# Ohio Environmental Protection Agency

John R. I<asich, Governor Mary Taylor, Lt. Governor
Scott J. Nally, Director

Ms. Susan Hedman Regional Administrator U.S. EPA Region 

### 5
77 W. Jackson Blvd. Chicago, IL 60604 

## OCT 05 2011

Re: PM2.5 redesignation request for the 1997 PM2.5 Annual Standard for the ClevelandAkron-Lorain Area

Dear Administrator Hedman:

I am writing to formally request a redesignation to attainment of the Cleveland-AkronLorain area (Ashtabula, Cuyahoga, Lake, Lorain, Medina, Portage, and Summit Counties) 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 Ouality Standard (NMOS) 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 NMOS indefinitely into the future. These programs will, therefore, constitute the attainment and maintenance plan for the Cleveland-Akron-Lorain area.

The enclosed information, compiled by the Ohio Environmental Protection Agency (Ohio EPA), Ohio Department of Transportation, and the Northeast Ohio Areawide Coordinating Agency (NOACA), 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 August 18, 2011. The public hearing for this package was held on September 23, 2011, in Twinsburg, Ohio.

50 West Town Street/ Suite 700 P.O. Box 1049 Columbus, OH 43216-1049 614 I 644 3020 614 I 644 3184 (fax) www.epa.ohio.gov

### If you have questions, please contact Jennifer Hunter in our Division of Air Pollution Control at (614) 644-3696.

Sincerely,

Scott J. Nally Director

Enclosure

# REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE CLEVELAND-AKRON-LORAIN ANNUAL PM 2.5 

# NONATTAINMENT AREA

Ashtabula, Cuyahoga, Lake, Lorain, Medina, Portage, and Summit, Ohio

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

September 2011

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### TABLE OF CONTENTS

Chapter One Introduction .................................................................................................................. ................. 1 Geographical description ...................................................................................................... ........ 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 4

Chapter Four Emission inventory ............................................................................................................ .......... 15 Base year inventory ........................................................................................................... ......... 15 Emission projections .......................................................................................................... ......... 16 Demonstration of maintenance .................................................................................................. . 25 Permanent and enforceable emissions reductions ..................................................................... 38 Provisions for future updates ................................................................................................. ..... 39

Chapter Five Control measures and regulations .............................................................................................. 40 Marginal nonattainment areas to implement RACM and RACT .................................................. 40 Show Reasonable Further Progress (RFP) ................................................................................ 42 Emission inventories .......................................................................................................... ......... 42 Implementation of past SIP revisions .......................................................................................... 43 New source review provisions ................................................................................................. .. 45 Assurance of continued controls ............................................................................................... .. 46

Chapter Six Contingency measures .......................................................................................................... ..... 47 Commitment to revise plan ..................................................................................................... .... 47 Commitment for contingency measures ..................................................................................... 47 Potential contingency measures ................................................................................................ . 48 List of PM 2.5 , SO 2 , and NO x sources ........................................................................................... 49

Chapter Seven Public participation .......................................................................................................... ............ 50

Chapter Eight Conclusions ................................................................................................................... ............. 51ii FIGURES

Figure 1 Map of the Cleveland-Akron-Lorain nonattainment area and monitor locations .... 9 Figure 2 PM 2.5 Annual Mean Trends LADCO States ......................................................... 13 Figure 3 PM 2.5 Annual Mean Trends Midwest States ........................................................ 13 Figure 4 PM 2.5 Annual Mean National Trends .................................................................. 14

TABLES

Table 1 Monitoring Data for Cleveland-Akron-Lorain area for 2008 – 2010 ..................... 11 Table 2 Comparison Between Original and Imputed Values for Monitors 39-035-006, 39-035-0065, and 39-035-1002 from 2004 to 2010 ............................................ 12 Table 3 Ashtabula County Emission Estimations for On-road Mobile Sources ................ 21 Table 4 Cuyahoga County Emission Estimations for On-road Mobile Sources ............... 22 Table 5 Lake County Emission Estimations for On-road Mobile Sources ........................ 22 Table 6 Lorain County Emission Estimations for On-road Mobile Sources ...................... 22 Table 7 Medina County Emission Estimations for On-road Mobile Sources .................... 22 Table 8 Portage County Emission Estimations for On-road Mobile Sources ................... 22 Table 9 Summit County Emission Estimations for On-road Mobile Sources .................... 23Table 10 Emission Estimations Totals for On-road Mobile Sources for the ClevelandAkron-Lorain Area ............................................................................................... 23 Table 11 Mobile Vehicle Emission Budget ......................................................................... 23 Table 12 Reductions in SO 2 and 

### NO x EGU Emissions Between 2008 and 2009. ............. 27 Table 13 Reductions in SO 2 and 

### NO x EGU Emissions Between the First Half of 2008 and 2010.... ......................................................................................................... 27 Table 14 Ashtabula County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 29 Table 15 Cuyahoga County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 29 Table 16 Lake County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 30 Table 17 Lorain County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ................................ 30 Table 18 Medina County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR ................ 30 Table 19 Portage County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 31 Table 20 Summit County PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 31 Table 21 Cleveland-Akron-Lorain PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 31 Table 22 Ashtabula County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 32 Table 23 Cuyahoga County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 32 Table 24 Lake County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 32 Table 25 Lorain County NO x Emission Inventory Totals for Base Year 2005,iii Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 33 Table 26 Medina County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 33 Table 27 Portage County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 33 Table 28 Summit County NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 34 Table 29 Cleveland-Akron-Lorain Area NO x Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .......... 34 Table 30 Ashtabula County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 34 Table 31 Cuyahoga County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 35 Table 32 Lake County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 35 Table 33 Lorain County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 35 Table 34 Medina County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 36 Table 35 Portage County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 36 Table 36 Summit County SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 36 Table 37 Cleveland-Akron-Lorain Area SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ........... 37 Table 38 Cleveland-Akron-Lorain Area Comparison of 2008 attainment year and 2015 and 2022 projected emission estimates (tpy) ...................................................... 37 Table 39 Cleveland-Akron-Lorain Area Combined Comparison of 2005 base year and 2008 attainment year on-road and EGU reductions ............................................ 39

APPENDICES

A Air Quality System (AQS) Data B Ohio 2005 SIP Base Year Inventory Discussion C Mobile Source Emissions Inventory for the Cleveland-Akron-Lorain PM 2.5 Nonattainment Area D LADCO Technical Support Document E Incomplete Monitoring Data Substitution Analysis F Public Participation Documentationiv 

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### REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE CLEVELAND-AKRON-LORAIN ANNUAL PM 2.5 

### NONATTAINMENT AREA

Ashtabula, Cuyahoga, Lake, Lorain, Medina, Portage, and Summit Counties, Ohio



### CHAPTER ONE

Introduction The Clean Air Act (CAA), as amended, requi res each State with areas failing to meet the annual PM 2.5 1 

### National Ambient Air Qua lity Standard (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standards. The United States Environmental Protection Agency (U.S. EPA) revised the NAAQS for particulate matte r 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 standard protec ting welfare. The standards include an annual standard set at 15.0 microgr ams 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 May 14, 1999, the D.C. Circuit remanded, without vacatur, the standard ba ck to U.S. EPA. The remand did not question the level at wh ich U.S. EPA set the st andards but rather the constitutionality of the CAA provision that authorizes U.S. EPA to set national air quality standards. U.S. EPA requested a rehearing wh ich the D.C. Circuit denied. Therefore, in December 1999, U.S. EPA appealed the D.C. Circuit decision to the U.S. Supreme Court. The U.S. Supreme Court issued a decision on February 27, 2001 that unanimously affi rmed the constitutionality of the CAA provision but did remand several other i ssues back to the D.C. Circuit, including the issue of whether U.S. EPA acted arbitrarily and capric iously in establishing the specific levels of the standards.

The D.C. Circuit heard arguments in this remanded case in December 2001, and issued its decision on March 26, 2002. The D. C. Circuit rejected the claims that

1 Particle pollution is a mixture of microscopic solid s and liquid droplets suspended in air. This pollution, also known as particulate matter, is made up of a number of components, including acids (such as nitrates and sulfates), organic chem icals, 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 diameter and smaller - 1/30th the diameter of a human hair. Fine particle pollution c an be emitted directly or formed secondarily in the atmosphere.2 

### the U.S. EPA had acted arbitr arily 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 designations were made and an effect ive date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendment s of 1990 which defined five ozone nonattainment classifications for the ar eas that exceed the NAAQS based on the severity of the ozone levels, PM 2.5 

### nonattainment designations are simply labeled “nonattainment.” The CAA Amendments require states with PM 2.5 

### nonattainment areas to submit a plan withi n three years of t he effective date of the designations (April 5, 2008) detailing how the PM 2.5 

### standards will be attained by April 5, 2010. Ohio EPA subm itted its attainment demonstration for the entire State of Ohio on July 16, 2008.

Section 107(d)(3)(E) of the CAA allows st ates to request nonattainment areas to be redesignated to attainment provided cert ain criteria are met. The following are the criteria that must be met in or der for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has attained the PM 2.5 

### standard. ii) An approved State Im plementation Plan (SIP) for the area under Section 110(k). iii) A determination that the improvem ent in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Sect ion 110 and Part D requirements have been met.

This document addresses each of these requirements, and provides additional information to support continued compliance with the annual PM 2.5 

### standard.

Geographical Description and Background The current Cleveland-Akron-Lorain nonattainment area is located in northeastern Ohio and includes the fo llowing counties: Ashtabula (partial nonattainment of Ashtabula Township onl y), Cuyahoga, Lake, Lorain, Medina, Portage, and Summit. This area is shown in Figure 1 under Chapter Three.

The Cleveland-Akron-Lorain area has not previously been subject to nonattainment area rulemakings for fine particles.

As a result of the 2005 PM 2.5 

### designations, U.S. EPA designated the ClevelandAkron-Lorain area nonattain ment for the 15.0 μg/m 3 

### annual standard 2 

### , and Ohio

2 There were no monitors in Ohio that violated the 1997 24-hour PM 2.5 standard of 65μg/m 3

.3 

### 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 demons trate that the area will meet the federal annual ai r quality standard by April 5, 2010. Ohio’s main PM 2.5 

### components are primary particles (or ganic carbon, crustal material, and elemental carbon), SO 2 

### and NO x 

### , which were included in the attainment demonstration analysis. Volatile or ganic compounds (VOCs) and ammonia (NH3) were not included in the analysis si nce they were not part of Ohio’s current attainment strategy for PM 2.5 

### (although controls for VOCs have been implemented for ozone nonattainment). This is consistent with U.S. EPA’s “Clean Air Particle Implementation Rule” [ 74FR 20856] (hereafter referred to as “Implementation Rule”). In the Implem entation Rule U.S. EPA presumes NH3 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 si gnificantly contribute to nonattainment of the annual PM 2.5 

### standard.

This document is intended to support Oh io’s request that the Cleveland-AkronLorain area be redesignated from nonattain ment to attainment for the annual PM 2.5 

### standard.

Status of Air Quality PM 2.5 

### complete quality-assured ambient ai r quality monitoring data for the most recent three (3) years, 2008 through 2010, demonstrate that 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 redesignati on to attainment for the Cleveland-Akron-Lorain area based on the requirements in Section 107( d)(3)(E) of the CAA as amended.4 

### CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed 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 pl an are based on the redesignation guidance, supplemented with additional guidanc e received from staff of U.S. EPA Region 5.

Below is a summary of each redesignat ion criterion as it applies to the Cleveland-Akron-Lorain area.

i.) Attainment of the standard (CAA Section 107(d)(3)(E)(i)) There are two components involved in making this demonstration. The first component relies on ambi ent air quality dat a. The data that are used to demonstrate atta inment should be the product of ambient monitoring that is repr esentative of t he area of highest concentration. The data should be collected and quality-assured in accordance with 40 CFR 58 and recorded in the Air Quality System (AQS) in order for it to be avail able to the public for review.

The second component relie s upon supplemental U.S. EPAapproved air quality modeling. While no modeling is required for redesignating nonattainment areas , the redesignation guidance states it is “generally necessary” for particulate matter redesignations. Appendix C and A ppendix D contains the most recent modeling results sho wing future attainment and maintenance are provided. C hapter Three 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 reasonabl y attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should es timate the percent reduction achieved from federal m easures as well as control measures that have been adopted and implement ed 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 rule s recently that will have an impact on statewide PM 2.5 

### emissions in the future:5 

### • Clean Air Interstate Rule (CAIR)

• NO x 

### SIP Call Rules

Ohio will also be subject to a Federal Implementation Plan under the CAIR replacement rule, the Cross-State Air Pollution Rule (CSAPR), that will result in even greater reductions than the CAIR program. In addition, since the initial designations were made federally enforceable consent decr ees have resulted in reductions in emissions from utilities across the state.

Chapters Four and Five discuss this requirement in more detail.

iii.) Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v)) For purposes of redesignation, a st ate must meet all requirements of Section 110 and Part D that were applicable prior to submittal of the complete redesignation request.

Subpart 1 of Part D consists of general requirements applicable to all areas which are designated nonat tainment based 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 pur pose of implementing the 1997 PM 2.5 

### standard, U.S. EPA’s Implem entation 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 CAA contains the general requirements for a SIP. Secti on 110(a)(2) provides that the implementation plan submitt ed by a state must have been adopted by the state after reasonable public notice and hearing, and that, among other things, it must include enforceable emission limitat ions and other control measures, means or techniques necessary to meet the requirements of the CAA; pr ovide for establishment and operation of appropriate dev ices, methods, systems and procedures necessary to m onitor ambient air quality; provide for implementation of a source permit program to regulate the modification and cons truction of any stationary source within the areas cove red by the plan; include provisions for the implementati on of Part C, prevention of significant deterioration (PSD) and Part D, NSR permit programs; include criteria fo r stationary source emission control measures, monito ring, and reporting; include provisions for air quality m odeling; and provide for public and local agency participation in planning and emission6 

### control rule development. In Ohio’s December 5, 2007 and September 4, 2009 infrastructure SIP submissions, Ohio verified that the State fulfills the requirements of Section 110(a)(2) of the Act.

Section 110(a)(2)(D) also requi res State plans to prohibit emissions from within t he State which contribute significantly to nonattainment or maintenance areas in any other State, or which interf ere with programs under Part C to prevent significant deterio ration 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 their obligations regarding r egionally 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 states. 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, 2011, U.S. EPA finalized a replacement to t he CAIR program, the CSAPR. CSAPR will further assist States in addressing their obligations regarding regiona lly 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 requirements for nonattainment plans. The requirements for reasonable further progress, identificat ion of certain emissions increases, and other measur es needed for attainment will not apply for redesignations because they only have meaning for areas not atta ining the standard. The requirements for an emission in ventory will be satisfied by the inventory requirements of the maintenance plan. Chapters Four and Five discuss this requirement in more detail.

iii.) Conformity The state must work with U.S. EPA to show that its SIP provisions are consistent with the Section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has

3 http://www. epa.ohio.gov/dapc/regs /regs.aspx#3745-1097 

### these procedures in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state must commit to follow U.S. EPA’s conformity regulation upon issuance, as applicable.

iv.) Maintenance plans (CAA Section 107(d)(3)(E)(iv)) Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a ma intenance 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) furt her states that the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures as the Administrator d eems necessary to ensure prompt correction of any violation of t he NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all meas ures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a.) attainment inventory; b.) maintenance demonstration; c.) monitoring network; d.) verification of continued attainment; and e.) contingency plan.

Chapter Six discusses this requirement in more detail.8 

### CHAPTER THREE

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 13 monitors measuring PM 2.5 

### concentrations in this nonattainment area. These moni tors are operated by Ohio EPA Division of Air Pollution Contro l, Northeast District Office, the Cleveland Department of Public Health, the Lake County General Health District, and the Akron Regional Air Quality Management District. A listing of the design values based on the three-year average of the annual mean conc entrations from 2008 through 2010 is shown in Table 1. The locations of the monitoring sites for this nonattainment area are shown on Figure 1.9 

### Demonstration

Figure 1 - Map of the Cleveland-Ak ron-Lorain nonattainment area and monitor locations

Requirement 2 of 4 Ambient monitoring data quality assur ed in accordance with 40 CFR 58.10, recorded in the U.S. EPA air quality syst em (AQS) database, and available for public view.

Demonstration Ohio EPA has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and all ot her federal requirements. Ohio EPA has recorded the data in the AQ S database and, therefore, the data are available to the public.

Requirement 3 of 4 A showing that the three-year av erage of the annual mean values, based on data from all monitoring sites in the ar ea or its affected downwind environs, are below 15.0 μg/m 3 

### . (This showing must rely on three complete, consecutive calendar years of quality assured data.)10 

### Background

The following information is taken from U.S. EPA's "Guidelineon Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999.

In accordance with the CAA Amendm ents, three comp lete years of monitoring data are required to demonstrate attainment 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 when the three-year aver age of the annual average is less than 15.0 μg/m 3 

### . While calculating design values, three significant digits must be carried in the co mputations, 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 area is in comp liance with the annual PM 2.5 

### NAAQS only if every monitoring site in the area meets the NAAQS. An individual site's 3-year average of the annual average concentrations is also called the site's design value. T he air quality design value for the area is the highest design value among all sites in the area.

Table 1 shows the monitoring data for 2008 – 2010 that were retrieved from the U.S. EPA AQS. The air quality design value for the area is the highest design value among all sites in the area.11 

### Demonstration

Table 1 - Monitoring Data for th e Cleveland-Akron-Lorain area for 2008 – 2010

Average

2008 2009 2010 2008-2010

39-035-0027 [a] 13.2 10.6

39-035-0034 10.9 10.2 10.9 10.7
39-035-0038 14.1 12.8 14.0 13.6
39-035-0045 13.7 11.8 13.3 12.9

39-035-0060 [b] 14.1 12.3 13.7 13.4
39-035-0065 14.6 12.4 13.2 13.4

39-035-1002 [c] 12.0 10.9 11.3 11.4

39-085-0007 [d] 10.4 10.4

39-085-3002 [e] 11.5
39-093-3002 Lorain 11.4 9.9 10.4 10.6

39-103-0003 Medina 11.8 10.8 10.8 11.1 39-133-0002 Portage 12.1 11.1 11.2 11.5

39-153-0017 13.8 12.6 13.4 13.3

39-153-0023 12.9 11.4 12.5 12.3 Less than 75% capture in at least one quarter

[a] This site was shut down in 7/2009 due to the demolition of the building that hosted the monitor. USEPA approved

the shut down without relocation.
[b] Although this is one of the highest reading monitor sites in the area, data from previous years show a decreasing trend in monitor readings. Ohio believes that had the missing data been collected it would not have resulted in a design

value that would exceed the standard. [c] Historically this monitor has been one of the, if not the, lowest reading monitor in Cuyahoga County. This monitor is located in a suburban-residential setting, approximately 2 miles away from the Cleveland Hopkins airport but more than 8.8 miles away from Cleveland's heaviest industrial area. Ohio believes that had the missing data been collected it would not have resulted in a design value that would exceed the standard. [d] and [e] Site [e] was relocated to site[d]. USEPA evaluate the candidate site [d] and approved the replacement
request, authorizing with this replacement, the combination of ozone and fine particulate data from both sites for the purpose of calculating desing values for NAAQS determinations. The three-year average (2008-201 0) from combining

the data from both sites is 1 0.8ug/m3 of PM2.5. Site Year County

Cuyahoga

Summit

Lake Annual Standard

10.8

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



### The design values calculated fo r the Cleveland-Akron-Lorain area demonstrate that the annual PM 2.5 

### NAAQS has been attained. However, three monitor sites in Cuyahoga C ounty, site 39-035-0060, site 39-035- 0065, and site 39-035-1002, did not co mply with the 75% data capture requirement for the 2008-2010 period. S pecifically, site 39-035-0060 has only 48% and 63% capture in the second and third quarter of 2009, respectively. Site 39-035-0065 has only 74% capture in the third quarter of 2010, and site 39-035-1002 has only 71% capture in the first quarter of 2008 and 73% capture in the third quarter of 2009. These monitoring sites experienced instrument malfunctions during the low percentage capture periods.12 

### Under 40 CFR Part 50, Appendix N, t he use of less than complete data may be approved by U.S. EPA consider ing such factors as monitoring site closures/moves, monitoring d iligence, and nearby concentrations in determining whether to use such data. Therefore, in order to further demonstrate that these monitors have attained the standard, Ohio EPA prepared a statistical analysis using mu ltiple imputations. Ohio EPA has imputed missing values for these sites and then performed an ordinary analysis as if the imputed values we re real measurements. Multiple imputations use random draws from t he conditional distribution of the target variable given the other va riables. When a regression model is used for imputation, the process invo lves adding a random residual to the “best guess” for missing values, to yiel d the same conditional variance as the original variable. Appendix E descr ibes and includes the full statistical analyses performed to show that the three-year averages (2008 to 2010) of the annual mean values, based on mi ssing data imputations, are below 15.0 μg/m 3



### .

Table 2 shows site 39-035-0060, si te 39-035-0065, and site 39-035-1002 before and after the imputation of missi ng data. Also the “new” sites (with imputed values) show a passing design value for 2008 to 2010 of less than 13.6 μg/m 3



### .

Table 2 – Comparison Between Original and Imputed Values for Monitors 39-035-0060, 39-035- 0065, and 39-035-1002 from 2004 to 2010

Annual Design Value

Site Year 2004

‐ 2006 2005

‐ 2007 2006

‐ 2008 2007

‐ 2009 2008

‐ 2010 2004 2005 2006 2007 2008 2009 2010

OLD 39-035-0060 16.4 19.4 15.0 15.9 14.1 12.3 13.7 16.9 16.8 15.0 14.1 13.4

NEW 39-035-0060 15.6 18.5 14.6 15.4 13.8 12.5 13.6 16.2 16.2 14.6 13.9 13.3

OLD 39-035-0065 15.2 18.6 13.1 15.8 14.6 12.4 13.2 15.6 15.8 14.5 14.3 13.4

NEW 39-035-0065 15.2 18.4 13.2 15.7 14.8 12.4 13.4 15.6 15.8 14.6 14.3 13.5

OLD 39-035-1002 13.2 16.8 11.6 13.4 12.0 10.9 11.3 13.9 13.9 12.3 12.1 11.4

NEW 39-035-1002 13.1 16.7 11.0 13.3 11.1 10.6 11.1 13.6 13.7 11.8 11.6 10.9 incomplete data (quarter with <75% capture)



### With the data imputation analysis and re sults, Requirement 3 of 4 has been met.13 

### 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:

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 PM2.5 Trends - Aug 26 2010.pptx14 

### 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 cont inue to operate an appropriate monitoring network to verify the maintenance of the attainment
status.

Demonstration Ohio EPA commits to continue monitoring PM 2.5 

### levels at the Ohio sites indicated in Figure 1 and T able 1. Ohio EPA will consult with U.S. EPA Region 5 prior to ma king changes to the existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. Connection to a c entral station and updates to the Ohio EPA web site 4 

### will provide real time availability of the data and knowledge of any exceedances . Ohio EPA will enter all data into AQS on a timely basis in a ccordance with federal guidelines.

4 www. epa.ohio.gov/dapc15 

### CHAPTER FOUR

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

U.S. EPA’s redesignation guidance require s the submittal of a comprehensive inventory of PM 2.5 

### precursor emissions (primary par ticles (organic carbon, crustal matter, and elemental carbon), SO 2 

### and NO x 5 

### ) representative of the year when the area achieves atta inment of the annual PM 2.5 

### air quality standard. Ohio also must demonstrate that the improvement in air qualit y between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable em ission reductions. Other emission inventory related requirements include a projection of the emission invent ory to a year at least 10 years following redesignation; a demonstration that t he 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 tracking of emission levels during the 10-year maintenance period.

The emissions inventory development and emissions projection discussion below, with the exception of the mob ile (on-road) emi ssions inventory and projections, identifies procedures us ed by Ohio EPA and the LADCO regarding emissions of all the countie s in the Cleveland-Akron-Lor ain area. All of these inventories and emissions projecti ons were prepared using similar methodologies. Mobile emissions invent ories and projections for all counties were prepared by the Northeast Ohio Areawide Coordinating Agency (NOACA) 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 tak en from Ohio's annual emissions reporting program. The 2005 periodi c inventory has been identified as one of the preferred databas es for SIP development and coincides with nonattainment air quality in the Cleveland-AkronLorain area.

Periodic inventories, which incl ude emissions from all sectors - mobile, area, non-road, and point sources - are prepared every three years.

5 VOC and NH 3 are not addressed.16 

### Demonstration The 2005 inventory is used as t he base year for the purpose of this submittal and was submitt ed 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 det ailed emission inventory information for the Cleveland-Akr on-Lorain 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 emission inventory to a year at least 10 years following redesignation.

Background Ohio EPA prepared a comprehensive in ventory for the Cleveland-AkronLorain area including area, mob ile, and point sources for PM 2.5 

### , SO 2 

### and NO x 

### for base year 2005. The 2005 invent ory was submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM 2.5 

### attainment demonstration SIP for this area. The information below describes the procedures Ohio EPA used to generate the 2005 base year in ventory and to develop SIP-ready modeling inventories and future y ear projections (Pechan Report 6 

### ) based on a 2005 base year inventory. T he report by Pechan generated future year estimates of annual emissions for each source sector using accepted growth surrogates. These in ventories were provided to the LADCO and have been processed to develop average daily emissions for use in the air quality analyses. T hese processed modeling inventories have been identified as the correct iterat ion of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organization. Note thatthe 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 projections were made from the U.S. Departm ent of Commerce Bureau of Economic Analysis (BEA) grow th factors, with some updated local information.

• Mobile source emissions were calculated from MOVES2010 produced emission factors. Only PM 2.5 

### and NO x 

### necessitate emissions inventory analysis. As documented in Ohio EPA’s atta inment demonstration SIP, Ohio EPA in consultation with U.S. EPA determined mobile

6 http://www.ladco.org/tech/emis/r5/r eports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con trols%20Report_Final.pdf17 

### sources are insignificant contributors for SO 2 

### . Consistent with Ohio EPA’s attainment demonstration, Ohio EPA continues to consider mobile source SO 2 

### to be an insignificant contributor to fine particles for this nonattainment area. Based on the demonstration below, SO 2 

### constitutes less than one percent (<1.21%) of the area’s total SO 2 

### emissions in 2005, 2008, 2015 and 2022 (ranging between 0.21% and 1.21%).

• Point source information wa s compiled from Ohio EPA’s 2005 annual emissions inv entory 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 M odel (NMIM) 2002 application. To address concerns about the accuracy of some of the categories in U.S. EPA’s non-road emissions model, LADCO contracted with two (2) companies to review the base data and make recommendations. One of the contractors also estimated emi ssions for three (3) non-road categories not included in U.S. EPA’s non-road model. Emissions were estimated fo r aircraft, commercial marine vessels, and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment cat egory were reviewed and updated based upon surveys completed in the Midwest, and the temporal allocation fo r agricultural sources also was updated.

Demonstration

On-Road Emission Estimations The on-road emission estimations for this nonattainment area where performed by the Ohio Department of Transportation (ODOT) for the Akron Metropo litan Area Transportation Study (AMATS) and Ashtabula Township areas, and by the Northeast Ohio Areawide Coordinating Agen cy (NOACA) for the counties of Cuyahoga, Lake, Lorain and Medina in its area.

The inventories include count y based, annual totals of PM 2.5 

### and Oxides of Nitrogen (NO X 

### ) for the base year 2005, the attainment year 2008, the interim year 2015, and the maintenance period horizon year 2022.

7 http://www. epa.gov/airmarkets/acidrain18 

### Overview U.S.EPA published a Federal Register notice 8 

### of availability on March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions Simulator), hereafter referred to as MOVES. Upon publication of the Federal Register notic e, 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 com puter program designed by the U.S. EPA to estimate air pollution emissions from mobile sources. MOVES replaces U.S. EPA’s prev ious emissions model for onroad mobile sources, MOBI LE6.2. MOVES can be used to estimate exhaust and evaporative em issions as well as brake and tire wear emissions from all types of on-road vehicles.

The CAA requires U.S. EPA to regul arly update its mobile source emission models. U.S. EPA c ontinuously collects data and measures vehicle emissions to ma ke sure the Agency has the best possible understanding of mobile source emissions. This assessment, in turn, informs the development of U.S. EPA’s mobile source emission models. MOVES represents the Agency’s most up-to-date assessment of on -road mobile source emissions. MOVES also incorporates seve ral changes to the U.S. EPA’s approach to mobile source emission modeling based upon recommendations made to the A gency by the National Academy of Sciences.

U.S.EPA believes that MOVES shoul d be used in ozone, CO, PM, and nitrogen dioxide SIP developm ent as expeditiously as possible. The CAA requires that SIP inventories and control measures be based on the most current information and applicable models that are available when a SIP is developed. Regarding transportation conformity, U.S. EPA and U.S. DOT intend to establish a two-year grace per iod before MOVES is required for new transportation conformity analyses.

The MOVES more detailed approac h (when compared with the previous MOBILE model) to mode ling allows U.S. EPA to easily incorporate large amounts of in-u se data from a wide variety of sources, such as data from v ehicle inspection and maintenance (I/M) programs, remote sensing dev ice (RSD) testing, certification testing, portable emission meas urement systems (PEMS), etc. This approach also allows users to incorporate a variety of activity

8 http://www.r egulations.gov/search/Regs/hom e.html#document Detail?R=0900006480ab1f9819 

### data to better estimate emissi on differences such as those resulting from changes to vehicl e speed and acceleration patterns. MOVES has a graphical user interfac e which allows users to more easily set up and run the m odel. MOVES database-centered design provides users much gr eater flexibility regarding output choices. Unlike earlier models whic h 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 emission factors (grams-per-m ile and in some cases grams-pervehicle). Output can be easily aggregated or disaggregated to examine emissions in a range of scales, from national emissions impacts down to the emissions impac ts of individual transportation projects. The database-centered des ign also allows U.S. EPA to update emissions data incorporat ed in MOVES more easily and will allow users to incorporate a much wider array of activity data to improve estimation of local emissions. For example, the improvements in MOVES will allow pr oject-level PM2.5 emissions to be estimated.

The annual PM 2.5 

### inventory runs meet the latest planning assumption requirement. The travel forecast modeling processes used to develop vehicles miles of travel (VMT) for the Akron Metropolitan Area Transportati on Study (AMATS) and the Northeast Ohio Areawide Coordinating Agency (NOACA) areas is calibrated using the latest popul ation and land use data available and are validated using corresponding traffic count data. Currently, the travel demand models are va lidated to year 2005. U.S.EPA’s emissions model MOVES is used fo r all mobile source emission analyses with inputs and output needs being established at various interagency consultation meetings . It was also established that annual emission estimates woul d be based on a single-season approach. Since travel dem and models produce average daily conditions, the daily emissions es timates are multiplied by 365 days to produce annual emissions esti mates expressed in tons per
year.

Finally, the regional emissions analysis includes emissions for Direct PM 2.5 

### (exhaust, brake, and tire wear), and Oxides of Nitrogen (NO X 

### ).Sulfur Dioxide (SO 2 

### ), Volatile Organic Compounds (VOCs) and Ammonia (NH 3 

### ) are considered insignificant at this time. (Appendix C)

NOACA maintains a PC-based regional travel demand forecasting model on the Citilabs CUBE pla tform for use in its urban transportation planning process. This model employs the traditional four step modeling proce ss to project existing and future20 

### traffic volumes and travel patterns on the regional transportation networks. The four step process consists of trip generation, trip distribution, mode split, and rout e assignment. Output from the model is link-by-link directional vo lumes for four time periods: AM peak, Midday, PM peak, and Night and is added together to create 24-hour traffic volumes for the existing or future regional transportation networks. The ODOT holds the transportation model for the AMATS area. AMATS pr epares and submits networks for its planning area to ODOT. ODOT prepares networks for Ashtabula County. ODOT's mode ling is also run on a PC-based CUBE platform.

Socio-economic variables were developed for all areas based on 2000 Census data and 2030 county-le vel Ohio Department of Development population projections . Minor adjustments to 2005 data have been made in an effort to have this data correspond to 2005 estimates released by the US Census Bureau.

Using MOVES, emission factor f iles were generated for base year2005, attainment year-2008, in terim year 2015, and maintenance year 2022. Assumptions for thes e runs include an I/M program in all but Ashtabula Township. Programs and corresponding MOVES parameters were developed in cons ultation with Ohio EPA. I/M program information was supplied by Ohio EPA. The I/M program was applied to all analysis years for every geography with the exception of Ashtabula Township.

Total emissions were computed wit h the aid of several custom programs by ODOT. The proc ess uses data on daily and directional traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM).

The first step in the process in volves running ODOT postcms.exe to calculate hourly link volume s based on the percentage of the daily volume (travel demand model output) determined by a link’s facility and area type. Link speeds from the travel demand model are not used in the analysis. T he speeds are estimated as a postprocess to the model based on HCM methods using a link’s volume-to-capacity ratio and link group code.

The second step (mmoves.exe) uses a combination of the MOVES emission factors and the hourly link volumes that are output of the postcms.exe program. The hourly volumes are multiplied by the MOVES emission factor for the corresponding hour of day, speed bin, and road type to calculate emi ssions for every network link for21 

### each hour. The final link on road v ehicle emissions for the area is the sum of all individual link-hour emissions.

The third step, (mvehicle.exe), ca lculates vehicl e-based emissions for each source type for each hour of the day. The vehicle source type is based on a combination of local and default data. The final vehicle emissions for each county are the sum of all individual hourly emissions for all vehicle types.

Intrazonal trips do not get loaded ont o the network, so the fourth step in the process requires a separate method to account for those trips that use local roads to travel within a zone. The mintra.exe program uses intrazonal trips to estimate VMT using the area in square miles and intraz onal trips of each zone. The zone is assumed circular and the radius of the circle is used as the average trip length for these intraz onal trips. Intrazonal emissions are then calculated by combin ing MOVES generated emissions with estimated intrazonal VMT. The emission rates are the same as those used to calculated link based emissions.

The final step is to summarize link, vehicle, and intrazonal emissions for each county, pollutant, and analyzed year, and to multiply annual average daily em issions by 365 to produce an annual estimate.

On-Road Mobile Emission Estimations Tables 3 through 10 contain the re sults of the emissions analysis for the appropriate years. All em issions estimations are expressed in tons per year (tpy).

Table 3 - Ashtabula County Emi ssions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 11.50 10.04 5.37 3.03

NO x (tpy) 294.66 232.83 107.68 54.49

SO 2 (tpy) 5.07 1.57 0.66 0.62

Annual VMT 79,693,005 80,604,775 82,946,980 85,561,840



### Table 4 – Cuyahoga County, Emi ssions Estimations for On-Road Mobile Sources22 2005 2008 2015 2022

PM 2.5 (tpy) 1,249.47 1,040.28 430.01 320.94

NO x (tpy) 36,545.59 28,227.20 12,371.38 6,065.83

SO 2 (tpy) 846.76 253.16 76.36 68.07

Annual VMT 10,619,449,065 10,658,861,035 10,602,063,020 10,701,988,340



### Table 5 – Lake County, Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 283.09 241.78 122.02 69.42

NO x (tpy) 8,071.90 6,425.00 2,840.39 1,417.15

SO 2 (tpy) 176.99 51.94 15.91 14.45

Annual VMT 2,113,418,985 2,155,625,760 2,180,087,695 2,251,831,000



### Table 6 – Lorain County, Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 319.85 274.43 143.34 81.69

NO x (tpy) 9,196.87 7,354.77 3,456.51 1,723.02

SO 2 (tpy) 200.28 60.17 18.51 16.83

Annual VMT 2,473,782,025 2,525,280,240 2,555,465,010 2,638,018,155



### Table 7 – Medina County, Emi ssions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 358.80 317.43 152.50 78.48

NO x (tpy) 9,328.78 7,603.83 3,306.35 1,677.58

SO 2 (tpy) 208.74 57.65 17.63 16.83

Annual VMT 2,112,372,530 2,241,630,710 2,322,864,380 2,505,814,790



### Table 8 – Portage County, Emi ssions Estimations for On-Road Mobile Sources

2005 2008 2015 2022

PM 2.5 (tpy) 187.71 160.90 87.54 49.45

NO x (tpy) 5,707.22 4,630.98 2,264.50 1,014.35

SO 2 (tpy) 96.74 30.52 13.23 7.40

Annual VMT 1,761,085,222 1,811,101,624 1,935,234,601 2,036,373,863



### Table 9 – Summit County, Emissi ons Estimations for On-Road Mobile Sources23 2005 2008 2015 2022

PM 2.5 (tpy) 611.78 511.43 251.70 162.98

NO x (tpy) 17,377.28 13,609.82 6,170.32 3,059.45

SO 2 (tpy) 319.72 100.66 42.76 39.57

Annual VMT 5,505,977,908 5,635,781,676 5,992,078,124 6,246,851,092



### Table 10 – Emissions Estimations Totals for On-Road Mobile Sources for the Cleveland-Akron-Lorain Area

2005 2008 2015 2022

PM 2.5 (tpy) 3,022.20 2,556.29 1,192.48 765.99

NO x (tpy) 86,522.30 68,084.43 30,517.13 15,011.87

SO 2 (tpy) 1,854.30 555.67 185.06 163.77

Annual VMT 24,665,778,740 25,108,885,820 25,670,739,810 26,466,439,080



### Motor Vehicle Emission Budget

Table 11 contains the motor v ehicle emissions budgets for the Cleveland-Akron-Lorain area.

Table 11 - 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) 1,192.48 178.87 1,371.35 765.99 114.90 880.89

NOx (tpy) 30,517.13 4,577.57 35,094.70 15,011.87 2,251.78 17,263.65

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



### The above budgets for the Clevel and-Akron-Lorain area, agreed upon as part of the interagency c onsultation process, include the emission estimates calculated for 2015 and 2022 (from Table 3 and Table 10) with an additional 15 percent margin of safety allocated for PM 2.5 

### and NO x 

### in 2015 and 2022.

In an effort to accommodate future variations in travel demand models and VMT forecast when no change to the network is planned, Ohio EPA consulted wit h 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 planni ng assumptions, and the safety margins allocations were determined through the interagency24 

### consultation process described in the Transportation Conformity Memorandum of Understanding (MO U) among NOACA, AMATS, Ohio DOT, and Ohio EPA.

A 15 percent margin of safety is appropriate because: 1) there is an acknowledged potential variation in VMT forecast and potential estimated mobile source emissi ons due to expected modifications to TDM and mobile emissions model s; and 2) the to tal decrease in emissions from all sources is sufficient to accommodate 15 percent allocation of safety margin (as defined in 40 CFR93.101 9 

### ) to mobile sources while still c ontinuing to maintain the total emissions in the Cleveland-Akron- Lorain 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 emi ssion estimates. Safety margin, as defined by the conformity rule, looks at the total emissions from all sources in the nonattainment area. The actual allocation is less than 15 percent of the total emissi on reduction from all sources as can be seen from Table 38.

In summary, the mobile budget safety margin allocation translates into an additional 178.87 tpy for PM 2.5 

### and 4,577.57 tpy for NO x 

### for 2015 and an additional 114.90 tpy for PM 2.5 

### and 2,251.78 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 safety margin for this

area.

The current PM 2.5 

### and NO x 

### mobile budgets for the fine particle NAAQS will no longer be applicable eit her after the effective date of the approved redesignat ion 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 th is submittal are adequate for transportation conformity purposes, whichever date comes first.

Finally, it is important to underline that all motor vehicle emission budgets in this Redesignation subm ittal, which are based on MOVES2010, will replace previous motor vehicle emission budgets on Attainment Demonstr ation submittals based on MOBILE6.2.

9 "Safety margin" means t he amount by which the total projected em issions from all sources of a given pollutant are less than the total em issions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance.25 

### Requirement 3 of 5 A demonstration that the projec ted level of emissions is sufficient 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 th is redesignation request. This document contains projected em issions inventories for 2015 and 2022.

Emission projections for the Cle veland-Akron-Lorain area were performed using the following approaches:

• As performed by NOACA and ODOT, mobile source emission projections are based on the U.S. EPA MOVES model. The analysis is described in more detail in Appendix C. All projections were made in accordance with “Procedures for Preparing Em issions Projections” U.S. EPA-45/4-91-019.

• Emissions inventories are requi red to be projected to future dates to assess the influence growth and future controls will have. LADCO has developed growth and control files for point, area, and non-road categorie s. These files were used to develop the future-year emissions estimates used in this document. This was done so the inventories used for redesignation are consistent with modeling performed in the future. Appendix D contains LADCO’s technical support document detailing the analysis used to project emissions (Base M 10 

### ).

• For the 2008 attainment year emissions were grown from the 2005 LADCO modeling inv entory, using LADCO’s growth factors, for all se ctors except point sources (electrical generating units and non-electrical generating units). Point source emissions for 2008 were compiled from Ohio EPA’s 2008 annual emissi ons inventory database. The 2015 interim year emissions were estimated based on the 2009 and 2018 LADCO modeli ng inventory, using LADCO’s growth factors, for all sectors. The 2022 maintenance year is based on emissions estimates from the 2018 LADCO modeling.

10 http://www.ladco.org/tech/emis/current/i ndex.php26 

### Ohio EPA is identifying emissi ons projections for 2015 and 2022 for EGUs with implementation of the CAIR program. U.S. EPA has raised concerns regarding the CA IR program and its remand. However, as discussed below, with the finalization of the CAIR replacement, the CSAPR, Ohio EPA believes these are the most appropriate and accurate future pr ojections. Additional modeling has yet to be conducted that account s for CSAPR. However, it is believed that CSAPR will provi de even greater reductions in emissions than the CAIR program ; therefore, these emissions projections will be conservative.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of 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 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were required to submit a CA IR SIP as part of this effort. Ohio submitted a CAIR SIP wh ich was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final action on Sept ember 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA projec ts 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 y ear 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 y ear while emissions of SO 2 

### will decrease to 208,000 tons per year, within Ohio 11



### .

On December 23, 2008, U.S. EPA’ s CAIR program was remanded without vacatur by the D.C. Circuit Court.

As can be seen in Table 12 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 12 

### and consent decrees. Table 12 - Reductions in SO 2 

### and NO x 

### EGU Emissions Between 2008 and 2009

SO 2 NO x 2008 2009 Change 2008 2009 Change

11 http://www. epa.gov/CAIR/oh.html 12 Under CAIR, NOx reductions are to occur begi nning in 2009 while SO2 reductions are to occur beginning in 2010.27 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 13



### Significant reductions also occu rred regionally and nationally as can be seen from the above. Data is also available for the first two quarters of 2010, the year SO 2 

### reductions are to be implemented under CAIR:

Table 13 – 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 14



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

“Based on emissions monitoring data, 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 controls, electric demand declined, and low natural gas prices made combined-cycle gas-fired units more competitive in several parts of the country. Thus, even after CAIR's vacatur and subsequent remand in late 2008, t he controls in place generally have continued to operate, helping to drive continued progress in reducing emissions. 15 

### ”

Ohio EPA is in agreement with t he 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.

On July 6, 2011, U.S. EPA finaliz ed a replacement to the CAIR program, the CSAPR. CSAPR will pres erve those initial reductions achieved under CAIR and provide even greater reductions in NO x 

### and SO 2 

### emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2. As a result of CSAPR , U.S. EPA projects that in 2012 emissions of NO x 

### will decrease to 90,842 tons per year and in

13 http://www. epa.gov/airmarkets/quarterlytracking.html 14 http://www. epa.gov/airmarkets/quarterlytracking.html 15 http://www. epa.gov/airmarkets/background.htm28 

### 2014 to 85,744 tons per year while SO 2 

### will decrease to 304,022 tons per year in 2012 and 134,333 t ons per year in 2014, within Ohio. In addition, U.S. EPA projections indicate that as a result of implementation of CSAPR, ther e will be no maintenance issues within this entire nonattainment area.

Therefore, it is Ohio EPA’s belief it is most appropriate to evaluate Ohio EPA’s demonstration that the projected le vel of emissions is sufficient to maintain the annual PM 2.5 

### standard by assessing future year emissions that include the CAIR program.

The detailed inventory informati on for Cleveland-Akron-Lorain area for 2005 is in Appendix B. Em ission trends are an important gauge for continued compliance with the PM 2.5 

### standard. Therefore, Ohio EPA performed an initial comparison of the inventories for the base year and maintenance years. Mobile source emission inventories are described in Appendix C.

Sectors included in the following tabl es are: Electrical Generating Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Ar ea (Other); Marine; Aircraft; Rail (MAR); and On-road Mobile (On-road).

Maintenance is demonstrated w hen the future-year (2022) projected emission totals are below the 2008 attainment year totals.

The Ohio emissions data in t he tables below are based on the following data sources: - All On-Road data source: NOAC A and ODOT’s Transportation Unit. - 2008 EGU and non-EGU: Ohio EPA’s 2008 annual emissions inventory database. - All other data source: Lake Mich igan Air Directors Consortium (LADCO).

Demonstration

PM 2.5



### The 2005 and 2008 actual PM 2.5 

### emissions data below generally contains particulate fraction emissions only and not the condensable fractions as Ohio EPA did not have a consistent reporting requirement during those years. U.S. EPA IPM modeling was used to generate future year EGU emissions with the CAIR program. The IPM modeling added additional PM 2.5 

### condensable emissions into future years. Therefore, comparing29 

### base and attainment year emissions with the future year predictions is not accurate in the IPM CAIR modeling. Th is step leads to a false perception of significant PM 2.5 

### emissions growth. Modeling performed by LADCO, without CAIR, did not incorporate added condensable fraction emissions. Although Ohio EPA has stated that it is most appropriate to evaluate future year emissions that include the CAIR program, because of this flaw it will be more accurate and appropr iate for the purposes of PM 2.5 

### to evaluate future year emissions without the CAIR program.

Table 14 - Ashtabula 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 36.28 58.30 44.93 39.87 18.43

Non-EGU 62.50 76.33 87.84 101.44

‐ 25.11

Non-road 109.41 95.76 65.76 35.58 60.18

Area 501.57 497.00 483.27 469.83 27.17

MAR 64.20 56.53 33.88 11.67 44.86

On-road 11.50 10.04 5.37 3.03 7.01

TOTAL 785.46 793.96 721.05 661.42 132.54



### Table 15 - Cuyahoga 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 81.43 99.40 29.82 0.00 99.40

Non-EGU 807.55 805.11 896.14 969.39

‐ 164.28

Non-road 630.80 553.24 433.84 308.64 244.60

Area 558.62 593.73 606.91 626.56

‐ 32.83

MAR 111.89 103.52 67.75 33.51 70.01

On-road 1,249.47 1,040.28 430.01 320.94 719.34

TOTAL 3439.76 3195.28 2464.47 2259.04 936.2430 

### Table 16 - Lake 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 215.93 209.96 228.06 241.39

‐ 31.43

Non-EGU 30.67 23.23 32.67 38.62

‐ 15.39

Non-road 136.94 118.35 87.81 56.06 62.29

Area 132.09 137.25 138.11 140.01

‐ 2.76

MAR 36.49 31.82 18.43 5.28 26.54

On-road 283.09 241.78 122.02 69.42 172.36

TOTAL 835.21 762.39 627.10 550.78 211.61



### Table 17 - Lorain 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 97.82 97.95 101.50 104.45

‐ 6.50

Non-EGU 428.05 471.83 513.52 559.22

‐ 87.39

Non-road 206.78 178.79 127.92 75.70 103.09

Area 401.71 404.47 397.99 392.72 11.75

MAR 57.49 50.13 29.17 8.56 41.57

On-road 319.85 274.43 143.34 81.69 192.74

TOTAL 1511.70 1477.60 1313.44 1222.34 255.26



### Table 18 - Medina 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 96.33 101.55 111.23 121.38

‐ 19.83
Non-road 118.08 102.70 70.71 38.35 64.35
Area 267.67 268.45 263.38 258.96 9.49

MAR 11.00 9.67 5.73 1.86 7.81
On-road 358.80 317.43 152.50 78.48 238.95
TOTAL 851.88 799.80 603.55 499.03 300.7731 

### Table 19 - Portage 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 23.59 23.42 30.04 31.11

‐ 7.69
Non-road 116.90 103.27 72.36 41.38 61.89
Area 253.00 253.83 249.01 240.15 13.68

MAR 28.11 24.24 13.66 3.22 21.02
On-road 187.71 160.90 87.54 49.45 111.45
TOTAL 609.31 565.66 452.61 365.31 200.35



### Table 20 - Summit 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 35.45 35.95 35.47 35.29 0.66
Non-road 233.20 203.09 144.73 85.25 117.84
Area 264.95 278.15 281.96 288.30

‐ 10.15

MAR 27.19 24.51 15.15 6.08 18.43
On-road 611.78 511.43 251.70 162.98 348.45
TOTAL 1172.57 1053.13 729.01 577.90 475.23



### Table 21 – Cleveland- Akron-Lorain 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

Ashtabula 785.46 793.96 721.05 661.42 132.54 Cuyahoga 3,439.76 3,195.28 2,464.47 2,259.04 936.24

Lake 835.21 762.39 627.10 550.78 211.61

Lorain 1,511.70 1,477.60 1,313.44 1,222.34 255.26

Medina 851.88 799.80 603.55 499.03 300.77
Portage 609.31 565.66 452.61 365.31 200.35

Summit 1,172.56 1,053.13 729.01 577.90 475.23
COMBINED PM 2.5 TOTAL 9205.88 8647.82 6911.23 6135.82 2512.00



### NO x32 

### Table 22 - Ashtabula County NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 1,592.35 1,462.80 1,931.77 2,132.76

‐ 669.96

Non-EGU 237.55 248.73 356.26 402.35

‐ 153.62

Non-road 1,057.58 940.93 701.40 458.81 482.12

Area 314.70 318.26 318.83 320.12

‐ 1.86

MAR 1,809.20 1,671.71 1,090.67 534.09 1,137.62

On-road 294.66 232.83 107.68 54.49 178.34

TOTAL 5,306.04 4,875.26 4,506.61 3,902.62 972.64



### Table 23 - Cuyahoga County NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 1,848.36 3,844.25 4,491.88 4,769.43

‐ 925.18

Non-EGU 3,081.22 2,990.08 2,890.16 2,724.22 265.86

Non-road 8,152.55 6,959.06 4,839.11 2,656.68 4,302.38

Area 5,103.40 5,162.21 5,203.60 5,254.00

‐ 91.79

MAR 3,672.47 3,463.56 2,376.29 1,345.39 2,118.17

On-road 36,545.59 28,227.20 12,371.38 6,065.83 22,161.37

TOTAL 58,403.59 50,646.36 32,172.42 22,815.55 27,830.81



### Table 24 - Lake County NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 12,969.08 11,211.15 11,819.69 11,562.04

‐ 350.89

Non-EGU 471.65 660.35 414.98 244.81 415.54

Non-road 1,873.78 1,638.69 1,228.21 804.76 833.93

Area 848.09 856.84 861.87 868.34

‐ 11.50

MAR 1,065.83 981.02 632.84 298.78 682.24

On-road 8,071.90 6,425.00 2,840.39 1,417.15 5,007.85

TOTAL 25,300.33 21,773.05 17,797.98 15,195.88 6,577.1733 

### Table 25 - Lorain County NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 6,959.73 5,696.00 2,730.14 1,459.05 4,236.95

Non-EGU 926.84 774.05 850.81 847.90

‐ 73.85

Non-road 2,507.76 2,175.67 1,521.52 856.02 1,319.65

Area 981.14 992.64 1,000.63 1,010.38

‐ 17.74

MAR 1,711.08 1,578.76 1,025.10 494.46 1,084.30

On-road 9,196.87 7,354.77 3,456.51 1,723.02 5,631.75

TOTAL 22,283.42 18,571.89 10,584.71 6,390.83 12,181.06



### Table 26 - Medina County NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 0.00 0.00 2.14 3.89

‐ 3.89

Non-EGU 72.84 96.42 63.45 39.34 57.08

Non-road 1,295.08 1,104.33 698.29 288.57 815.76

Area 577.42 583.55 587.11 591.69

‐ 8.14

MAR 331.57 308.06 202.58 101.85 206.21
On-road 9,328.78 7,603.83 3,306.35 1,677.58 5,926.25
TOTAL 11,605.69 9,696.19 4,859.92 2,702.92 6,993.27



### Table 27 - Portage County NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 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 83.19 83.68 83.47 82.05 1.63

Non-road 1,184.58 1,001.73 635.48 263.55 738.18

Area 559.86 565.77 568.13 571.56

‐ 5.79

MAR 908.80 838.60 543.41 260.56 578.04
On-road 5,707.22 4,630.98 2,264.50 1,014.35 3,616.63
TOTAL 8,443.65 7,120.76 4,094.99 2,192.07 4,928.6934 

### Table 28 - Summit County NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With 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 1,456.66 643.25 650.08 653.01

‐ 9.76

Non-road 2,953.59 2,459.48 1,520.22 560.88 1,898.60

Area 2,034.66 2,056.80 2,071.34 2,089.36

‐ 32.56

MAR 762.05 706.60 463.60 231.27 475.33
On-road 17,377.28 13,609.82 6,170.32 3,059.45 10,550.37
TOTAL 24,584.24 19,475.95 10,875.56 6,593.97 12,881.98



### Table 29 - Cleveland- Akron-Lorain Area NO x 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

NOx 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin

Ashtabula 5,306.04 4,875.26 4,506.61 3,902.62 972.62 Cuyahoga 58,403.59 50,646.36 32,172.42 22,815.55 27,529.98

Lake 25,300.33 21,773.05 17,797.98 15,195.88 6,577.17

Lorain 22,283.42 18,571.89 10,584.71 6,390.83 12,181.06

Medina 11,605.69 9,696.19 4,859.92 2,702.92 6,993.27
Portage 8,443.65 7,120.76 4,094.99 2,192.07 4,928.69

Summit 24,584.24 19,475.95 10,875.56 6,593.97 12,881.98
COMBINED NOx TOTAL 155,926.96 132,159.46 84,892.19 59,793.84 72,365.62



### SO 2



### Table 30 - Ashtabula County SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 4,159.96 3,850.10 4,982.36 5,567.61

‐ 1,717.51

Non-EGU 20.07 31.55 26.47 25.36 6.19

Non-road 104.56 38.61 6.72 1.78 63.83

Area 109.14 107.70 102.15 96.80 10.90

MAR 337.39 274.88 166.08 53.79 221.09

On-road 5.07 1.57 0.66 0.62 0.95

TOTAL 4,736.19 4,304.41 5,284.44 5,745.96

‐ 1,441.5535 

### Table 31 - Cuyahoga County SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 2,991.78 9,920.92 12,145.34 13,098.66 ‐ 3,177.74

Non-EGU 5,156.40 5,163.15 5,343.87 5,494.26

‐ 331.11

Non-road 736.73 271.28 47.13 12.64 258.64

Area 291.45 291.73 289.69 287.90 3.83

MAR 423.44 368.20 246.51 124.15 244.05

On-road 846.76 253.16 76.36 68.07 185.09

TOTAL 10,446.56 16,268.44 18,148.90 19,085.68 ‐ 2,817.24



### Table 32 - Lake County SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 80,187.84 57,730.81 42,363.35 17,921.95 39,808.86

Non-EGU 736.41 939.89 765.31 670.80 269.09

Non-road 162.20 59.94 10.78 3.24 56.70

Area 94.92 93.60 90.23 86.88 6.72

MAR 159.67 135.58 88.03 39.68 95.90

On-road 176.99 51.94 15.91 14.45 37.49

TOTAL 81,518.03 59,011.76 43,333.61 18,737.00 40,274.76



### Table 33 - Lorain County SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenance Safety Margin EGU Point 42,437.09 22,604.10 8,631.3

2 2,642.99 19,961.11

Non-EGU 547.68 485.35 541.89 573.40

‐ 88.05

Non-road 249.83 91.90 15.51 3.64 88.26

Area 50.97 49.74 47.45 45.11 4.63

MAR 252.94 214.35 138.69 61.69 152.66

On-road 200.28 60.17 18.51 16.83 43.3436 TOTAL 43,738.79 23,505.61 9,393.3

7 3,343.66 20,161.95 

### Table 34 - Medina County SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 142.11 149.84 163.54 178.04

‐ 28.20

Non-road 143.41 52.54 8.41 1.49 51.05

Area 88.82 87.65 84.06 80.55 7.10

MAR 29.01 28.47 22.59 17.15 11.32

On-road 208.74 57.65 17.63 16.83 40.82
TOTAL 612.09 376.15 296.23 294.06 82.09



### Table 35 - Portage County SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 10.24 13.01 13.60 14.93

‐ 1.92

Non-road 122.16 44.87 7.39 1.54 43.33

Area 143.62 141.66 134.24 127.08 14.58

MAR 78.55 76.83 60.86 46.01 30.82

On-road 96.74 30.52 13.23 7.40 23.12
TOTAL 451.31 306.89 229.32 196.96 109.93



### Table 36 - Summit County SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 10,866.52 11,102.30 10,899.96 10,835.99 266.31

Non-road 287.66 105.55 17.38 3.65 101.90

Area 174.88 172.54 168.39 164.11 8.43

MAR 66.17 64.83 51.36 38.86 25.97

On-road 319.72 100.66 42.76 39.57 61.09
TOTAL 11,714.95 11,545.88 11,179.85 11,082.18 463.703738 

### Table 37 - Cleveland-Akron-Lorain Area SO 2 

### Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR

SO2 2005 Base 2008 Attainment 2015 Interim 2022 Maintenanc

e Safety Margin

Ashtabula 4,736.19 4,304.41 5,284.44 5,745.96

‐ 1,441.55 Cuyahoga 10,446.56 16,268.44 18,148.90 19,085.68

‐ 2,817.24

Lake 81,518.03 59,011.76 43,333.61 18,737.00 40,274.76

Lorain 43,738.79 23,505.61 9,393.37 3,343.66 20,161.95

Medina 612.09 376.15 296.23 294.06 82.09
Portage 451.31 306.89 229.32 196.96 109.93

Summit 11,714.95 11,545.88 11,179.85 11,082.18 463.70
COMBINED SO2 TOTAL 153,217.92 115,319.14 87,865.72 58,485.50 56,833.64



### PM 2.5 

### , NO x 

### , and SO 2



### Table 38 - Cleveland-Akron-Lorain Area Comparison of 2008 attainment year and 2015 and 2022 projected emission estimates (tpy)

2008 Attainment 2015 Interim 2015 Projected Decrease 2022 Maintenance 2022 Projected Decrease

PM 2.5 8,647.82 6,911.23 1,736.59 6,135.82 2,512.00

NO x 132,159.46 84,892.19 47,267.27 59,793.84 72,365.62

SO 2 115,319.14 87,865.72 27,453.42 58,485.50 56,833.64



### As shown in the t able above (Table 38), PM 2.5 

### emissions in the nonattainment area are projected to decrease by 1,736.59 tpy in 2015 and 2,512.00 tpy in 2022. NO x 

### emissions in the nonattainment area are projected to decrease by 47,267.27 tpy in 2015 and 72,365.62 tpy in 2022. SO 2 

### emissions in the nonattainment area are projected to decline by 27,453.42 tpy in 2015 and 56,833.64 in 2022.

Area source emissions and point source emissions for some pollutants show a slight increas e due to expectations that the population will grow in this area; however, cleaner vehicles and fuels are expected to be in place in 2009 and 2018, and the CSAPR will be implemented in 2012 and 2014 and these programs should cause an overall drop in all three pollutants emissions. Decreases from U.S. EPA rules covering Tier 2 Motor39 

### Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 16 

### , Highway Heavy-Duty Engine Rule 17 

### , and the Non-Road Diesel Engine Rule 18 

### are factored into the changes.

In addition to the above, star ting in September 2011, First Energy’s Eastlake plant will onl y be used in the future for emergency power purposes. The fi ve units at this facility represent nearly half of the ava ilable megawatts for the entire area (1,233 of 2,494 megawatts).

Requirement 4 of 5 A demonstration that improvement in air quality bet ween the year violations occurred and the year attainment wa s achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background Ambient air quality data from all monito ring sites indicate that air quality met the NAAQS for PM 2.5 

### in 2008-2010. U.S. EPA’s redesignation guidance (p 9) states: “A state ma y generally demonstrate maintenance of the NAAQS by either showing that fu ture emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the future mix of sources and emissions rates will not cause a violation of the NAAQS.”

Demonstration Permanent and enforceable reductions of 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 realized due to the application of tighter federal standards on non-road diesel vehicles (Clean Air Non-road Diesel Rule) and the application of tighter federal standards on new vehicles. Also Title IV of the CAA, the NO x 

### SIP Call, CAIR, and f ederal consent decrees required the reductions of SO 2 

### and NO x 

### emissions from utility sources. Reductions achieved are discussed in greater detail under Chapter Five.

16 http://www. epa.gov/fedrgstr/EPA-AIR/2000/ February/Day-10/a19a.htm 17 http://www. epa.gov/fedrgstr/EPA-AIR/1997 /October/Day-21/a27494.htm 18 http://www. epa.gov/fedrgstr/EPA-AIR/1998 /October/Day-23/a24836.htm40 

### Table 39 - Cleveland-Akron-Lorai n Area Comparison of 2005 base year and 2008 attainment year on-road and EGU reductions
2005 2008 On-road PM 2.5 3,022.20 2,556.29 On-road NO x 86,522.30 68,084.43 On-road SO 2 1,854.30 555.67
Non-road PM 2.5 1,552.11 1,355.20 Non-road NO x 19,024.92 16,279.89 Non-road SO 2 1,806.55 664.69 EGU PM 2.5 431.46 465.61 EGU NO x 23,369.52 22,214.20 EGU SO 2 129,776.67 94,105.93



### Requirement 5 of 5 Provisions for future annual updates of the inventory to enable tracking of the emission levels, including an annual emissi on statement from major sources.

Demonstration In Ohio, major point sources in a ll counties are required to submit air emissions information annually, in accordance with U.S. EPA’s Consolidated Emissions Reporti ng 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 for future years as necessary to comply with the inventory reporting requirement s established in the CFR. Emissions information will be compared to the 2005 base year and the 2022 projected maintenance y ear inventories to assess emission trends, as necessary, and to assure continued compliance with the annual PM 2.5 

### standard.41 

### 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 Cl ean Air Act Amendments requires states with nonattainment areas to submit a SIP providing for implementation of all reasonably available control measures and as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a mini mum, of reasonable available control technology).

U.S. EPA’s Implementati on Rule interprets this requirement in great detail. Under U.S. EPA’s appr oach, RACT is determined as part of the broader RACM analysi s and identification of all measures (for stationary, mob ile, and area sources) that are technically and economically feasib le, and that would collectively contribute to advancing the attain ment 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 i dentify the attainment date that is as expeditious as practicabl e, and (3) selects the appropriate RACT and RACM.

The Implementation Rule also prov ides for a presumption that in States that fulfill their CAIR em ission reduction requirements, EGU compliance with CAIR is equivalent to RACM/RACT.

Demonstration In 1972, 1980, and 1991, Ohio pr omulgated rules requiring reasonably available controls meas ures for particulate emissions from stationary sources.

Statewide RACT rules have been applied to all new sources locating in Ohio since that time. RACT requirements are incorporated into permits along wit h monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations42 

### discovered by field office staff. The Ohio RACT rules for particulate matter are found in OAC Chapter 3745-17 19



### . In addition, Ohio EPA promulgated NO x 

### SIP Call rules (OAC Chapter 3745-14 20 

### ), CAIR (OAC Chapter 3745-109 21 

### ), and NO x 

### Reasonably Available Control Technology rules (OAC Chapter 3745-110 22 

### ) over the past five years. Emissions from EGUs make up a significant contribution to Oh io’s inventory. Beginning in 2009, Ohio implemented CAIR which has, and will, provide for significant reductions in NO x 

### , PM 2.5 

### , and SO 2 

### until such time CSAPR is implemented. Then the CSAPR will provide for even greater reductions.

As part of a larger initiative , LADCO, in consultation with two contractors, performed a series of studies exploring control measures for reducing bot h ozone precursors and PM 2.5 

### precursors in Ohio, Illinois, I ndiana, Michigan, and Wisconsin area. The first consultant, MACTEC, pr epared a series of white papers 23 

### researching different stationary source categories. The results were compiled into two reports 24 

### . The second consultant, Environ, investigated control options for m obile sources. The results were compiled into two reports 25 

### . The stationary and mobile source sectors (and associated control m easures) were selected by the LADCO States based on several fa ctors presented in the report (See Chapter 2).

Photochemical modeling was t hen conducted (as part of LADCO Round 4 modeling) to assess t he air quality benefit of the candidate control measures and a modeling report was developed 26 

### . Based on the results, the LA DCO project team felt it would not be possible to advance the attainment date for PM 2.5



### . Ohio EPA, in its attainment dem onstration submitted on July 18, 2008, demonstrated (using a weight of evidence approach) that

19 http://www. epa.ohio.gov/dapc/r egs/3745_17.aspx 20 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx 21 http://www. epa.ohio.gov/dapc/r egs/3745_109.aspx 22 http://www. epa.ohio.gov/dapc /regs/3745_110.aspx 23 http://www.ladco.org/r eports/control/white_papers 24 http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_i_april_2005.pdf; http://www.ladco.org/r eports/control/final_reports/identificat ion_and_evaluation_of_candi date_control_meas ures_ii_june_2006.pdf 25 http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_february_2006.pdf; http://www.ladco.org/r eports/control/final_reports/final_report _evaluation_of_candidat e_mobile_source_cont rol_measures_for_ladc o_states_in_2009_and_2012_march_2007.pdf 26 http://www.ladco.org/r eports/control/mode ling/round4_modeling.pdf43 

### attainment would be achieved in this area by 2009. Because of a projected 2009 attainment date, it would not have been reasonably possible or practicable for Ohio to develop RACT/RACM requirements, promulgate regulat ions and implement a control program prior to the proj ected attainment date.

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 atta inment date beyond 2010. The RFP would provide emission reductions showing linear progress between 2002 and 2009. If a State dem onstrates attainment will occur by 2010 or earlier, U.S. EPA considers the attainment demonstration to demonstrat e achievement of RFP.

Demonstration In Ohio’s attainment demonstrat ion submitted on July 18, 2008, Ohio demonstrated (using a weight of evidence approach) that attainment would be achieved in this area by 2009; and therefore, it was not necessary to submit a separate RFP plan.

Requirement 3 of 6 Section 172(c)(3) requires states to subm it 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 revisi ons as determined necessary. 40 CFR 51.1008 requires such inventor y to be submitted within three years of designation and requires a baseline emission inventory for calendar year 2002 or other suitable year to be used for attainment planning.

Demonstration The 2005 comprehensive inventory was submitted to U.S. EPA with Ohio’s PM 2.5 

### attainment demonstrati on SIP submitted on July 18, 2008. It was then subsequently revised and resubmitted on June 7, 2010.

Ohio also updates its inventor y in accordance with U.S. EPA’s CERR rule (i.e. emissions stat ements). Ohio EPA submitted its44 

### emissions statement SIP on Ma rch 18, 1994 which was approved by U.S. EPA on October 13, 1995 ( 59 FR 51863). As discussed in Chapter 4 (Requirement 4), Ohio EPA submits, and commits to submit, emission inventories (sta tements) every three years.

Requirement 4 of 6 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 emissi on reductions from large EGUs, industrial boilers, and cement kiln s in the eastern United States. Ohio passed this rule in 2001. NOx SIP Call requirements are incorporated into permits along wit h monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff. Compliance is tracked through the Clean Air Markets data monitori ng program. Beginning in 2004, this rule accounts for a reduction of approximately 31 percent of all NO x 

### emissions statewide compar ed to previous uncontrolled years. The other 21 states al so have adopted these rules.

On March 10, 2004, the U.S. EPA promulgated the CAIR. Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of 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 million tons by 2009, and 1.3 million tons in 2018 in 28 states. States were r equired to submit a CAIR SIP as part of this effort. Ohio submi tted 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).

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 reductions occurring in 2002 and 2003. Data ta ken from the U.S. EPA Clean Air Markets web site, quantify the gradual NO x 

### reductions that have occurred in Ohio as a resu lt 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 Chapter45 

### 3745-14 27 

### in response to the SI P Call. OAC Chapter 3745-14 regulates EGUs and certain non-EGUs under a cap and trade program based on an 85 percent reduc tion of NOx emissions from EGUs and a 60 percent reduction of NO x 

### emissions from nonEGUs, compared to historical le vels. This cap was in place through 2008, at which time the CAIR program superseded it as 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 la rge (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio EPA’s OAC rule 3745-14-12 addresses stat ionary internal combustion engines, all used in natural gas pipeline transmissions. U.S. EPA approved this revision to the SIP on April 4, 2008. An 82 percent NO x 

### reduction from 1995 levels is ant icipated. Completion of the compliance plan occurred by May 1, 2006, and the compliance demonstration began May 1, 2007.

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and li ght trucks, including sport utility vehicles (SUVs). Under this pr oposal, automakers will be required to sell cleaner cars, and refiner ies will be required to make cleaner, lower sulfur gasoline. Th is rule will apply nationwide. The federal rules will phase in bet ween 2004 and 2009. U.S. EPA has estimated that NO x 

### emission reductions will be approximately 77 percent for passenger cars, 86 per cent 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 approxim ately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoli ne 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

27 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx46 

### inventory. It also estima ted the level of sulfur in highway diesel fuel will be reduced by 97 percent by mid-2006.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highw ay diesel program. The new standards will cut emissions from non -road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this rule, currently accounts for 47 perc ent of diesel particulate matter (PM) and 25 percent of NO x 

### from mobile sources nationwide. Sulfur levels will be reduced in non -road diesel fuel by 99 percent from current levels, from appr oximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starti ng in 2008. Together, these rules will substantially reduce lo cal 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 fu lly implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745- 31 28 

### . The Chapter includes provis ions for the Prevention of Significant Deterioration (PSD) permitting program in OAC rules 3745-31-01 to 3745-31-20. Ohio's PSD program was conditionally approved on October 10, 2001 (66 FR 51570) and received final approval on January 22, 2003 (68FR 2909) by U.S. E PA as part of the SIP.

Demonstration Any facility that is not listed in the 2005 emission inventory, or for the closing of which credit was ta ken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable NSR r equirements. Once the area is redesignated, Ohio EPA will impl ement NSR through the PSD
program.

Requirement 6 of 6

28 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx47 

### Assure that all existing control measures will remain in effect after redesignation unless the State demonstrates through modeling that the standard can be maintained without one or more control measures.

Demonstration Ohio commits to maintaining t he aforementioned 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 maint enance of the annual PM 2.5 

### standard in the Cleveland-Akron-Lorain area, will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal offi ce, has the legal authority and necessary resources to actively enf orce any violations of its rules or permit provisions. After redesi gnation, it intends to continue enforcing all rules that rela te to the emission of PM 2.5 

### precursors in the Cleveland-Akron-Lorain area.48 

### 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 its maintenance plan eight years after redesignation, as required by Section 175(A) of the CAA

.
Requirement 2 of 4 A commitment to expeditiously enact and implement additional contingency control measures in response to ex ceeding specified predetermined levels (triggers) or in the event that future vi olations of the ambient standard occur.

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

Warning Level Response: A warning level response 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 ma intenance 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 increas ing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse t he trend taking into consideration ease and timing for implementation as well as economic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expeditiously as possible, but in no event later than 12 months from the conclusion of the most recent calendar year.

Should it be determined through the wa rning level study that action is necessary to reverse the noted trend, the procedur es for control selection and implementation outlined under “action level response” shall be followed.

Action Level Response: An action level response shall be prompted whenever a two-year average of the weighted annual means of 15.0 μg/m 3 

### or greater occurs within the maintenance ar ea. A violation of the standard49 

### (three-year average of the we ighted annual means of 15.0 μg/m 3 

### or greater) shall also prompt an ac tion level response . In the event that the action level is trigger ed and is not found to be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropolitan planning organizati on or regional council of governments, will determine additi onal control measures needed to assure future attainment of the NAAQS for annual PM 2.5 

### . In this case, measures that can be im plemented in a short time will be selected in order to be in place wit hin 18 months from the close of the calendar year that prompt ed the action level. Ohio EPA will also consider the timing of an ac tion level trigger and determine if additional, significant new regulations not currently included as part of the maintenance provisions will be implemented in a timely manner and will constitute our response.

Control Measure Sele ction and Implementation Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking.

If a new measure/control is alr eady promulgated and scheduled to be implemented at the federal or State level, and that measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Ohio will submit to U.S. EPA an analysis to demonstrate the pr oposed measures are adequate to return the area to attainment.

Requirement 3 of 4 A list of potential contingen cy measures that would be implemented in such an
event.

Demonstration Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the selection is m ade. The selection of measures will be based on cost-effectiveness, em ission reduction potential, economic and social cons iderations or other factors that Ohio EPA deems appropriate. Ohio EPA will solic it input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Be cause it is not possible at this time to determine what cont rol measures will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not exhaustive.50 

### 1) Diesel reduction emission strategies. 2) Alternative fuel (e.g., li quid propane and compressed natural gas) and diesel retrofit programs for fleet vehicle operations. 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 partici pation during which the relative costs and benefits of individual meas ures, at the time 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;51 

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesignat ion petition and maintenance plan in the widely distributed county publications on August 18, 2011.

The public hearing to receive comment s on the redesignation request was held on September 23, 2011, at the Twinsburg Public Library, Twinsburg, Ohio. The public comment period closed on Septem ber 23, 2011. Appendix F includes a copy of the public notice, certification of publication, and the transcript from the public hearing.52 

### CHAPTER EIGHT

CONCLUSIONS

The Cleveland-Akron-Lorain annual PM 2.5 

### nonattainment area has attained the 1997 annual NAAQS for PM 2.5 

### and complied with the applicable provisions of the 1990 Amendments to the CAA regar ding redesignations of PM 2.5 

### nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepared a redesignation request and maintenance pl an that meet the requirements of Section 110 (a)(1) of the 1990 CAA.

Based on this presentation, t he Cleveland-Akron-Lorain annual PM 2.5 

### nonattainment area meets the requirem ents for redesignation under the CAA and U.S. EPA guidance. Oh io has performed an analysis that shows the air quality improvements ar e due to permanent and enf orceable 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 t hat the Cleveland-Ak ron-Lorain annual PM 2.5 

### nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenance plan provisions contained herein.

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