Fine Particle Attainment Demonstration 

and 

Technical Support Document

For the Indiana Portion 

of the 

Cincinnati – Hamilton, OH-KY-IN 

Fine Particle Nonattainment Area

Lawrenceburg Township, Dearborn County 

Indiana

Prepared By: 

Indiana Department of Environmental Management 

Office of Air Quality 

 June 2008 

 

 
 

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TABLE OF CONTENTS 

1.0 OVERVIEW..........................................................................................................................1

1.1 INTRODUCTION ..................................................................................................................1 

1.2 NATIONAL AMBINET AIR QUALITY STANDARDS .....................................................1 

1.3 GEOGRAPHICAL DESCRIPTION.......................................................................................4 

1.4 CONTROL STRATEGY........................................................................................................6 

1.5 ATTAINMENT TEST............................................................................................................6 

2.0 CLEAN AIR ACT REQUIREMENTS...............................................................................8 

2.1 GENERAL REQUIREMENTS ..............................................................................................8 

 2.1.1 Reasonably Available Control Measures (RACM) .......................................................8 

 2.1.2 Reasonably Available Control Technology (RACT).....................................................9 

2.2 REASONABLE FURTHER PROGRESS..............................................................................9 

2.3 EMISSIONS INVENTORIES................................................................................................9 

2.4 IDENTIFICATION AND QUANTIFICATION OF EMISSIONS......................................10 

2.5 PERMIT PROGRAM FOR NEW AND MODIFIED MAJOR SOURCES.........................10 

2.6 OTHER CONTROL MEASURES, MEANS OR TECHNIQUES ......................................10 

2.7 COMPLIANCE WITH SECTION 110(A)(2) ......................................................................11 

2.8 EQUIVALENT TECHNIQUES...........................................................................................11 

2.9 CONTINGENCY MEASURES ...........................................................................................11 

2.10 ATTAINMENT DEMONSTRATION.................................................................................11 

 2.10.1 Photochemical Grid Modeling Analysis...................................................................12 

 2.10.2 Air Quality Trends Analysis .....................................................................................12 

 2.10.3 Emissions Trends Analysis.......................................................................................14 

2.11 CONTROL STRATEGY......................................................................................................14 

2.12 MOBILE SOURCE EMISSIONS BUDGET .......................................................................14 

3.0 TECHNICAL ELEMENTS OF DEMONSTRATION ...................................................15 

3.1 PHOTOCHEMICAL MODELING ANALYSIS .................................................................15 

 3.1.1 Modeling Methodology ...............................................................................................16 

 3.1.2 Modeling Preparation and Objectives..........................................................................16 

 3.1.3 Meteorology Selection.................................................................................................17 

 3.1.4 Modeling Domain ........................................................................................................17 

 3.1.5 Selection of Base Year.................................................................................................19 

 3.1.6 Selection of Future Years ............................................................................................19

 3.1.7 Emissions Inputs ..........................................................................................................19 

 3.1.8 Model Performance......................................................................................................20 

3.2 MODELED ATTAINMENT TEST .....................................................................................21 

3.3 ATTAINMENT TEST RESULTS .......................................................................................23 

3.4 UNMONITORED AREA ANALYSIS ................................................................................26 
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4.0 AIR QUALITY TRENDS ..................................................................................................30 

5.0 EMISSIONS TRENDS ANALYSIS..................................................................................34 

6.0 CONTROL STRATEGY ...................................................................................................43 

6.1 MODELED CONTROL MEASURES.................................................................................43 

 6.1.1 Heavy-Duty Gasoline and Diesel Highway Vehicle Standards...................................43 

 6.1.2 Large Non-Road Diesel Engine Standards ..................................................................44 

 6.1.3 Non-Road Spark-Ignition Engines and Recreational Engine Standards .....................44 

 6.1.4 NOx SIP Call................................................................................................................44 

 6.1.5 Clean Air Interstate Rule (CAIR) ................................................................................45 

6.2 ADDITIONAL CONTROL MEASURES............................................................................45 

 6.2.1 Federal Controls...........................................................................................................45 

 6.2.2 Indiana Statewide Controls..........................................................................................46 

 6.2.3 Kentucky Statewide Controls ......................................................................................47 

 6.2.4 Ohio Statewide Controls..............................................................................................48

 

7.0 WEIGHT OF EVIDENCE ANALYSIS............................................................................50 

7.1 LADCO’S ROUND 5 MODELING.....................................................................................50 

7.2 LADCO’S ROUND 5 SPECIATED MODELED ATTAINMENT TEST RESULTS........52 

7.3 LADCO’S ROUND 5 PARTICULATE SOURCE APPORTIONMENT RESULTS.........53 

7.4 DAILY MONITORED DATA COMPARISON FOR CINCINNATI PM2.5 MONITORING 

SITES....................................................................................................................................55 

7.5 SUMMARY OF ASSOCIATION FOR SOUTHEASTERN INTEGRATED PLANNING 

(ASIP) MODELING FOR KENTUCKY .............................................................................56 

7.6 SUMMARY OF ATTAINMENT TEST MODELING RESULTS .....................................58 

8.0 MOBILE SOURCE EMISSIONS BUDGET ...................................................................59 

8.1 ON-ROAD EMISSIONS ESTIMATIONS ..........................................................................59 

8.2 OVERVIEW .........................................................................................................................59 

8.3 EMISSIONS ESTIMATIONS..............................................................................................59 

9.0 CONTINGENCY MEASURES.........................................................................................61 

10.0 PUBLIC PARTICIPATION ..............................................................................................62 

11.0 CONCLUSION ...................................................................................................................62 
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FIGURES

Figure 1.1 U.S. EPA Fine Particle Nonattainment Area Designations............................................5 

Figure 3.1 LADCO Meteorological and Emissions Modeling Domain ........................................18 

Figure 3.2 Model Performance Metrics for Annual PM2.5 Modeling............................................21 

Figure 3.3 Spatial Representation for the Cincinnati Area PM2.5 Monitoring Sites......................27 

Figure 4.1 Controlling Monitor Design Values.............................................................................31 

Figure 4.2 Three-Year Fine Particle Design Values......................................................................32 

Figure 4.3 Annual PM2.5 Vales for the Cincinnati Area................................................................33 

Figure 5.1 Regional NOx Reductions 2005 - 2010 ........................................................................41 

Figure 5.2 Regional SO2 Reductions 2005 - 2010.........................................................................42 

Figure 7.1 Graph of Modeling Results for the Cincinnati Area PM2.5 Monitors for 2009, 2012 

and 2018.........................................................................................................................................52 

Figure 7.2 Daily Monitoring Data Comparison for the Cincinnati Area PM2.5 Monitors.............56 

TABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles............................................1 

Table 1.2 Cincinnati Area 2001-2003 Air Quality Monitoring Data used for Designation ............3 

Table 1.3 Attainment Test Results...................................................................................................7 

Table 3.1 Observed Quarterly Mean PM2.5/Quarterly Mean Composition, Murray Rd., Hamilton 

County, Monitor.............................................................................................................................23 

Table 3.2 Quarterly Mean Composition for each Component of PM2.5, Murray Rd., Hamilton 

County, Monitor.............................................................................................................................24 

Table 3.3 Relative Response Factors (RRFs) for each Component, Murray Rd., Hamilton 

County, Ohio, Monitor...................................................................................................................24 

Table 3.4 Projected Quarterly Species Estimates, Murray Rd., Hamilton County, Monitor. .......25 

Table 3.5 Attainment Test Results for the Cincinnati Area...........................................................25 

Table 3.6 Annual Design Values for Cincinnati Nonattainment Area from 2000 - 2006 .............28 

Table 3.7 Modeling Results for PM2.5 Monitors located in or near the Cincinnati Fine Particle 

Nonattainment Area for 2009, 2012 and 2018...............................................................................30 

Table 4.1 Cincinnati Nonattainment Area’s Annual Fine Particle Design Values........................30 

Table 5.1 NOx Emissions Inventories (tons per year) Entire Nonattainment Area .......................36 

Table 5.2 SO2 Emissions Inventories (tons per year) Entire Nonattainment Area ........................37 

Table 5.3 PM2.5 Emissions Inventories (tons per year) Entire Nonattainment Area .....................37 

Table 5.4 Statewide Annual NOx and SO2 EGU Budgets .............................................................40 

Table 7.1 LADCO’s Round 5 Modeling Results for the Clean Air Interstate Rule (CAIR).........51 

Table 7.2 LADCO’s Round 5 SMAT Modeling Results for the Cincinnati Area (Percent change 

from 2005 observed to 2009 modeled concentration) ...................................................................53 

Table 7.3 ASIP’s Base G4 Annual PM2.5 Modeling Results .........................................................57 

Table 8.1 Emissions Estimations for On-Road Mobile Sources ...................................................60 

Table 8.2 Mobile Vehicle Emissions Budget ................................................................................60 
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CHARTS

Chart 2.1 Fine Particle Design Value Trends ................................................................................13 

Chart 2.2 Fine Particle Design Values for the Cincinnati Nonattainment Area............................13 

Chart 3.1 Annual PM2.5 Values for the Cincinnati Nonattainment Area .......................................29 

Chart 4.1 Historical Design Values for the Cincinnati Nonattainment Area from 2001 - 2006 ...31 

Chart 5.1 Emissions Trends – All Anthropogenic Sources, 2005 and 2009 .................................34 

Chart 5.2 NOx Emissions Trends – All Anthropogenic Sources, 2005 and 2009 .........................35 

Chart 5.3 SO2 Emissions Trends – All Anthropogenic Sources, 2005 and 2009 ..........................35 

Chart 5.4 PM2.5 Emissions Trends – All Anthropogenic Sources, 2005 and 2009 .......................36 

Chart 5.5 NOx Emissions Trends – Dearborn County, 2005 and 2009 .........................................38 

Chart 5.6 SO2 Emissions Trends – Dearborn County, 2005 and 2009..........................................38 

Chart 5.7 PM2.5 Emissions Trends – Dearborn County, 2005 and 2009........................................39 

Chart 5.8 Statewide NOx Emissions Trends from EGUs...............................................................39 

Chart 7.1 Regional/Emission Sector PSAT Results, Murray Rd., Hamilton County, PM2.5

Monitor ......................................................................................................54 

Chart 7.2 Pie Charts of the Modeled Species Contributions to the Murray Rd. – St. Bernard, OH 

PM2.5 Monitor..................................................................................................55 

Chart 7.3 Pie Charts of the Modeled Species Contributions to the Univ. College - Covington, KY 

PM2.5 Monitor ...............................................................................................................................55 

APPENDICES

Appendix A .....................Aerometric Information Retrieval System (AIRS) Monitoring Data 

Appendix A-1..........................................Technical Supplement: 2007 Monitoring Data 

Appendix B..........................................................................Emissions Inventories 

Appendix C..............................................Section 110(a)(1) and (2) SIP Submittal Letter 

Appendix D.........................U.S. EPA Guidance on the Use of Models and Other Analyses 

Appendix E...............................LADCO’s Round 5 Modeling Technical Support Document 

Appendix F...........................LADCO’s Modeling Protocol Addendum: Technical Details 

Appendix G...............................Attainment Test Results for all Cincinnati Area Monitors 

Appendix H..........................................................Example MOBILE Input/Output Files 

Appendix I..................................................................Public Participation Documents 

Appendix J.......ASIP Base G4 Annual PM2.5 Modeling Results for all Cincinnati Area Monitors 

Appendix K.................Modeled Species Contributions at Northern Kentucky PM2.5 Monitor
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1.0 OVERVIEW 

1.1 INTRODUCTION

Particulate matter is one of six criteria air pollutants that scientists have identified as being 

particularly harmful to humans and the environment. National Ambient Air Quality Standards 

(NAAQS) have been developed for these six pollutants and are used as measurements of air 

quality. Fine particles and precursor pollutants are emitted by a wide range of sources, including 

power plants, cars, trucks, industrial sources and other burning or combustion-related activities. 

 

1.2 NATIONAL AMBIENT AIR QUALITY STANDARDS 

The Clean Air Act as amended in 1990 (CAAA) requires areas designated as nonattainment of 

the applicable NAAQS to develop State Implementation Plans (SIPs) to expeditiously attain and 

maintain the standard. In 1997, U.S. EPA set daily and annual air quality standards for fine 

particles (fine particulate matter), as shown in Table 1.1 below. The standards were legally 

challenged and upheld by the U.S. Supreme Court in February of 2001. In 1999, Indiana began 

monitoring for fine particle concentrations. The United States Environmental Protection Agency 

(U.S. EPA) designated areas in Indiana under the standards for fine particles on December 17, 

2004 as attainment, nonattainment or unclassifiable, with an effective date of April 5, 2005. 

Table 1.1 

National Ambient Air Quality Standards for Fine Particles 

Annual 24-Hour 

1997 Fine Particles 

Standards (PM2.5) 

15.0 μg/m3

Annual arithmetic mean, 

averaged over 3 years 

65.0 μg/m3

24-hour average, 98th percentile, 

averaged over 3 years 

2006 Fine Particles 

Standards (PM2.5) 

15.0 μg/m3

Annual arithmetic mean, 

averaged over 3 years 

35.0 μg/m3

24-hour average, 98th percentile, 

averaged over 3 years 

Note: The Cincinnati area meets the 1997 24-hour NAAQS’ for fine particles. Since this area is solely 

designated nonattainment under the 1997 annual standard for fine particles, this document only addresses 

the annual standard. Designations have not been made for the 2006 revised daily standard at this time. 

On December 17, 2004, based on 2001-2003 monitoring data, U.S. EPA designated the 

Cincinnati-Hamilton OH-KY-IN area as nonattainment of the annual standard for fine particles, 

and subject to CAA Part D Title 1, Section 172 of Subpart 1 requirements, including the 

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

emissions and a demonstration that the area will meet the annual standard for fine particles by 

April 5, 2010. 

These designations became effective on April 5, 2005. Also, on April 5, 2005, U.S. EPA issued 

a supplemental notice changing the designation status of several areas based on updated quality 
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assured monitoring data from 2002-2004. This action did not affect the Cincinnati area. 

Monitors for fine particle levels for the Cincinnati area are located in Campbell and Kenton 

counties in Kentucky and Butler, Clermont, and Hamilton counties in Ohio (see Figure 1.1). 

Based on the most recent three years of monitoring data, 2004-2006, the Cincinnati fine particle 

nonattainment area has not measured air quality that meets the standard. A comprehensive detail 

of the monitoring data is included in Appendix A. 

The Cincinnati-Hamilton OH-KY-IN area as defined in Section 1.3, has not previously been 

subject to nonattainment area rulemakings for fine particles. However, the area had been subject 

to nonattainment area rulemakings under the 1-hour and the 8-hour ozone standards. The 1-hour 

ozone standard was revoked on June 15, 2005, but the Cincinnati area remained designated as 

nonattainment under the 8-hour ozone standard. 

Table 1.2 

Cincinnati Area 2001-2003 Air Quality Monitoring Data used for Designation 
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SITE ID COUNTY SITE NAME YEAR 

Annual Average 

μg/m3

2001-2003 Average 

μg/m3

21-037-0003 Campbell Alexandria Pk. 2001 13.44 

21-037-0003 Campbell Alexandria Pk. 2002 14.81 

21-037-0003 Campbell Alexandria Pk. 2003 13.42 

13.89 

21-117-0007 Kenton Univ. College 2001 15.25 

21-117-0007 Kenton Univ. College 2002 15.06 

21-117-0007 Kenton Univ. College 2003 14.30 

14.87 

39-017-0003 Butler Bonita & St. John 2001 16.51 

39-017-0003 Butler Bonita & St. John 2002 16.66 

39-017-0003 Butler Bonita & St. John 2003 14.81 

 

 

15.99 

39-017-0016 Butler Nilles Rd. 2001 15.81 

39-017-0016 Butler Nilles Rd. 2002 15.29 

39-017-0016 Butler Nilles Rd. 2003 15.77 

 

 

15.62 

39-017-0017 Butler Wilwood 2001 15.72 

39-017-0017 Butler Wilwood 2002 15.53 

39-017-0017 Butler Wilwood 2003 14.44 

 

 

15.23 

39-017-1004 Butler Hook Field Airport 2001 No data for 2001 

39-017-1004 Butler Hook Field Airport 2002 13.69 

39-017-1004 Butler Hook Field Airport 2003 14.91 

 

 

14.30

39-061-0014 Hamilton Seymour & Vine St. 2001 18.38 

39-061-0014 Hamilton Seymour & Vine St. 2002 17.91 

39-061-0014 Hamilton Seymour & Vine St. 2003 17.19 

 

 

17.82 

39-061-0040 Hamilton Howard Taft 2001 15.76 

39-061-0040 Hamilton Howard Taft 2002 15.16 

39-061-0040 Hamilton Howard Taft 2003 15.42 

 

 

15.44 

39-061-0041 Hamilton Winneste Ave. 2001 16.01 

39-061-0041 Hamilton Winneste Ave. 2002 15.06 

39-061-0041 Hamilton Winneste Ave. 2003 15.21 

 

 

15.42 

39-061-0042 Hamilton W. 8th St. 2001 17.66 

39-061-0042 Hamilton W. 8th St. 2002 16.74 

39-061-0042 Hamilton W. 8th St. 2003 16.63 

 

 

17.01 

39-061-0043 Hamilton E. Kemper Rd. 2001 15.91 

39-061-0043 Hamilton E. Kemper Rd. 2002 15.41 

39-061-0043 Hamilton E. Kemper Rd. 2003 15.60 

 

 

15.64 

39-061-7001 Hamilton Sherman Ave. 2001 16.75 

39-061-7001 Hamilton Sherman Ave. 2002 16.03 

39-061-7001 Hamilton Sherman Ave. 2003 16.01 

 

 

16.26 

39-0061-8001 Hamilton Murray Rd. 2001 16.86 

39-0061-8001 Hamilton Murray Rd. 2002 16.92 

39-0061-8001 Hamilton Murray Rd. 2003 17.26 

 

 

17.01 

Value above the standard Less than three years of data 

Section 172 of the CAA stipulates the requirements that nonattainment areas must meet, 

including the development of a plan to reduce direct and precursor emissions of the applicable 
 4 

 

 

NAAQS. The plan must include a demonstration that the area will meet the ambient air quality 

standard within five (5) years of designation, or April 5, 2010. 

In accordance with U.S. EPA’s Clean Air Fine Particle Implementation Rule1, this document 

demonstrates that, with the combination of current clean air measures and the implementation of 

local and federally-required control measures, air quality in the Cincinnati nonattainment area 

will meet the annual fine particle standard by the attainment date. This document contains the 

annual fine particle standard attainment demonstration for the Cincinnati-Hamilton OH-KY-IN 

fine particle nonattainment area. 

 

1.3 GEOGRAPHICAL DESCRIPTION

The entire Cincinnati-Hamilton OH-KY-IN fine particle nonattainment area consists of 

Lawrenceburg Township in Dearborn County, Indiana; Butler, Clermont, Hamilton, and Warren 

counties, Ohio; and Boone, Campbell and Kenton counties, Kentucky and contains such cities as 

Cincinnati, Hamilton, and Middletown, all in Ohio. This area is depicted in Figure 1.1. 

Fine particle monitors are located in Campbell and Kenton counties in Kentucky and Butler, 

Clermont, and Hamilton counties in Ohio. There are no monitors for fine particles in the Indiana 

portion of the Cincinnati nonattainment area. The highest levels of fine particle concentrations 

have been typically monitored at the Murray Rd. monitor (39-0061-8001) in Hamilton County, 

Ohio. Refer to Figure 1.1 for the location of the monitors in the nonattainment area. 

Designations were made based upon monitored air quality data measured during 2001, 2002 and 

2003. Table 1.2 shows the monitored design values for 2001-2003. Two monitors, 400 

Clermont Dr. in Clermont County, Ohio and Grooms Rd. in Hamilton County, Ohio, did not 

have sufficient monitoring data to calculate design values for the 2001-2003 period, and 

therefore, are not included in Table 1.2. 

U.S. EPA designated areas under the fine particle standards as attainment, nonattainment or 

unclassifiable, on December 17, 2004, with an effective date of April 5, 2005. The Cincinnati 

fine particle nonattainment area was designated nonattainment of the annual fine particle 

standard pursuant to the CAA. As a result, Section 172(c) of the CAA set forth requirements for 

Indiana’s State Implementation Plan (SIP) submittal. 

Figure 1.1 

Cincinnati Fine Particle Area Designations and Monitor Locations 

 

1 http://www.epa.gov/fedrgstr/EPA-AIR/2007/April/Day-25/a6347.htm
 

The agencies responsible for assuring the fine particle nonattainment area complies with the 

CAA requirements are: 

< The Ohio Environmental Protection Agency (Ohio EPA), which is responsible for 

Butler, Clermont, Clinton, Hamilton and Warren counties, Ohio; 

< The Kentucky Department for Environmental Protection, (KDEP) which is 

responsible for Boone, Campbell and Kenton counties, Kentucky; and, 

< The Indiana Department of Environmental Management (IDEM), which is 

responsible for Lawrenceburg Township, Dearborn County, Indiana. 

These three (3) state agencies have worked cooperatively with U.S. EPA Regions IV and V to 

address attainment planning issues. 

Although the three (3) agencies, in the three (3) states, have worked together on a comprehensive 

plan for the multi-state nonattainment areas, each state is required to make a separate submittal 

for its portion of the planning components to U.S. EPA. Attainment demonstrations are SIP 

submittals and U.S. EPA action on them is taken separately. As such, this submittal covers 

Lawrenceburg Township in Dearborn County, Indiana. 

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1.4 CONTROL STRATEGY 

Several control measures already in place or being implemented over the next few years will 

reduce stationary point, on-road mobile, and non-road mobile source emissions. The expected 

federal and state control measures were modeled for the attainment year of 2009. 

The federal control measures that were modeled included the Tier 2 vehicle standards, the 

heavy-duty gasoline and diesel highway vehicle standards, low sulfur gasoline and diesel fuels, 

large non-road diesel engines standard and the non-road spark-ignition engines and recreational 

engines standard. 

The state control measures that were modeled include the NOx SIP Call and the Clean Air 

Interstate Rule (CAIR). The control measures included in the modeling are described in greater 

detail in Section 6.0. 

1.5 ATTAINMENT TEST

U.S. EPA guidance requires that attainment demonstrations for fine particles be supported by 

photochemical grid modeling. A computer model is used to predict maximum fine particle 

concentrations in every grid cell (or point of analysis) within the nonattainment area. 

The attainment test is not based on absolute modeling results, but rather Relative Responses 

achieved by comparing the modeled base year to the modeled control strategy, at specific 

monitoring sites. The benchmark for attainment is that the results of applying the relative 

response factors to the current monitored design values are below the annual fine particle 

standard. The latest regional modeling conducted by the Lake Michigan Air Director’s 

Consortium (LADCO) shows all future year concentrations below the annual fine particle 

NAAQS of 15.0 μg/m3. 

The results of the various steps used to calculate the predicted future year concentrations for 

each monitor located in the Cincinnati fine particle nonattainment area are shown in Table 1.3. 

The first three columns are the monitor identification number, monitor name and county in 

which the monitor is located. The next two columns are the modeling base year design value 

and the future year design value. As shown in Table 1.3, all of the monitors in the area are 

expected to be below the standard. According to U.S. EPA guidance, areas with future year 

design values between 14.5 μg/m3 and 15.5 μg/m3 need to provide a more comprehensive weight 

of evidence analyses to demonstrate that the area will attain the fine particle NAAQS. Areas 

with future year design values lower than 14.5 μg/m3 at each monitor site only need to provide a 

basic supplemental analysis that the area will attain the annual fine particle standard. 
 7 

 

 

Table 1.3 

Attainment Test Results for Cincinnati-Hamilton OH-KY-IN 

Monitor ID Monitor Name County 

Design Value 

2003-2006 

(μg/m3) 

Design Value 

2003-2007 

(μg/m3) 

Future Year 

2009 

(μg/m3) 

390170003 Bonita & St John Butler 16.1 15.80 13.3 

390170016 Nilles Rd. Butler 15.8 15.66 13.0 

390170017 Wilwood Butler 16.1 15.53 a 13.6 

390171004 Hook Field Airport Butler 14.9 14.86 12.4 

390250022 400 Clermont Dr. Clermont 14.7 14.62 11.8 

390610006 Grooms Rd. Hamilton 15.5 15.43 12.7 

390610014 Seymour & Vine St. Hamilton 17.4 17.27 14.4 

390610040 Howard Taft Hamilton 15.5 15.41 12.7 

390610041 Winneste Ave. Hamilton 15.4 14.57 b 13.0 

390610042 101 W. 8th St. Hamilton 17.0 16.83 13.9 

390610043 254 Kemper Rd. Hamilton 15.6 15.40 12.9 

390617001 Sherman Ave. Hamilton 16.3 16.11 13.3 

390618001 Murray Rd. Hamilton 17.7 17.44 14.6 

210370003 Alexandria Pk. Campbell 13.3 13.75 a 11.6 

211170007 Univ. College Kenton 14.4 14.29 11.8 a Monitors were not operational after 2005. 

 b Monitors were not operational after 2004.

Since the area’s future year design value is predicted to be below the fine particle standard, at 

14.6 μg/m3 at the Murray Rd. fine particle monitor, a weight of evidence analysis is necessary 

for Lawrenceburg Township. The analysis further demonstrates that the nonattainment area will 

comply with the annual fine particle standard by the prescribed attainment date of April 5, 2010. 

 This demonstration includes an analysis of air quality trends, emissions trends, and a current air 

quality data summary of emissions reductions still to occur in 2008 and 2009, along with 

additional measures that were not included in the air quality modeling. IDEM believes that the 

modeled attainment demonstration in conjunction with the weight of evidence analysis and an 

identified set of control measures provides the necessary evidence that the Cincinnati-Hamilton 

OH-KY-IN nonattainment area will attain the fine particle standard by April 5, 2010. 

The structure and content of this document addresses each of the elements required by the CAA 

and U.S. EPA guidance. Compliance with these elements provides the technical analysis 

necessary to support a demonstration of the following: 

 the Cincinnati area will attain the annual fine particle standard by the attainment date; 

 air quality in the area is improving; 

 emissions reductions from national and regional control measures included in the 

attainment plan will bring the area into attainment as expeditiously as possible; 

 regional modeling performed by LADCO demonstrates that with regional NOx and 
 8 

 

 

SO2 reductions, the area will be able to comply with the annual fine particle standard 

without additional control measures; and, 

 the additional implementation of control measures not included in the modeling 

analysis will provide further assurance that the standard is attained and maintained. 

2.0 CLEAN AIR ACT REQUIREMENTS

Section 172(c) of the CAA specifies the various planning requirements that apply to fine 

particulate matter nonattainment areas. Also, because the fine particle nonattainment area 

includes counties within the State of Kentucky, Section 182(j) of the CAA adds additional plan 

provisions. The CAA specifies the following requirements: 

1. General requirements for Reasonably Available Control Measures 

(RACM)/Reasonably Available Control Technology (RACT), 

2. Reasonable Further Progress (RFP), 

3. Emissions inventories, 

4. Identification and quantification of emissions, 

5. Permit program for new and modified sources, 

6. Other control measures, means or techniques 

7. Compliance with Section 110(a)(2), 

8. Equivalent techniques, 

9. Contingency measures, 

10. Demonstration of attainment based upon photochemical grid modeling or 

equivalent analytical method, and 

11. Mobile source emissions budget. 

These components were due by April 5, 2008. The following section provides an overview of 

Indiana’s progress in meeting the CAA requirements mentioned above. 

2.1 GENERAL REQUIREMENTS (SECTION 172(C)(1))

2.1.1 Reasonably Available Control Measures (RACM) 

The CAA requires a demonstration that the State has adopted all reasonable and available control 

measures to demonstrate attainment as expeditiously as practicable and that no additional 

measures that are reasonably available will advance the attainment date. Although regional 

photochemical modeling indicates that no additional control measures are necessary to achieve 

the annual fine particle standard by the attainment date, IDEM participates in the regional 

planning effort through LADCO to evaluate potential control measures to attain the 8-hour 

ozone and fine particle standards and achieve regional haze goals. 

Candidate control measures were evaluated primarily for feasibility, cost effectiveness, and the 

ability to implement them in a relatively short time frame (i.e., January 1, 2009, for the 2009 

monitoring year). Due mainly to the lengthy rulemaking process in Indiana, many of the control 

strategies evaluated could not be implemented by the 2009 monitoring year and were not 
 9 

 

 

pursued since they were not needed to demonstrate attainment in an expeditious fashion. 

2.1.2 Reasonably Available Control Technology (RACT) 

U.S. EPA’s Clean Air Fine Particle Implementation Rule makes a determination that areas 

classified under Subpart 1 will meet the CAA’s RACT requirement by submitting a 

demonstration that shows attainment as expeditiously as practicable, but no later than 5 years 

after designation. This document will show that this requirement will be met with the 

implementation of mandatory federal control measures and regional measures implemented in 

Ohio, Kentucky and Indiana. This document also shows that the projected annual fine particle 

design value will provide an ample margin of safety, well below U.S. EPA’s defined threshold 

for a detailed RACT analysis to be completed in conjunction with this submittal. 

2.2 REASONABLE FURTHER PROGRESS (SECTION 172 (C)(2))

Based on U.S. EPA’s Fine Particle Implementation rule, Reasonable Further Progress (RFP) is 

met by ensuring emissions reductions needed for attainment are implemented by the beginning 

of the monitoring season preceding the attainment date (i.e., by January 1, 2009). As confirmed 

by regional photochemical modeling, no additional local controls are necessary to attain the air 

quality standard by the attainment date. 

2.3 EMISSIONS INVENTORIES (SECTION 172 (C)(3))

U.S. EPA guidance requires the submittal of a comprehensive emissions inventory of direct fine 

particle and fine particle precursor emissions [oxides of nitrogen (NOx) and sulfur dioxide (SO2)] 

representative of the base year (2005). IDEM has also prepared comprehensive emissions 

inventory projections for the attainment year (2009). Consistent with the federal implementation 

rule for fine particles, Indiana does not consider volatile organic compounds or ammonia to be 

significant contributors to fine particles. IDEM meets this requirement through the submittal of 

the statewide emissions inventory under the Consolidated Emission Reporting Rule (CERR) for 

the State of Indiana. 

IDEM submitted a statewide 2005 emissions inventory for stationary and area sources to U.S. 

EPA in June 2007. The 2005 emissions inventory, for Dearborn County in Indiana is included as 

Appendix B. The emissions inventory used in this attainment demonstration is also subject to 

public comment along with the full attainment demonstration. 

It should be noted that Lawrenceburg Township is a small portion of Dearborn County, Indiana 

and only accounts for a portion of the county’s stationary and area source categories in the 

emissions inventory. However, the largest stationary point source within Dearborn County, 

Indiana, an electric generating facility, is located in Lawrenceburg Township. To be 

conservative in demonstrating attainment, the emissions inventory included in this document and

Appendix B consists of the entire county. 

2.4 IDENTIFICATION AND QUANTIFICATION OF EMISSIONS (SECTION 172 (C)(4))
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Section 172(c)(4) requires the SIP to identify and quantify the emissions of pollutants (in this 

case, particulate matter, NOx and SO2) that sources will be allowed from the construction and 

operation of major new and modified sources in accordance with Section 173(a)(1)(B), and will 

not interfere with attainment of the annual fine particle standard by the attainment date. 

Indiana’s permitting rules which meet this requirement are outlined in rule 326 IAC 2-3. 

2.5 PERMIT PROGRAM FOR NEW AND MODIFIED MAJOR SOURCES (SECTION 

172 (C)(5))

Section 172 (c)(5) requires the State to implement a permit program consistent with the 

requirements of Section 173. Indiana has a long standing and fully-implemented New Source 

Review (NSR) permitting program that is outlined in rule 326 IAC 2-3. Indiana’s NSR program 

was approved by U.S. EPA on Oct. 7, 1994 (94 FR 24838), as part of the SIP. 

Any facility that is not listed in the 2005 emissions 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 permit rule requirements, including an air quality 

analysis to evaluate whether the new source will threaten the NAAQS. 

2.6 OTHER CONTROL MEASURES, MEANS OR TECHNIQUES (SECTION 172 (C)(6))

Modeling conducted by LADCO to predict future year fine particle design values show that 

existing emission control measures will bring the Cincinnati area into attainment of the annual 

fine particle NAAQS and provide for an ample margin of safety. Federal and local control 

measures to be phased-in or implemented in the next several years will provide even greater 

assurance that air quality will continue to meet the standard into the future. 

In addition, LADCO modeling conducted to determine the impact of the Clean Air Interstate 

Rule in the region, shows that future year design values for the Cincinnati-Hamilton OH-KY-IN 

fine particle nonattainment area will attain the annual fine particle standard with values below 

15.0 μg/m3

. 

Existing and future national and regional control measures will ensure that attainment in each 

county will be maintained with an increasing margin of safety over time. These measures are 

discussed in greater detail in the Control Strategy Section (Section 6.0). 

Therefore, no additional control measures are being implemented and modeled to demonstrate 

attainment. However, additional control measures are being implemented to provide assurance 

of the area maintaining air quality below the standard. 

2.7 COMPLIANCE WITH SECTION 110(A)(2) (SECTION 172 (C)(7))
 11 

 

 

Section 172(c)(7) requires nonattainment SIPs to meet the applicable provisions of Section 

110(a)(2). IDEM has reviewed the requirements of Section 110(a)(2) and has concluded that 

prior rule submittals, along with this attainment demonstration, address the relevant requirements 

associated with rule development, state implementation plan submissions, and implementation 

and enforcement of required control measures. Within a letter to U.S. EPA dated December 7, 

2007, Indiana reaffirmed that it maintains the necessary infrastructure and resources to comply 

with Sections 110(a)(1) and (2) for all criteria pollutants (Appendix C). 

2.8 EQUIVALENT TECHNIQUES (SECTION 172(C)(8))

IDEM has followed U.S. EPA guidance on procedures for modeling, preparing emissions 

inventories and plan submittals. Therefore, IDEM is not requesting approval for equivalent 

techniques, as allowed under Section 172(c)(8). 

2.9 CONTINGENCY MEASURES (SECTION 172 (C)(9))

Section 172 (c)(9) of the CAA requires states with nonattainment areas to include contingency 

measures as part of attainment demonstrations. Contingency measures are specific measures to 

be undertaken in the event that the area fails to attain the standard by the applicable attainment 

date. The selected contingency measures are discussed in greater detail in Section 9.0 of this 

document. 

2.10 ATTAINMENT DEMONSTRATION 

U.S. EPA’s Fine Particle Implementation Rule requires the submittal of an attainment 

demonstration SIP that includes local, regional and/or national modeling analyses that meet the 

attainment modeling criteria set forth in U.S. EPA’s modeling guidance. Through LADCO, 

photochemical modeling was conducted using the Comprehensive Air Quality Model with 

Extensions (CAMx) for this modeled attainment demonstration. This modeling is being 

supplemented with regional modeling performed by LADCO in developing the Clean Air 

Interstate Rule (CAIR) and rulemaking to support national control measures. 

U.S. EPA modeling guidance for the annual fine particle standard stipulates that the following 

elements be included in an approvable attainment demonstration submittal: 

3⁄4 photochemical grid modeling analysis; 

3⁄4 air quality trends analysis; 

3⁄4 emissions trends analysis; 

3⁄4 identification of control measures factored into the modeling analysis as well as those not 

factored into the modeling analysis; and, 

3⁄4 identification of mobile source emissions budgets (SO2, NOx and direct PM2.5) for 

transportation conformity purposes. 

Each element of this attainment demonstration is described briefly below and in more detail in 
 12 

 

 

 

the Technical Elements of Demonstration (Sections 3.0 – 7.0) and Mobile Source Emissions 

Budgets (Section 8.0). 

2.10.1 Photochemical Grid Modeling Analysis 

A more detailed discussion of the photochemical grid modeling, model selection, methodologies, 

attainment test, model inputs, modeling protocol and analysis method is included in the 

Photochemical Modeling Analysis Section of the Technical Elements of Demonstration (Section 

3.1). 

2.10.2 Air Quality Trends Analysis 

Implementation of national control strategies has resulted in improvement in air quality within 

the Cincinnati annual fine particle nonattainment area. Data show emissions are decreasing, air 

quality peak values are on the decline, and the number of exceedances are also decreasing. 

The technical data (Sections 3.0-7.0) show a continual decline in the fine particle concentration 

levels since 2001. 

Chart 2.1 shows the decline in the controlling fine particle design value2 for the Cincinnati fine 

particle nonattainment area. During the 2001-2003 time period, the Seymour & Vine Street 

ambient monitor represented the area’s controlling annual fine particle design value. As shown 

in this table, the area’s design value has decreased from 17.82 μg/m3 to 17.33 μg/m3, a decline of 

0.49 μg/m3 since being designated as nonattainment. The current design value for 2004-2006 is 

shown in Chart 2.2. Modeling predicts that this value will decline by an additional 2.73 μg/m3 

by 2009. The controlling annual fine particle monitor for the latest 3-year design value (2004-

2006) is the Murray Road ambient monitor with a design value of 17.3 μg/m3

. Modeling 

predicts that this value will decline by an additional 3.1 μg/m3 by 2009, demonstrating 

attainment of the standard prior to the April 5, 2010 attainment date. 

Chart 2.1 

Fine Particle Design Value Trends 

2

The design value for a nonattainment area, which characterizes the severity of the area’s air quality problem, is represented by the highest 

design value at any individual fine particle monitoring site. The design value of a monitoring site is the average of the fine particle value over a three-year 

period. If a monitor is less than or equal to 15.0 μg/m3 it is considered attainment. A monitor that measures 15.05 μg/m3 or higher is considered 

nonattainment. (Decimals 0.049 or lower are rounded down, decimals 0.050 are rounded up). Three year design values are reported with only 1 decimal 

point. Values close to 15.0 may be shown with two decimal points for clarification.
12.00

13.00

14.00

15.00

16.00

17.00

18.00

Alexandria Pk.

Univ. College

Bonita & St. John

Nilles Rd.

Wilwood

Hook Field Airport

Clermont Dr.

Grooms Rd.

Seymour & Vine St.

Howard Taft

Winneste Ave.

W. 8th St.

E. Kemper Rd.

Sherman Ave.

Murray Rd.

ug/m3

2001-2003 2004-2006 Standard

Chart 2.2 

Fine Particle Design Values for the Cincinnati Nonattainment Area 

12.00

13.00

14.00

15.00

16.00

17.00

18.00

Alexandria Pk.

Univ. College

Bonita & St. John

Nilles Rd.

Wilwood

Hook Field Airport

Clermont Dr.

Grooms Rd.

Seymour & Vine St.

Howard Taft

Winneste Ave.

W. 8th St.

E. Kemper Rd.

Sherman Ave.

Murray Rd.

ug/m3

2004-2006 Standard

A more complete picture of the air quality improvement in the Cincinnati fine particle 

nonattainment area is shown in Chart 4.1 and Figure 4.3, included in Section 4.0 of this 

 13 

 

 
 14 

 

 

document. 

2.10.3 Emissions Trends Analysis 

Control measures have been implemented requiring substantial emissions reductions from 

mobile, industrial, and area sources. A detailed discussion of emissions trends is included in the 

Emissions Trends Analysis section of this document (Section 5.0). 

2.11 CONTROL STRATEGY 

Several control measures already in place or being implemented over the next few years will 

reduce point, on-road mobile and non-road mobile source emissions. The Federal and State 

control measures which were included in the photochemical modeling for the future year design 

value and additional control measures due to be implemented, but not included in the modeling, 

are discussed in greater detail in the Control Strategy section of this document (Section 6.0). 

2.12 MOBILE SOURCE EMISSIONS BUDGET

U.S. EPA requirements outlined in 40 CFR 93.118(e)(4) stipulate that a mobile source emissions 

budget be established as part of the attainment demonstration. The mobile source emissions 

budget is necessary to demonstrate conformity of transportation plans with the state 

implementation plan. 

The purpose of transportation conformity is to ensure that Federal transportation actions 

occurring in the nonattainment area do not hinder the area from attaining and maintaining the 

annual fine particle standard. This means that the level of emissions estimated by the 

metropolitan planning organization for the Transportation Implementation Plan and the Long 

Range Transportation Plan must not exceed the motor vehicle emissions budget as defined in this 

attainment demonstration. 

In general, while the total vehicle miles traveled (VMT) has increased throughout the region, 

mobile source emissions levels have decreased significantly since 1999. This decline in 

emissions is a result of federal motor vehicle control requirements and cleaner motor fuels. 

The mobile source emissions budget is included in Section 8.0 of this document. 
 15 

 

 

3.0 TECHNICAL ELEMENTS OF DEMONSTRATION

This section presents details of the technical work done to analyze air quality data to demonstrate 

attainment of the annual fine particle standard. The results of the computer modeling and an 

analysis of air quality and emissions inventory trends presents strong evidence that pending 

control measures will improve air quality, thereby assuring air quality levels below the annual 

fine particle NAAQS by April 5, 2010. 

3.1 PHOTOCHEMICAL MODELING ANALYSIS

Indiana is required to submit modeling as part of its attainment demonstration. U.S. EPA’s 

implementation guidance allows states to submit regional or national modeling as the sole 

(primary) modeling analysis. This modeling demonstration relies upon regional modeling as the 

primary modeling analysis and Indiana will include national modeling, conducted by U.S. EPA 

as a weight of evidence analysis. 

The primary attainment modeling analysis for the Cincinnati nonattainment area was performed 

in conjunction with the fine particle and regional haze modeling conducted by LADCO. LADCO 

is comprised of five Midwest states: Illinois, Indiana, Michigan, Ohio and Wisconsin. LADCO 

provides expertise in review of monitoring data, development of emissions inventories and 

meteorological files and application of photochemical modeling and evaluation of model 

performance and modeled results. LADCO prepared the “Regional Air Quality Analyses for 

Ozone, PM2.5, and Regional Haze: Technical Support Document” (LADCO, 2008), a detailed 

technical support document describing the methodology for the fine particle attainment 

demonstration modeling analysis for all the states supported by LADCO. This document can be 

found in Appendix E. 

Extensive regional modeling has been performed covering the Cincinnati fine particle 

nonattainment area to determine the effect of national, regional and local emission control 

strategies on fine particle levels. These modeling analyses determined that the Cincinnati area is 

impacted by regional transport of fine particles and its precursors; SO2, NOx, organic carbon 

(OC) and ammonium (NH4) associated with sulfates and nitrates. National emissions reductions, 

including those associated with CAIR are an effective way to demonstrate attainment of the 

annual fine particle standard in this area. Future year modeled annual fine particle 

concentrations in the Cincinnati area are expected to be reduced from baseline design values by 

13% to 20% in 2009 and reduced by 17% to 24% by 2018 leading to the attainment of the annual 

fine particle NAAQS of 15 μg/m3. 

The following paragraphs briefly describe the methods, inputs used and major components of 

this analysis. The attainment demonstration and modeling procedures followed were 

recommended by U.S. EPA’s “Guidance on the Use of Models and Other Analyses for 

Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze” (EPA454/B-07-002, April 2007), Appendix D. 
 16 

 

 

3.1.1 Modeling Methodology 

The modeling analysis is a complex technical evaluation that begins with selection of the 

modeling system. LADCO used the following modeling system: 

• Air Quality Model: Comprehensive Air Quality Model with Extensions 

(CAMx version 4.50). 

• Meteorological Model: Mesoscale Model (MM5) version 3.7. 

• Emissions Models: Emissions Modeling System (EMS-2003) and, 

Consolidated Community Emissions Processing Tool (CONCEPT). 

Model Selection

Title 40, Code of Federal Regulations, Part 51, Appendix W, does not offer specific 

recommendations for photochemical models to be used for attainment demonstrations. 

However, the models selected must be scientifically appropriate for the intended application and 

be freely available for review and available to stakeholders and their consultants for execution 

and verification at low or no cost. All of the models selected for use in this analysis meet these 

criteria and have been peer reviewed. Past performance has shown that the models are not 

biased toward under or overestimates. 

The air quality model selected for this technical analysis was CAMx (version 4.50), an Eulerian 

photochemical grid model developed by ENVIRON and approved by U.S. EPA for this use. 

CAMx allows for integrated “one-atmosphere” assessment of ozone and PM2.5. Notable features 

of CAMx include flexi-nesting, which allows for reconfiguration of nested grids within the 

model, multiple gas phase chemistry mechanism options and Particulate Source Apportionment 

Technology. CAMx modeling is performed on a Linux computing platform with a Portland 

Group (PGI) Fortran compiler to create executable files. 

3.1.2 Modeling Preparation and Objectives 

The modeling analysis included (1) preparation of a protocol, (2) preparation of emissions 

inventories, (3) preparation of meteorological inputs, (4) application of the model and diagnostic 

analysis of inputs, (5) evaluation of performance, (6) evaluation of reduction scenarios, and, (7) 

analysis of modeling results. The specific objectives of the analysis were to: 

 * apply the model to 2005 meteorological and emissions data and evaluate CAMx 

model performance, 

 * prepare future-year (2009) emissions inventory to evaluate future federal, regional 

and local emissions control strategies for the attainment of the annual fine particle 

standard, and, 

 * run the model for the future year to evaluate the combined effects of growth and 

emissions reductions resulting from national, regional and local measures. 
 17 

 

 

3.1.3 Meteorology Selection 

Domain and grid resolution for the modeling analyses included a national Regional Planning 

Organization grid at 36 kilometers for both the meteorological and emissions modeling. 

Landuse files were based on the Biogenic Emissions Landuse Database, version 3 (BELD3) 1 

kilometer data and photolysis rates were calculated with the Tropospheric Ultraviolet-Visible 

(TUV) radiation model. 

 

 3.1.4 Modeling Domain 

The domain for this modeling analysis was approximately centered on the Midwest portion of 

the country, including the Cincinnati fine particle nonattainment area. The meteorological 

modeling domain consists of a grid of 36 kilometer cells that extends over the entire continental 

United States. The photochemical modeling grid consists of a grid of 36 kilometer cells that 

extends over the LADCO five-state region and adjacent states. Selection of the domain was 

based upon distribution of emissions sources, locations of meteorological and air quality 

monitoring sites, and typical meteorological conditions in the area. Figure 3.1 shows the 

meteorological and emissions modeling domain. 
Figure 3.1 

LADCO Modeling Domain 

Meteorological inputs were processed using the National Center for Atmospheric Research 

(NCAR) 5th generation Mesoscale Model (MM5) version 3.7. A more detailed explanation of 

the inputs for the MM5 model are listed on page 48 of the “Regional Air Quality Analyses for 

Ozone, PM2.5, and Regional Haze Technical Support Document”, included in Appendix E. 

The modeling analysis involves several steps. Below is a brief overview of the steps involved. 

A more detailed explanation of the modeling analysis and methodology can be found in 

Appendix F of this document. 

Modeled Attainment Demonstration for Annual PM2.5

1) Calculating site-specific baseline concentrations. 

Annual arithmetic mean is calculated by averaging the four quarterly arithmetic mean 

concentrations observed during a calendar year. 

2) Identifying grid cells near monitoring site. 

U.S. EPA recommends using the single modeled value in or near the grid cell which 

contains the monitor. 

3) Choosing model predictions to calculate a relative response factor (RRF) near a monitor. 

a. For an annual PM2.5 prediction, U.S. EPA recommends taking the spatially 

 18 

 

 
 19 

 

 

 

averaged values of the nearby predictions (mean value of the grid cell array). 

b. The component-specific RRFs are computed by taking the ratio of the mean of the 

spatially averaged daily predictions. 

4) Estimating design values at unmonitored locations. 

a. Interpolate ambient data by creating a set of quarterly average spatial fields. 

b. The four (4) quarters can then be averaged to get an annual average set of fields. 

5) Choosing a base year emissions inventory to be projected for calculating RRFs. 

U.S. EPA recommends using emissions which correspond to the monitored period 

reflected by chosen baseline design value period. 

6) Choosing year to project future emissions. 

Emissions should be projected to the attainment year, based on an area’s air quality 

classification. 

3.1.5 Selection of Base Year 

There were two (2) base years selected in the LADCO modeling analyses: 20023 and 2005. 

2002 was run initially and as more recent emissions and meteorological data became available 

prior to the submittal of the attainment demonstration, 2005 was evaluated. The emissions for 

2005 take into account national emissions control strategies as opposed to 2002 which did not 

include national emissions control strategies such as the NOx SIP Call. 2005 had meteorological 

conditions considered to be conducive for fine particle development. LADCO performed several 

analyses on the meteorological data and trend analyses on fine particles and its pre-cursors. 

Results showed comparable meteorology for 2002 and 2005 and Theil trend analysis showed 

consistent improvement of fine particle concentrations throughout the Midwest since 1999 with 

annual decreases from 0.2 μg/m3 to 0.5 μg/m3 in the Cincinnati fine particle nonattainment area. 

3.1.6 Selection of Future Years 

The future year of interest for the Cincinnati area, due to its annual PM2.5 nonattainment status, 

was 2010 (five (5) years from the effective date of designation under the annual standard). This 

year represents the attainment date. Therefore, 2009 is the future year of interest in order to 

show emissions reductions preceding the attainment year to demonstrate attainment in the area. 

2012 and 2018 future years were also modeled in order to demonstrate continued attainment of 

the fine particle NAAQS. 

3.1.7 Emissions Inputs 

EMS and CONCEPT are two of the key emissions modeling tools used to determine emissions 

estimates for LADCO’s Round 5 photochemical modeling. 

 

- On-road source emissions were developed from CONCEPT using vehicle miles traveled 

3 US EPA guidance recommended using 2002 as the baseyear for modeling analyses, but allows states to use 2005. 

LADCO began the modeling exercise using 2002 as the baseyear, but as more recent emissions and meteorological 

data became available prior to the modeling being completed, a decision was made to switch to 2005 as the baseyear. 

This decision was discussed with U.S. EPA staff. 
 20 

 

 

(VMT) and vehicle speeds supplied by state and local planning agencies for 24 networks. 

The CONCEPT model was run for winter (January 15-17) and summer (July 16-18) 

emissions profile days representing a weekday, Saturday and Sunday. 

- Non-road sources were developed from the National Mobile Inventory Model 

(NMIM2005). Marine, aircraft and railroad emissions were prepared by ENVIRON and 

handled separately from non-road sources. 

- Area source emissions were developed with EMS for weekday, Saturday and Sunday 

emissions for each month of the modeled period. 

- Point source emissions were developed from state inventories and continuous emissions 

monitoring (CEM) data from electrical generating units. EMS calculated the point 

source emissions for weekday, Saturday and Sunday emissions for each month of the 

modeled period. 

- Biogenic emissions were supplied by Alpine using an updated CONCEPT/Model of 

Emissions of Gases and Aerosols from Nature (MEGAN) biogenic emissions model. 

- Ammonium emissions were developed from a Carnegie Mellon University-based 2002 

ammonia emissions model which were grown out to 2005 and adjusted by temporal 

monthly factors. 

- Canadian emissions were taken from the 2005 Canadian National Pollutant Release 

Inventory, Version 1.0 (NPRI). 

Future year emissions were grown from the basecase 2005 emissions and estimates were 

developed from the emissions models; EMS/CONCEPT and NMIM for on-road and non-road 

emissions sources. Future year emissions for EGUs were developed from Integrated Planning 

Model version 3.0 (IPM3.0) with several CAIR emissions control scenarios factored in. Growth 

and control factors were applied to area, marine/aircraft/ railroad and non-EGU point source 

emissions as well as emission changes due to applied local consent decrees, RACT and Best 

Achievable Retrofit Technology (BART). 

3.1.8 Model Performance 

Model performance was evaluated according to U.S. EPA statistical guideline recommendations, 

in order for the modeled concentrations to replicate observed concentrations. PM2.5 model 

performance was evaluated by LADCO through a variety of methods. Time series plots of 

monthly average mean bias and annual fractional bias were used and are shown in Figure 3.2. 

Figure 3.2 
Model Performance Metrics for Annual PM2.5 Modeling 

Model performance was relatively good for nitrates, elemental carbon, ammonium and soil with 

under prediction of organic carbon and over prediction of sulfates, although the sulfate 

performance would be considered acceptable with bias values within 35 percent. The day-today, as well as, the hour-to-hour variations from observed data and modeled data are consistent. 

There is acceptable modeled performance in the overall fine particle mass concentrations with 

some variability in the modeled performance of several of the species compositions of the fine 

particles. 

3.2 MODELED ATTAINMENT TEST

The modeled attainment demonstration consists of analyses that estimate whether existing and 

future emissions reductions along with appropriate growth factors for future emissions will result 

in future ambient concentrations that will meet the NAAQS. The attainment demonstration also 

identifies a set of emissions control measures that will ensure that an area will continue to attain 

the NAAQS into the future. In order to make this determination, a modeled attainment test is 

required. 

 21 

 

 
 22 

 

 

The annual PM2.5 attainment test, as described in U.S. EPA guidance, recommends a modeled 

attainment test in which the results are used in a “relative” rather than “absolute” sense. This 

approach takes the ratio of the photochemical modeling results and future to baseline predictions 

at specific monitoring sites. This ratio is known as a relative response factor (RRF). Once a 

RRF has been determined, the RRF is applied to the current design value of a pollutant or in the 

case of PM2.5, the different components which make up fine particles. The major components 

that make up fine particles are as follows: 

 - mass associated with sulfates (SO4); 

 - mass associated with nitrates (NO3); 

 - mass associated with ammonium (NH4); 

 - mass associated with organic carbon (OC); 

 - mass associated with elemental carbon (EC); 

 - mass associated with particle bound water (pbw); 

 - mass associated with “other” primary inorganic particulate matter (soil); and, 

 - passively collected mass. 

The steps involved in the annual PM2.5 modeled attainment test, otherwise known as the 

Speciated Modeled Attainment Test (SMAT) are listed below. The specific inputs and results of 

the SMAT for the Cincinnati area are listed in Section 3.3 of this document. 

Step 1: Compute the observed quarterly mean PM2.5 and quarterly mean composition of each 

monitor. 

- This is accomplished by multiplying the monitored quarterly mean concentration 

of Federal Reference Method (FRM) derived PM2.5 by the monitored fractional 

composition of PM2.5 species for each quarter. 

- In the event that monitored speciated data is not available, LADCO used 

chemically speciated IMPROVE and STN PM2.5 data to develop seasonal spatial 

fields for each PM2.5 species. SAS software package PROC KRIG function 

(EPA, 2004b) was used to develop these spatial fields. 

Step 2: Using model results, derive component-specific RRFs at each monitor for each quarter 

for each of the components for PM2.5. 

- Air quality modeling is applied to estimate current and future year concentrations 

for each component of PM2.5. 

- Relative response factors are derived by taking the ratio of future year 

concentrations over the baseline modeled concentrations at the monitoring site. 

Step 3: Apply the component-specific relative response factors to the observed air quality to 

obtain quarterly species estimates. 

 

- The current quarterly mean component concentration from Step 1 is multiplied by 

the component-specific RRF derived in Step 2, which gives an estimated future 

quarterly mean concentration for each component. 
 23 

 

 

Step 4: Calculate a future year annual average PM2.5 estimate. 

 - The quarterly mean components (estimated in Step 3) are summed together for a 

quarterly mean PM2.5 value. 

 - The four quarterly mean PM2.5 values are determined and the average of these 

four quarterly mean PM2.5 values will give a future year annual average PM2.5 

value for each monitor analyzed. 

3.3 ATTAINMENT TEST RESULTS 

LADCO performed the attainment tests for all upper Midwest state monitoring sites, including 

those located in the Cincinnati area. LADCO followed U.S. EPA guidance concerning the 

modeled attainment test for the Cincinnati area. LADCO’s latest modeling (Round 5) showed all 

future year concentrations were below the annual fine particle NAAQS of 15.0 micrograms per 

cubic meter. 

Results of Step 1 of the attainment test for the annual fine particle NAAQS are shown in 

following two tables. Table 3.1 shows the percentage of the quarterly mean for each individual 

pollutant of the observed quarterly mean. Table 3.2 shows the mass of each individual 

component of the quarterly mean of the fine particle samples. This is the observed quarterly 

mean and composition of the controlling monitor for the Cincinnati area, which is the Murray 

Road monitor, St. Bernard, Ohio. 

Table 3.1 

Percent of Quarterly Mean Composition 

 Murray Rd., Hamilton Co. Monitor 

Pollutant (percent of 

total mass) 

Quarter 1 Quarter 2 Quarter 3 Quarter 4 

SO4 26.85 35.75 37.22 26.5 

NO3 23.78 0.25 0 12.03 

OC 19.0 19.82 12.1 21.64 

EC 3.5 4.65 3.09 5.2 

Soil 2.29 2.88 1.99 3.33 

NH4 15.83 12.12 11.78 12.74 

Pbw 8.74 12.78 12.61 8.41 
 24 

 

 

Table 3.2 

Observed Quarterly Mean/Quarterly Mean 

 Composition for each Component of PM2.5 

Murray Rd., Hamilton Co. Monitor 

Pollutant 

(μg/m3) 

Quarter 1 Quarter 2 Quarter 3 Quarter 4 Average 

SO4 4.4571 5.8523 8.2256 3.9830 5.6 

NO3 3.9475 0.0409 0.0000 1.8081 1.4 

OC 3.1540 3.2445 2.6741 3.2525 3.1 

EC 0.5810 0.7612 0.6829 0.7816 0.7 

Soil 0.3801 0.4715 0.4398 0.5005 0.4 

NH4 2.6278 1.9840 2.6034 1.9148 2.3 

Pbw 1.4508 2.0921 2.7868 1.2640 1.9 

Quarterly 

FRM Mean 

(total mass) 

16.6 16.37 22.1 15.03 

Passively collected mass is not used in the modeling and calculation of the RRFs. Passive mass 

appears to result from contamination of the filters from handling and contact with the FRM 

cassette. It is not included in Tables 3.1 and 3.2 above. For this reason, the percentages in Table 

3.1 may not total 100% and the mass of the individual pollutant components may not equal the 

total mass of the Quarterly FRM Mean. 

Once the observed quarterly mean and composition of the fine particle concentrations are 

determined, Step 2 of the attainment test requires that the component-specific relative response 

factors be derived for each quarter from the basecase and future year modeled concentrations at 

each monitor. The results of this step are shown in Table 3.3. 

Table 3.3 

Relative Response Factors (RRFs) for each Component 

Murray Rd., Hamilton Co. Monitor 

Pollutant Quarter 1 Quarter 2 Quarter 3 Quarter 4 

SO4 0.8104 0.6331 0.577 0.7754 

NO3 1.0886 1.0155 1.0923 0.9857 

OC 0.961 1.0798 1.082 1.0235 

EC 0.8969 0.9228 0.9099 0.8876 

Soil 1.4146 1.3785 1.537 1.4007 

NH4 0.9077 0.6968 0.6441 0.846 

Pbw 0.8687 0.6307 0.5734 0.8172 

The derived relative response factors for each quarter are then applied to the observed quarterly 

compositions of the fine particle concentrations to calculate the projected quarterly species 

estimates for each monitor, as per Step 3 of the attainment test guidance. Results are shown in 
 25 

 

 

Table 3.4. 

Table 3.4 

Projected Quarterly Species Estimates Murray Rd., Hamilton Co. Monitor 

Pollutant (μg/m3) Quarter 1 Quarter 2 Quarter 3 Quarter 4 TOTAL 

SO4 3.6120 3.7051 4.7462 3.0884 3.8 

NO3 4.2972 0.0416 0.0000 1.7823 1.5 

OC 3.0310 3.5034 2.8934 3.3289 3.2 

EC 0.5211 0.7024 0.6214 0.6937 0.6 

Soil 0.5377 0.6499 0.6760 0.7010 0.6 

NH4 2.3852 1.3825 1.6768 1.6199 1.8 

Pbw 1.2603 1.3195 1.5980 1.0330 1.3 

TOTAL 15.64 11.30 12.21 12.25 

Finally, Step 4 of the attainment test calculates the future year annual average fine particle 

concentrations, which are compared to the annual fine particle NAAQS of 15.0 micrograms per 

cubic meter. Table 3.5 shows a summary of the future year, 2009, modeled concentrations that 

show all fine particle monitors in the Cincinnati area will attain the annual fine particle standard. 

 

Table 3.5

Attainment Test Results for Cincinnati-Hamilton OH-KY-IN Nonattainment Area 

Monitor ID Monitor Name County 

Modeled 

Design Value 

2003-2006 

(μg/m3) 

Futurecase 

2009 

(μg/m3) 

390170003 Bonita & St John Butler 16.1 13.3 

390170016 Nilles Rd. Butler 15.8 13.0 

390170017 Wilwood Butler 16.1 13.6 

390171004 Hook Field Airport Butler 14.9 12.4 

390250022 Clermont Dr. Clermont 14.7 11.8 

390610006 Grooms Rd. Hamilton 15.5 12.7 

390610014 Seymour & Vine St. Hamilton 17.4 14.4 

390610040 Howard Taft Hamilton 15.5 12.7 

390610041 Winneste Ave. Hamilton 15.4 13.0 

390610042 W. 8th St. Hamilton 17.0 13.9 

390610043 E. Kemper Rd. Hamilton 15.6 12.9 

390617001 Sherman Ave. Hamilton 16.3 13.3 

390618001 Murray Rd. Hamilton 17.7 14.6 

210373002 Alexandria Pk. Campbell 13.3 11.6 

211170007 Univ. College Kenton 14.4 11.8 

An additional adjustment is made to values in Table 3.4 to arrive at results in Table 3.5. The 

reason is, again, passively collected mass. In the attainment test calculations, the passive mass is 
 26 

 

 

assumed to remain constant over time, e.g. the RRF equals 1.0. Therefore, the portion of the 

observed basecase sample attributed to passive mass is added back into the projected 2009 mass, 

to provide the averages in Table 3.5. 

Modeled results show similar mean species compositions and relative response factors at all the 

fine particle monitoring sites and all monitors show compliance with the annual fine particle 

NAAQS. 

3.4 UNMONITORED AREA ANALYSIS

U.S. EPA has recommended in its “Guidance on the Use of Models and Other Analyses for 

Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze” (EPA454/B-07-002, April 2007) an “unmonitored area analysis” for areas without monitors that could 

potentially exceed the NAAQS if monitors existed in those areas. The “unmonitored area 

analysis” uses a combination of ambient data to provide spatial fields for monitored and 

unmonitored areas and model outputs for predicted concentrations throughout a region. 

Lawrenceburg Township in Dearborn County, Indiana was designated as nonattainment for the 

annual fine particle standard despite the fact that there is no fine particle monitor in the county. 

This county is adjacent to Hamilton County in Ohio, which has monitors in the southern, central, 

and northeastern portions of the county. 

 

Ambient fine particle monitors in the Cincinnati area provide adequate coverage, as per 40 CFR, 

Part 58, Appendix D, 4.7. Indiana has placed fine particle monitors throughout the state as per 

this guidance that based the number of monitors on the population of the metropolitan statistical 

area (MSA) and the design values for monitored areas. The monitors are therefore concentrated 

in the more urban areas where higher pollutant concentrations are expected. Due to the 

rural nature of Dearborn County and its location upwind of the Cincinnati area, there are no fine 

particle monitors located in Dearborn County. There are fine particle monitors located in nearby 

Butler and Clermont counties in Ohio and Campbell and Kenton counties in Kentucky. While 

these Campbell and Kenton county monitors were sited upwind of the urban center of the 

Cincinnati OH MSA, the resulting design values between these monitors are comparable with 

the latest 3-year design values (2004-2006) and range between 13.8 and 14.1 μg/m3. 

Figure 3.3 shows the Cincinnati area PM2.5 monitoring network. Circles surrounding the 

monitors indicate the spatial scale of coverage for each of the monitors. The spatial scale of 

representation describes the physical dimensions of the air parcel measured at and near the 

monitor. In the rural areas, the air quality in the spatial coverages of the regional and urban 

monitor is considered to have similar concentrations. The monitors shown in Figure 3.3 are 

those closest to the unmonitored nonattainment areas. 

An urban monitor has a spatial scale of representation which extends from 4 to 50 kilometers 

from the monitoring site. Nilles Rd. and Hook Field Airport fine particle monitors are urban 

monitors and their spatial scale of representation extends into Dearborn County and Hamilton 

and Clermont counties in Ohio. Nilles Rd. ambient monitor represents a downwind urban scale 

monitor, whose air quality monitoring extends out 50 kilometers. The Nilles Rd. fine particle 
monitor’s current annual PM2.5 3-year design value (2004-2006) is 15.5 μg/m3

. Hook Field 

Airport ambient monitor represents a downwind urban scale monitor, whose air quality 

monitoring extends out 50 kilometers. The Hook Field Airport fine particle monitor’s current 

annual PM2.5 3-year design value (2004-2006) is 14.6 μg/m3. All other monitors in the 

Cincinnati area are neighborhood monitors that have spatial scales of representation which 

extend from 0.5 to 4 kilometers. 

Figure 3.3 

Spatial Representation for the Cincinnati Area PM2.5 Monitoring Sites 

Lawrence

Township

Rush

Ripley

Henry

Wayne

Franklin

Decatur

Randolph

Jefferson

Fayette

Switzerland

Ohio

Dearborn

Union

Darke

Brown

Clark

Miami

Clinton

Greene

Champaign

Clermont

Butler

Preble

Warren

Hamilton

Montgomery

Grant

Pendleton

Gallatin Bracken

Boone

Kenton

Campbell

PM2.5 Monitor

ohiostatebndy polygon

PM2.5 Attainment Area

PM2.5 Nonattainment Area

50km

50km

Table 3.6 shows the fine particle monitors located outside the urban center of Cincinnati; the 

monitors in Butler and Clermont counties in Ohio and the Campbell and Kenton county monitors 

 27 

 

 
 28 

 

 

in Kentucky have displayed typically lower annual design values than the monitors impacted by 

the Cincinnati urban core emissions. Average differences in concentrations between the rural 

monitors and urban monitors range from 3.0 μg/m3 to 5.5 μg/m3. In addition, the Butler County 

monitor in Ohio and Kenton and Campbell county monitors in Kentucky, show lower design 

values that would be more representative of air quality in Dearborn County. It is apparent that 

the higher annual fine particle concentrations are found in or near the urban center of Cincinnati. 

This fact is shown in the annual design values for each of the Cincinnati area fine particle 

monitors over the past seven (7) years (2000-2006). Chart 3.1 shows the general downward 

trend in fine particle concentrations in the Cincinnati area, with the exception of 2005. 

Table 3.6 

Annual Design Values for the Cincinnati Nonattainment Area from 2000 – 2006

County Site 2000 2001 2002 2003 2004 2005 2006 

Butler Bonita & St John 17.0 16.5 16.7 14.8 14.1 18.6 14.1 

Butler Nilles Rd. 18.9 15.8 15.3 15.8 14.7 17.9 13.9 

Butler Wilwood 17.9 15.7 15.5 14.4 14.3 17.2 N/D 

Butler Hook Field Airport N/D N/D 13.7 14.9 13.6 16.9 13.4 

Clermont Clermont Dr. N/D N/D N/D N/D N/D 15.6 12.7 

Hamilton Grooms Rd. N/D N/D N/D N/D N/D 16.6 13.3 

Hamilton Seymour & Vine St. 19.3 18.4 17.9 17.2 16.0 19.7 15.4 

Hamilton Howard Taft 16.7 15.8 15.2 15.4 14.7 17.4 13.5 

Hamilton Winneste Ave. 19.8 16.0 15.1 15.2 14.4 N/D N/D 

Hamilton W. 8th St. 20.6 17.7 16.7 16.6 16.1 19.1 14.9 

Hamilton E. Kemper Rd. 19.1 15.9 15.4 15.6 15.0 16.6 14.4 

Hamilton Sherman Ave. 17.2 16.8 16.0 16.0 15.4 18.3 14.3 

Hamilton Murray Rd. 19.3 16.9 16.9 17.3 16.1 20.0 16.0 

Campbell Alexandria Pk. 15.1 13.4 14.8 13.4 12.8 14.8 11.5 

Kenton Univ. College 16.3 15.3 15.1 14.3 13.4 15.9 13.3 

N/D No data 

Chart 3.1 
Annual PM2.5 Values for Cincinnati Nonattainment Area 

10.0

12.0

14.0

16.0

18.0

20.0

22.0

2001 2002 2003 2004 2005 2006

Standard Alexandria Pk. Univ. College Bonita & St. John

Nilles Rd. Wilwood Hook Field Airport Clermont Dr.

Grooms Rd. Seymour & Vine St. Howard Taft Winneste Ave.

 W. 8th St. E. Kemper Rd. Sherman Ave. Murray Rd.

 29 

 

 

U.S. EPA has developed the “Modeled Attainment Test Software” (MATS) to spatially interpret 

data, adjust spatial fields with modeled output gradients and multiply the fields by modeled 

RRFs. However, the PM2.5 portion of MATS is not available at this time. U.S. EPA guidance 

recommends using nearby ambient data as well as modeled output to determine the 

concentrations in unmonitored areas. In the case of the unmonitored areas of Dearborn County, 

ambient monitored data in Hamilton, Clermont and Butler counties in Ohio and Campbell and 

Kenton counties in Kentucky show decreasing annual design values and future year modeled 

results in the Cincinnati area fine particle monitors fall below the annual fine particle standard. 

 

A review of the LADCO Round 5 modeling results for the Cincinnati area PM2.5 monitoring sites 

is shown in Table 3.7. The 2009 modeled results show that the highest modeled concentrations 

will be 14.6 μg/m3

, 0.4 μg/m3 below the annual fine particle NAAQS of 15.0 μg/m3 with other 

modeled results in the Cincinnati area and other nearby areas much lower. Modeling results for 

2012 and 2018 indicate future year design values will continue to decrease in all CincinnatiHamilton OH-KY-IN area monitors. These results confirm that the adjacent U.S. EPA 

designated nonattainment Indiana county of Dearborn will be in attainment of the annual fine 

particle standard by 2009 and continue through 2018 as modeled fine particle concentrations are 

less than 14.0 μg/m3

 and continue to decrease in the future. 
 30 

 

 

Table 3.7 

Modeling Results for PM2.5 Monitors located in or near the Cincinnati Fine Particle 

Nonattainment Area for 2009, 2012 and 2018 

2005 2009 2012 2018 

Monitor Site County Base Year Future Year Future Year Future Year

390170003 Bonita & St John Butler 16.1 13.3 13.2 12.6 

390170016 Nilles Rd. Butler 15.8 13.0 13.0 12.4 

390170017 Wilwood Butler 16.1 13.6 13.5 12.9 

390171004 Hook Field Airport Butler 14.9 12.4 12.3 11.8 

390250022 Clermont Dr. Clermont 14.7 11.8 11.7 11.2 

390610006 Grooms Rd. Hamilton 15.5 12.7 12.6 12.1 

390610014 Seymour & Vine St. Hamilton 17.4 14.4 14.3 13.7 

390610040 Howard Taft Hamilton 15.5 12.7 12.6 12.1 

390610041 Winneste Ave. Hamilton 15.4 13.0 12.9 12.3 

390610042 W. 8th St. Hamilton 17.0 13.9 13.8 13.2 

390610043 E. Kemper Rd. Hamilton 15.6 12.9 12.8 12.3 

390617001 Sherman Ave. Hamilton 16.3 13.3 13.2 12.7 

390618001 Murray Rd. Hamilton 17.7 14.6 14.5 13.9 

210370003 Alexandria Pk. Campbell 13.3 11.6 11.5 11.0 

211170007 Univ. College Kenton 14.4 11.8 11.7 11.2 

4.0 AIR QUALITY TRENDS 

One benchmark for attainment with the annual fine particle standard is the area’s design value. 

Table 4.1 shows the yearly trend in the design value for the area since 2003. This value is 

determined by the average of each monitor’s PM2.5 values over a three-year period. 

Table 4.1 

Cincinnati Nonattainment Area’s Annual Fine Particle Design Values 

Year Design Value [μg/m3

] (Monitor 

Location) 

3-Year Period 

2006 17.33 (Murray Rd.) 2004-2006 

2005 17.76 (Murray Rd.) 2003-2005 

2004 17.02 (Seymour & Vine St.) 2002-2004 

2003 17.82 (Seymour & Vine St.) 2001-2003 

Figure 4.1 

Controlling Monitor Design Values 
Direct PM 2.5 Trends

(Controlling Monitor Values)

12.00

13.00

14.00

15.00

16.00

17.00

18.00

19.00

20.00

2001-2003 2002-2004 2003-2005 2004-2006

ug/m3

Controlling Monitor Standard

As shown in Figure 4.1, the data shows a relatively continual decline since the implementation 

of federal control programs such as NOx SIP Call and the new engine and fuel standards. To 

give a more complete picture of the air quality improvement in the nonattainment area, 

Chart 4.1 lists the design values for each of the ambient fine particle monitors in the 

nonattainment area. 

Chart 4.1

Historical Design Values for Cincinnati Nonattainment Area from 2001-2006 

Three-Year Design Values 

2001-2006

10.00

11.00

12.00

13.00

14.00

15.00

16.00

17.00

18.00

19.00

20.00

Alexandria Pk.

Univ. College

Bonita & St. John

Nilles Rd.

Wilwood

Hook Field Airport

Clermont Dr.

Grooms Rd.

Seymour & Vine St.

Howard Taft

Winneste Ave.

 W. 8th St.

E. Kemper Rd.

Sherman Ave.

Murray Rd.

ug/m3

2001-2003 2002-2004 2003-2005 2004-2006 Standard

 31 

 

 
Figure 4.2 shows the design values for the Cincinnati fine particle nonattainment area from 2001 

through 2006. 

Figure 4.2 

Three-Year Fine Particle Design Values

12.0

13.0

14.0

15.0

16.0

17.0

18.0

19.0

20.0

2001-2003 2002-2004 2003-2005 2004-2006

ug/m3

Standard Alexandria Pk. Univ. College Bonita & St. John

Nilles Rd. Wilwood Hook Field Airport Seymour & Vine St.

Howard Taft Winneste Ave. W. 8th St. E. Kemper Rd.

Sherman Ave. Murray Rd. Clermont Dr. Grooms Rd.

 32 

 

 

Looking at the design value for each year between 2001 and 2006, as shown in Chart 4.1 and 

Figure 4.2, the annual design values for the Cincinnati fine particle nonattainment area monitors 

generally show a downward trend. In the figure, the NAAQS value for annual PM2.5 of 15.0 

μg/m3

 is identified by the red line. A general downward trend can be noticed with the exception 

of 2005. 2005 had extended meteorological events that led to several PM2.5 episodes in which 

daily PM2.5 concentrations in the Cincinnati area were extremely high. This in turn, weighed the 

annual PM2.5 concentrations and the latest 3-year design value for the area. 

Figure 4.3 shows the monitored values from 2001-2006 for each of the monitors in the 

Cincinnati fine particle nonattainment area.
Figure 4.3 

Annual PM2.5 Values for the Cincinnati Area 

10.0

12.0

14.0

16.0

18.0

20.0

22.0

2001 2002 2003 2004 2005 2006

Standard Alexandria Pk. Univ. College Bonita & St. John

Nilles Rd. Wilwood Hook Field Airport Clermont Dr.

Grooms Rd. Seymour & Vine St. Howard Taft Winneste Ave.

 W. 8th St. E. Kemper Rd. Sherman Ave. Murray Rd.

 33 

 

 
5.0 EMISSIONS TRENDS ANALYSIS 

Charts 5.1, 5.2, 5.3, and 5.4 compare 2005 actual SO2, NOx and direct PM2.5 emissions, which 

were used in the modeling demonstration, to the projected 2009 emissions. 

Chart 5.1

Emissions Trends – All Anthropogenic Sources 

Trends- All Anthropogenic Sources 

Cincinnati Nonattainment Area

0

50,000

100,000

150,000

200,000

250,000

300,000

2005 2009

Annual Tons

NOx Direct PM2.5 SO2

 34 

 

 
Chart 5.2 

NOx Emissions Trends 

 

NOx Trends - All Anthropogenic Sources 

Entire Nonattainment Area

-

20,000.00

40,000.00

60,000.00

80,000.00

100,000.00

120,000.00

140,000.00

160,000.00

NOX NOX

2005 2009

Annual Tons

Ohio Total

Kentucky Total

Indiana Total

Chart 5.3 

SO2 Emissions Trends 

SO2 Trends - All Anthropogenic Sources 

Entire Nonattainment Area

-

50,000.00

100,000.00

150,000.00

200,000.00

250,000.00

300,000.00

SO2 SO2

2005 2009

Annual Tons

Ohio Total

Kentucky Total

Indiana Total

 35 

 

 
Chart 5.4 

Direct PM2.5 Emissions Trends 

Direct PM2.5 Trends - All Anthropogenic Sources 

Entire Nonattainment Area

-

2,000.00

4,000.00

6,000.00

8,000.00

10,000.00

12,000.00

Direct PM 2.5 Direct PM 2.5

2005 2009

Annual Tons

Ohio Total

Kentucky Total

Indiana Total

Table 5.1 shows the NOx emissions that were modeled for the nonattainment area, broken down 

by state and by emissions source sectors (point, area, mobile, and non-road). The 2005 

estimated emissions were pulled from the LADCO emissions inventory files used to support 

modeling (Appendix B). 

Table 5.1 

NOx Emissions Inventories (tons per year) 

Entire Nonattainment Area 

Sector NOx 2005 NOx 2009 %Reduction 2005-2009 

Area 7,820.06 5,305.69 32.15 

Non-road 21,627.45 15,954.40 26.23 

On-road 43,955.54 33,851.76 53.94 

Point 66,820.05 40,628.18 39.20 

Total 140,223.10 95,740.03 43.60 

Table 5.2 shows the SO2 emissions for the attainment area by emission source sectors (point, 

area, mobile, and non-road). The projected 2009 emissions were pulled from the LADCO 

emissions inventory files to support the modeling (Appendix B). 

 36 

 

 
 37 

 

 

Table 5.2 

SO2 Emissions Inventories (tons per year) 

Entire Nonattainment Area 

Sector SO2 2005 SO2 2009 %Reduction 2005-2009 

Area 3,499.85 1,680.40 51.99 

Non-road 2,322.65 846.29 63.56 

On-road 884.77 221.01 75.02 

Point 235,432.16 137,302.85 41.68 

Total 242,139.43 140,050.55 42.16 

Table 5.3 shows the PM2.5 emissions for the nonattainment area by emission source sectors 

(point, area, mobile, and non-road). The 2005 estimated emissions were pulled from the LADCO 

emissions inventory files used to support the modeling (Appendix B). 

Table 5.3 

PM2.5 Emissions Inventories (tons per year) 

Entire Nonattainment Area 

Sector Direct PM2.5 2005 Direct PM2.5 2009 %Reduction 2005-2009 

Area 2,080.89 1,623.83 21.96 

Non-road 1,397.24 1,089.48 22.03 

On-road 758.54 551.82 27.25 

Point 2,816.58 6,998.93 -148.49 

Total 7,053.25 10,264.06 -45.52 

The CAIR rule provides annual state caps for NOx and SO2 in two phases, with the Phase I caps 

for NOx and SO2 starting in 2009 and 2010, respectively. In response to U.S. EPA’s rulemaking, 

IDEM adopted its state rule in 2006 based on the federal rule. IDEM’s rule includes an annual 

and seasonal NOx trading program, and an annual SO2 trading program. Indiana’s NOx and SO2

EGU budgets are shown in Table 5.4. EGU reductions occurring outside of the Cincinnati fine 

particle nonattainment area will have a positive affect on the area. 

Charts 5.5, 5.6, and 5.7 compare 2005 actual SO2, NOx and direct PM2.5 emissions, which were 

used in the modeling demonstration, to the projected 2009 emissions for Dearborn County in 

Indiana. While projected emissions for Dearborn County in 2009 do not decrease, the cap and 

trade programs, as illustrated in Charts 5.2 and 5.3, result in significant decreases in SO2 and 

NOx across the nonattainment area. 
Chart 5.5 

Direct NOx Emissions Trends 

NOx Point Source Emission Trends 

Dearborn County

0

2,000

4,000

6,000

8,000

10,000

12,000

2005 2009

Annual Tons

NOx

Chart 5.6 

Direct SO2 Emissions Trends 

SO2 Point Source Emissions Trends 

Dearborn County

0

10,000

20,000

30,000

40,000

50,000

60,000

2005 2009

Annual Tons

SO2

 38 

 

 
Chart 5.7 

Direct PM2.5 Emissions Trends 

Direct PM2.5 Point Source Emission Trends 

Dearborn County

0

20

40

60

80

100

120

140

160

2005 2009

Annual Tons

Direct PM2.5

Chart 5.8 

Statewide NOx Emissions Trends 

Statewide NOx Emissions from EGUs

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

1999 2000 2001 2002 2003 2004 2005 2006

Annual Tons

NOx

 39 

 

 
 40 

 

 

Table 5.4 

Statewide Annual SO2 and NOx EGU Budgets 

STATEWIDE EGU 

SO2 TRENDS 

STATEWIDE EGU 

NOx TRENDS 

Year 

SO2 Emissions, 

tons / annual Year 

NOx Emissions, 

tons / annual 

1999 941,852.4 1999 347,217 

2000 874,617.2 2000 334,522 

2001 795,505.6 2001 315,420 

2002 778,868.0 2002 281,146 

2003 804,828.6 2003 260,980 

2004 862,876.4 2004 224,311 

2005 870,811.8 2005 207,982 

2006 820,993.4 2006 202,728 

Budget 2010-2014 254,599 Budget 2009-2014 108,935 

Budget 2015 and 

later 178,219 

Budget 2015 and 

later 90,779 

As demonstrated by Figure 5.1, significant reductions of NOx associated with the NOx SIP Call 

and CAIR have been achieved statewide as well as regionally. For the six (6) state (Arkansas, 

Indiana, Illinois, Kentucky, Missouri and Tennessee) region shown in Figure 5.1 (the area south 

of latitude 39.3052 and west of longitude -84.8194 (the southwest quadrant denoted by 

crosshairs)) there is an estimated reduction in upwind EGU emissions of more than 203,000 tons 

of NOx from 2005 to 2010. 
Figure 5.1 

Regional NOx Reductions 2005 through 2010 

Difference in Tons Per Year

> -30000

-30000 - -20000

-20000 - -10000

-10000 - -1

-1 - 1

1 - 4000

NOx Difference 2005 - 2010

 41 

 

 
Figure 5.2 

Regional SO2 Reductions 2005 through 2010 

Difference in Tons Per Year

> -75000

-75000 - -50000

-50000 - -25000

-25000 - -1

-1 - 1

1 - 25000

SO2 Difference 2005 - 2010

 42 

 

 
 43 

 

 

As demonstrated by Figure 5.2, reductions of regional SO2 from upwind EGUs have also been 

achieved. For the six (6) state (Arkansas, Indiana, Illinois, Kentucky, Missouri and Tennessee) 

region shown in Figure 5.1 (the area south of latitude 39.3052 and west of longitude -84.8194 

(the southwest quadrant denoted by crosshairs)) there is an estimated reduction in upwind EGU 

emissions of more than 570,000 tons of SO2 from 2005 to 2010. 

6.0 CONTROL STRATEGY

Several control measures already in place or being implemented over the next few years will 

reduce point, on-road mobile and non-road source emissions. The federal and state control 

measures included in the photochemical modeling for the future year design value and those 

additional control measures due to be implemented, but not included in the modeling, are less 

certain, discussed in sections 6.1 and 6.2. While the impacts of VOC reductions are minimal, 

they are nevertheless beneficial for controlling fine particle levels. Therefore, control measures 

that reduce VOC emissions are included in the following sections. 

6.1 MODELED CONTROL MEASURES 

Federal Tier 2 motor vehicle standards require all passenger vehicles in a manufacturer’s fleet, 

including light-duty trucks and sport utility vehicles (SUVs), to meet an average standard of 0.07 

grams of NOx per mile. Implementation began in 2004 and was completed in 2007. The Tier 2 

standards also cover passenger vehicles over 8,500 pounds gross vehicle weight rating (larger 

pickup trucks and SUVs), which are not covered by the current Tier 1 regulations. For these 

vehicles, the standards will be phased in beginning in 2008, with full compliance in 2009. The 

new standards require vehicles to be 77% to 95% cleaner than those on the road today. The Tier 

2 standards also reduced the sulfur content of gasoline to 30 ppm beginning in January 2006. 

Most gasoline sold in Indiana prior to January 2006 had a sulfur content of about 500 ppm. 

Sulfur occurs naturally in gasoline, but interferes with the operation of catalytic converters on 

vehicles resulting in higher NOx emissions. Lower sulfur gasoline is necessary to achieve the 

Tier 2 vehicle emission standards. 

 

 6.1.1 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards 

New U.S. EPA standards designed to reduce NOx and VOC emissions from heavy-duty gasoline 

and diesel highway vehicles began to take effect in 2004. A second phase of standards and 

testing procedures, which began in 2007, reduced particulate matter from heavy-duty highway 

engines, and also reduced highway diesel fuel sulfur content to 15 ppm since the sulfur can 

damage emissions control devices. The total program is expected to achieve a 90% reduction in 

direct particulate matter (PM) emissions and a 95% reduction in NOx emissions for these new 

engines using low sulfur diesel, compared to existing engines using higher-content diesel. There 

will also be SO2 reductions from these rules. The U.S. EPA has not quantified the expected 

reductions. 
 44 

 

 

6.1.2 Large Non-Road Diesel Engines Standards 

In May 2004, U.S. EPA promulgated new rules for large non-road diesel engines, such as those 

used in construction, agricultural and industrial equipment, to be phased in between 2008 and 

2014. The non-road diesel rules also reduce the allowable sulfur in non-road diesel fuel by over 

99%. Non-road diesel fuel currently averages approximately 3,400 ppm sulfur. This rule limited 

non-road diesel sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined engine 

and fuel rules will reduce NOx and PM emissions from large non-road diesel engines by over 

90%, compared to current non-road engines using higher-content diesel. 

6.1.3 Non-Road Spark-Ignition Engines And Recreational Engines Standards 

The new standard, effective in July 2003, regulates NOx, VOCs and carbon monoxide (CO), for 

groups of previously unregulated non-road engines. The new standard applies to all new engines 

sold in the United States and imported after the standards went into effect. The standard applies 

to large spark-ignition engines (forklifts and airport ground service equipment), recreational 

vehicles (off-highway motorcycles and all-terrain vehicles), and recreational marine diesel 

engines. The regulation varies based upon the type of engine and vehicle. 

The large spark-ignition engines contribute to ozone formation and ambient CO and PM levels in 

urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like 

the large spark-ignition, recreational vehicles contribute to ozone formation and ambient CO and 

PM levels. For the off-highway motorcycles and all-terrain vehicles, model year 2006, at least 

50% of a manufacture’s fleet was required to meet the new exhaust emissions standard and 

100% of the fleet was required to meet the standards in 2007. Recreational marine diesel 

engines over 37 kilowatts are used in yachts, cruisers, and other types of pleasure craft. 

Recreational marine engines contribute to ozone formation and PM levels, especially 

surrounding marinas. 

When all of the non-road spark-ignition engines and recreational engine standards are fully 

implemented, an overall 72% reduction in VOCs, 80% reduction in NOx and 56% reduction in 

CO emissions are expected by 2020. These controls will help reduce ambient concentrations of 

ozone, CO and fine PM. 

 6.1.4 NOx SIP Call 

The U.S. EPA NOx SIP Call required twenty-two (22) states to adopt rules that would result in 

significant emissions reductions from large electric generating units (EGUs), industrial boilers, 

and cement kilns in the eastern United States. Indiana adopted this rule in 2001. Beginning in 

2004, this rule accounts for a reduction of approximately 31% of total NOx emissions statewide 

compared to previous uncontrolled years. 

Twenty-one (21) other states have also adopted these rules, including states surrounding Indiana. 

The result is that significant reductions have occurred upwind and within Cincinnati fine particle 

nonattainment area because of the number of affected sources within the region. 
 45 

 

 
 46 

 

 

6.1.5 Clean Air Interstate Rule (CAIR) 

On May 12, 2005, the U.S. EPA promulgated the “Rule to Reduce Interstate Transport of Fine 

Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to Acid Rain Program; 

Revisions to the NOx SIP Call”; Final Rule. This rule established the requirement for states to 

adopt rules limiting the emissions of NOx and sulfur dioxide (SO2) and provided a model rule for 

the states to use in developing their rules to meet Federal requirements. The purpose of CAIR is 

to reduce interstate transport of precursors to fine particles and ozone. 

CAIR applies to: (1) any stationary, fossil-fuel-fired boiler or stationary, fossil-fuel-fired 

combustion turbine, a generator with nameplate capacity of more than 25 MWe producing 

electricity for sale, or (2) a unit that qualifies as a cogeneration unit during the 12-month period 

starting on the date that the unit first produces electricity and continues to qualify as a 

cogeneration unit, a cogeneration unit serving at any time a generator with a nameplate capacity 

of more than 25 MWe and supplying in any calendar year more than one-third of the unit’s 

potential electric output capacity or 219,000 MWh, whichever is greater to any utility power 

distribution system for sale. 

This rule provides annual state caps for NOx and SO2 in two phases, with the Phase I caps for 

NOx and SO2 starting in 2009 and 2010, respectively. Phase II caps become effective in 2015. 

The U.S. EPA is allowing the caps to be met through a cap and trade program if a state chooses 

to participate in the program. 

In response to U.S. EPA’s rulemaking, IDEM adopted its state rule in 2006 based on the model 

federal rule. IDEM’s rule includes an annual and seasonal NOx trading program, and an annual 

SO2 trading program. This rule requires compliance effective January 1, 2009. 

6.2 ADDITIONAL CONTROL MEASURES 

This section provides a summary of the additional control measures that have been or will be 

implemented in the nonattainment area and were not included in the modeling demonstration. 

6.2.1 Federal Controls 

 * Portable Fuel Container (Gas Can) Controls 

U.S. EPA issued a final rule on February 26, 2007 (71 FR 15830) to regulate VOC 

emissions from portable gasoline containers, or gas cans. Portable fuel containers are 

consumer products used to refuel a wide variety of gasoline-powered equipment, 

including lawn and garden equipment, recreational equipment, and passenger vehicles 

that have run out of gas. The proposed standards will reduce hydrocarbon emissions 

from evaporation, permeation, and spillage. These standards would significantly reduce 

benzene and other toxics, as well as VOC more generally. 
 47 

 

 

The rule proposed a performance-based standard of 0.3 grams per gallon per day of 

hydrocarbons, based on the emissions from the can over a diurnal test cycle. The 

standard will apply to gas cans manufactured on or after January 1, 2009. The U.S. EPA 

also proposed test procedures and a certification and compliance program, in order to 

ensure that gas cans meet the emissions standard over a range of in-use conditions. The 

proposed standards will result in the use of best available control technologies, such as 

durable permeation barriers, automatically closing spouts, and cans that are well-sealed. 

Emissions reductions expected to be 18% by 2009, 54% reduction at full implementation 

in 2015. 

 * Small Non-Road Engine Rule 

On April 17, 2007, U.S. EPA proposed a rule to control emissions from new gasolinepowered small non-road engines, including lawn and garden equipment (<25 hp) and 

recreational watercraft. Under the proposed rule, the exhaust emissions standards for 

Class I non-road engines will take effect in 2012 and for Class II engines in 2011. The 

watercraft standards will take effect in 2009. U.S. EPA anticipates that when fully 

implemented, the proposed standards will result in a 70% reduction in hydrocarbon and 

NOx emissions and a 20% reduction in CO from new engines’ exhaust, as well as a 70% 

reduction in evaporative emissions. 

 

6.2.2 Indiana Statewide Controls 

IDEM is proposing to implement several statewide VOC control rules. Through MRPO 

consultation, the other MRPO states (Illinois, Indiana, Michigan, Ohio, and Wisconsin) 

have also agreed to implement a series of similar controls to address regional ozone and 

particulate matter nonattainment areas in the upper Midwest. The rules will apply 

region-wide to consumer and commercial products, architectural and industrial 

maintenance (AIM), automobile refinishing operations, cold cleaning degreasing and 

Stage I vapor recovery. 

 * Consumer and Commercial Products (326 IAC 8) 

This is a proposed new rule to adopt OTC model rule with additional product coverage 

and more stringent VOC limits (14.2 % reduction beyond Federal Part 59 rule, for a total 

reduction of 21% from uncontrolled emissions). 

• Architectural and Industrial Maintenance (AIM) Coatings (326 IAC 8-14) 

This rule will adopt more stringent VOC limits for AIM coatings based on Ozone 

Transport Commission model rule, 21% reduction beyond Federal Part 59 limits. 

 
 48 

 

 

* Automobile Refinishing Operations (326 IAC 8-10) 

This rule will extend existing regulations statewide. A 55% reduction is expected from 

uncontrolled emissions, 24% reduction beyond Federal Part 59 limits. 

 

 * Stage I Vapor Recovery (326 IAC 8-4) 

The existing regulation requires gasoline dispensing facilities with a monthly gasoline 

throughput of 10,000 gallons per month or greater to maintain vapor balance systems to 

collect gasoline vapors displaced during the transfer of gasoline between storage tanks 

and delivery trucks. The proposed rulemaking will amend 326 IAC 4-1 to apply to all 

gasoline dispensing facilities regardless of when the storage tank was installed. IDEM 

estimates that the rules requiring submerged loading and vapor balancing will achieve a 

90% reduction in VOC emissions versus uncontrolled underground storage tank loading. 

6.2.3 Kentucky Statewide Controls 

Kentucky has adopted a number of regulations and legislation to address pollution issues 

across the state. These include the NOx SIP Call Rule, Open Burning Ban and Clean Air 

Interstate Rule. All of these regulations were modeled in the attainment demonstration. 

These regulations are summarized below. 

* NOx SIP Call Rule 

In response to the U.S. EPA’s NOx SIP call, Kentucky adopted rules to control the 

emissions of NOx from EGUs and large stationary combustion sources. These rules 

cover (1) fossil fuel-fired stationary boilers, combustion turbines, and combined cycle 

systems serving a generator with a nameplate capacity greater than 25 megawatts and 

selling any amount of electricity, (2) fossil fuel-fired stationary boilers, combustion 

turbines, and combined cycle systems having a maximum design heat input greater than 

250 million British thermal units per hour, and (3) reciprocating stationary internal 

combustion engines rated at equal or greater than 2400 brake horsepower (3000 brake 

horsepower for diesel engines and 4400 brake horsepower for dual fuel engines). As part 

of the NOx SIP call, the U.S. EPA rules established a NOx budget for sources in 

Kentucky and other states. Kentucky’s NOx SIP Call rule was predicted to reduce 

summertime NOx emissions from power plants and other industries by 66% by 2006. In 

August 2001, the Kentucky Natural Resources and Environmental Protection Cabinet 

adopted rules requiring the reductions. 
 49 

 

 

* Open Burning Bans 

Kentucky revised the open burning regulation to prohibit most types of open burning in 

moderate ozone nonattainment areas within Kentucky during the period of MaySeptember. This requirement continues in the Northern Kentucky area.

 * Clean Air Interstate Rule 

In response to the U.S. EPA’s CAIR, the KYDAQ developed rules to implement CAIR. 

Under the rule, Kentucky has caps as follows: 

• Annual NOx: 83,205 tons for 2009-2014 and 69,337 tons for 2015 and each year 

thereafter. 

• Ozone season NOx: 36,109 tons for 2009-2014 and 30,651 tons for 2015 and each year 

thereafter. 

• Annual SO2: 188,773 tons for 2010-2014 and 132,141 tons for 2015 and each year 

thereafter. 

The state’s NOx allocations have been distributed based on allocation methodologies in 

401 KAR 52:210 and 220. The U.S. EPA will determine the SO2 allocations, which are 

based on the acid rain program. For the most part the rules follow the U.S. EPA’s model 

rule. This rule does not preclude the DAQ from adopting additional emissions reduction 

requirements for covered sources if necessary to attain or maintain an ambient air quality 

standard. 

The KYDAQ CAIR regulations became effective February 2, 2007.

6.2.4 Ohio Statewide Controls 

Ohio has adopted a number of regulations and legislation to address pollution issues 

across the state. These include the 7.8 RVP Gasoline Rule, the High Volume, Low 

Pressure Autobody Repair Facilities Rule, and the Portable Fuel Containers Rule. All of 

these regulations were modeled in the attainment demonstration. These regulations are 

summarized below. 

* 7.8 RVP Gasoline 

This state rule is fully state-adopted and is effective one year following approval of a 

waiver by U.S. EPA under CAA Section 211 (c)(4)(C). Given the May 25, 2007 final 

approval (72 FR 29269) by U.S. EPA, the 7.8 RVP gasoline will be in place for the 2008 

ozone season. 

* High Volume, Low Pressure Autobody Repair Facilities: 

This state rule has been effective since the 2006 ozone season. U.S. EPA approved this 

revision into the SIP on March 30, 2007. 
 50 

 

 

 * Cold Cleaner Degreaser Operations 

This state rule has been effective since the 2006 ozone season. U.S. EPA approved this 

revision into the SIP on March 30, 2007. 

* Portable Fuel Containers 

This rule is an effective state rule which has a compliance date of July 1, 2007. U.S. 

EPA approved this revision into the SIP on March 30, 2007. 

* Tier II Emissions 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 emissions reductions

will be approximately 77% for passenger cars, 86% for smaller SUVs, light trucks, and 

minivans, and 65% to 95% reductions 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 ultra low sulfur diesel fuel standards. This rule applies to heavy-duty 

gasoline and diesel trucks and buses. It is anticipated that this rule will result in 

significant reductions in NOx from diesel trucks and buses, a large sector of the mobile 

sources NOx inventory. 

* 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%. Non-road 

diesel equipment, as described in this rule, currently accounts for 47% of diesel 

particulate matter (PM) and 25% of NOx from mobile sources nationwide. Sulfur levels 

will be reduced in non-road diesel fuel by 99% from current levels, from approximately 

3,000 parts per million (ppm) now to 15 ppm in 2010. New engine standards take effect, 

based on engine horsepower, starting in 2008. Together, these rules will substantially 

reduce local and regional sources of ozone precursors. 

* Architectural and Industrial Maintenance (AIM) Coatings 

This rule has been adopted by the State of Ohio. 
 51 

 

 

* Consumer and Commercial Products (CP) 

This rule has been adopted by the State of Ohio and has compliance dates of March 15, 

2008 and Jan. 1, 2009. 

7.0 WEIGHT OF EVIDENCE ANALYSIS 

U.S. EPA’s fine particle modeling guidance requires states to submit a weight of evidence 

analysis demonstration if future year modeled design values are “close” to the standard (between 

14.5 and 15.5 μg/m3), see “Guideline on the Use of Models and Other Analysis in Demonstrating 

Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze (April 2007). 

Because the 2009 future year design value for the Cincinnati nonattainment area is below the 

annual fine particle standard but within the 14.5 to 15.5 μg/m3 (14.6 μg/m3 at the Murray Rd. 

ambient fine particle monitor), Indiana is including a weight of evidence analysis to demonstrate 

that the area will attain the standard by the required date. 

The weight of evidence analysis relies on existing modeling conducted by LADCO and U.S. 

EPA for CAIR and reductions from additional control measures to be implemented that were not 

included in the modeling analyses. The weight of evidence analysis further supports the fact that 

the design value will continue downward and leads to the conclusion that the nonattainment area 

will comply with the fine particle standard by the attainment date. 

7.1. LADCO’S ROUND 5 MODELING

LADCO conducted modeling to determine the impact of CAIR in the Midwest. LADCO’s 

modeling used the CAMx applied to the year 2005 meteorology, as processed by MM5. 

Emissions input into CAMx included sulfur dioxide, nitrogen oxides, volatile organic 

compounds, ammonia and direct PM2.5 for 2005. The modeling was based on 2003 through 

2006 design values. Future year modeling for 2009, 2012, and 2018 was conducted and the 

future year design values were determined, as shown below in Table 7.1. 
 52 

 

 

Table 7.1 

LADCO’s Round 5 Modeling Results for the Clean Air Interstate Rule 

Monitor ID 

Monitor 

Name County 

Design 

Value 

2003-2006 

Futurecase 

with CAIR 

2009 

Futurecase 

with CAIR 

2012 

Futurecase 

with CAIR 

2018 

(μg/m3) (μg/m3) (μg/m3) (μg/m3) 

390170003 Bonita & St John Butler 16.1 13.3 13.2 12.6 

390170016 Nilles Rd. Butler 15.8 13.0 13.0 12.4 

390170017 Wilwood Butler 16.1 13.6 13.5 12.9 

390171004 Hook Field Airport Butler 14.9 12.4 12.3 11.8 

390250022 Clermont Dr. Clermont 14.7 11.8 11.7 11.2 

390610006 Grooms Rd. Hamilton 15.5 12.7 12.6 12.1 

390610014 Seymour & Vine St. Hamilton 17.4 14.4 14.3 13.7 

390610040 Howard Taft Hamilton 15.5 12.7 12.6 12.1 

390610041 Winneste Ave. Hamilton 15.4 13.0 12.9 12.3 

390610042 W. 8th St. Hamilton 17.0 13.9 13.8 13.2 

390610043 E. Kemper Rd. Hamilton 15.6 12.9 12.8 12.3 

390617001 Sherman Ave. Hamilton 16.3 13.3 13.2 12.7 

390618001 Murray Rd. Hamilton 17.7 14.6 14.5 13.9 

210373002 Alexandria Pk. Campbell 13.3 11.6 11.5 11.0 

211170007 Univ. College Kenton 14.4 11.8 11.7 11.2 

Results of the LADCO CAIR modeling show that all counties within the Cincinnati fine particle 

nonattainment area will attain the annual NAAQS for fine particles of 15 μg/m3

 by 2009. As 

shown in Figure 7.1, future year modeled annual fine particle concentrations for 2009 will be 

13% to 20% lower than baseline annual fine particle design values, 14% to 20% lower in 2012 

and 17% to 24% lower in 2018 and will continue to decrease, thereafter. 
Figure 7.1 

Graph of Modeling Results for Cincinnati Area PM2.5 Monitors for 2009, 2012 and 2018 

10

11

12

13

14

15

16

17

18

2005 2009 2012 2018

Concentrations (ug/m3)

Standard Bonita & St John Nilles Rd. Wilw ood

Hook Field Airport Clermont Dr. Grooms Rd Seymour & Vine St.

How ard Taft Winneste Ave. W. 8th St. E. Kemper Rd.

Sherman Ave. Murray Rd. Fort Thomas Covington

7.2 LADCO’S ROUND 5 SPECIATED MODELED ATTAINMENT TEST RESULTS

The Speciated Modeled Attainment Test (SMAT) is the attainment test for annual fine particles. 

To determine the future year annual fine particle concentrations, speciated data is calculated. 

The different species that were modeled and are associated with fine particles include sulfates, 

nitrates, organic carbon, elemental carbon, ammonium, particle bound water, “other” primary 

inorganic fine particles and passively collected mass. The SMAT results from LADCO’s Round 

5 modeling are listed below. Percent ranges of the modeled results from the fine particle 

monitors in the Cincinnati area were broken down into these speciated constituents of fine 

particle emissions. The percent change from the observed and spatial fields speciated data in 

2005 to the future year modeled results for 2009 are listed below in Table 7.2. 

 53 

 

 
 54 

 

 

Table 7.2 

LADCO’s Round 5 SMAT Modeling Results for the Cincinnati Area 

(Percent reduction observed from 2005 to 2009 modeled concentrations) 

Species of PM2.5 2009 

Sulfates 29% - 36% 

Nitrates -9% - 0% 

Organic Carbon -6% - (-2%) 

Elemental Carbon 0% - 17% 

Ammonium 19% - 26% 

Particle Bound Water 24% - 38% 

The results show that sulfate, ammonium and particle bound water concentration decreases are 

projected to occur by at least 19% in the future year 2009. Lesser elemental carbon reductions 

are projected to occur, up to 17%, with nitrate and organic carbon increases occurring up to 9%. 

LADCO modeling shows good performance for sulfates and elemental carbon predicted baseline 

concentrations, slight over-prediction for nitrate concentrations and under-predictions of organic 

carbon concentrations. Overall, model performance is adequate for SIP planning and gives a 

good idea of the effects of emissions reductions from national emission control measures for the 

Cincinnati area. 

7.3 LADCO’S ROUND 5 PARTICULATE SOURCE APPORTIONMENT RESULTS 

Particulate Source Apportionment (PSAT) modeled was also conducted by LADCO. The results 

of the PSAT Round 5 modeling show the contributions from regional and emissions sectors on 

each monitor that was modeled. Chart 7.1 below shows the regional and emissions sector 

contributions for the Murray Rd. fine particle monitor, with Ohio being the biggest regional 

contributor. The PSAT Round 5 modeling results show the majority of Indiana’s emissions 

sector contributions to fine particle concentrations at the Murray Rd. ambient monitor come from 

electric generating units (EGUs), ammonium, onroad emissions sources, off-road (including 

marine, aircraft and railroad), non-EGU and area sources. These results are considered to be 

representative of the entire Cincinnati area as EGU, mobile and ammonium emissions impact on 

the entire area. 
Chart 7.1 

Regional/Emissions Sector PSAT Results Murray Road, Hamilton Co., PM2.5 Monitor 

The following pie charts depict the species contributions to fine particle concentrations at the 

Cincinnati area fine particle monitors. The pie charts include both the observed 2005 

contributions and future year 2009 modeled contributions for each monitor. Since the monitors 

are in close proximity of each other, results are fairly similar in the distribution of species 

concentrations among the monitors. Charts 7.2 and 7.3 cover the fine particle monitors in the 

Cincinnati area that are used to determine compliance with the annual NAAQS. 

 55 

 

 
CHART 7.2 

Modeled Species Contributions to St. Bernard, OH - Murray Rd. PM2.5 Monitor 

Observed 2005 Contributions at St. Bernard - Murray Rd 

PM2.5 Monitor

so4

35%

no3

8%

oc

23%

ec

4%

soil

3%

nh4

13%

pbw

11%

blan

3%

so4

no3

oc

ec

soil

nh4

pbw

blan

2009 Modeled Contributions at St. Bernard - Murray Rd 

PM2.5 Monitor

so4

27%

no3

10%

oc

27%

ec

5%

soil

5%

nh4

13%

pbw

9%

blan

4%

so4

no3

oc

ec

soil

nh4

pbw

blan

CHART 7.3 

Modeled Species Contributions to Covington, KY - University College PM2.5 Monitor 

Observed 2005 Contributions at Covington - University College 

PM2.5 Monitor

so4

35%

no3

8%

oc

23%

ec

4%

soil

3%

nh4

13%

pbw

11%

blan

3%

so4

no3

oc

ec

soil

nh4

pbw

blan

2009 Modeled Contributions at Covington - University College 

PM2.5 Monitor

so4

27%

no3

10%

oc

27%

ec

5%

soil

5%

nh4

13%

pbw

9%

blan

4%

so4

no3

oc

ec

soil

nh4

pbw

blan

Results of the Round 5 PSAT modeling for all the Cincinnati area fine particle monitors (see 

Appendix E) show the highest pollutant contributors to basecase and future year fine particle 

concentrations are sulfate, organic carbon, ammonium and nitrate. Future year modeling show 

decreases in sulfates (due to the emissions reductions from CAIR) and ammonium. The future 

year modeling did show slight increases in organic carbon and nitrates from the basecase 

modeled concentrations. However, these increases are offset by the larger decreases in sulfates. 

7.4 DAILY MONITORED DATA COMPARISON FOR CINCINNATI PM2.5

MONITORING SITES 

The consistent PSAT results are evident in the monitoring data through the Cincinnati fine 

particle nonattainment area, as the trends for each of the Cincinnati area monitors follow each 

other on a daily and annual basis. The daily monitored data was compared for each year 

between 2003 through 2006. Analyzed for all monitored fine particle days, the Cincinnati area 

fine particle monitors had average daily impacts which varied from 6 to 10 μg/m3

; some days 

had impacts greater between the urban and rural sites. Average annual impacts between 5.2 and 

 56 

 

 
7.6 μg/m3 of each fine particle monitor in the Cincinnati area, indicating a more urban influence 

to 

the fine particle concentrations in the area. As can be seen in Figure 7.2, all of the Cincinnati

area fine particle monitors track fairly close together each year with higher fine particle episodes 

evident in 2005. 

Figure 7.2 

Daily Monitoring Data Comparison for Cincinnati PM2.5 Monitors 

2003 2004 

Cincinnati OH-KY-IN Nonattainment Area

2003 PM2.5 Monitor Data

0

10

20

30

40

50

60

1-Jan

1-Feb1-Mar1-Apr

1-May

1-Jun

1-Jul

1-Aug

1-Sep

1-Oct

1-Nov1-Dec

1-Jan

Calendar Year 2005

Micrograms/Cubic Meter

Ft Thomas

Covington

Bonita

Nilles

Wildwood

Hook

Seymour/Vine

Taft

Winneste

W. 8th St.

Kemper Rd.

Sherman Rd.

Murray

Cincinnati OH-KY-IN Nonattainment Area

2004 PM2.5 Monitor Data

0

10

20

30

40

50

60

1-Jan

1-Feb1-Mar1-Apr

1-May

1-Jun

1-Jul

1-Aug

1-Sep

1-Oct

1-Nov1-Dec

1-Jan

Calendar Year 2005

Micrograms/Cubic Meter

Ft. Thomas

Covington

Bonita

Nilles

Wildwood

Hook

Seymour/Vine

Taft

Winneste

W. 8th St.

Kemper Rd.

Sherman

Murray

2004 chart

2005 2006 

Cincinnati OH-KY-IN Nonattainment Area

2005 PM2.5 Monitor Data

0

10

20

30

40

50

60

1-Jan

1-Feb1-Mar

1-Apr

1-May

1-Jun

1-Jul

1-Aug1-Sep

1-Oct

1-Nov1-Dec

1-Jan

Calendar Year 2005

Micrograms/Cubic Meter

Ft. Thomas

Covington

Bonita

Nilles

Wildwood

Hook

Clermont

Grooms

Seymour/Vine

Taft

Winneste

W. 8th St.

Kemper Rd

Sherman

Murray

Southwest Indiana

2006 PM2.5 Monitor Data

0

10

20

30

40

50

60

1-Jan

1-Feb1-Mar

1-Apr

1-May

1-Jun

1-Jul

1-Aug1-Sep

1-Oct

1-Nov

1-Dec

1-Jan

Calendar Year 2006

Micrograms/Cubic Meter

Ft. Thomas

Covington

Bonita

Nilles

Wildwood

Clermont

Grooms

Seymour/Vine

Taft

W. 8th St.

Kemper Rd.

Sherman

Murray

7.5 SUMMARY OF ASSOCIATION FOR SOUTHEASTERN INTEGRATED PLANNING 

(ASIP) MODELING FOR KENTUCKY

Kentucky is located in a different U.S. EPA region than Indiana. Region 4 has a separate 

technical support group that conducts emissions, monitoring and photochemical modeling for all 

 57 

 

 
 58 

 

 

the Region 4 states, including Kentucky. This group is known as the Association for 

Southeastern Integrated Planning (ASIP). ASIP has conducted photochemical modeling for 

annual fine particles, using the Community Multiscale Air Quality (CMAQ) model with their 

BaseG4 emissions and meteorology taken from 2002. 

Modeling results for the Cincinnati-Hamilton OH-KY-IN fine particle nonattainment area show 

the highest modeled annual fine particle concentrations for Hamilton County, Ohio will exceed 

the annual fine particle NAAQS of 15.0 μg/m3. ASIP modeled at a 12 kilometer grid resolution 

and the 12 km results showed modeled values to be less than 15.0 μg/m3 in all but one urban fine 

particle monitor in Hamilton County in Ohio. 

Table 7.3 

ASIP’s BaseG4 Annual PM2.5 Modeling Results 

Monitor ID 

Monitor 

Name County 

Design Value 

2000-2004 

Basecase 

2009 

12 km 

(μg/m3) (μg/m3) 

39-017-0003 Bonita & St John Butler 16.05 14.06 

39-017-0016 Nilles Rd. Butler 15.68 13.40 

39-017-0017 Wilwood Butler 15.38 13.38 

39-017-1004 Hook Field Airport Butler a a

39-025-0022 Clermont Dr. Clermont a a

39-061-0006 Grooms Rd. Hamilton a a

39-061-0014 Seymour & Vine St. Hamilton 17.67 15.44 

39-061-0040 Howard Taft Hamilton 15.56 13.33 

39-061-0041 Winneste Ave. Hamilton 15.40 13.16 

39-061-0042 W. 8th St. Hamilton 17.10 14.87 

39-061-0043 E. Kemper Rd. Hamilton 15.76 13.47 

39-061-7001 Sherman Ave. Hamilton 16.26 14.01 

39-061-8001 Murray Rd. Hamilton 17.24 15.03 

21-037-0003 Fort Thomas Campbell 14.00 11.98 

21-117-0007 Univ. College Kenton 14.88 12.68 a

 No Speciated Modeled Attainment Test data available 

Further results can be found in Appendix J, which shows charts of all Ohio and Kentucky fine 

particle sites and the results of the BaseG4 modeling. All sites fall below the annual fine particle 

NAAQS with the exception of the Seymour & Vine St. fine particle monitor, which had a 

modeled fine particle concentration of 15.44 μg/m3

. Decreases in concentrations from the base 

year design values, based on 2000-2004, to the modeled future year of 2009 were approximately 

2.0 μg/m3

. Therefore, reductions in current monitored design values would further reflect the 

decreasing concentrations in the future. The monitored design value ASIP used for the Seymour 

and Vine St. fine particle monitor, taken from 2000-2004, was 17.67 μg/m3

, where as the current 

design value from 2003-2007 is 17.27 μg/m3

. This decrease of 0.4 μg/m3, reflective of more 
 59 

 

 

current emissions, would provide a modeled future year design value below the annual fine 

particle NAAQS. 

Results from the LADCO and ASIP modeling are different for a number of reasons. LADCO 

used the Comprehensive Air Quality Model with extension (CAMx) while ASIP used the 

Community Multiscale Air Quality model (CMAQ). Both models are photochemical models but 

have different computing algorithms. Another difference is the baseyear emissions and 

meteorological data modeled; LADCO modeled 2005 emissions and 2005 meteorology while 

ASIP modeled 2002 emissions and 2005 meteorology. Fine particle conducive conditions were 

evident for both years with higher fine particle readings evident in Southern Indiana in 2005. 

7.6 SUMMARY OF ATTAINMENT TEST MODELING RESULTS

Indiana, in conjunction with LADCO, has performed technical analyses on the air quality in the 

Midwest in order to develop SIPs for areas that do not presently attain current NAAQS, 

including the Cincinnati area. LADCO provided the technical support in order to conduct the air 

quality analyses necessary to demonstrate future-year compliance with the current annual fine 

particle NAAQS. Results of the attainment test for annual fine particles for the Cincinnati area 

show that the area will attain the current annual fine particles NAAQS by 2009, one year before 

the attainment date deadline of 2010. 

Additional analyses, using particulate source apportionment (PSAT) and outputs from the 

Speciated Modeled Attainment Test (SMAT), show that regional, emissions sector and species 

contributions to fine particle concentrations overall in the Cincinnati area will be reduced in the 

future. Species contributions are fairly consistent between all the Cincinnati area monitors and 

emissions reductions will result in similar decreases in fine particle concentrations as well as 

species contributions to fine particle composition throughout the Cincinnati area. Sulfates are 

the highest contributing species of fine particles composition in the Cincinnati area and will be 

reduced as a result of the Clean Air Interstate Rule as well as other emissions control regulations. 

LADCO modeling for future year design values have shown that existing national emissions 

control measures will reduce fine particle concentrations in the Cincinnati area and bring the 

nonattainment counties into attainment of the annual NAAQS for fine particles. Emissions 

control measures to be implemented in the next several years, including the Clean Air Interstate 

Rule will help the area attain the annual standard for fine particles with modeled future year 

design values below 15 μg/m3

. Future national and local emissions control strategies will ensure 

that each Cincinnati area county will continue to maintain the annual fine particle standard of 

15.0 μg/m3 with an increasing margin of safety over time. 
 60 

 

 

8.0 MOBILE SOURCE EMISSIONS BUDGET

The following is a summary of the detailed mobile input and output calculation files located in 

Appendix H. 

8.1 ON-ROAD EMISSIONS ESTIMATIONS 

The Ohio-Kentucky-Indiana Regional Council of Governments (OKI) is the Metropolitan 

Planning Organization (MPO) for the Greater Cincinnati/Northern Kentucky area which includes 

Dearborn County in Indiana; Butler, Clermont, Clinton, Hamilton, and Warren counties in Ohio; 

as well as, Boone, Campbell and Kenton counties in Kentucky. This organization maintains a 

travel demand forecasting model that is used to simulate the traffic in the area and to predict 

what traffic would be in future years given growth expectations. The model is used mostly to 

identify where travel capacity will be needed and to determine the infrastructure requirements 

necessary to meet that need. It is also used to support the calculation of mobile source 

emissions. The travel demand forecasting model is used to predict the total daily vehicle miles 

traveled (VMT) and the U.S. EPA software program referred to as MOBILE6 is used to produce 

emission factors to calculate the emissions per mile. The product of these two outputs, once 

combined, is the total amount of pollution emitted by on-road vehicles for the particular 

analyzed area. 

8.2 OVERVIEW 

Broadly described, MOBILE6 is used to determine “emissions factors”, which are the average 

emissions per mile (grams/mile) for direct PM2.5 and PM2.5 precursors, including NOx and SO2. 

There are numerous variables that can affect the emission factors. The vehicle fleet (vehicles on 

the road) age and the vehicle-types have a major effect on the emission factors. The facility type 

the vehicles are traveling on (MOBILE6 facility types are Freeway, Arterial, Local and Ramp) 

and the vehicle speeds also affect the emission factor values. Meteorological factors, such as air 

temperature and humidity, affect the emission factors and any Vehicle Inspection/Maintenance 

program in the area will also affect emissions. These data are estimated using the best available 

data to create emission factors for direct PM2.5 and PM2.5 precursors including NOx and SO2. 

After emission factors are determined, the emission factor(s) must be multiplied by the VMT to 

determine the quantity of vehicle-related emissions. This information derives from the travel 

demand model. 

It should be noted that each year analyzed will have different emission factors, volumes, speeds, 

and likely some additional links. MOBILE6 input and output files can be found in Appendix H. 

8.3 EMISSIONS ESTIMATIONS 

Table 8.1 outlines the on-road emissions estimates for the entire nonattainment area, with 

subtotals for the Indiana and Ohio portions of the nonattainment area, for the years 2005 and 

2009. The 2005 and 2009 emissions estimates are based on the actual travel demand model 

network for the years 2005 and 2009. 
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Table 8.1 

Emissions Estimations for On-Road Mobile Sources 

Cincinnati NA Area Total 2005 2009 

PM2.5 (tons/year) 758.54 551.82 

NOx (tons/year) 43,955.54 33,851.76 

Indiana and Ohio 

Emissions Subtotal 

PM2.5 (tons/year) 608.94 439.96 

NOx (tons/year) 35,203.94 27,007.22 

Lawrenceburg Township/IN 

(Emissions Subtotal) 

PM2.5 (tons/year) 8.84 6.12 

NOx (tons/year) 497.76 359.72 

Lawrenceburg Township/IN 

(Percent of NA Area Subtotal) 

PM2.5 (tons/year) 1.17% 1.11% 

NOx (tons/year) 1.13% 1.06% 

Table 8.2 contains the motor vehicle emissions budget (Budget) for 2009. 

 

Table 8.2 

Mobile Vehicle Emissions Budget 

2009 

PM 2.5 (tons/year) 461.96 

NOx (tons/year) 28,357.58 

Consistent with the federal implementation rule for fine particles, Indiana does not consider SO2

from on-road mobile sources to be a significant contributor to fine particles for this 

nonattainment area, as they constitute below 3.5% of the area’s projected total SO2 emissions. 

This document creates a motor vehicle emission’s budget (Budget) for 2009 for the Indiana and 

Ohio portions of the nonattainment area that describes the maximum on-road emissions that 

cannot be exceeded from the year 2009 and beyond. The emission estimates are derived from 
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the MPO’s travel demand model and Mobile6 as described above. A reasonable cushion has 

been applied to the Budget for the year 2009. Cushions are used to accommodate the impact of 

refined assumptions in the modeling process. With the cushion applied to the 2009 projected 

emissions, the 2009 Budget total PM2.5 and NOx emissions remain well below the base year 

emissions for the Indiana and Ohio portions of the nonattainment area referenced in Table 8.1. 

All methodologies, latest planning assumptions and the cushions were determined through the 

interagency consultation process. 

9.0 CONTINGENCY MEASURES 

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. Listed below are example 

measures that may be considered. The selection of measures will be based upon costeffectiveness, emissions reduction potential, economic and social considerations or other factors 

that IDEM deems appropriate. IDEM will solicit input from interested and affected persons in 

the nonattainment area prior to selecting appropriate contingency measures. All of the listed 

contingency measures are potentially effective or proven methods of obtaining significant 

reductions of fine particle precursor emissions. Because it is not possible at this time to 

determine what control measure will be appropriate at an unspecified time in the future, the list

of contingency measures outlined below is not comprehensive. Indiana anticipates that if 

contingency measures should ever be necessary, it is unlikely that a significant number (i.e., all 

those listed below) will be required. 

1) Alternative fuel and diesel retrofit programs for fleet vehicle operations. 

2) Require NOx or SO2 emissions offsets for new and modified major sources. 

3) Require NOx

4) Increase the ratio of emissions offsets required for new sources. 

or SO2 emissions offsets for new and modified minor sources. 

5) Require NOx or SO2 controls on new minor sources (less than 100 tons). 

6 Wood stove change-out program. 

7) Require increased recovery efficiency at sulfur recovery plants. 

8) Various emissions reduction measures or dust suppressant for unpaved roads and/or parking 

lots. 

9) Idling Restrictions. 

10) Broader geographic applicability of existing measures. 

11) One or more transportation control measures sufficient to achieve at least a half a percent 

(0.5%) reduction in actual area-wide precursor emissions. Transportation measures will be 

selected from the following, based upon the factors listed above, after consultation with 

affected local governments: 

a) Trip reduction programs, including, but not limited to, employer-based transportation 

management plans, area wide rideshare programs, work schedule changes, and 

telecommuting. 

b) Transit improvements. 

c) Traffic flow improvements. 
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d) Other new or innovative transportation measures not yet in widespread use that affects 

state and local governments deemed appropriate. 

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. 

10.0 PUBLIC PARTICIPATION 

Indiana published notification for a public hearing and solicitation for public comment 

concerning the draft Attainment Demonstration Plan in the Indianapolis Star, Indianapolis, 

Indiana; Dearborn County Register, Lawrenceburg, Indiana; the Rising Sun Recorder, Rising 

Sun, Indiana; the Ohio County News, Rising Sun, Indiana; and, the Versailles Republican, 

Versailles, Indiana on or before April 4, 2008. 

A public hearing to receive comments on the attainment demonstration plan was held on May 8, 

2008, at the Lawrenceburg Public Library, Depot Meeting Room, 150 Mary Street, 

Lawrenceburg, Indiana and no comments were received. The public comment period closed on 

May 9, 2008. One comment letter was received during the public comment period. Appendix I 

includes a copy of the public notice, certifications of publication, the transcript from the public 

hearing, public hearing attendance record, copies of all written comments received and a 

summary of comments received that includes IDEM’s responses, as applicable. 

11.0 CONCLUSION 

Monitored air quality in the Cincinnati fine particle nonattainment area has shown steady 

decreases in fine particle levels as a result of national and local control strategies implemented 

since designation. In fact, the current design value for the nonattainment area is within 1 

microgram per cubic meter of the standard. The design value in the area has dropped since 2001 

and is predicted to continue to decline and achieve compliance with the standard in an expedient 

fashion. 

This demonstration shows that NOx and SO2 emissions reductions since designation have had a 

positive effect on regional fine particle levels. This attainment demonstration shows that once 

the photochemical modeling results are considered along with additional national, regional, and 

local control measures to be phased-in or implemented in 2008 and 2009, air quality in the area 

will achieve attainment of the fine particles standard by April 5, 2010, and provide for an ample 

margin of safety. 

Indiana has submitted an analysis that shows the air quality improvements are due to permanent 

and enforceable measures and that additional significant regional NOx and SO2 reductions 

following implementation of Phase II NOx SIP Call and CAIR will ensure continued compliance 

(maintenance) with the standard. 
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This plan satisfies Indiana’s obligation under Section 172(c) of the CAA to demonstrate how the 

area will attain the air quality annual standard for fine particles by the attainment date, and, as a 

result, realize cleaner air. The development of this plan will bring this region into compliance 

with state and federal fine particle air quality standards, and provide real progress in the state’s 

journey toward cleaner air.