 

program in OAC rules 3745-31-01 to 3745-31-20. Ohio's PSD program was 

conditionally approved on October 10, 2001 (66 FR 51570) and received final 

approval on January 22, 2003 (68FR 2909) by U.S. EPA as part of the SIP. 

Demonstration

Any facility that is not listed in the 2005 emission inventory, or for the closing 

of which credit was taken in demonstrating attainment, will not be allowed to 

construct, reopen, modify, or reconstruct without meeting all applicable NSR 

requirements. Once the area is redesignated, Ohio EPA will implement NSR 

through the PSD program. 

Requirement 6 of 6

Assure that all existing control measures will remain in effect after redesignation unless the 

State demonstrates through modeling that the standard can be maintained without one or 

more control measures. 

Demonstration

Ohio commits to maintaining the aforementioned control measures after 

redesignation. Ohio hereby commits that any changes to its rules or emission 

limits applicable to PM2.5, SO2, and NOx as required for maintenance of the 

annual PM2.5 standard in the Columbus area, will be submitted to U.S. EPA 

for approval as a SIP revision. 

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

necessary resources to actively enforce any violations of its rules or permit 

provisions. After redesignation, it intends to continue enforcing all rules that 

relate to the emission of PM2.5 precursors in the Columbus area. 

 

32 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx 
41 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4

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

Demonstration

Ohio hereby commits to review its maintenance plan eight years after 

redesignation, as required by Section 175(A) of the CAA. 

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency control 

measures in response to exceeding specified predetermined levels (triggers) or in the event 

that future violations of the ambient standard occur. 

Demonstration

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

Warning Level Response: 

A warning level response shall be prompted whenever the PM2.5 average of 

the weighted annual mean of 15.5 μg/m3 occurs in a single calendar year 

within the maintenance area. A warning level response will consist of a study 

to determine whether the PM2.5 value indicates a trend toward higher PM2.5

values or whether emissions appear to be increasing. The study will evaluate 

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

necessary to reverse the trend taking into consideration ease and timing for 

implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

later than 12 months from the conclusion of the most recent calendar year. 

Should it be determined through the warning level study that action is 

necessary to reverse the noted trend, the procedures for control selection 

and implementation outlined under “action level response” shall be followed. 

Action Level Response: 

An action level response shall be prompted whenever a two-year average of 

the weighted annual means of 15.0 μg/m3

 or greater occurs within the 

maintenance area. A violation of the standard (three-year average of the 

weighted annual means of 15.0 μg/m3

 or greater) shall also prompt an action 

level response. In the event that the action level is triggered and is not found 
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to be due to an exceptional event, malfunction, or noncompliance with a 

permit condition or rule requirement, Ohio EPA in conjunction with the 

metropolitan planning organization or regional council of governments, will 

determine additional control measures needed to assure future attainment of 

the NAAQS for annual PM2.5. In this case, measures that can be 

implemented in a short time will be selected in order to be in place within 18 

months from the close of the calendar year that prompted the action level. 

Ohio EPA will also consider the timing of an action level trigger and 

determine if additional, significant new regulations not currently included as 

part of the maintenance provisions will be implemented in a timely manner 

and will constitute our response. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the necessary 

administrative and legal process. This process will include publication of 

notices, an opportunity for public hearing, and other measures required by 

Ohio law for rulemaking. 

If a new measure/control is already promulgated and scheduled to be 

implemented at the federal or State level, and that measure/control is 

determined to be sufficient to address the upward trend in air quality, 

additional local measures may be unnecessary. Furthermore, Ohio will 

submit to U.S. EPA an analysis to demonstrate the proposed measures are 

adequate to return the area to attainment. 

Requirement 3 of 4

A list of potential contingency measures that would be implemented in such an event. 

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the time 

the selection is made. The selection of measures will be based on costeffectiveness, emission reduction potential, economic and social 

considerations or other factors that Ohio EPA deems appropriate. Ohio EPA 

will solicit input from all interested and affected persons in the maintenance 

area prior to selecting appropriate contingency measures. Because it is not 

possible at this time to determine what control measures will be appropriate 

at an unspecified time in the future, the list of contingency measures outlined 

below is not exhaustive. 

1) Diesel reduction emission strategies. 

2) Alternative fuel (e.g., liquid propane and compressed natural gas) and 

diesel retrofit programs for fleet vehicle operations. 
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3) Tighter PM2.5, SO2, and NOx emissions offsets for new and modified major 

sources. 

4) Impact crushers located at recycle scrap yards – upgrade wet 

suppression. 

5) Concrete manufacturing – upgrade wet suppression. 

6) Additional NOx RACT statewide. 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

benefits of individual measures, at the time they are under consideration, can 

be fully evaluated. 

Requirement 4 of 4 

A list of PM2.5, SO2, and NOx sources potentially subject to future additional control 

requirements. 

Demonstration

The following is a list of PM2.5, SO2, and NOx sources potentially subject to future 

controls. 

• ICI Boilers - SO2 and NOx controls; 

• EGUs; 

• process heaters; 

• internal combustion engines; 

• combustion turbines; 

• other sources greater than 100 tons per year; 

• fleet vehicles; 

• concrete manufacturers; 

• aggregate processing plants; 
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CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment 

concerning the draft redesignation petition and maintenance plan in the widely distributed 

county publications on March 14, 2011. 

The public hearing to receive comments on the redesignation request was held on April 21, 

2011, at the Ohio EPA’s Central Office, Columbus, Ohio. The public comment period 

closed on April 21, 2011. Appendix E includes a copy of the public notice, certification of 

publication, and the transcript from the public hearing. 
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CHAPTER EIGHT 

CONCLUSIONS

The Columbus area annual PM2.5 nonattainment area has attained the 1997 annual NAAQS 

for PM2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA 

regarding redesignations of PM2.5 nonattainment areas. Documentation to that effect is 

contained herein. Ohio EPA has prepared a redesignation request and maintenance plan 

that meet the requirements of Section 110 (a)(1) of the 1990 CAA. 

Based on this presentation, the Columbus area annual PM2.5 nonattainment area meets the 

requirements for redesignation under the CAA and U.S. EPA guidance. Ohio has 

performed an analysis that shows the air quality improvements are due to permanent and 

enforceable measures. Furthermore, because this area is subject to significant transport of 

pollutants, significant regional SO2 and NOx reductions will ensure continued compliance 

(maintenance) with the standard with an increasing margin of safety. 

The State of Ohio hereby requests that the Columbus area annual PM2.5 nonattainment 

area be redesignated to attainment simultaneously with U.S. EPA approval of the 

maintenance plan provisions contained herein. 
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