# I Environmental 

### 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: PM 2

. 5 Redesignation Request and Maintenance Plan for the 1997 PM 2

. 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 PM 2

. 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 PM 2

. 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.govIf 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 PM 2.5 

# NONATTAINMENT AREA

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

Prepared by: Ohio Environmental Protection Agency Division of Air Pollution Control

May 2011This page left intentionally blankTABLE OF CONTENTS

Chapter One Introduction .................................................................................................................. ................. 1 Geographical description and background .................................................................................. 2 Status of air quality ......................................................................................................... .............. 3

Chapter Two Requirements for redesignation ................................................................................................ .... 4

Chapter Three PM 2.5 monitoring ................................................................................................................... ......... 8 Annual PM 2.5 NAAQS .................................................................................................................... 8 Ambient data quality assured ........................................................................................................ 9 Three complete years of data .................................................................................................. ..... 9 Commitment to continue monitoring ........................................................................................... 1 2

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 PM 2.5 , SO 2 , and NO x sources ........................................................................................... 43

Chapter Seven Public participation .......................................................................................................... ............ 44

Chapter Eight Conclusions ................................................................................................................... ............. 45FIGURES

Figure 1 Map of the Columbus nonattainment area and monitor locations ......................... 9 Figure 2 PM 2.5 Annual Mean Trends LADCO States ......................................................... 11 Figure 3 PM 2.5 Annual Mean Trends Midwest States ........................................................ 11 Figure 4 PM 2.5 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 SO 2 and NO x EGU Emissions Between 2008 and 2009. ............. 23 Table 10 Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010.... ......................................................................................................... 24 Table 11 Coshocton County, PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR ................ 25 Table 12 Delaware County, PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 26 Table 13 Fairfield County, PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 26 Table 14 Franklin County, PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 26 Table 15 Licking County, PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR ................ 27 Table 16 Columbus Area PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 27 Table 17 Coshocton County, NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 27 Table 18 Delaware County, NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 28 Table 19 Fairfield County, NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 28 Table 20 Franklin County, NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 28 Table 21 Licking County, NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 29 Table 22 Columbus Area NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 29 Table 23 Coshocton County, SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 29 Table 24 Delaware County, SO 2 Emission Inventory Totals for Base Year 2005,Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 30 Table 25 Fairfield County, SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 30 Table 26 Franklin County, SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 30 Table 27 Licking County, SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 31 Table 28 Columbus Area SO 2 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 DocumentationThis page left intentionally blank1 REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE COLUMBUS ANNUAL PM 2.5 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 Q uality Standards (NAAQS) PM 2.5 1 to develop State Implementation Plans (SIPs) to expeditiously attain and maintain t he standards. The United States Environmental Protection Agency (U.S. EPA) revised the NAAQS for particulate matter in July 1997. It replaced the existing PM 10 standard with a health-based PM 2.5 standard and retained the PM 10 standard as a particulate standar d protecting welfare. The standards include an annual standar d set at 15.0 micrograms per cubic meter (μg/m 3 ), based on the 3-year average of annual mean PM 2.5 concentrations, and a 24-hour standard of 65 μg/m 3 , based on the 3-year average of the 98 th 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 Ma y 14, 1999, the D.C. Cir cuit remanded, without vacatur, the standards back to U.S. EPA. T he 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 qua lity standards. U.S. EPA requested a rehearing which the D.C. Circuit denied. Therefore, in Decem ber 1999, U.S. EPA appealed the D.C. Circuit decision to the U.S. Supreme Court. The U.S. Suprem e Court issued a decision on February 27, 2001 that unanimously affirmed the constitutionality of t he 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 c apriciously in establishing t he specific levels of the standards.

The D.C. Circuit heard arguments in this rem anded 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 PM 2.5 nonattainment areas designations for the PM 2.5 standards across the country. Modifications to those

1 Particle pollution is a mixture of microscopic solids and li quid droplets suspended in air. This pollution, also known as particulate matter, is made up of a number of components, including acids (s uch 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 PM 2.5 describes particulate matter that is 2.5 micrometers in diamet er and smaller - 1/30th the diameter of a human hair. Fine parti cle 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, PM 2.5 nonattainment designations are simply l abeled “nonattainment.” The CAA Amendments require states with PM 2.5 nonattainment areas to submit a plan within three years of the effective date of the designations (April 5, 2008) det ailing how the PM 2.5 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 stat es to request nonattainment areas to be redesignated to attainment provided certain crit eria are met. The following are the criteria that must be met in order for an area to be r edesignated from nonattainment to attainment:

i) A determination that the area has attained the PM 2.5 standard. ii) An approved State Implementation Plan (S IP) for the area under Section 110(k). iii) A determination that the im provement in air quality is due to permanent and enforceable reductions in emissions result ing from implementat ion 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 require ments, and provides additional information to support continued compliance with the annual PM 2.5 standard.

Geographical Description and Background The current Columbus nonattainment area is located in central Ohio and includes the following counties: Coshocton (partial nonattain ment of Franklin Town ship only), Delaware, Fairfield, Franklin and Licking. This area is shown in Figure 1 under Chapter Three.

The Columbus area has not previously been subj ect to nonattainment area rulemakings for fine particles.

As a result of the 2005 PM 2.5 designations, U.S. EPA desi gnated the Columbus area nonattainment for the 15.0 μg/m 3 annual standard 2 , and Ohio EPA was required to develop a plan to reduce oxides of nitrogen (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and to demonstrate that the area will meet the f ederal annual air quality standard by April 5, 2010. Ohio’s main PM 2.5 components are primary particl es (organic carbon, crustal material, and elemental carbon), SO 2 and NO x , which were included in the attainment demonstration analysis. Volatile organic com pounds (VOCs) and ammonia (NH3) were not included in the analysis since they were not part of Ohio’s current attainment strategy for PM 2.5 (although controls for VOCs have been impl emented 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 PM 2.5 standard of 65 μg/m 3

.3 (hereafter referred to as “Implementation Ru le”). In the Implementation Rule, U.S. EPA presumes NH 3 emissions are not a PM 2.5 attainment plan precurso r and that States are not required to address VOC unless the State or U.S. EPA makes technical demonstration that emissions of VOCs significantly cont ribute to nonattainment of the annual PM 2.5 standard.

This document is intended to support Ohio ’s request that the Columbus area be redesignated from nonattainment to attainment for the annual PM 2.5 standard.

Status of Air Quality PM 2.5 complete quality-assured ambient air qua lity monitoring data for the most recent three (3) years, 2008 through 2010, demonstrate t hat the air quality has met the NAAQS for annual PM 2.5 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 t he requirements in Section 107(d)(3)(E) of the CAA as amended.4 

### CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed gui dance 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 guidanc e, supplemented with additional guidance received from staff of U.S. EPA Region 5.

Below is a summary of each redesignation crit erion 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 ma king this demonstration. The first component relies on ambient air quality data. The data that are used to demonstrate attainment should be the pr oduct of ambient monitoring that is representative of the area of highest concentration. The data should be collected and quality-assured in accor dance 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 s upplemental 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 r edesignations. Appendix C and Appendix D contains the most rec ent modeling results showing future attainment and maintenance are provided. Chapter Th ree discusses this requirement in more detail and provides the attainment demonstration.

ii.) Permanent and enforceable improvem ent in air quality (CAA Section 107(d)(3)(E)(iii)) The state must be able to reasonably attr ibute 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 PM 2.5 emissions in the future:

• Clean Air Interstate Rule (CAIR)

• NO x SIP Call Rules5 In addition, since the initial designat ions were made federally enforceable consent decrees have resulted in reducti ons 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 mu st meet all requir ements of Section 110 and Part D that were applicable prio r to submittal of the complete redesignation request.

Subpart 1 of Part D consists of general requirements applicable to all areas which are designated nonattainment bas ed on a violation of the NAAQS. Subpart 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 ). However, for the purpose of implementing the 1997 PM 2.5 standard, U.S. EPA’s Im plementation Rule stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 .[72 FR 20589]

i.) Section 110(a) requirements Section 110(a) of Title I of the C AA contains the general requirements for a SIP. Section 110(a)(2) provi des that the implementation plan submitted by a state must hav e 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 nece ssary 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 im plementation 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 c ontrol measures, monitoring, and reporting; include provisions for ai r quality modeling; and provides for public and local agency participation in planning and emission control rule development. In Ohio’s De cember 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 St ate plans to prohibit emissions from within the State which contribut e significantly to nonattainment or maintenance areas in any other St ate, or which interfere with6 programs under Part C to prevent significant deterioration of air quality or to achieve reasonable progress towa rd the national visibility goal for Federal class I areas (national parks and wilderness areas). In order to assist States in addressing thei r obligations regarding regionally transported pollution, U.S. EPA finalized CAIR to reduce SO 2 and NO x emissions from large electric generating units (EGU). Ohio has met the requirements of the f ederal CAIR to reduce NO x and SO 2 emissions contributing to downwind st ates. On February 1, 2008, U.S. EPA approved Ohio’s CAIR program, which can be found in Ohio Administrative Code (OAC) Chapter 3745-109 3 . On July 6, 2010, U.S. EPA proposed a replacement to t he 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 NO x and SO 2 emissions in 2012 and 2014.

ii.) Section 172(c) requirements This Section contains general requi rements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for attainment will not apply for redesi gnations 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. Chapter s 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 Se ction 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 mu st 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#3745-1097 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 mini mum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignat ion of a nonattainment ar ea 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

PM 2.5 MONITORING CAA Section 107(d)(3)(E)(i)

Requirement 1 of 4 A demonstration that the NAAQS for annual PM 2.5 , as published in 40 CFR 50.7, has been attained.

Background There are three monitors measuring PM 2.5 concentrations in this nonattainment area, all of them in Franklin County. T hese monitors are operated by Ohio EPA Division of Air Pollution Control, Centra l District Office. A listing of the design values based on the three-year aver age of the annual mean concentrations from 2008 through 2010 is s hown 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 acco rdance 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 show n in Appendix A in accordance with 40 CFR 58.10 and all other federal requirements. Ohio EPA ha s recorded the data in the AQS database and, therefor e, the data are available to the public.

Requirement 3 of 4 A showing that the three-y ear average of the annual mean values, based on data from all monitoring sites in the area or its affe cted downwind environs, are below 15.0 μg/m 3 . (This showing must rely on three complete, consecut ive 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 N AAQS," U.S. EPA-45 4/R-99-008, April 1999.10 In accordance with the CAA Amendments, th ree complete years of monitoring data are required to demonstrate attain ment at a monitoring site. The annual PM 2.5 primary and secondary ambient air quality standards are met at an ambient air quality monitoring site w hen the three-year average of the annual average is less than 15.0 μg/m 3 . While calculating design values, three significant digits must be carried in the computations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, and those less than 0.05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than, or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard; values equal to or greater than 15.1 μg/m 3 exceed the standard. An ar ea is in compliance with the annual PM 2.5 NAAQS only if every monitoring site in the area meets t he 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 fo r 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 desi gn 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 Co lumbus area demonstrat e that the annual PM 2.5 NAAQS has been attained. The area's design values have trended downward as emissions have declined due to such fact ors as cleaner automobiles and fuels, and controls for EGUs, at the national, regional and local level.

National monitoring for PM 2.5 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 - PM 2.5 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 - PM 2.5 Annual Mean Trends Midwest States

Source: LADCO; Recent Ozone and PM25 Trends - Aug 26 2010.pptx12 Design values have also trended downward nationally:

Figure 4 - PM 2.5 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 ma intenance of the attainment status.

Demonstration Ohio EPA commits to continue monitoring PM 2.5 levels at the Ohio sites indicated in Figure 1 and Table 1. Oh io EPA will consult with U.S. EPA Region 5 prior to making changes to the existi ng monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirem ents of 40 CFR 58 and all other federal requirements. Connection to a centra l station and updates to the Ohio EPA web site 4 will provide real time availabilit y 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/dapc13 

### CHAPTER FOUR

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

U.S. EPA’s redesignation guidance requires the s ubmittal of a compr ehensive inventory of PM 2.5 precursor emissions (primary particles (o rganic carbon, crustal matter, and elemental carbon), SO 2 and NO x 5 ) representative of the year when the area achieves attainment of the annual PM 2.5 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 r eductions. Other emission inventory related requirements include a projection of the emi ssion inventory to a year at least 10 years following redesi gnation; a demonstration that the projected level of emissions is sufficient to maintain the annual PM 2.5 standard; and a commitment to provide future updates of the inventory to enable tra cking of emission levels during the 10-year maintenance period.

The emissions inventory development and emissi ons projection discussion below, with the exception of the mobile ( on-road) emissions inventor y and projections, identifies procedures used by Ohio EPA and the LADCO regarding emissions of all the counties in the Columbus area. All of these inventorie s and emissions projecti ons were prepared using similar methodologies. Mobile emissions inv entories and projections for all counties were prepared by the Mid-Ohio Regional Pl anning Commission (MORPC) and the Ohio Department of Transportation (ODOT).

Requirement 1 of 5 A comprehensive emission inventory of PM 2.5 , SO 2 and NO x completed for the base year.

Background The point source data are taken fr om Ohio's annual emissions reporting program. The 2005 periodic inventory has been identified as one of the preferred databases for SIP developm ent and coincides with nonattainment air quality in the Columbus area.

Periodic inventories, which include emissi ons from all sectors - mobile, area, non-road, and point sources - ar e prepared every three years.

Demonstration The 2005 inventory is used as the base y ear for the purpose of this submittal and was submitted to U. S. EPA with Ohio’s PM 2.5 attainment demonstration SIP submitted on July 18, 2008 and revised on June 7, 2010. The detailed

5 VOC and NH 3 are not addressed.14 emission inventory information for the Co lumbus area is provided in Appendix B. Emissions of PM 2.5, SO 2 and NO x for 2005 are identified under Requirement Three of this Chapter.

Requirement 2 of 5 A projection of the emi ssion inventory to a year at leas t 10 years following redesignation.

Background Ohio EPA prepared a comprehensive inventor y for the Columbus area including area, mobile, and point sources for PM 2.5 , SO 2 and NO x for base year 2005. The 2005 inventory was submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM 2.5 attainment demonstration SIP for this ar ea. 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 Report 6 ) based on a 2005 base year inventor y. The report by Pechan generated future year estimates of annual emissions for each source sector using accepted growth surrogates. These inventories we re 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 redesignati on. In this document, references to LADCO include the Midwest Regional Planning Organi zation. Note, the on-road mobile source sector was addr essed by specific PM 2.5 and NO x modeling as discussed below.

• Area sources were taken from the Ohio 2005 periodic inventory submitted to U.S. EPA. These proj ections were made from the U.S. Department of Commerce Bureau of Economic Analysis (BEA) growth factors, with some updated local information.

• Mobile source emissions we re calculated from MOVES2010 - produced emission factors. Only PM 2.5 and NO x necessitate emissions inventory analysis. As document ed in Ohio EPA’s attainment demonstration SIP, Ohio EPA in consultation with U.S. EPA determined mobile sources are in significant contributors for SO 2

. Consistent with Ohio EPA’s atta inment demonstration, Ohio EPA continues to consider mobile source SO 2 to be an insignificant contributor to fine particles for th is nonattainment area. Based on the demonstration below, SO 2 constitutes less than one percent (<1%) of the area’s total SO 2 emissions in 2005, 2008, 2015 and 2022 (ranging between 0.28% and 0.76%).

6 http://www.ladco.org/tech/emis/r5/r eports/LADCO%202005%20Base%20Yr% 20Growth%20and%20Controls%20Rep ort_Final.pdf15 • Point source information was compiled from Ohio EPA’s 2005 annual emissions inventory database and the 2005 U.S. EPA Air Markets acid rain database 7

.

• 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 contract ed 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 mo del. Emissions were estimated for aircraft, commercial marine ve ssels, and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were si gnificantly updated. The populations for the construction equipment ca tegory 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 fo r the on-road emission estimation analysis is divided into a modeled area comprised of Franklin, Delaware, Licking Counties and part of Fairfield C ounty, and into the donut area which includes the remainder of Fairfiel d County and Franklin Township in Coshocton County. The model cover age area uses the post-processor linklevel procedures to compute the emissions, while the non-modeled donut areas will utilize ODOT’s Highway Perfo rmance Monitoring Systems (HPMS) county level vehicle miles traveled (V MT) by functional class data (see Appendix C for further details). The travel demand model provides, among other things, daily traffic volumes, c ongested travel times, speeds, volume to capacity ratios, vehicle miles traveled, and vehicle hours trav eled. Areas that are not within the regional trav el demand model boundary utilize HPMS based on travel characteristics data. The travel demand model was used in evaluating emissions for Franklin, De laware, 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/acidrain16 Overview U.S.EPA published a Federal Register notice 8 of availability on March 2, 2010, to approve MOVES2010 (Motor V ehicle Emissions Simulator), hereafter referred to as MOVES. Upon pub lication of the Federal Register notice, MOVES became U.S. EPA’s approved motor vehicle emission factor model for estimating VOCs, NO x , CO, PM 10 and PM 2.5 and other pollutants and precursors from cars, trucks, mo torcycles, and buses by state and local agencies. MOVES is a computer progr am 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 collect s data and measures vehicle emissions to make sure the Agency has the best possible understanding of mobile source emissions. This assessm ent, in turn, informs the development of U.S. EPA’s mobile source em ission models. MO VES represents the Agency’s most up-to-date assessment of on-road mobile source emissions. MOVES also incorporates several c hanges 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 ex peditiously as possible. The CAA requires that SIP inventories and c ontrol measures be based on the most current information and applicable models t hat are available when a SIP is developed.

The MOVES more detailed approach (w hen compared with the previous MOBILE model) to modeling allows U. S. EPA to easily incorporate large amounts of in-use data from a wide vari ety 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 emissi on differences such as those resulting from changes to vehicle speed and acceleration patterns. MOVES has a graphical user interface which allows us ers 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.r egulations.gov/search/Regs/hom e.html#document Detail?R=0900006480ab1f9817 emission factors (grams-per-mile and in some cases grams-per-vehicle). Output can be easily aggregated or dis aggregated to examine emissions in a range of scales, from national emissi ons impacts down to the emissions impacts of individual transportation projects. The database-centered design also allows U.S. EPA to update emissi ons data incorporated in MOVES more easily and will allow users to in corporate a much wider array of activity data to improve estimation of local emissions . For example, t he improvements in MOVES will allow project-level PM2. 5 emissions to be estimated.

The latest planning assumptions avail able for the Central Ohio area were used. For the travel demand model, m odel validation is a joint process between MORPC, LCATS 9 , 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, Dela ware, Licking Counties and part of Fairfield County). Areas outside the regi onal model are remainder of Fairfield County and Franklin Township in Coshoc ton County. Forecasted variables such as population, employment, tra ffic counts, and roadway network, were developed by MORPC in coordination with LCATS and used for the analysis.

Independent variables (land use, socio-ec onomic data, etc.) were developed as well as interpolated for intermediat e years of analysis. MORPC continually monitors land use, population and em ployment information, and performs complete land use inventories every fi ve 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 MO RPC were developed for the direct PM 2.5 pollutants, tail pipe, break and ti re wear and the precursors of NO x and SO 2

.
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 we ll as more up to date volume /delay functions. The process uses codes abl e 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 t he daily volume, determined by a link’s facility and area type, 2) the calculation of emi ssions for every network link for each hour (this is done using a combinati on of the MOVES emission factors and

9 Licking County Area Transportation Study18 the hourly link volumes in the previous step), 3) the calcul ation of vehiclebased emissions for each source type for each hour of the day, 4) the calculation of intrazonal emi ssions by combining MOVES generated emissions with estimated intrazonal VM T, and 5) summarizing link, vehicle, and intrazonal emissions for each count y, pollutant, and analyzed year, and to multiply annual average daily em issions 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 whic h includes portions of Fairfield County and Franklin Township in Coshoct on County. This process requires estimating the proportion of county VM T 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 forwar d based on standard growth rates.

On-Road Mobile Emission Estimations Tables 2 through 7 contain the result s of the emissions analysis for the appropriate years. All emissions estima tions are expressed in tons per year (tpy).

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

2005 2008 2015 2022

PM 2.5 (tpy) 2.63 2.15 1.06 0.58

NO x (tpy) 66.14 49.71 21.10 8.76

SO 2 (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

PM 2.5 (tpy) 151.99 139.75 78.79 53.78

NO x (tpy) 5,372.30 4,716.95 2,500.97 1,308.18

SO 2 (tpy) 85.14 29.32 14.35 15.14

Annual VMT 1,583,202,465 1,783,481,615 2,169,135,870 2,542,369,90519 Table 4 – Fairfield County, Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 112.09 92.45 47.66 29.22

NO x (tpy) 3,564.05 2,789.29 1,331.20 624.84

SO 2 (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

PM 2.5 (tpy) 1,232.19 1,076.57 557.77 355.44

NO x (tpy) 38,665.96 32,410.28 15,519.51 7,455.60

SO 2 (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

PM 2.5 (tpy) 161.43 140.17 74.25 47.18

NO x (tpy) 5,722.16 4,859.58 2,439.49 1,200.45

SO 2 (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

PM 2.5 (tpy) 1,660.33 1,451.09 759.53 486.20

NO x (tpy) 53,390.61 44,825.81 21,812.27 10,597.83

SO 2 (tpy) 864.22 283.05 127.37 124.45

Annual VMT 15,307,837,200 16,508,237,885 18,424,404,300 20,060,774,12520 Motor Vehicle Emission Budget

Table 8 contains the motor vehicle em issions 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, incl ude the emission estimates calculated for 2015 and 2022 (from Table 7) with an additional 15 percent margin of safety allocated to PM 2.5 and NO x in 2015 and 2022.

In an effort to accommodate future va riations in travel demand models and VMT forecast when no change to t he 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 Conf ormity 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 VM T forecast and potential estimated mobile source emissions due to expec ted modifications to TDM and mobile emissions models; and 2) the total decreas e in emissions from all sources is sufficient to accommodate this 15 percent allocation of safety margin (as defined in 40 CFR93.101 10 ) 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 sa tisfy the applicable requirement for reas onable further progress, attainment, or maintenance.21 conformity rule, looks at the total emissions from all sources in the nonattainment area. The actual allocati on is less than 15 perc ent of the total emission reduction from all source s as can be seen from Table 44.

In summary, the mobile budget safety margin allocation translates into an additional 113.93 tpy for PM 2.5 and 3,271.84 tpy for NO x for 2015 and an additional 72.93 tpy for PM 2.5 and 1,589.67 tpy for NO x 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 sa fety margin for this area.

The current PM 2.5 and NO x 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 PM 2.5 and NO x conformity budgets included in this submittal are adequate for transportation conformi ty purposes, whichever date comes first.

Finally, it is important to underline t hat all motor vehicle emission budgets in this Redesignation submittal, wh ich are based on MO VES2010, will replace previous motor vehicle emission budgets on Attainment Demonstration submittals based on MOBILE6.2.

Requirement 3 of 5 A demonstration that the projec ted level of emissions is su fficient to maintain the PM 2.5 standard.

Background In consultation with U.S. EPA, Ohio EPA selected the year 2022 as the maintenance year for this redesignat ion request. This document contains projected emissions inventories for 2015 and 2022.

Emission projections for the Colum bus area were performed using the following approaches:

• As performed by MORPC, mobile source emission projections are based on the U.S. EPA MO VES model. The analysis is described in more detail in Appendix C. All proj ections were made in accordance with “Procedures for Preparing Emi ssions 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 futu re controls will have. LADCO has developed growth and control file s 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 redesignati on are consistent with modeling performed in the future. Appendix D contains LADCO’s technical support document detailing the analysi s used to project emissions (Base M 11 ).

• For the 2008 attainment year emi ssions were grown from the 2005 LADCO modeling inventory, using LA DCO’s growth factors, for all sectors except point sources (e lectrical 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 we re estimated based on the 2009 and 2018 LADCO modeling inventory, us ing LADCO’s growth factors, for all sectors. The 2022 maintenanc e 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 PM 2.5 standard. Therefore, Ohio EPA performed an init ial comparison of the inventories for the base year and ma intenance years. Mobile source emission inventories are described in Section 5 of Appendix B.

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

Ohio EPA is identifying emissions pr ojections for 2015 and 2022 for EGUs without the implementati on 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 prom ulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of Columbia to signifi cantly reduce emissions of NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. The intent of the CAIR program is for national NO x emissions to be cut from 4.5 milli on tons in 2004, to a cap of 1.5

11 http://www.ladco.org/tech/emis/current/i ndex.php23 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 acti on on September 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA proj ects that in 2009 emissions of NO x will decrease from a baseline of 264,000 tons per year to 93,000 tons per year while in 2010 emissions of SO 2 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 NO x will decrease to 83,000 tons per year while emissions of SO 2 will decrease to 208,000 tons per year, within Ohio 12

.
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 reduc tions 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 prov ide 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 NO x and 1,373,000 tons of SO 2 emitted in 2005. In 2008 and 2009 facilities began preparing for and implementing control programs to address CAIR 13 and consent decrees.

Table 9 - Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2009
SO 2 NO x 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 Tracking 14

Significant reductions also occurred r egionally and nationally as can be seen from the above. Data is also availabl e for the first two quarters of 2010, the year SO 2 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.html24 Table 10 – Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010
SO 2 NO x 2008 (1 st half) 2010 (1 st half) Change 2008 (1 st half) 2010 (1 st 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 Tracking 15

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

“Based on emissions monitoring dat a, EPA has observed substantial reductions in SO 2 emissions from 2005 to 2009 and in the first two quarters of 2010 as companies installed more c ontrols, electric demand declined, and low natural gas prices made combined- cycle gas-fired units more competitive in several parts of the country. T hus, even after CAIR's vacatur and subsequent remand in late 2008, the c ontrols in place generally have continued to operate, helping to dr ive 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 begi n in 2012. As proposed, the Transport Rule will preserve those initial reduc tions achieved under CAIR and provide more reductions in NO x and SO 2 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 PM 2.5 attainment in this nonattainment area and throughout Ohio. It is also Ohio EPA’ s belief that the Transport Rule, when finalized, will continue to provi de the necessary reductions, and likely even greater reductions, t hat will be necessary for maintenance of the annual PM 2.5 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 site 17 is projected to be in attainment and only one site 18 is projected to have a maintenance problem for annual PM2.5 in 2014 with the emissions reductions expected from this pr oposal.” [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, AL25 within this area will not have maint enance issues in 2012 or 2014 even without the Transport Rule (or CAIR) 19

Maintenance is demonstrated when t he future-year (2022) projected emission totals are below the 2008 attainment year totals.

The Ohio emissions data in the tabl es below are based on the following data

sources: - All On-Road data source: MORPC Transportation Modeling Department and ODOT’s Division of Transportati on 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

PM 2.5

Table 11 - Coshocton County, PM 2.5 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, PM 2.5 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, PM 2.5 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, PM 2.5 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 1,130.1627 Table 15 - Licking County, PM 2.5 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 PM 2.5 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 PM 2.5 TOTAL 5,749.9
3 5,533.30 4,645.26 4,174.02 1,359.28

NO x
Table 17 - Coshocton County, NO x 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 40.9528 TOTAL 22,680.31 21,688.78 10,429.42 4,743.95 16,944.83

Table 18 - Delaware County, NO x 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, NO x 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, NO x 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 24,954.6829 TOTAL 52,526.76 45,064.81 25,344.84 14,475.00 30,589.81

Table 21 - Licking County, NO x 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 NO x 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

SO 2
Table 23 - Coshocton County, SO 2 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 0.2530 TOTAL 109,830.31 93,424.01 43,435.96 22,012.69 71,411.32

Table 24 - Delaware County, SO 2 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, SO 2 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, SO 2 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 1,068.96 453.2931 Table 27 - Licking County, SO 2 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 SO 2 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

PM 2.5 , NO x , and SO 2

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
PM 2.5 5,533.30 4,645.26 888.04 4,174.02 1,359.28
NO x 87,462.56 48,662.84 38,799.72 27,377.11 60,085.45
SO 2 96,130.01 45,571.71 50,558.30 24,066.23 72,063.78

As shown in the table above (Table 29), PM 2.5 emissions in the nonattainment area are projected to decrease by 888.04 tpy in 2015 and 1,359.28 tpy in 2022. NO x emissions in the nonattain ment area are projected32 to decrease by 38,799.72 tpy in 2015 and 60,085.45 tpy in 2022. SO 2 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 populati on 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 impl emented in 2012 and 2014 and these programs should cause an overall drop in all three pollutants emissions. Decreases from U.S. EPA rules coveri ng Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 20 , Highway Heavy-Duty Engine Rule 21 , and the Non-Road Diesel Engine Rule 22 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 SO 2 controls in late 2007 and early 2008 per a consent decree. The third Cardinal unit (630 megawatts) has plans for advanced SO 2 control to comply with a December 2012 deadline within the same consent decree. The Conesville AEP Station, also in Cos hocton 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 decr ee, by continuously operating their existing advanced SO 2 controls and accepting a restricted SO 2 allowable emissions rate that will not cause or c ontribute to a violat ion 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 NO x and SO 2 controls in June 2009, as required by their consent decree.

All projections (PM 2.5 , SO 2 , and NOx) do not take in to account reductions expected from the CAIR. In many cases, Ohio utilities subject to CAIR have already, or will be installing c ontrols and reducing NOx and SO 2 emissions beyond those projected for EGUs above.

As can be seen from the projected decr eases above, even in the absence of consideration of reductions resulting fr om CAIR, and its fu ture 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.htm33 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 econom ic conditions or unusually favorable meteorology.

Background Ambient air quality data from all monitoring sites indicate that air quality met the NAAQS for PM 2.5 in 2008-2010. U.S. EPA’s redesignati on guidance (p 9) states: “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its pr ecursors 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 PM 2.5 , NO x , and SO 2 emissions have contributed to the attainment of the annual PM 2.5 standard. Some of these reductions were due to the application of ti ghter federal standards on new vehicles. Also Title IV of the CAA, the NO x SIP Call, CAIR, and federal consent decrees required the reductions of SO 2 and NO x emissions from utility sources. Reductions achieved are discussed in great er 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 PM 2.5 1,660.33 1,451.09 On-road NO x 53,390.61 44,825.81 On-road SO 2 864.22 283.05 EGU PM 2.5 657.22 656.49 EGU NO x 21,465.83 20,449.55 EGU SO 2 109,750.80 93,358.73

Requirement 5 of 5 Provisions for future annual updates of the in ventory to enable tracking of the emission levels, including an annual emission st atement from major sources.

Demonstration In Ohio, major point sources in all counties are required to submit air emissions information annually, in acco rdance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic inventory for all PM 2.5 precursor emission sectors every three years. These PM 2.5 precursor inventories will be prepared fo r future years as necessary to comply with the inventory reporting r equirements established in the CFR. Emissions information will be compared to the 2005 base year and the 202234 projected maintenance year inventor ies to assess emission trends, as necessary, and to assure cont inued compliance with the annual PM 2.5 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 Ac t 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 m easures (for statio nary, mobile, and area sources) that are technically and economically feasible, and that would collectively contribute to advancing the a ttainment 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 fo r 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 prom ulgated 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 ar e incorporated into permits along with monitoring, recordkeeping, and repor ting necessary to ensure ongoing compliance. Ohio EPA also has an ac tive enforcement program to address violations discovered by field office st aff. The Ohio RACT rules are found in OAC Chapter 3745-17 23

.

23 http://www. epa.ohio.gov/dapc/r egs/3745_17.aspx36 In addition, Ohio EPA promulgated NO x SIP Call rules (OAC Chapter 3745- 14 24 ), CAIR (OAC Chapter 3745-109 25 ), and NO x Reasonably Available Control Technology rules (OAC Chapter 3745-110 26 ) over the past five years. Emissions from EGUs make up a signific ant contribution to Ohio’s inventory. Beginning in 2009, Ohio implemented CA IR which has, and will, provide for significant reductions in NO x , PM 2.5 , and SO 2 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 explori ng control measures for reducing both ozone precursors and PM 2.5 precursors in Ohio, Illinois, Indiana, Michigan, and Wisconsin area. The first consul tant, MACTEC, prepared a series of white papers 27 researching different stationary source categories. The results were compiled into two reports 28 . The second consultant, Environ, investigated control options for mobile sources. The results were compiled into two reports 29 . The stationary and mobile sour ce 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 c onducted (as part of LADCO Round 4 modeling) to assess the air quality benefit of the candidate control measures and a modeling report was developed 30 . Based on the results, the LADCO project team felt it w ould not be possible to advance the attainment date for PM 2.5 . Ohio EPA, in its attainment demonstration submitted on July 18, 2008, demonstrated (using a weight of ev idence approach) that attainment would be achieved in this area by 2009. Because of a projected 2009 attainment date, it w ould not have been reasonably possible or practicable for Ohio to develop RACT/RACM require ments, promulgate regulations and implement a control program prior to the projected attainment date.

24 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx 25 http://www. epa.ohio.gov/dapc/r egs/3745_109.aspx 26 http://www. epa.ohio.gov/dapc/r egs/3745_110.aspx 27 http://www.ladco.org/r eports/control/white_papers 28 http://www.ladco.org/r eports/control/final_reports/ident ification_and_evaluati on_of_candidate_control_ measures_i_april_2 005.pdf; http://www.ladco.org/r eports/control/final_reports/ident ification_and_evaluati on_of_candidate_control_ measures_ii_june_2 006.pdf 29 http://www.ladco.org/r eports/control/final_reports/final_report_evaluat ion_of_candidate_mobile_sour ce_control_measures _february_2006.pdf; http://www.ladco.org/r eports/control/final_reports/final_report_evaluat ion_of_candidate_mobile_sour ce_control_measures _for_ladco_states_ in_2009_and_2012_march_2007.pdf 30 http://www.ladco.org/r eports/control/modeli ng/round4_modeling.pdf37 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 dat e 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 achi evement of RFP.

Demonstration In Ohio’s attainment demonstrati on submitted on July 18, 2008, Ohio demonstrated (using a weight of evidenc e approach) that attainment would be achieved in this area by 2009; and t herefore, 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 desi gnation and requires a baseline emission inventory for calendar year 2002 or ot her suitable year to be used for attainment planning.

Demonstration The 2005 comprehensive inventory was s ubmitted to U.S. EPA with Ohio’s PM 2.5 attainment demonstration SIP submi tted 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 s ubmitted its emissi ons statement SIP on March 18, 1994 which was approved by U.S. EPA on October 13, 1995 (59 FR 51863). As discussed in C hapter 4 (Requirement 4), Ohio EPA submits, and commits to submit, emi ssion inventories (statements) every three years.

Requirement 4 of 638 Evidence that control meas ures required in past PM 2.5 SIP revisions have been fully implemented.

Background In addition to the historic RACT requirements for PM, the U.S. EPA NO x SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industria l 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. Co mpliance is tracked through the Clean Air Markets data monitoring program. Beginning in 2004, this rule accounts for a reduction of approximatel y 31 percent of all NO x emissions statewide compared to previous uncontrolled year s. The other 21 states also have adopted these rules.

On March 10, 2004, the U.S. EPA prom ulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of Columbia to signifi cantly reduce emissions of NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. National NO x emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 m illion tons by 2009, and 1.3 million tons in 2018 in 28 stat es. States were required to submit a CAIR SIP as part of this effort. Ohio subm itted 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 revis ed CAIR SIP was approved as a direct final action on September 25, 2009 (74 FR 48857).

Demonstration Controls for EGUs under the NO x SIP Call formally commenced May 31, 2004. Emissions covered by this program have been generally trending downward since 1998 with larger r eductions occurring in 2002 and 2003. Data taken from the U.S. EPA Clean Air Markets web site, quantify the gradual NO x reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 31 in response to the SIP Call. OAC Chapter 3745-14 regulates EGUs and certain non-EGUs under a c ap and trade program based on an 85 percent reduction of NOx emissions fr om EGUs and a 60 per cent reduction of NO x 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/r egs/3745_14.aspx39 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 NO x SIP Call that establishes a budget for large (great er than 1 ton per day emissions) stationary internal combustion engi nes. Ohio EPA’s OAC rule 3745-14-12 addresses stationary internal combus tion engines, all used in natural gas pipeline transmissions. U.S. EPA approved th is revision to the SIP on April 4, 2008. An 82 percent NO x reduction from 1995 leve ls 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 f ederal rule to significantly reduce emissions from cars and light trucks, in cluding 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 f ederal rules will phase in between 2004 and 2009. U.S. EPA has esti mated that NO x 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 SU Vs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issu ed a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur di esel 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 NO x from diesel trucks and buses, a large sector of the mobile sources NO x 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 industrie s 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. N on-road diesel equipment, as described in this rule, currently accounts for 47 per cent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nation wide. Sulfur levels will be reduced in non-road diesel fuel by 99 percent from current levels, from40 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 PM 2.5 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 address ed in OAC Chapter 3745-31 32 . The Chapter includes provisions for the Prevention of Signi ficant 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 lis ted in the 2005 emission invent ory, or for the closing of which credit was taken in demonstrat ing attainment, will not be allowed to construct, reopen, modify, or reconstr uct without meeting all applicable NSR requirements. Once the area is r edesignated, Ohio EPA will implement NSR through the PSD program.

Requirement 6 of 6 Assure that all existing control measures will re main in effect after redesignation unless the State demonstrates through m odeling that the standard can be maintained without one or more control measures.

Demonstration Ohio commits to maintaining the af orementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicable to PM 2.5 , SO 2 , and NO x as required for maintenance of the annual PM 2.5 standard in the Columbus area, will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal secti on, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it int ends to continue enforcing all rules that relate to the emission of PM 2.5 precursors in the Columbus area.

32 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx41 

### CHAPTER SIX

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

Requirement 1 of 4 A commitment to submit a revised pl an eight years after redesignation.

Demonstration Ohio hereby commits to review it s 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 im plement additional contingency control measures in response to exceeding specified pr edetermined levels (triggers) or in the event that future violations of the ambient standard occur.

Demonstration Ohio hereby commits to adopt and ex peditiously implement necessary corrective actions in the following circumstances:

Warning Level Response: A warning level response sha ll be prompted whenever the PM 2.5 average of the weighted annual mean of 15.5 μg/m 3 occurs in a single calendar year within the maintenance area. A warning level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to c ontinue and, if so, t he control measures necessary to reverse the trend taking in to consideration ease and timing for implementation as well as econom ic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expedi tiously 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 warn ing 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 prom pted whenever a two- year average of the weighted annual means of 15.0 μg/m 3 or greater occurs within the maintenance area. A violation of t he standard (three-year average of the weighted annual means of 15.0 μg/m 3 or greater) shall also prompt an action level response. In the ev ent that the action level is triggered and is not found42 to be due to an exceptional event, ma lfunction, or noncompliance with a permit condition or rule requiremen t, Ohio EPA in conjunction with the metropolitan planning organization or r egional council of governments, will determine additional control measures needed to assure future attainment of the NAAQS for annual PM 2.5 . In this case, measures that can be implemented in a short time will be select ed 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 timi ng of an action level trigger and determine if additional, signifi cant 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 Sele ction and Implementation Adoption of any additional control meas ures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public heari ng, 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 t hat 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 dem onstrate the proposed measures are adequate to return the area to attainment.

Requirement 3 of 4 A list of potential contingency measures t hat would be implemented in such an event.

Demonstration Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appr opriate and effective at the time the selection is made. The select ion of measures will be based on costeffectiveness, emission reduction potential, economic and social considerations or other factors t hat Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to selecting appropriate cont ingency measures. Because it is not possible at this time to determine w hat control measur es will be appropriate at an unspecified time in the future, t he list of contingen cy 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.43 3) Tighter PM 2.5 , SO 2 , and NO x 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 NO x 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 ti me they are under consideration, can be fully evaluated.

Requirement 4 of 4 A list of PM 2.5 , SO 2 , and NO x sources potentially subject to future additional control requirements.

Demonstration The following is a list of PM 2.5 , SO 2 , and NO x sources potentially subject to future controls.

• ICI Boilers - SO 2 and NO x controls;

• EGUs;

• process heaters;

• internal combustion engines;

• combustion turbines;

• other sources greater than 100 tons per year;

• fleet vehicles;

• concrete manufacturers;

• aggregate processing plants;44 

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hear ing 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, Co lumbus, Ohio. The public comment period closed on April 21, 2011. Appendix E includes a copy of the public notice, certification of publication, and the transcrip t from the public hearing.45 

### CHAPTER EIGHT

CONCLUSIONS

The Columbus area annual PM 2.5 nonattainment area has attained the 1997 annual NAAQS for PM 2.5 and complied with the applicable provisi ons of the 1990 Amendm ents to the CAA regarding redesignations of PM 2.5 nonattainment areas. Document ation to that effect is contained herein. Ohio EPA has prepared a r edesignation request and maintenance plan that meet the requirements of Sect ion 110 (a)(1) of the 1990 CAA.

Based on this presentation, the Columbus area annual PM 2.5 nonattainment area meets the requirements for redesignation under t he CAA and U.S. EPA guidance. Ohio has performed an analysis that shows the air qualit y improvements are du e to permanent and enforceable measures. Furthermore, because this area is subject to significant transport of pollutants, significant regional SO 2 and NO x 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 PM 2.5 nonattainment area be redesignated to attainment simu ltaneously with U.S. EPA approval of the maintenance plan provisions contained herein.46 This page left intentionally blank