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 PM2.5 annual standard. The enclosed submittal

combines the redesignation request and the required maintenance plan for this area.

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

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

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

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

maintain the 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 PM2.5 

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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 i 

TABLE OF CONTENTS 

Chapter One 

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

Geographical description .............................................................................................................. 2 

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

Chapter Two 

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

Chapter Three 

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

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

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

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

Commitment to continue monitoring ........................................................................................... 14 

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 PM2.5, SO2, and NOx sources ........................................................................................... 49 

Chapter Seven 

Public participation ...................................................................................................................... 50 

Chapter Eight 

Conclusions ................................................................................................................................ 51 
 ii 

FIGURES 

Figure 1 Map of the Cleveland-Akron-Lorain nonattainment area and monitor locations .... 9 

Figure 2 PM2.5 Annual Mean Trends LADCO States ......................................................... 13 

Figure 3 PM2.5 Annual Mean Trends Midwest States ........................................................ 13 

Figure 4 PM2.5 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 .................... 23 

Table 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 SO2 and NOx EGU Emissions Between 2008 and 2009. ............. 27 

Table 13 Reductions in SO2 and NOx EGU Emissions Between the First Half of 2008 

 and 2010.... ......................................................................................................... 27 

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

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 29 

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

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 29 

Table 16 Lake County PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 30 

Table 17 Lorain County PM2.5 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ................................ 30 

Table 18 Medina County PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR ................ 30 

Table 19 Portage County PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 31 

Table 20 Summit County PM2.5 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 31 

Table 21 Cleveland-Akron-Lorain PM2.5 Emission Inventory Totals for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR. ............... 31 

Table 22 Ashtabula County NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 32 

Table 23 Cuyahoga County NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 32 

Table 24 Lake County NOx Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 32 

Table 25 Lorain County NOx Emission Inventory Totals for Base Year 2005, 
 iii 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .................... 33 

Table 26 Medina County NOx Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 33 

Table 27 Portage County NOx Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 33 

Table 28 Summit County NOx Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 34 

Table 29 Cleveland-Akron-Lorain Area NOx Emission Inventory Totals for Base Year 

 2005, Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR. .......... 34 

Table 30 Ashtabula County SO2 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 34 

Table 31 Cuyahoga County SO2 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 35 

Table 32 Lake County SO2 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 35 

Table 33 Lorain County SO2 Emission Inventory Totals for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR ..................... 35 

Table 34 Medina County SO2 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 36 

Table 35 Portage County SO2 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR. ..................................... 36 

Table 36 Summit County SO2 Emission Inventory Totals for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR ...................................... 36 

Table 37 Cleveland-Akron-Lorain Area SO2 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 PM2.5 Nonattainment 

Area 

D LADCO Technical Support Document 

E Incomplete Monitoring Data Substitution Analysis 

F Public Participation Documentation
 iv 

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REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 

CLEVELAND-AKRON-LORAIN 

ANNUAL PM2.5 NONATTAINMENT AREA 

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

Counties, Ohio 

CHAPTER ONE 

Introduction 

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

meet the annual PM2.5

1

 National Ambient Air Quality 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 matter in July 1997. It replaced the existing 

PM10 standard with a health-based PM2.5 standard and retained the PM10

standard as a particulate standard protecting welfare. The standards include an 

annual standard set at 15.0 micrograms per cubic meter (μg/m3), based on the 

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

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

concentrations. 

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

District of Columbia Circuit (the D.C. Circuit). On May 14, 1999, the D.C. Circuit 

remanded, without vacatur, the standard back to U.S. EPA. The remand did not 

question the level at which U.S. EPA set the standards but rather the 

constitutionality of the CAA provision that authorizes U.S. EPA to set national air 

quality standards. U.S. EPA requested a rehearing which the D.C. Circuit 

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

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

on February 27, 2001 that unanimously affirmed the constitutionality of the CAA 

provision but did remand several other issues back to the D.C. Circuit, including 

the issue of whether U.S. EPA acted arbitrarily and capriciously in establishing 

the specific levels of the standards. 

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

issued its decision on March 26, 2002. The D.C. Circuit rejected the claims that 

 

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

also known as particulate matter, is made up of a number of components, including acids (such as 

nitrates and sulfates), organic chemicals, metals, soil or dust particles, and allergens (such as fragments 

of pollen or mold spores). 

Fine particle pollution or PM2.5 describes particulate matter that is 2.5 micrometers in diameter and 

smaller - 1/30th the diameter of a human hair. Fine particle pollution can be emitted directly or formed 

secondarily in the atmosphere.
 2 

the U.S. EPA had acted arbitrarily and capriciously in setting the levels of the 

standards. 

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

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

those designations were made and an effective date was set at April 5, 2005. 

Unlike Subpart 2 of the CAA Amendments of 1990 which defined five ozone 

nonattainment classifications for the areas that exceed the NAAQS based on the 

severity of the ozone levels, PM2.5 nonattainment designations are simply 

labeled “nonattainment.” The CAA Amendments require states with PM2.5

nonattainment areas to submit a plan within three years of the effective date of 

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

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

the entire State of Ohio on July 16, 2008. 

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

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

the criteria that must be met in order for an area to be redesignated from 

nonattainment to attainment: 

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

ii) An approved State Implementation Plan (SIP) for the area 

under Section 110(k).

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

permanent and enforceable reductions in emissions resulting 

from implementation of the SIP and other federal requirements.

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

v) A determination that all Section 110 and Part D requirements 

have been met. 

This document addresses each of these requirements, and provides additional 

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

 

Geographical Description and Background 

The current Cleveland-Akron-Lorain nonattainment area is located in 

northeastern Ohio and includes the following counties: Ashtabula (partial 

nonattainment of Ashtabula Township only), 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 PM2.5 designations, U.S. EPA designated the ClevelandAkron-Lorain area nonattainment for the 15.0 μg/m3 annual standard2

, and Ohio 

 

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

EPA was required to develop a plan to reduce oxides of nitrogen (NOx), sulfur 

dioxide (SO2) and direct PM2.5 emissions and to demonstrate that the area will 

meet the federal annual air quality standard by April 5, 2010. Ohio’s main PM2.5

components are primary particles (organic carbon, crustal material, and 

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

demonstration analysis. Volatile organic compounds (VOCs) and ammonia 

(NH3) were not included in the analysis since they were not part of Ohio’s 

current attainment strategy for PM2.5 (although controls for VOCs have been 

implemented for ozone nonattainment). This is consistent with U.S. EPA’s “Clean 

Air Particle Implementation Rule” [74FR 20856] (hereafter referred to as 

“Implementation Rule”). In the Implementation Rule U.S. EPA presumes NH3 

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

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

demonstration that emissions of VOCs significantly contribute to nonattainment 

of the annual PM2.5 standard. 

This document is intended to support Ohio’s request that the Cleveland-AkronLorain area be redesignated from nonattainment to attainment for the annual 

PM2.5 standard. 

Status of Air Quality 

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

recent three (3) years, 2008 through 2010, demonstrate that the air quality has 

met the NAAQS for annual PM2.5 in this nonattainment area. The NAAQS 

attainment, accompanied by decreases in emission levels discussed in Chapter 

Four, supports a redesignation to attainment for the 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 guidance in a document entitled Procedures for 

Processing Requests to Redesignate Areas to Attainment (redesignation 

guidance), issued September 4, 1992, to Regional Air Directors. The 

redesignation request and maintenance plan are based on the redesignation 

guidance, supplemented with additional guidance received from staff of U.S. 

EPA Region 5. 

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

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 ambient air quality data. The data 

that are used to demonstrate attainment should be the product of 

ambient monitoring that is representative of the area of highest 

concentration. The data should be collected and quality-assured 

in accordance with 40 CFR 58 and recorded in the Air Quality 

System (AQS)in order for it to be available to the public for review. 

 The second component relies upon supplemental U.S. 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 Appendix D contains the most 

recent modeling results showing future attainment and 

maintenance are provided. Chapter Three discusses this 

requirement in more detail and provides the attainment 

demonstration. 

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

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

 The state must be able to reasonably attribute the improvement in 

air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures that 

have been adopted and implemented by the state. 

It was not necessary for Ohio to adopt or implement control 

measures for these counties beyond the federal measures. 

Ohio EPA has adopted several rules recently that will have an 

impact on statewide PM2.5 emissions in the future: 
 5 

• Clean Air Interstate Rule (CAIR) 

• NOx 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 decrees have resulted in reductions 

in emissions from utilities across the state. 

 Chapters Four and Five discuss this requirement in more detail. 

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

 For purposes of redesignation, a state must meet all requirements 

of Section 110 and Part D that were applicable prior to submittal of 

the complete redesignation request. 

 Subpart 1 of Part D consists of general requirements applicable to 

all areas which are designated nonattainment based on a violation 

of the NAAQS. Subpart 4 of Part D consists of more specific 

requirements applicable to particulate matter (specifically to 

address PM10). However, for the purpose of implementing the 

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

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

implementing PM2.5.[72 FR 20589] 

 i.) Section 110(a) requirements 

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

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

implementation plan submitted by a state must have been 

adopted by the state after reasonable public notice and 

hearing, and that, among other things, it must include 

enforceable emission limitations and other control 

measures, means or techniques necessary to meet the 

requirements of the CAA; provide for establishment and 

operation of appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 

provide for implementation of a source permit program to 

regulate the modification and construction of any stationary 

source within the areas covered by the plan; include 

provisions for the implementation of Part C, prevention of 

significant deterioration (PSD) and Part D, NSR permit 

programs; include criteria for stationary source emission 

control measures, monitoring, and reporting; include 

provisions for air quality modeling; and provide for public 

and local agency participation in planning and emission 
 6 

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

September 4, 2009 infrastructure SIP submissions, Ohio 

verified that the State fulfills the requirements of Section 

110(a)(2) of the Act. 

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

emissions from within the State which contribute 

significantly to nonattainment or maintenance areas in any 

other State, or which interfere with programs under Part C 

to prevent significant deterioration of air quality or to 

achieve reasonable progress toward the national visibility 

goal for Federal class I areas (national parks and 

wilderness areas). In order to assist States in addressing 

their obligations regarding regionally transported pollution, 

U.S. EPA finalized CAIR to reduce SO2 and NOx emissions 

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

the requirements of the federal CAIR to reduce NOx and 

SO2 emissions contributing to downwind states. On 

February 1, 2008, U.S. EPA approved Ohio’s CAIR 

program, which can be found in Ohio Administrative Code 

(OAC) Chapter 3745-1093. On July 6, 2011, U.S. EPA 

finalized a replacement to the CAIR program, the CSAPR. 

 CSAPR will further assist States in addressing their 

obligations regarding regionally transported pollution by 

providing reductions in NOx and SO2 emissions in 2012 and 

2014. 

 ii.) Section 172(c) requirements 

 This Section contains general requirements for 

nonattainment plans. The requirements for reasonable 

further progress, identification of certain emissions 

increases, and other measures needed for attainment will 

not apply for redesignations because they only have 

meaning for areas not attaining the standard. The 

requirements for an emission inventory will be satisfied by 

the inventory requirements of the maintenance plan. 

Chapters Four and Five discuss this requirement in more 

detail. 

 iii.) Conformity 

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

provisions are consistent with the Section 176(c)(4) 

conformity requirements. The redesignation request should 

include conformity procedures, if the state already has 

 

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

these procedures in place. If a state does not have 

conformity procedures in place at the time that it submits a 

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

EPA’s conformity regulation upon issuance, as applicable. 

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

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

U.S. EPA must fully approve a maintenance plan that meets the 

requirements of Section 175(A). The maintenance plan will 

constitute a SIP revision and must provide for maintenance of the 

relevant NAAQS in the area for at least 10 years after 

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

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

ensure such maintenance. 

In addition, the maintenance plan shall contain such contingency 

measures as the Administrator deems necessary to ensure prompt 

correction of any violation of the NAAQS. At a minimum, the 

contingency measures must include a requirement that the state 

will implement all measures contained in the nonattainment SIP 

prior to redesignation. 

States seeking redesignation of a nonattainment area should 

consider the following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 Chapter Six discusses this requirement in more detail. 
 8 

CHAPTER THREE 

PM2.5 MONITORING 

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

Requirement 1 of 4 

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

has been attained. 

Background

 There are 13 monitors measuring PM2.5 concentrations in this 

nonattainment area. These monitors are operated by Ohio EPA 

Division of Air Pollution Control, 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 concentrations from 2008 through 

2010 is shown in Table 1. The locations of the monitoring sites for 

this nonattainment area are shown on Figure 1. 
 9 

Demonstration

 

Figure 1 - Map of the Cleveland-Akron-Lorain nonattainment area and 

monitor locations 

Requirement 2 of 4 

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

recorded in the U.S. EPA air quality system (AQS) database, and available for 

public view. 

Demonstration

Ohio EPA has quality assured all data shown in Appendix A in 

accordance with 40 CFR 58.10 and all other federal requirements. Ohio 

EPA has recorded the data in the AQS database and, therefore, the data 

are available to the public. 

Requirement 3 of 4 

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

data from all monitoring sites in the area or its affected downwind environs, are 

below 15.0 μg/m3

. (This showing must rely on three complete, consecutive 

calendar years of quality assured data.) 

 
 10 

Background

 

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

on Data Handling Conventions for the PM NAAQS," U.S. EPA454/R-99-008, April 1999. 

 In accordance with the CAA Amendments, three complete years of 

monitoring data are required to demonstrate attainment at a 

monitoring site. The annual PM2.5 primary and secondary ambient 

air quality standards are met at an ambient air quality monitoring 

site when the three-year average of the annual average is less 

than 15.0 μg/m3

. While calculating design values, three significant 

digits must be carried in the computations, with final values 

rounded to the nearest 0.1 μg/m3

. Decimals 0.05 or greater are 

rounded up, and those less than 0.05 are rounded down, so that 

15.049 μg/m3

 is the largest concentration that is less than, or equal 

to 15.0 μg/m3. Values at or below 15.0 μg/m3 meet the standard; 

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

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

every monitoring site in the area meets the NAAQS. An individual 

site's 3-year average of the annual average concentrations is also 

called the site's design value. The air quality design value for the 

area is the highest design value among all sites in the area. 

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

retrieved from the U.S. EPA AQS. The air quality design value for 

the area is the highest design value among all sites in the area. 
 11 

Demonstration

Table 1 - Monitoring Data for the 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 (2008-2010) from combining

the data from both sites is 10.8ug/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 for the Cleveland-Akron-Lorain area 

demonstrate that the annual PM2.5 NAAQS has been attained. However, 

three monitor sites in Cuyahoga County, site 39-035-0060, site 39-035-

0065, and site 39-035-1002, did not comply with the 75% data capture 

requirement for the 2008-2010 period. Specifically, 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, the use of less than complete data 

may be approved by U.S. EPA considering such factors as monitoring 

site closures/moves, monitoring diligence, 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 multiple imputations. Ohio EPA has 

imputed missing values for these sites and then performed an ordinary 

analysis as if the imputed values were real measurements. Multiple 

imputations use random draws from the conditional distribution of the 

target variable given the other variables. When a regression model is 

used for imputation, the process involves adding a random residual to the 

“best guess” for missing values, to yield the same conditional variance as 

the original variable. Appendix E describes and includes the full statistical 

analyses performed to show that the three-year averages (2008 to 2010) 

of the annual mean values, based on missing data imputations, are below 

15.0 μg/m3. 

Table 2 shows site 39-035-0060, site 39-035-0065, and site 39-035-1002 

before and after the imputation of missing data. Also the “new” sites (with 

imputed values) show a passing design value for 2008 to 2010 of less 

than 13.6 μg/m3. 

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‐

   2004 2005 2006 2007 2008 2009 2010 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 results, Requirement 3 of 4 has 

been met. 
 13 

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

Lake Michigan Air Directors Consortium (LADCO) states, there has been 

a clear downward trend in design values: 

Figure 2 - PM2.5 Annual Mean Trends LADCO States 

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

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

Figure 3 - PM2.5 Annual Mean Trends Midwest States 

Source: LADCO; Recent Ozone and PM2.5 Trends - Aug 26 2010.pptx 
 14 

Design values have also trended downward nationally: 

Figure 4 - PM2.5 Annual Mean National Trends 

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

Requirement 4 of 4 

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

appropriate monitoring network to verify the maintenance of the attainment 

status. 

Demonstration

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

sites indicated in Figure 1 and Table 1. Ohio EPA will consult with 

U.S. EPA Region 5 prior to making changes to the existing 

monitoring network, should changes become necessary in the 

future. Ohio EPA will continue to quality assure the monitoring 

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

requirements. Connection to a central station and updates to the 

Ohio EPA web site4

 will provide real time availability of the data 

and knowledge of any exceedances. Ohio EPA will enter all data 

into AQS on a timely basis in accordance with federal guidelines. 

 

4 www.epa.ohio.gov/dapc 
 15 

CHAPTER FOUR 

EMISSION INVENTORY

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

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

inventory of PM2.5 precursor emissions (primary particles (organic carbon, crustal 

matter, and elemental carbon), SO2 and NOx

5

) representative of the year when 

the area achieves attainment of the annual PM2.5 air quality standard. Ohio also 

must demonstrate that the improvement in air quality between the year that 

violations occurred and the year that attainment was achieved is based on 

permanent and enforceable emission reductions. Other emission inventory 

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

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

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

commitment to provide future updates of the inventory to enable tracking of 

emission levels during the 10-year maintenance period. 

The emissions inventory development and emissions projection discussion 

below, with the exception of the mobile (on-road) emissions inventory and 

projections, identifies procedures used by Ohio EPA and the LADCO regarding 

emissions of all the counties in the Cleveland-Akron-Lorain area. All of these 

inventories and emissions projections were prepared using similar 

methodologies. Mobile emissions inventories and projections for all counties 

were prepared by the Northeast Ohio Areawide Coordinating Agency (NOACA) 

and the Ohio Department of Transportation (ODOT). 

Requirement 1 of 5 

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

base year. 

Background

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

reporting program. The 2005 periodic inventory has been identified 

as one of the preferred databases for SIP development and 

coincides with nonattainment air quality in the Cleveland-AkronLorain area. 

Periodic inventories, which include emissions from all sectors - 

mobile, area, non-road, and point sources - are prepared every 

three years. 

 

5 VOC and NH3 are not addressed. 
 16 

Demonstration

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

this submittal and was submitted to U.S. EPA with Ohio’s PM2.5

attainment demonstration SIP submitted on July 18, 2008 and 

revised on June 7, 2010. The detailed emission inventory 

information for the Cleveland-Akron-Lorain area is provided in 

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

identified under Requirement Three of this Chapter. 

Requirement 2 of 5 

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

redesignation. 

Background

Ohio EPA prepared a comprehensive inventory for the Cleveland-AkronLorain area including area, mobile, and point sources for PM2.5, SO2 and 

NOx for base year 2005. The 2005 inventory was submitted to U.S. EPA 

on July 18, 2008 as part of Ohio’s PM2.5 attainment demonstration SIP for 

this area. The information below describes the procedures Ohio EPA 

used to generate the 2005 base year inventory and to develop SIP-ready 

modeling inventories and future year projections (Pechan Report6) based 

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

year estimates of annual emissions for each source sector using 

accepted growth surrogates. These inventories were provided to the 

LADCO and have been processed to develop average daily emissions for 

use in the air quality analyses. These processed modeling inventories 

have been identified as the correct iteration of the inventory for use in the 

redesignation. In this document, references to LADCO include the 

Midwest Regional Planning Organization. Note thatthe on-road mobile 

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

discussed below. 

• Area sources were taken from the Ohio 2005 periodic 

inventory submitted to U.S. EPA. These projections were 

made from the U.S. Department of Commerce Bureau of 

Economic Analysis (BEA) growth factors, with some 

updated local information. 

• Mobile source emissions were calculated from 

MOVES2010 produced emission factors. Only PM2.5 and 

NOx necessitate emissions inventory analysis. As 

documented in Ohio EPA’s attainment demonstration SIP, 

Ohio EPA in consultation with U.S. EPA determined mobile 

 

6 

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

trols%20Report_Final.pdf 
 17 

sources are insignificant contributors for SO2. Consistent 

with Ohio EPA’s attainment demonstration, Ohio EPA 

continues to consider mobile source SO2 to be an 

insignificant contributor to fine particles for this 

nonattainment area. Based on the demonstration below, 

SO2 constitutes less than one percent (<1.21%) of the 

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

(ranging between 0.21% and 1.21%). 

• Point source information was compiled from Ohio EPA’s 

2005 annual emissions inventory database and the 2005 

U.S. EPA Air Markets acid rain database7

. 

• Biogenic emissions are not included in these summaries. 

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

National Mobile Inventory Model (NMIM) 2002 application. 

To address concerns about the accuracy of some of the 

categories in U.S. EPA’s non-road emissions model, 

LADCO contracted with two (2) companies to review the 

base data and make recommendations. One of the 

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

categories not included in U.S. EPA’s non-road model. 

Emissions were estimated for aircraft, commercial marine 

vessels, and railroads. Recreational motorboat population 

and spatial surrogates (used to assign emissions to each 

county) were significantly updated. The populations for the 

construction equipment category were reviewed and 

updated based upon surveys completed in the Midwest, 

and the temporal allocation for agricultural sources also 

was updated. 

 

Demonstration

On-Road Emission Estimations 

The on-road emission estimations for this nonattainment area 

where performed by the Ohio Department of Transportation 

(ODOT) for the Akron Metropolitan Area Transportation Study 

(AMATS) and Ashtabula Township areas, and by the Northeast 

Ohio Areawide Coordinating Agency (NOACA) for the counties of 

Cuyahoga, Lake, Lorain and Medina in its area. 

 

The inventories include county based, annual totals of PM2.5 and 

Oxides of Nitrogen (NOX) 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/acidrain 
 18 

Overview 

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

March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions 

Simulator), hereafter referred to as MOVES. Upon publication of 

the Federal Register notice, MOVES became U.S. EPA’s 

approved motor vehicle emission factor model for estimating 

VOCs, NOx, CO, PM10 and PM2.5 and other pollutants and 

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

local agencies. MOVES is a computer program designed by the 

U.S. EPA to estimate air pollution emissions from mobile sources. 

MOVES replaces U.S. EPA’s previous emissions model for onroad mobile sources, MOBILE6.2. MOVES can be used to 

estimate exhaust and evaporative emissions as well as brake and 

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

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

emission models. U.S. EPA continuously collects data and 

measures vehicle emissions to make sure the Agency has the best 

possible understanding of mobile source emissions. This 

assessment, in turn, informs the development of U.S. EPA’s 

mobile source emission models. MOVES represents the Agency’s 

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

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

approach to mobile source emission modeling based upon 

recommendations made to the Agency by the National Academy 

of Sciences. 

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

and nitrogen dioxide SIP development as expeditiously as 

possible. The CAA requires that SIP inventories and control 

measures be based on the most current information and applicable 

models that are available when a SIP is developed. Regarding 

transportation conformity, U.S. EPA and U.S. DOT intend to 

establish a two-year grace period before MOVES is required for 

new transportation conformity analyses. 

The MOVES more detailed approach (when compared with the 

previous MOBILE model) to modeling allows U.S. EPA to easily 

incorporate large amounts of in-use data from a wide variety of 

sources, such as data from vehicle inspection and maintenance 

(I/M) programs, remote sensing device (RSD) testing, certification 

testing, portable emission measurement systems (PEMS), etc. 

This approach also allows users to incorporate a variety of activity 

 

8 http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ab1f98 
 19 

data to better estimate emission differences such as those 

resulting from changes to vehicle speed and acceleration patterns. 

MOVES has a graphical user interface which allows users to more 

easily set up and run the model. MOVES database-centered 

design provides users much greater flexibility regarding output 

choices. Unlike earlier models which provided emission factors in 

grams-per-mile in fixed output formats, MOVES output can be 

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

as emission factors (grams-per-mile 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 impacts of individual transportation 

projects. The database-centered design also allows U.S. EPA to 

update emissions data incorporated in MOVES more easily and will 

allow users to incorporate a much wider array of activity data to 

improve estimation of local emissions. For example, the 

improvements in MOVES will allow project-level PM2.5 emissions 

to be estimated. 

The annual PM2.5 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 Transportation Study (AMATS) and the 

Northeast Ohio Areawide Coordinating Agency (NOACA) areas is 

calibrated using the latest population and land use data available 

and are validated using corresponding traffic count data. Currently, 

the travel demand models are validated to year 2005. U.S.EPA’s 

emissions model MOVES is used for 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 would be based on a single-season 

approach. Since travel demand models produce average daily 

conditions, the daily emissions estimates are multiplied by 365 

days to produce annual emissions estimates expressed in tons per 

year. 

Finally, the regional emissions analysis includes emissions for 

Direct PM2.5 (exhaust, brake, and tire wear), and Oxides of 

Nitrogen (NOX).Sulfur Dioxide (SO2), Volatile Organic Compounds 

(VOCs) and Ammonia (NH3) are considered insignificant at this 

time. (Appendix C) 

NOACA maintains a PC-based regional travel demand forecasting 

model on the Citilabs CUBE platform for use in its urban 

transportation planning process. This model employs the 

traditional four step modeling process to project existing and future 
 20 

traffic volumes and travel patterns on the regional transportation 

networks. The four step process consists of trip generation, trip 

distribution, mode split, and route assignment. Output from the 

model is link-by-link directional volumes 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 prepares and submits networks for 

its planning area to ODOT. ODOT prepares networks for 

Ashtabula County. ODOT's modeling 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-level 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 files were generated for base year2005, attainment year-2008, interim year 2015, and maintenance 

year 2022. Assumptions for these runs include an I/M program in 

all but Ashtabula Township. Programs and corresponding MOVES 

parameters were developed in consultation 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 with the aid of several custom 

programs by ODOT. The process 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 involves running ODOT postcms.exe 

to calculate hourly link volumes 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. The 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 emissions for every network link for 
 21 

each hour. The final link on road vehicle emissions for the area is 

the sum of all individual link-hour emissions. 

 

The third step, (mvehicle.exe), calculates vehicle-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 onto 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 intrazonal trips of each zone. The 

zone is assumed circular and the radius of the circle is used as the 

average trip length for these intrazonal trips. Intrazonal emissions 

are then calculated by combining 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 emissions by 365 to produce an 

annual estimate. 

On-Road Mobile Emission Estimations 

Tables 3 through 10 contain the results of the emissions analysis 

for the appropriate years. All emissions estimations are expressed 

in tons per year (tpy). 

Table 3 - Ashtabula County Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 11.50 10.04 5.37 3.03 

NOx (tpy) 294.66 232.83 107.68 54.49 

SO2 (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, Emissions Estimations for On-Road 

Mobile Sources 
 22 

 2005 2008 2015 2022 

PM2.5 (tpy) 1,249.47 1,040.28 430.01 320.94

NOx (tpy) 36,545.59 28,227.20 12,371.38 6,065.83

SO2 (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 

PM2.5 (tpy) 283.09 241.78 122.02 69.42

NOx (tpy) 8,071.90 6,425.00 2,840.39 1,417.15

SO2 (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 

PM2.5 (tpy) 319.85 274.43 143.34 81.69

NOx (tpy) 9,196.87 7,354.77 3,456.51 1,723.02

SO2 (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, Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 358.80 317.43 152.50 78.48

NOx (tpy) 9,328.78 7,603.83 3,306.35 1,677.58

SO2 (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, Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2022 

PM2.5 (tpy) 187.71 160.90 87.54 49.45

NOx (tpy) 5,707.22 4,630.98 2,264.50 1,014.35

SO2 (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, Emissions Estimations for On-Road 

Mobile Sources 
 23 

 2005 2008 2015 2022 

PM2.5 (tpy) 611.78 511.43 251.70 162.98

NOx (tpy) 17,377.28 13,609.82 6,170.32 3,059.45

SO2 (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 

PM2.5 (tpy) 3,022.20 2,556.29 1,192.48 765.99

NOx (tpy) 86,522.30 68,084.43 30,517.13 15,011.87

SO2 (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 vehicle 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 Cleveland-Akron-Lorain area, agreed 

upon as part of the interagency consultation 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 PM2.5 and NOx in 2015 and 2022. 

In an effort to accommodate future variations in travel demand 

models and VMT forecast when no change to the network is 

planned, Ohio EPA consulted with U.S. EPA to determine a 

reasonable approach to address this variation. Based on this 

discussion, a 15 percent margin of safety allocation was agreed 

upon and has been added to the emissions estimates for this 

nonattainment area. 

All methodologies, the latest planning assumptions, and the safety 

margins allocations were determined through the interagency 
 24 

consultation process described in the Transportation Conformity 

Memorandum of Understanding (MOU) 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 emissions due to expected modifications 

to TDM and mobile emissions models; and 2) the total decrease in 

emissions from all sources is sufficient to accommodate 15 

percent allocation of safety margin (as defined in 40 CFR93.1019

) 

to mobile sources while still continuing 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 emission 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 emission 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 PM2.5 and 4,577.57 tpy for NOx for 

2015 and an additional 114.90 tpy for PM2.5 and 2,251.78 tpy for 

NOx for 2022. 

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

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

this allocation is significantly below the total safety margin for this 

area. 

The current PM2.5 and NOx mobile budgets for the fine particle 

NAAQS will no longer be applicable either after the effective date 

of the approved redesignation or after the effective date of any 

U.S. EPA action approving a finding that the PM2.5 and NOx

conformity budgets included in this submittal are adequate for 

transportation conformity purposes, whichever date comes first. 

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

budgets in this Redesignation submittal, which are based on 

MOVES2010, will replace previous motor vehicle emission 

budgets on Attainment Demonstration submittals based on 

MOBILE6.2. 

 

9 "Safety margin" means the amount by which the total projected emissions from all sources of a given 

pollutant are less than the total emissions that would satisfy the applicable requirement for reasonable 

further progress, attainment, or maintenance.
 25 

Requirement 3 of 5 

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

PM2.5 standard. 

Background

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

as the maintenance year for this redesignation request. This 

document contains projected emissions inventories for 2015 and 

2022. 

Emission projections for the Cleveland-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 Emissions Projections” U.S. 

EPA-45/4-91-019. 

• Emissions inventories are required to be projected to future 

dates to assess the influence growth and future controls will 

have. LADCO has developed growth and control files for 

point, area, and non-road categories. These files were used 

to develop the future-year emissions estimates used in this 

document. This was done so the inventories used for 

redesignation are consistent with modeling performed in the 

future. Appendix D contains LADCO’s technical support 

document detailing the analysis used to project emissions 

(Base M10). 

• For the 2008 attainment year emissions were grown from 

the 2005 LADCO modeling inventory, using LADCO’s 

growth factors, for all sectors except point sources 

(electrical generating units and non-electrical generating 

units). Point source emissions for 2008 were compiled from 

Ohio EPA’s 2008 annual emissions inventory database. 

The 2015 interim year emissions were estimated based on 

the 2009 and 2018 LADCO modeling inventory, using 

LADCO’s growth factors, for all sectors. The 2022 

maintenance year is based on emissions estimates from 

the 2018 LADCO modeling. 

 

10 http://www.ladco.org/tech/emis/current/index.php 
 26 

Ohio EPA is identifying emissions projections for 2015 and 2022 

for EGUs with implementation of the CAIR program. U.S. EPA has 

raised concerns regarding the CAIR 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 projections. Additional modeling 

has yet to be conducted that accounts for CSAPR. However, it is 

believed that CSAPR will provide 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 NOx and SO2. CAIR replaced the NOx SIP Call for 

EGUs. The intent of the CAIR program is for national NOx

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

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

States were required to submit a CAIR SIP as part of this effort. 

Ohio submitted a CAIR SIP which was approved by U.S. EPA on 

February 1, 2007. Revisions to the CAIR SIP were again 

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

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

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

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

tons per year while in 2010 emissions of SO2 will decrease from a 

baseline of 1,373,000 tons per year to 298,000 tons per year, 

within Ohio. And by 2015 U.S. EPA projects emissions of NOx will 

decrease to 83,000 tons per year while emissions of SO2 will 

decrease to 208,000 tons per year, within Ohio11. 

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 NOx and 1,373,000 tons of SO2

emitted in 2005. In 2008 and 2009 facilities began preparing for 

and implementing control programs to address CAIR12 and 

consent decrees. 

Table 12 - Reductions in SO2 and NOx EGU Emissions 

Between 2008 and 2009 

SO2 NOx

2008 2009 Change 2008 2009 Change 

 

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

12 Under CAIR, NOx reductions are to occur beginning 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 Tracking13

Significant reductions also occurred regionally and nationally as 

can be seen from the above. Data is also available for the first two 

quarters of 2010, the year SO2 reductions are to be implemented 

under CAIR: 

Table 13 – Reductions in SO2 and NOx EGU Emissions 

Between the First Half of 2008 and 2010 

SO2 NOx

2008 

 (1st half) 

2010 

(1st half) 

Change 2008 

(1st half) 

2010 

(1st half)

Change 

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

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

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

Source: Clean Air Markets Quarterly Emissions Tracking14

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

“Based on emissions monitoring data, EPA has observed 

substantial reductions in SO2 emissions from 2005 to 2009 and in 

the first two quarters of 2010 as companies installed more 

controls, electric demand declined, and low natural gas prices 

made combined-cycle gas-fired units more competitive in several 

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

subsequent remand in late 2008, the controls in place generally 

have continued to operate, helping to drive continued progress in 

reducing emissions.15” 

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

CAIR program is providing real reductions at this time, Ohio 

believes these reductions have assisted with PM2.5 attainment in 

this nonattainment area and throughout Ohio. 

On July 6, 2011, U.S. EPA finalized a replacement to the CAIR 

program, the CSAPR. CSAPR will preserve those initial reductions 

achieved under CAIR and provide even greater reductions in NOx

and SO2 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 NOx 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.htm
 28 

2014 to 85,744 tons per year while SO2 will decrease to 304,022 

tons per year in 2012 and 134,333 tons per year in 2014, within 

Ohio. In addition, U.S. EPA projections indicate that as a result of 

implementation of CSAPR, there 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 level of emissions is 

sufficient to maintain the annual PM2.5 standard by assessing 

future year emissions that include the CAIR program. 

The detailed inventory information for Cleveland-Akron-Lorain area 

for 2005 is in Appendix B. Emission trends are an important 

gauge for continued compliance with the PM2.5 standard. 

Therefore, Ohio EPA performed an initial comparison of the 

inventories for the base year and maintenance years. Mobile 

source emission inventories are described in Appendix C. 

Sectors included in the following tables are: Electrical Generating 

Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Area (Other); Marine; Aircraft; Rail 

(MAR); and On-road Mobile (On-road). 

Maintenance is demonstrated when the future-year (2022) 

projected emission totals are below the 2008 attainment year 

totals. 

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

following data sources: 

- All On-Road data source: NOACA and ODOT’s Transportation 

Unit. 

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

inventory database. 

- All other data source: Lake Michigan Air Directors Consortium 

(LADCO). 

Demonstration

PM2.5 

The 2005 and 2008 actual PM2.5 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 

PM2.5 condensable emissions into future years. Therefore, comparing 
 29 

base and attainment year emissions with the future year predictions is not 

accurate in the IPM CAIR modeling. This step leads to a false perception 

of significant PM2.5 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 appropriate for the purposes of PM2.5 to 

evaluate future year emissions without the CAIR program. 

Table 14 - Ashtabula County PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2022 (tpy) – Without CAIR

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 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 PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2022 (tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU 

Point 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 2259.04 936.24

 

 
 30 

Table 16 - Lake County PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 

(tpy) – Without CAIR

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 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 PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 

(tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

EGU Point 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 PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 

(tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 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 851.88 799.80 603.55 499.03 300.77
 31 

Table 19 - Portage County PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 

(tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 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 PM2.5 Emission Inventory Totals for Base 

Year 2005, Estimated 2008, and Projected 2015 and 2022 

(tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim

2022 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 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 PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and projected 

2015 and 2022 (tpy) – Without CAIR 

PM2.5

2005 

Base 

2008 

Attainment 

2015 

Interim 

2022 

Maintenance 

Safety 

Margin 

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 

PM2.5 TOTAL 9205.88 8647.82 6911.23 6135.82 2512.00

NOx 
 32 

Table 22 - Ashtabula County NOx 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 NOx 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 NOx 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 6,577.17

 
 33 

 

Table 25 - Lorain County NOx 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 NOx 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 NOx 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 4,928.69
 34 

Table 28 - Summit County NOx 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 NOx 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

SO2

Table 30 - Ashtabula County SO2 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 ‐1,441.55
 35 

Table 31 - Cuyahoga County SO2 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 SO2 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 SO2 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 43.34
 36 

TOTAL 

43,738.79 23,505.61

9,393.3

7 3,343.66 20,161.95

Table 34 - Medina County SO2 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 SO2 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 SO2 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 11,082.18 463.70
 37 

 
 38 

Table 37 - Cleveland-Akron-Lorain Area SO2 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

PM2.5, NOx, and SO2

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 

PM2.5 8,647.82 6,911.23 1,736.59 6,135.82 2,512.00 

NOx 132,159.46 84,892.19 47,267.27 59,793.84 72,365.62 

SO2 115,319.14 87,865.72 27,453.42 58,485.50 56,833.64 

As shown in the table above (Table 38), PM2.5 emissions in the 

nonattainment area are projected to decrease by 1,736.59 tpy in 

2015 and 2,512.00 tpy in 2022. NOx emissions in the 

nonattainment area are projected to decrease by 47,267.27 tpy in 

2015 and 72,365.62 tpy in 2022. SO2 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 increase due to expectations that the 

population will grow in this area; however, cleaner vehicles and 

fuels are expected to be in place in 2009 and 2018, and the 

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 Motor 
 39 

Vehicle Emissions Standards and Gasoline Sulfur Control 

Requirements16, Highway Heavy-Duty Engine Rule17, and the 

Non-Road Diesel Engine Rule18 are factored into the changes. 

In addition to the above, starting in September 2011, First 

Energy’s Eastlake plant will only be used in the future for 

emergency power purposes. The five units at this facility 

represent nearly half of the available megawatts for the entire 

area (1,233 of 2,494 megawatts). 

Requirement 4 of 5 

A demonstration that improvement in air quality between the year violations 

occurred and the year attainment was achieved is based on permanent and 

enforceable emission reductions and not on temporary adverse economic 

conditions or unusually favorable meteorology. 

Background 

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

met the NAAQS for PM2.5 in 2008-2010. U.S. EPA’s redesignation 

guidance (p 9) states: “A state may generally demonstrate maintenance 

of the NAAQS by either showing that future emissions of a pollutant or its 

precursors will not exceed the level of the attainment inventory, or by 

modeling to show that the future mix of sources and emissions rates will 

not cause a violation of the NAAQS.” 

Demonstration 

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

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

these reductions were 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 NOx SIP Call, CAIR, and federal consent decrees 

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

Reductions achieved are discussed in greater detail under Chapter Five. 

 

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.htm 
 40 

Table 39 - Cleveland-Akron-Lorain Area Comparison of 2005 base 

year and 2008 attainment year on-road and EGU 

reductions 

 2005 2008 

On-road PM2.5 3,022.20 2,556.29 

On-road NOx 86,522.30 68,084.43 

On-road SO2 1,854.30 555.67 

Non-road PM2.5 1,552.11 1,355.20 

Non-road NOx 19,024.92 16,279.89 

Non-road SO2 1,806.55 664.69 

EGU PM2.5 431.46 465.61 

EGU NOx 23,369.52 22,214.20 

EGU SO2 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 emission statement from major sources. 

Demonstration

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

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

Consolidated Emissions Reporting Rule (CERR). Ohio EPA 

prepares a new periodic inventory for all PM2.5 precursor emission 

sectors every three years. These PM2.5 precursor inventories will 

be prepared for future years as necessary to comply with the 

inventory reporting requirements established in the CFR. 

Emissions information will be compared to the 2005 base year and 

the 2022 projected maintenance year inventories to assess 

emission trends, as necessary, and to assure continued 

compliance with the annual PM2.5 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 Clean 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 minimum, of reasonable available 

control technology). 

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

great detail. Under U.S. EPA’s approach, RACT is determined as 

part of the broader RACM analysis and identification of all 

measures (for stationary, mobile, and area sources) that are 

technically and economically feasible, and that would collectively 

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

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

and RACM, that (1) identifies potential measures that are 

reasonable, (2) uses modeling to identify the attainment date that 

is as expeditious as practicable, and (3) selects the appropriate 

RACT and RACM. 

The Implementation Rule also provides for a presumption that in 

States that fulfill their CAIR emission reduction requirements, EGU 

compliance with CAIR is equivalent to RACM/RACT. 

Demonstration

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

reasonably available controls measures for particulate emissions 

from stationary sources. 

Statewide RACT rules have been applied to all new sources 

locating in Ohio since that time. RACT requirements are 

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio EPA 

also has an active enforcement program to address violations 
 42 

discovered by field office staff. The Ohio RACT rules for particulate 

matter are found in OAC Chapter 3745-1719. 

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

Chapter 3745-1420), CAIR (OAC Chapter 3745-10921), and NOx

Reasonably Available Control Technology rules (OAC Chapter 

3745-11022) over the past five years. Emissions from EGUs make 

up a significant contribution to Ohio’s inventory. Beginning in 2009, 

Ohio implemented CAIR which has, and will, provide for significant 

reductions in NOx, PM2.5, and SO2 until such time 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 both ozone precursors and PM2.5 

precursors in Ohio, Illinois, Indiana, Michigan, and Wisconsin area. 

The first consultant, MACTEC, prepared a series of white papers23

researching different stationary source categories. The results 

were compiled into two reports24. The second consultant, Environ, 

investigated control options for mobile sources. The results were 

compiled into two reports25. The stationary and mobile source 

sectors (and associated control measures) were selected by the 

LADCO States based on several factors presented in the report 

(See Chapter 2). 

Photochemical modeling was then conducted (as part of LADCO 

Round 4 modeling) to assess the air quality benefit of the 

candidate control measures and a modeling report was 

developed26. Based on the results, the LADCO project team felt it 

would not be possible to advance the attainment date for PM2.5. 

Ohio EPA, in its attainment demonstration submitted on July 18, 

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

 

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

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

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

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

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

24 

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

ures_i_april_2005.pdf; 

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

ures_ii_june_2006.pdf 

25

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

rol_measures_february_2006.pdf; 

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

rol_measures_for_ladco_states_in_2009_and_2012_march_2007.pdf

26 http://www.ladco.org/reports/control/modeling/round4_modeling.pdf
 43 

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

projected 2009 attainment date, it would not have been reasonably 

possible or practicable for Ohio to develop RACT/RACM 

requirements, promulgate regulations and implement a control 

program prior to the projected attainment date. 

Requirement 2 of 6

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

demonstration SIPs for nonattainment areas to show reasonable further 

progress (RFP). 

Background

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

which a State projects an attainment date beyond 2010. The RFP 

would provide emission reductions showing linear progress 

between 2002 and 2009. If a State demonstrates attainment will 

occur by 2010 or earlier, U.S. EPA considers the attainment 

demonstration to demonstrate achievement of RFP. 

Demonstration

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

Ohio demonstrated (using a weight of evidence approach) that 

attainment would be achieved in this area by 2009; and therefore, 

it was not necessary to submit a separate RFP plan. 

Requirement 3 of 6

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

emissions. 

Background

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

inventory of actual emissions in the area, including the 

requirement for periodic revisions as determined necessary. 40 

CFR 51.1008 requires such inventory to be submitted within three 

years of designation and requires a baseline emission inventory 

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

attainment planning. 

Demonstration

The 2005 comprehensive inventory was submitted to U.S. EPA 

with Ohio’s PM2.5 attainment demonstration SIP submitted on July 

18, 2008. It was then subsequently revised and resubmitted on 

June 7, 2010. 

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

CERR rule (i.e. emissions statements). Ohio EPA submitted its 
 44 

emissions statement SIP on March 18, 1994 which was approved 

by U.S. EPA on October 13, 1995 (59 FR 51863). As discussed in 

Chapter 4 (Requirement 4), Ohio EPA submits, and commits to 

submit, emission inventories (statements) every three years. 

Requirement 4 of 6

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

fully implemented. 

Background

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

EPA NOx SIP Call required 22 states to pass rules that would 

result in significant emission reductions from large EGUs, 

industrial boilers, and cement kilns in the eastern United States. 

Ohio passed this rule in 2001. NOx SIP Call requirements are 

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio EPA 

also has an active enforcement program to address violations 

discovered by field office staff. Compliance is tracked through the 

Clean Air Markets data monitoring program. Beginning in 2004, 

this rule accounts for a reduction of approximately 31 percent of all 

NOx emissions statewide compared to previous uncontrolled 

years. The other 21 states also have adopted these rules. 

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

Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 

eastern states and the District of Columbia to significantly reduce 

emissions of NOx and SO2. CAIR replaced the NOx SIP Call for 

EGUs. National NOx emissions will be cut from 4.5 million tons in 

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

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

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

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

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

approved as a direct final action on September 25, 2009 (74 FR 

48857). 

Demonstration

Controls for EGUs under the NOx SIP Call formally commenced 

May 31, 2004. Emissions covered by this program have been 

generally trending downward since 1998 with larger reductions 

occurring in 2002 and 2003. Data taken from the U.S. EPA Clean 

Air Markets web site, quantify the gradual NOx reductions that 

have occurred in Ohio as a result of Title IV of the 1990 CAA 

Amendments and the beginning of the NOx SIP Call Rule. Ohio 

developed the NOx Budget Trading Program rules in OAC Chapter 
 45 

3745-1427 in response to the SIP Call. OAC Chapter 3745-14 

regulates EGUs and certain non-EGUs under a cap and trade 

program based on an 85 percent reduction of NOx emissions from 

EGUs and a 60 percent reduction of NOx emissions from nonEGUs, compared to historical levels. 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 NOx SIP 

Call that establishes a budget for large (greater than 1 ton per day 

emissions) stationary internal combustion engines. Ohio EPA’s 

OAC rule 3745-14-12 addresses stationary internal combustion 

engines, all used in natural gas pipeline transmissions. U.S. EPA 

approved this revision to the SIP on April 4, 2008. An 82 percent 

NOx reduction from 1995 levels is anticipated. Completion of the 

compliance plan occurred by May 1, 2006, and the compliance 

demonstration began May 1, 2007. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur 

Standards 

In February 2000, U.S. EPA finalized a federal rule to significantly 

reduce emissions from cars and light trucks, including sport utility 

vehicles (SUVs). Under this proposal, automakers will be required 

to sell cleaner cars, and refineries will be required to make 

cleaner, lower sulfur gasoline. This rule will apply nationwide. The 

federal rules will phase in between 2004 and 2009. U.S. EPA has 

estimated that NOx emission reductions will be approximately 77 

percent for passenger cars, 86 percent for smaller SUVs, light 

trucks, and minivans, and 65 to 95 percent reductions for larger 

SUVs, vans, and heavier trucks. The sulfur content of gasoline is 

estimated to be reduced by up to 90 percent. VOC emission 

reductions will be approximately 12 percent for passenger cars, 18 

percent for smaller SUVs, light trucks, and minivans, and 15 

percent for larger SUVs, vans, and heavier trucks. 

Heavy-Duty Diesel Engines 

In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty 

Engines, a program which includes low-sulfur diesel fuel 

standards, which will be phased in from 2004 through 2007. This 

rule applies to heavy-duty gasoline and diesel trucks and buses. 

This rule will result in a 40 percent reduction in NOx from diesel 

trucks and buses, a large sector of the mobile sources NOx

 

27 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 
 46 

inventory. It also estimated the level of sulfur in highway diesel fuel 

will be reduced by 97 percent by mid-2006. 

Clean Air Non-road Diesel Rule 

In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. 

 This rule applies to diesel engines used in industries such as 

construction, agriculture, and mining. It also contains a cleaner 

fuel standard similar to the highway diesel program. The new 

standards will cut emissions from non-road diesel engines by more 

than 90 percent. Non-road diesel equipment, as described in this 

rule, currently accounts for 47 percent of diesel particulate matter 

(PM) and 25 percent of NOx from mobile sources nationwide. 

Sulfur levels will be reduced in non-road diesel fuel by 99 percent 

from current levels, from approximately 3,000 parts per million 

(ppm) now to 15 ppm in 2009. New engine standards take effect, 

based on engine horsepower, starting in 2008. Together, these 

rules will substantially reduce local and regional sources of PM2.5

precursors. 

Requirement 5 of 6

Acceptable provisions to provide for new source review. 

Background

Ohio has a longstanding and fully implemented New Source 

Review (NSR) program. This is addressed in OAC Chapter 3745-

3128. The Chapter includes provisions for the Prevention of 

Significant Deterioration (PSD) permitting program in OAC rules 

3745-31-01 to 3745-31-20. Ohio's PSD program was conditionally 

approved on October 10, 2001 (66 FR 51570) and received final 

approval on January 22, 2003 (68FR 2909) by U.S. EPA as part of 

the SIP. 

Demonstration

Any facility that is not listed in the 2005 emission inventory, or for 

the closing of which credit was taken in demonstrating attainment, 

will not be allowed to construct, reopen, modify, or reconstruct 

without meeting all applicable NSR requirements. Once the area is 

redesignated, Ohio EPA will implement NSR through the PSD 

program. 

Requirement 6 of 6

 

28 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx 
 47 

Assure that all existing control measures will remain in effect after redesignation 

unless the State demonstrates through modeling that the standard can be 

maintained without one or more control measures. 

Demonstration

Ohio commits to maintaining the aforementioned control measures 

after redesignation. Ohio hereby commits that any changes to its 

rules or emission limits applicable to PM2.5, SO2, and NOx as 

required for maintenance of the annual PM2.5 standard in the 

Cleveland-Akron-Lorain area, will be submitted to U.S. EPA for 

approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal office, has the legal authority and 

necessary resources to actively enforce any violations of its rules 

or permit provisions. After redesignation, it intends to continue 

enforcing all rules that relate to the emission of PM2.5 precursors in 

the 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 plan eight years after redesignation. 

Demonstration

Ohio hereby commits to review its maintenance plan eight years 

after redesignation, as required by Section 175(A) of the CAA. 

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

(triggers) or in the event that future violations of the ambient standard occur. 

Demonstration

Ohio hereby commits to adopt and expeditiously implement 

necessary corrective actions in the following circumstances: 

Warning Level Response: 

A warning level response shall be prompted whenever the PM2.5

average of the weighted annual mean of 15.5 μg/m3 occurs in a 

single calendar year within the maintenance area. A warning level 

response will consist of a study to determine whether the PM2.5

value indicates a trend toward higher PM2.5 values or whether 

emissions appear to be increasing. The study will evaluate 

whether the trend, if any, is likely to continue and, if so, the control 

measures necessary to reverse the trend taking into consideration 

ease and timing for implementation as well as economic and social 

considerations. Implementation of necessary controls in response 

to a warning level response trigger will take place as expeditiously 

as possible, but in no event later than 12 months from the 

conclusion of the most recent calendar year. 

Should it be determined through the warning level study that action 

is necessary to reverse the noted trend, the procedures for control 

selection and implementation outlined under “action level 

response” shall be followed. 

Action Level Response: 

An action level response shall be prompted whenever a two-year 

average of the weighted annual means of 15.0 μg/m3

 or greater 

occurs within the maintenance area. A violation of the standard 
 49 

(three-year average of the weighted annual means of 15.0 μg/m3

or greater) shall also prompt an action level response. In the event 

that the action level is triggered and is not found to be due to an 

exceptional event, malfunction, or noncompliance with a permit 

condition or rule requirement, Ohio EPA in conjunction with the 

metropolitan planning organization or regional council of 

governments, will determine additional control measures needed 

to assure future attainment of the NAAQS for annual PM2.5. In this 

case, measures that can be implemented in a short time will be 

selected in order to be in place within 18 months from the close of 

the calendar year that prompted the action level. Ohio EPA will 

also consider the timing of an action level trigger and determine if 

additional, significant new regulations not currently included as 

part of the maintenance provisions will be implemented in a timely 

manner and will constitute our response. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the 

necessary administrative and legal process. This process will 

include publication of notices, an opportunity for public hearing, 

and other measures required by Ohio law for rulemaking. 

If a new measure/control is already promulgated and scheduled to 

be implemented at the federal or State level, and that 

measure/control is determined to be sufficient to address the 

upward trend in air quality, additional local measures may be 

unnecessary. Furthermore, Ohio will submit to U.S. EPA an 

analysis to demonstrate the proposed measures are adequate to 

return the area to attainment. 

Requirement 3 of 4

A list of potential contingency measures that would be implemented in such an 

event. 

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective 

at the time the selection is made. The selection of measures will 

be based on cost-effectiveness, emission reduction potential, 

economic and social considerations or other factors that Ohio EPA 

deems appropriate. Ohio EPA will solicit input from all interested 

and affected persons in the maintenance area prior to selecting 

appropriate contingency measures. Because it is not possible at 

this time to determine what control measures will be appropriate at 

an unspecified time in the future, the list of contingency measures 

outlined below is not exhaustive. 
 50 

1) Diesel reduction emission strategies. 

2) Alternative fuel (e.g., liquid propane and compressed natural 

gas) and diesel retrofit programs for fleet vehicle operations. 

3) Tighter PM2.5, SO2, and NOx emissions offsets for new and 

modified major sources. 

4) Impact crushers located at recycle scrap yards – upgrade wet 

suppression. 

5) Concrete manufacturing – upgrade wet suppression. 

6) Additional NOx RACT statewide. 

No contingency measure shall be implemented without providing 

the opportunity for full public participation during which the relative 

costs and benefits of individual measures, at the time they are 

under consideration, can be fully evaluated. 

Requirement 4 of 4 

A list of PM2.5, SO2, and NOx sources potentially subject to future additional 

control requirements. 

Demonstration

The following is a list of PM2.5, SO2, and NOx sources potentially 

subject to future controls. 

• ICI Boilers - SO2 and NOx controls; 

• EGUs; 

• process heaters; 

• internal combustion engines; 

• combustion turbines; 

• other sources greater than 100 tons per year; 

• fleet vehicles; 

• concrete manufacturers; 

• aggregate processing plants; 
 51 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in the 

widely distributed county publications on August 18, 2011. 

The public hearing to receive comments on the redesignation request was held 

on September 23, 2011, at the Twinsburg Public Library, Twinsburg, Ohio. The 

public comment period closed on September 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 PM2.5 nonattainment area has attained the 

1997 annual NAAQS for PM2.5 and complied with the applicable provisions of the 

1990 Amendments to the CAA regarding redesignations of PM2.5 nonattainment 

areas. Documentation to that effect is contained herein. Ohio EPA has prepared 

a redesignation request and maintenance plan that meet the requirements of 

Section 110 (a)(1) of the 1990 CAA. 

Based on this presentation, the Cleveland-Akron-Lorain annual PM2.5 

nonattainment area meets the requirements for redesignation under the CAA 

and U.S. EPA guidance. Ohio has performed an analysis that shows the air 

quality improvements are due to permanent and enforceable measures. 

Furthermore, because this area is subject to significant transport of pollutants, 

significant regional SO2 and NOx reductions will ensure continued compliance 

(maintenance) with the standard with an increasing margin of safety. 

The State of Ohio hereby requests that the Cleveland-Akron-Lorain annual PM2.5 

nonattainment area be redesignated to attainment simultaneously with U.S. EPA 

approval of the maintenance plan provisions contained herein. 
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