STEVEN L. BESHEAR 

GOVERNOR 

Ms. Gwendolyn Keyes Fleming 

Regional Administrator 

U.S. EPA, Region 4 

Sam Nunn Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, Georgia 30303 

ENERGY AND ENVIRONMENT CABINET 

OFFICE OF THE SECRETARY 

500 MERO STREET 

12TH FLOOR, CAPITAL PLAZA TOWER 

FRANKFORT, KY 40601 

TELEPHONE: 502-564-3350 

FACSIMILE: 502-564-3354 

February 9, 2012 

RE: Redesignation ofKentucky Portion ofthe Huntington-Ashland WV-KY-OH 

Fine Particulate Nonattainment Area 

Dear Ms. Fleming: 

LECNARD K. PETERS 

SECRETARY 

Enclosed for your consideration is the final revision to Kentucky's State Implementation Plan to redesignate 

the Kentucky portion of the Huntington-Ashland WV-KY-OH PM2.5 nonattainment area (Boyd and a portion ofLawrence 

County) as attainment for the PM2.5 National Ambient Air Quality Standard. 

A public hearing to receive comments on this revision was scheduled for December 22, 2011, at 6:00 p.m. in 

the Conference Room of the Ashland-Boyd County Health Department, 2916 Holt Street, Ashland, Kentucky. No request 

for a public hearing was received, and the hearing was cancelled. Comments were received during the 30-day comment 

period. A copy of the public hearing notice and the statement of consideration are included in this submittal. 

West Virginia and Ohio are making separate redesignation requests for their respective portions of the 

metropolitan area and have submitted those demonstrations to U.S. EPA, Region 5. 

Your prompt consideration of this request is appreciated. If you have any questions or comments concerning 

this matter, please contact Andrea Smith with the Division for Air Quality at (502) 564-3999. 

Enclosures 

cc: Beverly Banister 

R. Scott Davis 

Sincerely yours, 

Leonard K. Peters 

Secretary 
REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

THE KENTUCKY PORTION OF THE 

HUNTINGTON-ASHLAND,

OH-KY-WV

ANNUAL PM2.5

NONATTAINMENT AREA

Boyd and a portion of Lawrence 

Counties, Kentucky

Prepared by:

Energy and Environment Cabinet

Kentucky Division for Air Quality

February 8, 2012
2 

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3

TABLE OF CONTENTS

Chapter One-Introduction........................................................................................................ 7

Geographical description and background ................................................................................. 8

Status of air quality..................................................................................................................... 9

Clean Data Determination .......................................................................................................... 9

Chapter Two-Requirements for redesignation..................................................................... 11

Chapter Three-PM2.5 monitoring............................................................................................ 16

Ambient data quality assured ................................................................................................... 16

Data handling guidelines .......................................................................................................... 16

Commitment to continue monitoring ......................................................................................... 20

Chapter Four-Emission inventory......................................................................................... 21

Base year inventory.................................................................................................................. 21

Emission projections ................................................................................................................ 22

Demonstration of maintenance................................................................................................. 31

Permanent and enforceable emissions reductions ................................................................... 47

Provision for future inventory update........................................................................................ 48

Chapter Five-Control measures and regulations................................................................. 49

Nonattainment areas to implement RACM and RACT.............................................................. 49

Show Reasonable Further Progress (RFP) .............................................................................. 50

Emission inventories ................................................................................................................ 50

Implementation of previous SIP revisions................................................................................. 51

New source review provisions ................................................................................................. 59

Assurance of continued controls .............................................................................................. 59

Chapter Six-Contingency measures ..................................................................................... 60

Commitment to review maintenance plan................................................................................. 60

Commitment for contingency measures to be implemented ..................................................... 60

Potential contingency measures............................................................................................... 61

List of PM2.5, SO2, and NOx sources ......................................................................................... 62

Chapter Seven

Public participation ................................................................................................................... 63

Chapter Eight

Conclusions ............................................................................................................................. 64
4

FIGURES

Figure 1 Map of the Huntington-Ashland, OH-KY-WV nonattainment area and monitor locations ..............................17

Figure 2 PM2.5 Annual Mean National Trends..............................................................................................................20

TABLES

Table 1 ............Monitoring Data for Huntington-Ashland, OH-KY-WV area for 2008 - 2010....................................19

Table 2 ............Adams County, Ohio Emission Estimations for On-road Mobile Sources .......................................28

Table 3 ............Gallia County, Ohio Emission Estimations for On-road Mobile Sources .........................................28

Table 4 ............Lawrence County, Ohio Emission Estimations for On-road Mobile Sources ...................................28

Table 5 ............Scioto County, Ohio Emission Estimations for On-road Mobile Sources.........................................28

Table 6 ............Summary of Ohio Emissions Estimations for On-road Mobile Sources..........................................28

Table 7 ............Boyd County, Kentucky Emission Estimations for On-road Mobile Sources ...................................29

Table 8 ............Lawrence County (partial), Kentucky Emission Estimations for On-road Mobile 

Sources ..........................................................................................................................................29

Table 9 ............Summary of Kentucky Emission Estimations for On-Road Mobile Sources ....................................29

Table 10............Cabell County, West Virginia Emission Estimations for On-road Mobile Sources ...........................29

Table 11............Mason County (partial), West Virginia Emission Estimations for On-road Mobile 

Sources ..........................................................................................................................................30

Table 12............Wayne County, West Virginia Emission Estimations for On-road Mobile Sources ..........................30

Table 13............Summary of West Virginia Emissions Estimations for On-road Mobile Sources ............................30

Table 14............Emission Estimations Totals for On-road Mobile Sources for Huntington-Ashland

Area ..........................................................................................................................................30

Table 15............Percent of Mobile Emissions for the Huntington-Ashland Area in 2015 and 2022...........................31

Table 16............Reductions in SO2 and NOx EGU Emissions Between 1990 and 2010...........................................34

Table 17............Adams County, Ohio PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR.............................................36

Table 18............Gallia County, Ohio PM2.5 Emission Inventory Total for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – Without CAIR..............................................................36

Table 19............Lawrence County, Ohio PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR.............................................36

Table 20............Scioto County, Ohio PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR.............................................37

Table 21............Boyd County, Kentucky PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR.............................................37

Table 22............Lawrence County, Kentucky PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR.............................................37

Table 23............Cabell County, West Virginia PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR.............................................38

Table 24............Mason County, West Virginia PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR.............................................38

Table 25............Wayne County, West Virginia PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR.............................................38

Table 26............Huntington-Ashland Area PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – Without CAIR.............................................39

Table 27............Adams County, Ohio NOx Emission Inventory Total for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR...................................................................39

Table 28............Gallia County, Ohio NOx Emission Inventory Total for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR.................................................................. 39

Table 29............Lawrence County, Ohio NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................40

Table 30............Scioto County, Ohio NOx Emission Inventory Total for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR...................................................................40

Table 31............Boyd County, Kentucky NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................40

Table 32............Lawrence County, Kentucky NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................41

Table 33............Cabell County, West Virginia NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................41
5

Table 34............Mason County, West Virginia NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................41

Table 35............Wayne County, West Virginia NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................42

Table 36............Huntington-Ashland Area NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................42

Table 37............Adams County, Ohio SO2 Emission Inventory Total for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR...................................................................42

Table 38............Gallia County, Ohio SO2 Emission Inventory Total for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR...................................................................43

Table 39............Lawrence County, Ohio SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................43

Table 40............Scioto County, Ohio SO2 Emission Inventory Total for Base Year 2005, Estimated 

2008, and Projected 2015 and 2022 (tpy) – With CAIR...................................................................43

Table 41............Boyd County, Kentucky SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................44

Table 42............Lawrence County, Kentucky SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................44

Table 43............Cabell County, West Virginia SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................44

Table 44............Mason County, West Virginia SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................45

Table 45............Wayne County, West Virginia SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................45

Table 46............Huntington-Ashland Area SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2022 (tpy) – With CAIR..................................................45

Table 47............Huntington-Ashland Comparison of 2008 attainment year and 2015 and 2022

projected emission estimates (tpy)..................................................................................................46

Table 48............Huntington-Ashland Area Combined Comparison of 2005 base year and 2008 

attainment year on-road, non-road and EGU reductions.................................................................48

APPENDICES

A............Air Quality System (AQS) Data and Federal Registers

B............Kentucky 2005 SIP Base Year Inventory Discussion, Spreadsheets,

 and QAPP letter

C............Mobile Source Emissions Inventory for the Huntington-Ashland PM2.5

 Nonattainment Area and USEPA Finding of Insignificance letter,

 March 23, 2010

D............VISTA and LADCO Technical Support Documents

E............Kentucky’s PM2.5 Attainment Demonstration submitted December 31,

 2008 (provided as electronic copy on disc) and Federal Register

F............ Public Participation Documentation and Statement of Consideration
6 

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7

REDESIGNATION REQUEST AND MAINTENANCE PLAN

FOR THE KENTUCKY PORTION OF THE HUNTINGTON-ASHLAND, 

OH-KY-WV

ANNUAL PM2.5 NONATTAINMENT AREA

Boyd and a portion of Lawrence Counties, Kentucky

CHAPTER ONE - INTRODUCTION

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

annual National Ambient Air Quality Standards (NAAQS) to develop State 

Implementation Plans (SIPs) to expeditiously attain and maintain the 

standards. The United States Environmental Protection Agency (U.S. EPA) 

revised the NAAQS for particulate matter in July 1997. It replaced the 

existing PM10 standard with a health based PM2.51standard and retained 

the PM10 standard as a particulate standard protecting welfare. The 

standards include an annual standard set at 15.0 micrograms per cubic 

meter (μg/m3), based on the 3-year average of annual mean PM2.5 

concentrations and a 24-hour standard of 65 μg/m3, based on the 3-year 

average of the 98th percentile of 24-hour concentrations.

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

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

D.C. Circuit remanded, without vacatur, the standards back to U.S. EPA. 

The remand did not question the level at which U.S. EPA set the standards 

but rather the constitutionality of the CAA provision that authorizes U.S. 

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

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

appealed the D.C. Circuit decision to the U.S. Supreme Court. The U.S. 

Supreme Court issued a decision on February 27, 2001 that unanimously 

affirmed the constitutionality of the CAA provision but did remand several 

other issues back to the D.C. Circuit, including the issue of whether U.S. 

EPA acted arbitrarily and capriciously in establishing the specific levels of 

the standards.

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

2001, and issued its decision on March 26, 2002. The D.C. Circuit rejected 

the claims that the U.S. EPA had acted arbitrarily and capriciously in 

setting the levels of the standards. 

 

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

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

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

as fragments of pollen or mold spores).

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

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

formed secondarily in the atmosphere.
8

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

nonattainment areas designations for the PM2.5 standards across the 

country. Modifications to those designations were made and an effective 

date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendments of 

1990 which defined five ozone nonattainment classifications for the areas 

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

nonattainment designations are simply labeled “nonattainment.” The CAA 

Amendments require states with PM2.5 nonattainment areas to submit a 

plan within three years of the effective date of the designations (April 5, 

2008) detailing how the PM2.5 standards will be attained by April 5, 2010. 

The Kentucky Division for Air Quality (KYDAQ) submitted its attainment 

demonstration for the entire state on December 3, 2008.

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

areas to be redesignated to attainment provided certain criteria are met. 

The following are the criteria that must be met in order for an area to be 

redesignated from nonattainment to attainment: 

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

standard.

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

under Section 110(k).

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

to permanent and enforceable reductions in emissions 

resulting from implementation of the SIP and other federal 

requirements.

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

v) A determination that all Section 110 and Part D 

requirements have been met. 

This document addresses each of these requirements, and provides 

additional information to support continued compliance with the annual 

PM2.5 standard.

Geographical Description and Background

The current Huntington-Ashland nonattainment area is located in eastern 

Kentucky and includes the following counties: Boyd and Lawrence (partial 

nonattainment of Lawrence County described by U.S. Census 2000 block 

group identifier 21-127-9901-6) in Kentucky; Adams (partial nonattainment 

of Monroe and Sprigg townships only), Gallia (partial nonattainment of 

Cheshire Township only), Lawrence and Scioto in Ohio; and Cabell, Wayne 

and Mason (partial nonattainment of Graham Tax District only), in West 

Virginia. This area is shown in Figure 1 under Chapter Three.
9

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

Huntington-Ashland area nonattainment for the 15.0 μg/m3annual 

standard2, and KYDAQ was required to develop a plan to reduce oxides of 

nitrogen (NOx), sulfur dioxide (SO2) and direct PM2.5 emissions and to 

demonstrate that the area will meet the federal annual air quality standard 

by April 5, 2010. Kentucky’s main PM2.5 components are primary particles 

(organic carbon, crustal material, and elemental carbon), SO2 and NOx, 

which were included in the attainment demonstration analysis. Volatile 

organic compounds (VOCs) and ammonia (NH3) were not included in the 

analysis since they were not part of Kentucky’s current attainment strategy 

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

nonattainment). This is consistent with U.S. EPA’s Clean Air Particle 

Implementation Rule [72 FR 20586] (hereafter referred to as 

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

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

are not required to address VOC unless the State or U.S. EPA makes 

technical demonstration that emissions of VOCs significantly contribute to 

nonattainment of the annual PM2.5 standard.

This document is intended to support Kentucky’s request that the Kentucky 

portion of the Huntington-Ashland area be redesignated from 

nonattainment to attainment for the annual PM2.5 standard. In addition, the 

States of Ohio and West Virginia also intend to submit requests for their 

respective portions of the Huntington-Ashland area. The Ohio 

Environmental Protection Agency submitted their proposed redesignation 

of the Ohio portion on May 4, 2011. The U. S. EPA published that 

proposal in the Federal Register on December 22, 2011. (see Appendix A)

Status of Air Quality

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

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

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

NAAQS attainment, accompanied by decreases in emission levels 

discussed in Chapter Four, supports a redesignation to attainment for the 

Kentucky portion of the Huntington-Ashland area based on the 

requirements in Section 107(d)(3)(E) of the CAA as amended. 

Clean Data Determination

In the Federal Register [76 FR 55542] published September 7, 2011

(Appendix A), U.S. EPA made making two determinations regarding the 

Huntington-Ashland PM2.5 nonattainment area. First, that the area has 

attained the 1997 annual PM2.5 NAAQS based upon data available in U.S. 

EPA’s Air Quality System (AQS). This determination suspended the 

requirements for the area to submit attainment demonstrations and 

associated reasonably available control measures (RACM), a reasonable 

 

2 There were no monitors in Kentucky that violated the 1997 24-hour PM2.5 standard of 65 μg/m3.
10

further progress (RFP) plan, contingency measures, and other planning 

SIP revisions related to attainment of the standard for so long as the area 

continues to attain the annual PM2.5 standard. Second, based on qualityassured and certified monitoring data for the 2007-2009 period, the area 

has attained the NAAQS by its applicable attainment data of April 15, 2010. 
11

CHAPTER TWO – REQUIREMENTS FOR REDESIGNATION

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

Procedures for Processing Requests to Redesignate Areas to Attainment

(redesignation guidance), issued September 4, 1992, to Regional Air 

Directors. The redesignation request and maintenance plan are based on 

the redesignation guidance, supplemented with additional guidance 

received from staff of U.S. EPA Region 4.

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

Huntington-Ashland area.

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

There are two components involved in making this 

demonstration. The first component relies on ambient air 

quality data. The data that is used to demonstrate attainment 

should be the product of ambient monitoring that is 

representative of the area of highest concentration. The data 

should be collected and quality-assured in accordance with 

40 CFR 58 and recorded in the AQS in order for it to be 

available to the public for review.

The second component relies upon supplemental U.S. EPAapproved air quality modeling but is not required. Therefore, 

no modeling was included in this redesignation request.

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

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

The state must be able to reasonably attribute the 

improvement in air quality to emission reductions which are 

permanent and enforceable. The state should estimate the 

percent reduction achieved from federal measures as well as 

from control measures that have been adopted and 

implemented by the state.

For this PM2.5 redesignation, it was not necessary for 

Kentucky to adopt or implement local control measures

beyond the federal measures. 

KYDAQ adopted several rules that will have an impact on 

statewide PM2.5 emissions in the future:

Clean Air Interstate Rule (CAIR)

NOx SIP Call Rules
12

In addition, since the initial PM2.5 designations were made,

federally enforceable consent decrees have resulted in 

reductions in emissions from utilities across the state.

Chapter Four discusses these reductions in more detail in the 

demonstration of maintenance portion, Requirement 3 of 5 

(page 31).

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

For purposes of redesignation, a state must meet all 

requirements of Section 110 and Part D that were applicable 

prior to submittal of the complete redesignation request.

Subpart 1 of Part D consists of general requirements 

applicable to all areas which are designated nonattainment 

based on a violation of the NAAQS. Subpart 4 of Part D 

consists of more specific requirements applicable to 

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

the purpose of implementing the 1997 PM2.5 standard, U.S. 

EPA’s Implementation Rule stated Subpart 1, rather than 

Subpart 4, is appropriate for the purpose of implementing 

PM2.5 [72 FR 20589].

i.) Section 110(a) requirements

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

general requirements for a SIP. Section 110(a)(2) 

provides that the implementation plan submitted by a 

state must have been adopted by the state after

reasonable public notice and hearing; and that among 

other things, it must include enforceable emission 

limitations and other control measures, means or 

techniques necessary to meet the requirements of the 

CAA; provide for establishment and operation of 

appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 

provide for implementation of a source permit program 

to regulate the modification and construction of any 

stationary source within the areas covered by the plan; 

include provisions for the implementation of Part C, 

prevention of significant deterioration (PSD) and Part 

D, new source review (NSR) permit programs; include 

criteria for stationary source emission control 

measures, monitoring and reporting; include provisions 

for air quality modeling; and provide for public and 

local agency participation in planning and emission 

control rule development. In Kentucky’s September 8, 
13

2009, infrastructure SIP submissions, Kentucky 

verified that the State fulfills the requirements of 

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

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

prohibit emissions from within the State which 

contribute significantly to nonattainment or 

maintenance areas in any other State, or which 

interfere with programs under Part C to prevent 

significant deterioration of air quality or to achieve 

reasonable progress toward the national visibility goal 

for Federal class I areas (national parks and 

wilderness areas). In order to assist States in 

addressing their obligations regarding regionally 

transported pollution, U.S. EPA finalized CAIR to 

reduce SO2 and NOx emissions from large electric 

generating units (EGU). Kentucky had met the 

requirements of the federal CAIR to reduce NOx and 

SO2 emissions contributing to downwind states. On 

February 2, 2007, Kentucky’s Administrative 

Regulations (KAR) 401 KAR 51:210, 401 KAR 51:220, 

and 401 KAR 51:220 became effective. The CAIR 

replacement rule was finalized on July 6, 2011, as the 

Cross-State Air Pollution Rule (CSAPR) and will 

further assist States in addressing their obligations 

regarding regionally transported pollution by providing 

reductions in NOx and SO2 emissions in 2012 and 

2014. 

In the interim, the Kentucky regulations are still 

providing reductions. According to U.S. EPA in the 

National Program & Grant Guidance (Draft, February 

25, 2011, Publication EPA-440-11-001) page 12

states:

“2009 was the first compliance season for the 

CAIR seasonal NOx program. There were 3,279 

affected units: 3,071 electricity generating units 

(EGUs) and 208 industrial units. Through a wide 

range of pollution control strategies and an 

active seasonal NOx allowance trading market, 

emissions by the affected sources have

continued to decrease. Between 2008 and 

2009, ozone season NOx emissions fell in DC 

and every state of the 25 states participating in 

the CAIR NOx seasonal program. Units in the 
14

program reduced their overall NOx emissions 

from 689,000 tons to 495,000 tons.”

Thus, the overall NOx emissions of 495,000 in 2009 is 

a 28% reduction from the previous level of 689,000 

tons per year in 2008.

ii.) Section 172(c) requirements

This Section contains general requirements for 

nonattainment plans. The requirements for reasonable 

further progress, identification of certain emissions 

increases, and other measures needed for attainment 

will not apply for redesignations because they only 

have meaning for areas not attaining the standard. The 

requirements for an emission inventory will be satisfied 

by the inventory requirements of the maintenance 

plan. Chapters Four and Five discuss this requirement 

in more detail.

iii.) Conformity

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

SIP provisions are consistent with the Section 

176(c)(4) conformity requirements. The redesignation 

request should include conformity procedures, if the 

state already has these procedures in place. If a state 

does not have conformity procedures in place at the 

time that it submits a redesignation request, the state 

must commit to follow U.S. EPA’s conformity 

regulation upon issuance, as applicable. 

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

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

redesignated, U.S. EPA must fully approve a maintenance 

plan that meets the requirements of Section 175(A). The 

maintenance plan will constitute a SIP revision and must 

provide for maintenance of the relevant NAAQS in the area 

for at least 10 years after redesignation. Section 175 (A) 

further states that the plan shall contain such additional 

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

maintenance.

In addition, the maintenance plan shall contain such 

contingency measures as the Administrator deems necessary 

to ensure prompt correction of any violation of the NAAQS. At 

a minimum, the contingency measures must include a 
15

requirement that the state will implement all measures 

contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should 

consider the following provisions:

a) attainment inventory;

b) maintenance demonstration;

c) monitoring network;

d) verification of continued attainment; and

e) contingency plan.

Chapter Six discusses this requirement in more detail.
16

CHAPTER THREE – PM2.5 MONITORING

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

PM2.5 Monitoring, Requirement 1 of 4

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

50.7, has been attained.

Demonstration

There are currently four Federal Reference Method monitors 

measuring PM2.5 concentrations in the Huntington-Ashland

nonattainment area. One is located in Kentucky3and is 

operated by the Kentucky Division for Air Quality. The

locations of the monitoring sites for this nonattainment area

are shown on Figure 1. A listing of the design values based 

on the three-year average of the annual mean concentrations

from 2008 through 2010 is shown in Table 1. Monitor 

readings for 2008 through 2010 were retrieved from AQS and 

are located in Appendix A.

Ambient Data Quality-Assured, Requirement 2 of 4

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

recorded in the U.S. EPA AQS database, and available for public view.

Demonstration

KYDAQ has quality assured all data shown in Appendix A in 

accordance with 40 CFR 58.10 and all other federal requirements. 

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

the data are available to the public.

Data Handling Guidelines, Annual PM2.5 NAAQS, Requirement 3 of 4

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

on data from all monitoring sites in the area or its affected downwind 

environs, are below 15.0 μg/m3. (This showing must rely on three 

complete, consecutive calendar years of quality assured data.)

 

3 The three remaining PM2.5 monitors are located in Ohio (two) and West Virginia (one) respectively.
17

Figure 1 - Map of the Huntington-Ashland, OH-KY-WV nonattainment 

area and monitor locations

Background

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

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

In accordance with the CAA Amendments, three complete 

years of monitoring data are required to demonstrate 

attainment at a monitoring site. The annual PM2.5 primary and 

secondary ambient air quality standards are met at an 

ambient air quality monitoring site when the three-year 

average of the annual average is less than 15.0 μg/m

3

. While 

calculating design values, three significant digits must be 

carried in the computations, with final values rounded to the 

nearest 0.1 μg/m3. Decimals 0.05 or greater are rounded up, 

and those less than 0.05 are rounded down, so that 15.049 

μg/m3is the largest concentration that is less than, or equal to 

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

values equal to or greater than 15.1 μg/m3exceed the 

standard. An area is in compliance with the annual PM2.5 
18

NAAQS only if every monitoring site in the area meets the 

NAAQS. An individual site's 3-year average of the annual 

average concentrations is also called the site's design value. 

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

value among all sites in the area. Table 1 shows the 

monitoring data for 2008-2010 that were retrieved from AQS.
19

Demonstration

Table 1 - Monitoring Data for the Huntington-Ashland, OH-KYWV area for 2008 – 2010

Average

2008 2009 2010 2008-2010

39-087-0010 [a] 10.8

39-087-0012 [b] 13.1 11.3 12.1

39-145-0013 Scioto, OH 12.1 10.9 11.8 11.6

21-019-0017 Boyd, KY 12.1 10.9 11.2 11.4

54-011-0006 Cabell, WV 14.1 12.0 13.2 13.1

Less than 75% capture in at least one quarter

[a] and [b] The monitoring site 39-087-0010 was shutdown in 2/2008 due to the demolition

 of the building that hosted the monitor. The monitor was moved approximately

 one mile away to a new site (39-087-0012) which began samping in early

 2/2008, making both sites incomplete for 2008 when viewed separately.

 If the sites at Lawrence County were considered one site and data combined, it

 would meet the 75% capture requirement. There are no significant industrial

 sources in Ohio where this monitor is located (Ironton, Ohio). The closest 

 significant source is AK Steel in Ashland, Kentucky. Prior to relocation of this

 monitor, it was approximately 1.58 miles from AK Steel. The new site is 

 approximately 0.85 miles from AK Steel. Notice, the new site collected data from 

 February 2008 and achieved a 2008 design value of 13.1 μg/m3, significantly 

 lower than previous year design value even though it is now closer to the largest

 industrial source. Both monitors show attainment of the standard separately and 

 combined.

 In addition, on 9/7/2011 U.S. EPA finalized the determination of attainment of 

 the 1997 annual fine particulate standard for the area [76 FR 55542]. 

 This final rule is effective on October 7, 2011 (Appendix A).

Annual Standard

Site County Year

Lawrence, OH 11.8

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

The design values calculated for the Huntington-Ashland area 

demonstrate that the annual PM2.5 NAAQS has been attained. The 

area's design values have trended downward as emissions have

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

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

EPA published the clean data determination for the area on 

September 7, 2011; the rule is effective October 7, 2011 (Appendix 

A). Further, national monitoring for PM2.5 began in 1999 and there 

has been a clear downward trend overall in design values (Figure 2). 
20

Figure 2 - PM2.5 Annual Mean National Trends

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

Commitment to Continue Monitoring, Requirement 4 of 4

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

appropriate monitoring network to verify the maintenance of the attainment 

status.

Demonstration

Kentucky commits to continue monitoring PM2.5 levels at the 

Kentucky site indicated in Figure 1 and Table 1. KYDAQ will 

consult with U.S. EPA Region IV prior to making changes to 

the existing monitoring network, should changes become 

necessary in the future. KYDAQ will continue to quality 

assure the monitoring data to meet the requirements of 40 

CFR 58 and all other federal requirements. KYDAQ will enter 

all data into AQS on a timely basis in accordance with federal 

guidelines.
21

CHAPTER FOUR – EMISSION INVENTORY

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

INTRODUCTION

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

comprehensive inventory of PM2.5 precursor emissions. The precursors 

consist of primary particles (organic carbon, crustal matter, and elemental 

carbon), SO2 and NOx and are representative of the year when the area 

achieves attainment of the annual PM2.5 air quality standard4. Kentucky 

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

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

on permanent and enforceable emission reductions. Other emission 

inventory related requirements include a projection of the emission 

inventory to a year at least 10 years following redesignation; a 

demonstration that the projected level of emissions is sufficient to maintain 

the annual PM2.5 standard; and a commitment to provide future updates of 

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

maintenance period.

The emissions inventory development and emissions projection discussion 

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

projections, identifies procedures used by KYDAQ, VISTAS, and the 

LADCO regarding emissions from Kentucky’s portion of the counties in the 

Huntington-Ashland area. Specific emissions data are provided for all 

counties, including those in Kentucky, Ohio and West Virginia. Ohio and 

West Virginia emissions data were also obtained though the LADCO 

emissions inventory and projections. All of these inventories and 

emissions projections were prepared using similar methodologies. Ohio 

and West Virginia have submitted separate redesignation requests and 

maintenance plans for their portions of the nonattainment area. Mobile 

emissions inventories and projections for all counties were prepared by 

Kimley-Horn and Associates Inc. on behalf of the Kentucky-Ohio-West 

Virginia In Interstate Planning Commission (KYOVA), with data provided by 

KYOVA, Ohio Department of Transportation (ODOT), Ohio EPA, West 

Virginia Department of Transportation (WVDOT), West Virginia Department 

of Environmental Protection (WVDEP), Kentucky Transportation Cabinet 

(KYTC), and Kentucky Division for Air Quality (KYDAQ). 

Base Year Emission Inventory, Requirement 1 of 5

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

the base year.

Background

The point source data for the 2005 base year and 2008 

attainment year is from Kentucky's emission inventory system 

 

4 VOC and NH3 are not addressed.
22

(KyEIS). This agency has a Quality Assurance Project Plan 

(QAPP) that was reviewed and approved by U.S. EPA in a 

letter (Appendix B) dated August 18, 2010 by the Chief of the 

Air Quality Modeling and Transportation Section, R. Scott 

Davis. 

Demonstration

The stationary source inventory for the Kentucky portion used 

2005 and 2008 point source emissions from the Kentucky EIS 

database. The years 2015 and 2022 were interpolated and 

extrapolated from those EIS years.

VISTAS provided 2009 and 2018 inventory numbers for the 

nonroad and area sources, upon which Kentucky interpolated 

and extrapolated for the 2005 base year, the 2008 attainment 

year, the 2015 interim year, and the 2022 maintenance year.

All mobile numbers were generated by MOVES with input 

from KYOVA (MPO), the Kentucky Division for Air Quality, 

and the Kentucky Transportation Cabinet.

The detailed emission inventory information for the Kentucky 

portion of the Huntington-Ashland area is provided in 

Appendix B. Emissions of PM2.5, SO2 and NOx are identified in 

the demonstration of maintenance, requirement 3 of 5 of this 

chapter.

Emission Projections, Requirement 2 of 5

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

redesignation.

Background

KYDAQ prepared a comprehensive inventory for the Kentucky 

portion of the Huntington-Ashland area including area, mobile, and 

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

inventory was submitted to U.S. EPA on December 3, 2008 as part 

of Kentucky’s PM2.5 attainment demonstration SIP for this area

(Appendix E, document provided electronically on disc).

The information below describes the procedures KYDAQ used to 

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

modeling inventories and future year projections.

Point source emissions for Kentucky for 2009, 2015 

and 2022 were interpolated and extrapolated from the 
23

2005 and 2008 emissions in the Kentucky EIS 

inventory.

Area sources and non-road emissions were 

interpolated for 2005-2008-2015-2022 from the 

inventory emissions provided by VISTAS (2002-2009-

2018). See Appendix B.

The on-road mobile source sector was addressed by

specific PM2.5 and NOx modeling. Mobile source 

emissions were calculated from MOVES2010-

produced emission factors. In Kentucky’s December 3, 

2008 PM2.5 attainment demonstration SIP (provided 

electronically in Appendix E), Kentucky found that the 

regional highway emissions of PM2.5, NOx, and SO2

were insignificant contributors to the nonattainment 

problems and, therefore, none of the three pollutants 

necessitated emissions inventory analysis. As 

documented in Kentucky’s attainment demonstration 

SIP, KYDAQ in consultation with U.S. EPA (Appendix 

C) determined that the Huntington-Ashland 

nonattainment area is not significantly impacted by onroad mobile emissions as compared to other source 

emissions. In addition, mobile source emissions in the 

area were expected to decrease. Based on the results 

of mobile source emission projections prepared as a 

part of this redesignation and maintenance plan, 

KYDAQ is again making a finding that the regional 

highway emissions of PM2.5, NOx, and SO2 continue to 

be insignificant contributors to the nonattainment 

problems in this area, as discussed in the 

demonstration section. 

Biogenic emissions are not included in these 

summaries.

Ohio’s point source information was compiled by the contractor, E.H. 

Pechan & Associates, from Ohio’s annual emissions inventory 

database, and the 2005 U.S. EPA Air Markets acid rain database. 

This report by Pechan (Appendix B) generated a 2005 base year 

inventory and future year estimates of annual emissions for each 

source sector using accepted growth surrogates. These inventories 

were provided to LADCO (in cooperation with the Midwest Planning 

Organization) and have been processed to develop average daily 

emissions for use in the air quality analyses. These processed 

modeling inventories have been identified as the correct iteration of 

the inventory for use in the Ohio redesignation request. 
24

Demonstration

On-Road Emission Estimations

The Huntington-Ashland nonattainment area for the on-road 

emission estimation analysis is divided into a modeled area 

composed of Cabell, Wayne, and Mason (partial) Counties in 

West Virginia; Lawrence, Scioto, Adams (partial), and Gallia 

(partial) Counties in Ohio; and Boyd and Lawrence (partial) 

Counties in Kentucky. Cabell County and Wayne Counties in

WV, and Lawrence County, OH are represented within the 

KYOVA Travel Demand Model by the KYOVA Interstate 

Planning Commission (MPO). Boyd County, KY is 

represented by the KYTC’s Ashland Regional Travel Demand 

Model. For these areas, information from the travel demand 

models combined with Highway Performance Monitoring 

Systems (HPMS) county-level data from each respective area 

were used in the emissions analysis. For the full or partial 

counties not encompassed within the available travel demand 

models, HPMS data was relied upon more heavily for the 

travel characteristics. Appendix C of this redesignation 

request provides a full description of the data sources and 

analysis procedures used in this analysis effort.

MOVES

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

March 2, 2010, to approve MOVES2010 (Motor Vehicle 

Emissions Simulator), hereafter referred to as MOVES. Upon 

publication of the Federal Register notice, MOVES became 

U.S. EPA’s approved motor vehicle emission factor model for 

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

pollutants and precursors from cars, trucks, motorcycles, and 

buses by state and local agencies. MOVES is a computer 

program designed by the U.S. EPA to estimate air pollution 

emissions from mobile sources. MOVES replaces U.S. EPA’s 

previous emissions model for on-road mobile sources, 

MOBILE6.2. MOVES can be used to estimate exhaust and 

evaporative emissions as well as brake and tire wear 

emissions from all types of on-road vehicles.

An updated version of this software, MOVES2010a, was used 

for the purposes of this analysis. MOVES2010a is a minor 

update to MOVES2010. MOVES2010a includes general 

performance improvements from MOVES2010, and also 

allows users to account for emissions under new car and light 

truck energy and greenhouse gas standards. 

The CAA requires U.S. EPA to regularly update its mobile 
25

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

and measures vehicle emissions to make sure the Agency 

has the best possible understanding of mobile source 

emissions. This assessment, in turn, informs the development 

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

represents the Agency’s most up-to-date assessment of onroad mobile source emissions. MOVES also incorporates 

several changes to the U.S. EPA’s approach to mobile source 

emission modeling based upon recommendations made to 

the Agency by the National Academy of Sciences.

U.S.EPA requires that MOVES should be used in VOC, CO, 

PM, and NOx SIP development. The CAA requires that SIP 

inventories and control measures be based on the most 

current information and applicable models that are available 

when a SIP is developed.

Regarding transportation conformity, U.S. EPA and U.S. DOT 

established a two-year grace period before MOVES is 

required for new transportation conformity analyses.

The MOVES more detailed approach (when compared with 

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

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

variety of sources, such as data from vehicle inspection and 

maintenance (I/M) programs, remote sensing device (RSD) 

testing, and certification testing, portable emission 

measurement systems (PEMS), etc. This approach also 

allows users to incorporate a variety of activity data to better 

estimate emission differences such as those resulting from 

changes to vehicle speed and acceleration patterns. MOVES 

has a graphical user interface which allows users to more 

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

design provides users much greater flexibility regarding output 

choices. Unlike earlier models which provided emission 

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

output can be expressed as total mass (in tons, pounds, 

kilograms, or grams) or as emission factors (grams-per-mile 

and in some cases grams-per-vehicle). Output can be easily 

aggregated or disaggregated to examine emissions in a range 

of scales, from national emissions impacts down to the 

emissions impacts of individual transportation projects. The 

database-centered design also allows U.S. EPA to update 

emissions data incorporated in MOVES more easily and will 

allow users to incorporate a much wider array of activity data 

to improve estimation of local emissions. For example, the 
26

improvements in MOVES will allow project-level PM2.5 

emissions to be estimated.

KYOVA and KYTC Travel Demand Model

The latest planning assumptions available for the HuntingtonAshland non-attainment area were used. Both the KYOVA 

Travel Demand Model and the KYTC Ashland Regional 

Travel Demand Model are the most recent and approved 

regional travel demand models for their respective areas. For 

each travel demand model, model validation is a joint process 

between KYOVA and the appropriate state review agencies.

The KYOVA Travel Demand Model is a three step model. 

Trip generation, trip distribution, and trip assignment 

components are included in the model. Mode choice is not an 

element of the current model. The Travel Demand Model 

covers Cabell and Wayne Counties, WV, and Lawrence 

County, OH. The current base year for the travel demand 

model is 2000. Socioeconomic data was forecasted to the 

year 2035 as a part of the most recent regional metropolitan 

transportation plan. The QRS II modeling platform was used 

to develop this model. The KYOVA Interstate Planning 

Commission’s currently adopted transportation plan, titled 

Huntington-Ironton Area Transportation Study (HIATS), The 

Year 2035 Long-Range Transportation Plan was prepared in 

May 2009. Appendix C of this document contains the 

assumptions and methodology used to develop the Travel 

Demand Model. 

Similar to the KYOVA Travel Demand Model, the Ashland 

Regional Travel Demand Model is a traditional three-step 

model. The model includes trip generation, trip distribution, 

and trip assignment components. Transit operations are not 

included in the model; as a result, there is no mode choice 

component. The Travel Demand Model covers Boyd and 

Greenup Counties in Kentucky. Updated in 2007, this model 

has a base year of 2007 and a final horizon year of 2040. 

Forecast years of 2010, 2020, and 2030 were also 

incorporated into the model. The TransCAD modeling 

platform was used to develop this model. The document titled 

Ashland Regional Travel Demand Model, Model Update 

Report was developed in January 2008 for KYTC. This 

document contains the assumptions and methodology used to 

develop the current Travel Demand Model.
27

For areas of the modeling region within a county with a travel 

demand model, information from this model was applied for 

the analysis. Specifically, VMT data in the HPMS vehicle 

class format and ramp fractions for rural and urban restricted 

roadways were obtained from the travel demand models. For 

areas outside of the travel demand model extents, ramp 

fractions were assumed to mirror those seen in their 

respective states. HPMS vehicle class VMTs for areas 

outside the travel demand model limits were derived and 

forecasted from current HPMS traffic data in those areas.

In addition to the information above, numerous additional data 

sources were consulted to obtain the needed information for 

the MOVES software. Source type population and vehicle age 

distribution data were obtained from ODOT, WVDEP, and 

KYTC by each state. The ODOT and KYTC provided data 

about hourly vehicle distributions. Guidance and data for 

meteorological, fuel supply, and fuel formulation data was 

obtained from ODOT and KYDAQ. The KYOVA supplied 

information on the transit vehicle population for the region.

The analysis was performed using the emission rates method. 

As a result, post-processing of the data was required to arrive 

at the overall emissions output. To do this, the rate per 

distance and rate per vehicle output data were matched with 

the appropriate geographic area, analysis year, source types, 

pollutant types, road types, modeling hours, and speed 

classes and then aggregated with the corresponding source 

type population and vehicle miles traveled information. The 

resulting information was summarized by pollutant type for 

each full or partial county being analyzed to generate the 

overall emissions in tons per year.

Appendix C provides additional detail on the data sources 

gathered, modeling assumptions, and post-processing steps.

The KYOVA document from the MPO planning organization, 

page A-2, Appendix C, discusses methods for all mobile 

inventory years developed using MOVES.

On-Road Mobile Emission Estimations

Tables 2 through 12 contain the results of the emissions 

analysis for the appropriate years. All emissions estimations 

are expressed in tons per year (tpy). 
28

Table 2 - Adams (partial) County, Ohio Emissions Estimations 

for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 122.49 103.66 54.82 26.21

SO2 (tpy) 2.10 0.71 0.32 0.32

PM2.5 (tpy) 4.20 3.69 2.17 1.39

Annual VMT 34,049,176 35,647,156 39,080,671 42,602,717

Table 3 – Gallia (partial) County, Ohio Emissions Estimations 

for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 59.34 50.43 26.89 12.94

SO2 (tpy) 1.02 0.34 0.16 0.16

PM2.5 (tpy) 2.03 1.81 1.06 0.68

Annual VMT 16,493,759 17,341,207 19,175,027 21,051,915

Table 4 – Lawrence County, Ohio Emissions Estimations for 

On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 1,692.81 1,403.49 759.82 397.98

SO2 (tpy) 28.08 9.16 4.14 4.48

PM2.5 (tpy) 57.15 48.87 28.76 20.08

Annual VMT 449,711,752 457,366,121 503,049,909 595,949,049

Table 5 – Scioto County, Ohio Emissions Estimations for OnRoad Mobile Sources

2005 2008 2015 2022

NOx (tpy) 2,081.20 1,761.97 983.09 486.95

SO2 (tpy) 34.53 11.52 5.39 5.47

PM2.5 (tpy) 70.26 61.40 37.35 24.56

Annual VMT 552,962,632 575,354,151 655,158,989 728,816,580

Table 6 – Summary of Ohio Emissions Estimations for On-Road 

Mobile Sources

2005 2008 2015 2022

NOx (tpy) 3,955.84 3,319.55 1,824.62 924.08

SO2 (tpy) 65.73 21.73 10.01 10.43

PM2.5 (tpy) 133.64 115.77 69.34 46.71

Annual VMT 1,053,217,319 1,085,708,635 1,216,464,596 1,388,420,261
29

Table 7 – Boyd County, Kentucky Emissions Estimations for 

On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 2,673.25 2,172.59 1,154.59 647.64

SO2 (tpy) 11.89 11.62 11.89 12.12

PM2.5 (tpy) 114.31 97.91 51.16 29.08

Annual VMT 488,758,339 473,274,668 510,947,840 560,930,984

Table 8 – Lawrence (partial), Kentucky Emissions Estimations 

for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 170.69 139.16 70.54 37.96

SO2 (tpy) 0.76 0.74 0.73 0.71

PM2.5 (tpy) 7.30 6.27 3.12 1.69

Annual VMT 31,232,092 30,348,132 31,171,751 32,686,140

Table 9 – Summary of Kentucky Emissions Estimations for OnRoad Mobile Sources

2005 2008 2015 2022

NOx (tpy) 2,843.94 2,311.75 1,225.13 685.60

SO2 (tpy) 12.65 12.36 12.62 12.83

PM2.5 (tpy) 121.61 104.18 54.28 30.77

Annual VMT 519,990,431 503,622,800 542,119,591 593,617,124

Table 10 – Cabell County, West Virginia Emissions Estimations 

for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 4,262.48 3,504.59 1,702.34 847.76

SO2 (tpy) 81.13 21.95 9.39 9.13

PM2.5 (tpy) 173.92 151.98 80.07 43.32

Annual VMT 960,538,915 989,243,546 1,059,033,672 1,140,870,563
30

Table 11 – Mason County (partial), West Virginia Emissions 

Estimations for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 31.12 27.36 15.33 8.72

SO2 (tpy) 0.54 0.16 0.07 0.08

PM2.5 (tpy) 1.19 1.09 0.64 0.38

Annual VMT 6,176,333 6,741,932 8,005,850 9,286,512

Table 12 – Wayne County, West Virginia Emissions Estimations 

for On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 1720.01 1,432.79 676.93 386.80

SO2 (tpy) 32.87 9.02 3.76 4.26

PM2.5 (tpy) 70.36 62.37 32.03 20.13

Annual VMT 389,577,827 407,030,689 424,609,965 533,508,781

Table 13 – Summary of West Virginia Emissions Estimations for 

On-Road Mobile Sources

2005 2008 2015 2022

NOx (tpy) 6,013.61 4,964.74 2,394.60 1,243.28

SO2 (tpy) 114.54 31.13 13.22 13.47

PM2.5 (tpy) 245.47 215.44 112.74 63.83

Annual VMT 1,356,293,075 1,403,016,167 1,491,649,487 1,683,665,856

Table 14 – Emissions Estimations Totals for On-Road Mobile 

Sources for the Huntington-Ashland Area

2005 2008 2015 2022

NOx (tpy) 12,813.39 10,596.04 5,444.35 2,852.96

SO2 (tpy) 192.92 65.22 35.85 36.73

PM2.5 (tpy) 500.72 435.39 236.36 141.31

Annual VMT 2,929,500,825 2,992,347,602 3,250,233,674 3,665,703,241

The following table identifies the percentage of mobile emissions of 

all emissions, as indentified under Demonstration of Maintenance 

(Requirement 3 of 5) below, for each pollutant in the entire 

Huntington-Ashland area and Kentucky’s portion of this area for 

2015 and 2022.
31

Table 15 – Percent of Mobile Emissions for the HuntingtonAshland Area in 2015 and 2022

NOx SO2 PM2.5

2015 2022 2015 2022 2015 2022

HuntingtonAshland 

Area

Total (tpy) 95,137.30 71,097.29 149,647.27 113,654.75 10,100.29 9,928.94

Mobile (tpy) 5,444.35 2,852.96 35.85 36.73 236.36 141.31

% Mobile 5.7% 4.0% 0.0% 0.0% 2.3% 1.4%

Kentucky

Portion

KY Total (tpy) 14,622.66 12,776.03 32,578.86 24,761.97 2,540.30 2508.47

Mobile (tpy) 1,225.13 685.60 12.62 12.83 54.28 30.77

% Mobile 8.4% 5.4% 0.0% 0.0% 2.1% 1.2%

NOx constitutes less than nine percent (<9%) of the 

area’s total NOx emissions in the 2015 and 2022 

horizon years.

SO2 constitutes less than one percent (<1%) of the 

area’s total SO2 emissions in the 2015 and 2022 

horizon years.

PM2.5 constitutes less than three percent (<3%) of the area’s 

total PM2.5 emissions in the 2015 and 2022 horizon years.

Therefore, the KYDAQ is herein making a finding that the area’s 

highway emissions for PM2.5, NOx, and SO2 continue to be 

insignificant contributors to the nonattainment problem of the 

Huntington-Ashland area, as agreed upon as a part of the 

interagency consultation process. In a letter (Appendix C) to 

KYDAQ dated March 23, 2010, U.S. EPA agreed with Kentucky’s 

finding of insignificance for direct PM2.5 and NOx regarding the 

Huntington-Ashland area attainment demonstration submitted 

December 3, 2008 (Appendix E). Because of this finding it is not 

necessary to establish mobile emission budgets for this area in the 

2015 and 2022 horizon years. 

Demonstration of Maintenance, Requirement 3 of 5

A demonstration that the projected level of emissions is sufficient to 

maintain the PM2.5 standard.

Background

In consultation with U.S. EPA, Kentucky selected the year 

2022 as the maintenance year for this redesignation request. 

This document contains projected emissions inventories for 

2015 and 2022. 

Emission projections for the Huntington-Ashland area were 

performed using the following approaches:
32

As performed by Kimley-Horn and Associates Inc., 

mobile source emission projections are based on the 

U.S. EPA MOVES model. The analysis is described in 

more detail in Appendix C. All projections were made 

in accordance with Procedures for Preparing 

Emissions Projections, U.S. EPA-45/4-91-019. As 

discussed above, it was determined that the mobile 

emission contribution as a percent of the total emission 

inventory from the area is not significant.

Emissions inventories are required to be projected to 

future dates to assess the influence growth and future 

controls will have. VISTAS has developed growth and 

control files for area and non-road categories. These 

files were used to develop the future-year emissions 

estimates used in this document. This was done so 

the inventories used for redesignation are consistent 

with modeling performed in the future. Appendix D

contains VISTAS technical support document detailing 

the analysis used to project emissions. 

Point source emissions for 2005 and 2008 were 

compiled from KYDAQ’s 2005 and 2008 emissions 

inventory database. The 2015 interim year emissions 

were estimated based on the 2009 and 2018 VISTAS 

modeling inventory, using a straight line interpolation 

method. The 2022 maintenance year is based on 

extrapolating emissions estimates from the VISTAS 

inventory using 2009 and 2018.

The detailed inventory information for the Kentucky portion of 

the Huntington-Ashland area is in Appendix B. Emission 

trends are an important gauge for continued compliance with 

the PM2.5 standard. Therefore, KYDAQ performed a 

comparison of the inventories for the base year and 

maintenance years. Mobile source emission inventories are 

described in Section 5 of Appendix C. 

Sectors included in the following tables are Point, Nonroad, 

Area, and Mobile for Kentucky. Electrical Generating Unit 

(EGU-Point), Non-Electrical Generating Unit (Non-EGU), 

Non-road Mobile (Non-road), Other Area (Other), Marine; 

Aircraft; Rail (MAR), and On-road Mobile (On-road) sectors 

are included for Ohio and West Virginia. 
33

Ohio is identifying PM2.5 emissions projections for 2015 and 

2022 for EGUs without implementation of the CAIR program. 

KYDAQ is identifying PM2.5 emissions projections for 2015 

and 2022 for EGUs with implementation of the CAIR 

program. This is further discussed in the demonstration of 

PM2.5. U.S. EPA has raised concerns regarding the CAIR 

program and its remand. However, as discussed below, with 

the CAIR replacement rule (CSAPR) finalized, these are the 

most appropriate and accurate future projections.

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

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

28 eastern states and the District of Columbia to significantly 

reduce emissions of NOx and SO2. CAIR replaced the NOx 

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

was for national emissions to be cut from 4.5 million tons in 

2004 to 1.5 million tons by 2009 and to 1.3 million tons in 

2018. States were required to submit a CAIR SIP as part of 

this effort. KYDAQ submitted a CAIR SIP to U.S. EPA on 

July 19, 2007. The CAIR SIP was approved as a direct final 

action on October 4, 2007 [74 FR 48857]. The Kentucky 

administrative regulations developed for the CAIR SIP 

became effective December 3, 2007 (401 KAR 51:210, 220, 

230). As a result of CAIR, U.S. EPA projected that in 2009 

emissions of NOx decreased from a baseline of 176,000 tons 

per year (tpy) to 107,000 tons per year (tpy) while in 2010 

emissions of SO2 decreased from a baseline of 447,000 tpy 

to 341,000 tpy, within Kentucky. U.S. EPA projects by 2015 

NOx emissions will decrease to 77,000 tpy while emissions of 

SO2 will decrease to 270,000 tpy, within Kentucky5. 

On December 23, 2008, U.S. EPA’s CAIR program was 

remanded without vacatur by the D.C. Circuit Court. As 

mentioned above, KYDAQ has not incorporated these 

expected CAIR reductions for PM2.5 into this redesignation 

request. It should also be noted that Kentucky’s SIPapproved NOx SIP Call program and regulations are still in 

place, and reductions in NOx and SO2 have occurred. In 

2009 and 2010 facilities began preparing for and 

implementing control programs to address requirements 

implemented due to CAIR6and consent decrees. 

 

5 http://www.epa.gov/CAIR/ky.html

6 Under CAIR, NOx reductions were to occur beginning in 2009 while SO2 reductions were to occur 

beginning in 2010.
34

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

Division:

“Based on emissions monitoring data, U.S. EPA has 

observed substantial reductions in SO2 emissions from 2005 

to 2009 and in the first two quarters of 2010 as companies 

installed more controls, electric demand declined, and low 

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

competitive in several parts of the country. Thus, even after 

CAIR's vacatur and subsequent remand in late 2008, the 

controls in place generally have continued to operate, helping 

to drive continued progress in reducing emissions.” The 

significant emission reductions are illustrated in Table 16.

Table 16 – Annual Reductions Nationwide in SO2 and NOx

EGU Emissions Between 1990 and 2010

1990 through 2010 Emission National Comparisons, Annual 

Acid Rain Program Emissions at National Level 

(All Units).

1990 through 2008 data are final, 2010 are preliminary data 

submitted

to EPA from sources as of February 8, 2011.

1990 2000 2005 2008

Preliminary

2010

SO2 (million tons) 15.73 11.20 10.22 7.62 5.11

NOx (million tons) 6.66 5.10 3.63 3.00 2.05

Source: Clean Air Markets Quarterly Emissions Tracking –

EPA will update as it receives and verifies data.

On July 6, 2011, U.S. EPA finalized the new Air Transport Rule, 

CSAPR, which includes reductions scheduled to begin in 2012. As 

finalized, CSAPR will preserve those initial reductions achieved 

under CAIR and provide more reductions in NOx and SO2 emissions 

in 2012 and 2014, ahead of the 2015, Phase 2 requirements of the 

CAIR.

The emission reductions under the first phase of compliance begins 

January 1, 2012 for SO2 and annual NOx reductions and May 1, 

2012 for ozone season NOx reductions. The second phase of SO2

reductions begins January 1, 2014. By 2014, CSAPR and other 

state and U.S. EPA actions will reduce power plant SO2 emissions 

by 73% from 2005 levels. Power plant NOx emissions will drop by 

54%. 

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

program provided real reductions in emissions. These reductions 

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

throughout Kentucky. Further CSAPR will continue to provide for 

even greater reductions for maintenance of the annual PM2.5 
35

standard. This was additionally supported in the proposed CSAPR 

[75 FR 45345], “ ...the results of the air quality modeling indicate 

that all but one site7is projected to be in attainment and only one 

site8is projected to have a maintenance problem for annual PM2.5 in 

2014 with the emissions reductions expected from this proposal.” 

Demonstration

PM2.5

The 2005 and 2008 PM2.5 emissions data below contains 

particulate fraction emissions and the condensable fractions.

Area and nonroad emissions were taken from the U.S. EPA 

2008 National Emissions Inventory (NEI). As stated above, 

Kentucky utilized Point source information using KYDAQ’s

annual emissions inventory database and the U.S. EPA Air 

Markets acid rain database.

Maintenance is demonstrated when the future-year (2022) 

projected emission totals are below the 2008 attainment year 

totals.

The Kentucky emissions data in the tables below are based 

on the following data sources:

- All On-Road data source: Kimley-Horn and Associates 

Inc.

- All other data source: Visibility Improvement - State and 

Tribal Association of the Southeast (VISTAS).

Tables 17 through 25 provide the PM2.5 county emissions for 

each sector for the 2005 base year to the maintenance year 

of 2022. Table 26 provides the summary for each county and 

demonstrates maintenance of the area. Similarly, Tables 27 

through 36 illustrate maintenance for NOx, and Tables 37 

through 46 illustrate maintenance for SO2 emissions. 

 

7 Allegheny, PA

8 Birmingham, AL
36

PM2.5

Table 17 - Adams County, Ohio PM2.5 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – Without CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 3344.63 3585.29 3569.95 3544.65 40.64

Non-EGU 6.90 7.28 13.13 15.64 -8.36

Non-road 15.62 13.28 8.70 4.04 9.24

Area 247.97 278.00 285.55 282.69 -4.69

MAR 7.39 6.79 4.21 1.74 5.05

On-road 4.20 3.69 2.17 1.39 2.30

TOTAL 3,626.71 3,894.33 3,883.71 3,850.15 44.18

Table 18 - Gallia County, Ohio PM2.5 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – Without CAIR

Sector 2005 Base 2008 

Attainmen

t

2015

Interim

2022

Maintenance

Safety 

Margin

EGU Point 1,011.49 1,031.94 1,073.20 1,100.12 -68.18

Non-EGU 0.00 0.00 0.00 0.00 0.00

Non-road 11.87 10.33 7.22 4.07 6.26

Area 132.22 168.24 181.29 182.52 -14.28

MAR 7.50 6.91 4.32 1.84 5.07

On-road 2.03 1.81 1.06 0.68 1.13

TOTAL 1,165.11 1,219.23 1,267.09 1,289.23 -70.00

Table 19 - Lawrence County, Ohio PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 0.00 0.94 0.69 0.14 0.80

Non-EGU 1.21 1.39 1.75 1.90 -0.51

Non-road 13.78 11.67 7.90 4.02 7.65

Area 134.89 134.73 131.79 129.08 5.65

MAR 20.16 17.97 10.67 3.57 14.40

On-road 57.15 48.87 28.76 20.08 28.79

TOTAL 227.19 215.57 181.56 158.79 56.78
37

Table 20 - Scioto County, Ohio PM2.5 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – Without CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 84.20 138.92 111.08 102.50 36.42

Non-road 37.43 33.07 22.69 12.33 20.74

Area 199.12 290.87 327.40 330.38 -39.51

MAR 37.29 32.74 18.94 5.44 27.30

On-road 70.26 61.40 37.35 24.56 36.84

TOTAL 428.30 557.00 517.46 475.21 81.79

Table 21 - Boyd County, Kentucky PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

Point 10467.19 9103.06 5920.08 2737.1 6365.96

Non-road 126.47 122.34 118.93 116.57 5.77

Area 726.35 742.11 783.40 825.44 -83.33

On-road 114.31 97.91 51.16 29.08 68.83

TOTAL 11,434.32 10,065.42 6,873.57 3,708.19 6357.23

Table 22 - Lawrence County, Kentucky PM2.5 Emission 

Inventory Totals for Base Year 2005, Estimated 2008, 

and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022 

Maintenance

Safety 

Margin

Point 3986.51 3226.75 1453.96 1453.96 1772.79

Non-road 1.98 1.91 1.67 1.41 0.5

Area 14.35 14.66 15.20 15.72 -1.06

On-road 7.3 6.27 3.12 1.69 4.58

TOTAL 4010.14 3249.59 1473.95 1472.78 1776.81
38

Table 23 - Cabell County, West Virginia PM2.5 Emission 

Inventory Total for Base Year 2005, Estimated 2008, 

and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 316.84 345.42 408.05 440.72 -95.30

Non-road 31.58 30.57 22.72 15.39 15.18

Area 356.40 353.80 357.80 360.85 -7.05

MAR 44.99 42.41 31.61 21.25 21.16

On-road 173.92 151.98 80.07 43.32 108.66

TOTAL 923.73 924.18 900.25 881.53 42.65

Table 24 - Mason County, West Virginia PM2.5 Emission 

Inventory Totals for Base Year 2005, Estimated 2008, 

and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022

Maintenance

Safety Margin

EGU Point 245.67 244.58 259.80 266.33 -21.75

Non-EGU 5.80 5.73 6.49 6.81 -1.08

Non-road 16.45 13.94 9.38 4.70 9.24

Area 135.88 136.83 139.42 141.99 -5.16

MAR 47.73 46.01 35.53 25.66 20.35

On-road 1.19 1.09 0.64 0.38 0.71

TOTAL 452.72 448.18 451.26 445.87 2.31

Table 25 - Wayne County, West Virginia PM2.5 Emission 

Inventory Totals for Base Year 2005, Estimated 2008, 

and Projected 2015 and 2022 (tpy) – Without CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022

Maintenance

Safety Margin

EGU Point 3.36 3.85 1.16 0.01 3.84

Non-EGU 48.01 51.14 54.62 56.11 -4.97

Non-road 11.09 9.62 6.97 4.24 5.38

Area 188.18 185.27 182.15 178.69 6.58

MAR 107.34 104.45 81.73 60.51 43.94

On-road 70.36 62.37 32.03 20.13 42.24

TOTAL 428.34 416.70 358.66 319.69 97.01
39

Table 26 – Huntington-Ashland Area PM2.5 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

projected 2015 and 2022 (tpy) – Without CAIR

PM2.5 2005 

Base

2008 

Attainment

2015 

Interim

2022 

Maintenance

Safety 

Margin

Adams, OH 3,626.71 3,894.33 3,883.71 3,850.15 44.18

Gallia, OH 1,165.11 1,219.23 1,267.09 1,289.23 -70

Lawrence, OH 227.19 215.57 181.56 158.79 56.78

Scioto, OH 428.3 557 517.46 475.21 81.79

Boyd, KY 11,434.32 10,065.42 6,873.57 3,708.19 6357.23

Lawrence, KY 4010.14 3249.59 1473.95 1472.78 1776.81

Cabell, WV 923.73 924.18 900.25 881.53 42.65

Mason, WV 452.72 448.18 451.26 445.87 2.31

Wayne, WV 428.34 416.7 358.66 319.69 97.01

COMBINED PM2.5

TOTAL 22,696.56 20,990.20 15,907.51 12,601.44 8,388.76

NOx

Table 27 - Adams County, Ohio NOx Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 30,205.82 31,258.94 25,671.39 23,276.73 7,982.21

Non-EGU 665.42 703.45 1,266.52 1,770.27 -1,066.82

Non-road 142.28 128.52 92.82 57.47 71.05

Area 127.85 132.58 134.84 137.93 -5.35

MAR 325.30 307.93 199.67 97.77 210.16

On-road 122.49 103.66 54.82 26.21 77.45

TOTAL 31,589.16 32,635.08 27,420.06 25,366.38 7,268.70

Table 28 - Gallia County, Ohio NOx Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 57,523.60 59,688.25 24,476.65 9,385.96 50,302.29

Non-EGU 0.00 0.00 0.00 0.00 0.00

Non-road 110.23 96.65 67.88 38.85 57.80

Area 122.81 128.27 131.45 135.53 -7.26

MAR 316.92 299.78 194.41 95.18 204.60

On-road 59.34 50.43 26.89 12.94 37.49

TOTAL 58,132.90 60,263.38 24,897.28 9,668.46 50,594.92
40

Table 29 - Lawrence County, Ohio NOx Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 0.00 96.19 105.90 110.06 -13.87

Non-EGU 68.51 77.46 97.06 154.65 -77.19

Non-road 165.50 142.30 92.01 41.36 100.94

Area 232.73 235.97 238.92 242.31 -6.34

MAR 785.48 736.28 477.77 232.77 503.51

On-road 1,692.81 1,403.49 759.82 397.98 1,005.51

TOTAL 2,945.03 2,691.69 1,771.48 1,179.13 1,512.56

Table 30 - Scioto County, Ohio NOx Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 570.12 659.89 512.83 407.21 252.68

Non-road 324.89 281.37 185.85 89.77 191.60

Area 240.86 254.58 262.42 272.52 -17.94

MAR 1,337.52 1,245.14 805.82 387.53 857.61

On-road 2,081.20 1,761.97 983.09 486.95 1,275.02

TOTAL 4,554.59 4,202.95 2,750.01 1,643.98 2,558.97

Table 31 - Boyd County, Kentucky NOx Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022 

Maintenance

Safety 

Margin

Point 5109.31 4543.57 3223.52 1903.47 2640.1

Non-road 3228.05 3137.05 2922.28 2707.10 429.95

Area 41.82 44.68 51.53 56.98 -12.3

On-road 2673.25 2172.59 1,154.59 647.64 1524.95

TOTAL 11,052.43 9,897.89 7,351.92 5,315.19 4,582.70
41

Table 32 - Lawrence County, Kentucky NOx Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022 

Maintenance

Safety 

Margin

Point 12,000.30 13,408.95 16,695.79 19,982.63 -6,573.68

Non-road 47.20 45.40 40.86 36.27 9.13

Area 5.94 6.16 6.48 6.70 -0.54

On-road 170.69 139.16 70.54 37.96 101.20

TOTAL 12,224.13 13,599.67 16,813.67 20,063.56 -6,463.89

Table 33 – Cabell County, West Virginia NOx Emission 

Inventory Total for Base Year 2005, Estimated 2008, 

and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 244.27 246.61 278.40 305.36 -58.75

Non-road 316.80 284.81 202.59 121.07 163.74

Area 669.93 678.75 757.21 830.23 -151.48

MAR 1,578.63 1,566.32 1,205.55 875.99 690.33

On-road 4,262.48 3,504.59 1,702.34 847.76 2,656.83

TOTAL 7,072.11 6,281.08 4,146.09 2,980.41 3,300.67

Table 34 – Mason County, West Virginia NOx Emission 

Inventory Totals for Base Year 2005, Estimated 2008, 

and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 21,694.07 13,490.21 11,957.32 11,300.37 2,189.84

Non-EGU 80.53 82.91 91.22 99.02 -16.11

Non-road 160.56 153.38 124.24 96.26 57.12

Area 356.63 368.52 391.32 414.58 -46.06

MAR 1,334.41 1,303.31 971.05 663.19 640.12

On-road 31.12 27.36 15.33 8.72 18.64

TOTAL 23,657.32 15,425.69 13,550.48 12,582.14 2,843.55
42

Table 35 – Wayne County, West Virginia NOx Emission 

Inventory Totals for Base Year 2005, Estimated 2008, 

and Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 60.51 15.13 7.32 3.97 11.16

Non-EGU 3,279.16 2,817.34 2,847.64 2,674.22 143.12

Non-road 117.56 109.12 87.13 65.37 43.75

Area 156.84 159.33 175.43 190.56 -31.23

MAR 2,872.80 2,846.00 2,184.79 1,579.84 1,266.16

On-road 1,720.01 1,432.79 676.93 386.80 1,045.99

TOTAL 8,206.88 7,379.71 5,979.24 4,900.76 2,478.95

Table 36 - Huntington-Ashland Area NOx Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

NOx 2005 Base 2008 

Attainment

2015 

Interim

2022 

Maintenance

Safety 

Margin

Adams, OH 31,589.18 32,635.08 27,420.06 25,366.38 7,268.70

Gallia, OH 58,132.90 60,263.38 24,897.28 9,668.46 50,594.92

Lawrence, OH 2,945.03 2,691.69 1,771.48 1,179.13 1,512.56

Scioto, OH 4,554.59 4,202.95 2,750.01 1,643.98 2,558.97

Boyd, KY 11,052.43 9,897.89 7,351.92 5,315.19 4,582.70

Lawrence, KY 12,224.13 13,599.67 16,813.67 20,063.56 -6,463.89

Cabell, WV 7,072.11 6,281.08 4,146.09 2,980.41 3,300.67

Mason, WV 23,657.32 15,425.69 13,550.48 12,582.14 2,843.55

Wayne, WV 8,206.88 7,379.71 5,979.24 4,900.76 2,478.95

COMBINED NOx TOTAL 159,434.57 152,377.14 104,680.23 83,700.01 68,677.13

SO2

Table 37 - Adams County, Ohio SO2 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety Margin

EGU Point 125,070.34 35,946.20 27,077.57 23,276.73 12,669.47

Non-EGU 4.37 3.73 8.04 11.62 -7.89

Non-road 15.33 5.67 0.91 0.14 5.53

Area 33.56 33.54 31.73 30.08 3.46

MAR 28.54 19.33 6.61 1.79 17.54

On-road 2.10 0.71 0.32 0.32 0.39

TOTAL 125,154.24 36,009.18 27,125.18 23,320.68 12,688.50
43

Table 38 - Gallia County, Ohio SO2 Emission Inventory Totals

 for Base Year 2005, Estimated 2008, and Projected

 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety Margin

EGU Point 100,102.91 91,889.46 41,924.16 20,510.45 71,379.01

Non-EGU 0.00 0.00 0.00 0.00 0.00

Non-road 10.76 3.98 0.67 0.15 3.83

Area 16.36 16.60 15.91 15.35 1.25

MAR 27.78 19.07 6.90 2.26 16.81

On-road 1.02 0.34 0.16 0.16 0.18

TOTAL 100,158.83 91,929.45 41,947.80 20,528.37 71,401.08

Table 39 - Lawrence County, Ohio SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety Margin

EGU Point 0.00 0.69 0.21 0.00 0.69

Non-EGU 0.24 0.05 0.35 0.55 -0.50

Non-road 18.98 6.95 1.11 0.19 6.76

Area 30.33 29.94 28.93 27.94 2.00

MAR 68.18 53.99 29.93 5.03 48.96

On-road 28.08 9.16 4.14 4.48 4.68

TOTAL 145.81 100.78 64.67 38.19 62.59

Table 40 - Scioto County, Ohio SO2 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 

2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 977.12 1,477.24 993.09 723.09 754.15

Non-road 36.15 13.28 2.17 0.42 12.86

Area 36.63 37.53 35.89 34.61 2.92

MAR 116.50 100.91 66.76 32.41 68.50

On-road 34.53 11.52 5.39 5.47 6.05

TOTAL 1,200.93 1,640.48 1,103.30 796.00 844.48
44

Table 41 - Boyd County, Kentucky SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022 

Maintenance

Safety 

Margin

Point 5288.46 7857.23 13851.02 19844.81 -11987.58

Non-road 438.11 394.26 375.20 370.03 24.23

Area 557.59 573.14 599.93 619.94 -46.8

On-road 11.89 11.62 11.89 12.12 -0.5

TOTAL 6,296.05 8,836.25 14,838.04 20,846.90 -12,010.65

Table 42 - Lawrence County, Kentucky SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022 

Maintenance

Safety 

Margin

Point 53,956.75 38,978.43 4,029.02 4,029.02 34,949.41

Non-road 4.78 3.83 3.32 3.10 0.73

Area 6.59 6.78 6.70 6.57 0.21

On-road 0.76 0.74 0.73 0.71 0.03

TOTAL 53,968.88 38,989.78 4,039.77 4,039.40 34,950.38

Table 43 - Cabell County, West Virginia SO2 Emission Inventory 

Total for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 

Base

2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 0.00 0.00 0.00 0.00 0.00

Non-EGU 118.63 118.03 141.50 160.39 -42.36

Non-road 16.75 7.30 1.75 0.56 6.74

Area 1,457.65 1,503.71 1,598.18 1,693.86 -190.15

MAR 53.52 23.87 5.55 1.33 22.54

On-road 81.13 21.95 9.39 9.13 12.82

TOTAL 1,727.68 1,674.86 1,756.37 1,865.27 -190.41
45

Table 44 - Mason County, West Virginia SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 82,132.82 50,518.10 44,094.05 41,340.89 9,177.21

Non-EGU 1.91 1.90 2.13 2.32 -0.42

Non-road 10.40 4.53 1.03 0.25 4.28

Area 119.53 120.73 123.14 125.60 -4.87

MAR 42.13 18.81 4.38 1.06 17.75

On-road 0.54 0.16 0.07 0.08 0.08

TOTAL 82,307.33 50,664.23 44,224.80 41,470.20 9,194.03

Table 45 - Wayne County, West Virginia SO2 Emission Inventory 

Totals for Base Year 2005, Estimated 2008, and 

Projected 2015 and 2022 (tpy) – With CAIR

Sector 2005 Base 2008 

Attainment

2015 

Interim

2022

Maintenance

Safety 

Margin

EGU Point 0.53 0.13 0.04 0.00 0.13

Non-EGU 285.67 277.75 281.84 281.79 -4.04

Non-road 6.96 2.99 0.68 0.19 2.80

Area 490.95 507.00 540.51 574.39 -67.39

MAR 98.34 48.22 19.46 13.44 34.78

On-road 32.87 9.01 3.76 4.26 4.76

TOTAL 915.32 845.11 846.29 874.07 -28.96

 

Table 46 - Huntington-Ashland Area SO2 Emission Inventory Totals

 for Base Year 2005, Estimated 2008, and Projected 2015

and 2022 (tpy) – With CAIR

SO2

2005 Base

2008 

Attainment

2015 

Interim

2022 

Maintenance

Safety Margin

Adams, OH 125,154.24 36,009.18 27,125.18 23,320.68 12,688.50

Gallia, OH 100,158.83 91,929.45 41,947.80 20,528.37 71,401.08

Lawrence, OH 145.81 100.78 64.67 38.19 62.59

Scioto, OH 1,200.93 1,640.48 1,103.30 796 844.48

Boyd, KY 6,296.05 8,836.25 14,838.04 20,846.90 -12,010.65

Lawrence, KY 53,968.88 38,989.78 4,039.77 4,039.40 34,950.38

Cabell, WV 1,727.68 1,674.86 1,756.37 1,865.27 -190.41

Mason, WV 82,307.33 50,664.23 44,224.80 41,470.20 9,194.03

Wayne, WV 915.32 845.11 846.29 874.07 -28.96

COMBINED SO2 TOTAL 371,875.07 230,690.12 135,946.22 113,779.08 116,911.04
46

PM2.5, NOx, and SO2

 Table 47 - Huntington-Ashland Area Comparison of 2008 attainment

 year and 2015 and 2022 projected emission estimates (tpy) 

2008 Base 2015 

Interim

2015 

Projected 

Decrease

2022 

Maintenance

2022

Projected 

Decrease

PM2.5 20,990.20 15,907.51 5,082.69 12,601.44 8,388.76

NOx 152,377.14 104,680.23 47,696.91 83,700.01 68,677.13

SO2 230,690.12 135,946.22 94,743.90 113,779.08 116,911.04

As shown in Table 47, PM2.5 emissions in the nonattainment 

area are projected to decrease by 5,082.69 tpy in 2015 and 

8,388.76 tpy in 2022. NOx emissions in the nonattainment 

area are projected to decrease by 51,834.95 tpy in 2015 and 

75,874.96 tpy in 2022. SO2 emissions in the nonattainment 

area are projected to decline by 85,253.82 tpy in 2015 and 

121,246.34 in 2022.

Area source emissions and, to a lesser extent, point sources 

show an increase due to expectations that the population will 

grow in this area; however, cleaner vehicles and fuels are 

expected to be in place in 2009 and 2018, and CSAPR will be 

implemented in 2012 and 2014. These programs will cause 

an overall drop in all three pollutants emissions. Additional 

decreases resulted from U.S. EPA rules covering Tier 2 

Motor Vehicle Emissions Standards and Gasoline Sulfur 

Control Requirements, Highway Heavy-Duty Engine Rule,

and the Non-Road Diesel Engine Rule.

In addition to the above emission reductions, the Kentucky 

Electric Power, Big Sandy, Unit #2 will reduce SO2

emissions in Boyd County through a federally enforceable 

consent decree which will install a fluidized gas 

desulfurization unit, or SO2 scrubber, to be operational by 

December 31, 2015. 

KYDAQ notes also that in Greenup County, E. I. Dupont, 

through a federally enforceable consent decree will reduce 

SO2 emissions at four sulfuric acid pieces of equipment 

equivalent to Best Available Control Technology (BACT),

and will continue to implement best work practices at these 

four pieces of equipment. Greenup County, while not in the 
47

nonattainment area, is located contiguous to the Ohio and 

Kentucky portions of this nonattainment area. 

Geographically, Greenup County shares a common border 

to the southeast with Boyd County, Kentucky, and to the 

northeast with both Lawrence and Scioto Counties in Ohio.

Additionally, AK Steel – Ashland Works, Ashland, KY in 

Boyd County ceased all coke plant operations by June 23, 

2011. Plant workers made final charges to the batteries on 

June 20, 2011. A shutdown notification has been submitted 

to KYDAQ.

Although Kentucky is not taking credit in the projection 

inventory for the reduction benefits of these consent decrees

and shutdowns, we are noting them as significant reductions 

of benefit to the nonattainment area. 

KYDAQ is also anticipating the approval of Regional 

Haze/BART SIPs by the spring of 2012 which will provide

regional area reductions to NOx, SO2, and PM2.5. 

Permanent and Enforceable Emission Reductions, Requirement 4 of 5

A demonstration that improvement in air quality between the year violations 

occurred and the year attainment was achieved is based on permanent 

and enforceable emission reductions and not on temporary adverse 

economic conditions or unusually favorable meteorology.

Background

Ambient air quality data from all monitoring sites indicate that 

air quality met the NAAQS for PM2.5 in 2008-2010. U.S. 

EPA’s redesignation guidance (p 9) states: “A state may 

generally demonstrate maintenance of the NAAQS by either 

showing that future emissions of a pollutant or its precursors 

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

modeling to show that the future mix of sources and 

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

Demonstration

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

SO2 emissions have contributed to the attainment of the 

annual PM2.5 standard. Some of these reductions were due 

to the application of tighter federal standards on non-road 

diesel vehicles (Clean Air Non-road Diesel Rule), the 

application of tighter federal standards on new vehicles, Title 

IV of the CAA, the NOx SIP Call, CAIR/CSAPR, and federal 

consent decrees which required the reductions of SO2 and 
48

NOx emissions from utility sources. These reductions are 

compared in table 48. Reductions achieved are discussed in 

greater detail under Chapter Five.

Table 48 - Huntington-Ashland Area Combined Comparison of 

2005 base year and 2008 attainment year on-road, 

non-road and EGU reductions

Type 2005 2008

On-road PM2.5 500.72 435.39

On-road NOx 12,813.39 10,596.04

On-road SO2 192.92 65.22

Non-road PM2.5 158.65 142.17

Non-road NOx 1,566.88 1,401.13

Non-road SO2 127.85 50.13

EGU PM2.5 5,005.20 5,274.28

EGU NOx 121,991.60 109,294.19

EGU SO2 357,165.83 219,072.36

Provisions for Future Inventory Updates, Requirement 5 of 5

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

the emission levels, including an annual emission statement from major 

sources.

Demonstration

In Kentucky, major point sources in all counties are required 

to submit air emissions information annually, in accordance 

with U.S. EPA’s Consolidated Emissions Reporting Rule 

(CERR). KYDAQ prepares a new periodic inventory for all 

PM2.5 precursor emission sectors every three years. These 

PM2.5 precursor inventories will be prepared for future years 

as necessary to comply with the inventory reporting 

requirements established in the CFR. Emissions information 

will be compared to the 2008 attainment year and the 2022

projected maintenance year inventories to assess emission 

trends, as necessary, and to assure continued compliance 

with the annual PM2.5 standard.
49

CHAPTER FIVE– CONTROL MEASURES AND

REGULATIONS

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

Nonattainment Areas to Implement RACM & RACT, Requirement 1 of 6

Section 172(c)(1) of the 1990 CAA Amendments requires states with 

nonattainment areas to implement reasonably available control measures 

(RACM) and reasonably available control technology (RACT).

Background

Section 172(c)(1) of the 1990 CAA Amendments requires 

states with nonattainment areas to submit a SIP providing for 

implementation of all RACM as expeditiously as practicable 

(including such reductions in emissions from existing sources 

in the area as may be obtained through the adoption, at a 

minimum, of RACT.

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

great detail. U.S. EPA determined RACT is part of the 

broader RACM analysis and identification of all measures (for 

stationary, mobile, and area sources) that are technically and 

economically feasible, and that would collectively contribute 

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

States are required to use a combined approach to RACT 

and RACM, that identifies potential measures that are 

reasonable; uses modeling to identify the attainment date that 

is as expeditious as practicable; and selects the appropriate 

RACT and RACM. The Implementation Rule also established 

that that EGU compliance with CAIR is equivalent to 

RACM/RACT for a state that fulfills the CAIR emission 

reduction requirements.

Demonstration

In 1979, 1981, and 1998 Kentucky promulgated rules 

requiring RACM for particulate emissions from stationary 

sources. Statewide RACT rules have been applied to all new 

sources locating in Kentucky since that time. RACT 

requirements are incorporated into permits along with 

monitoring, recordkeeping, and reporting necessary to ensure 

ongoing compliance. KYDAQ also has an enforcement 

program to address violations. The KYDAQ RACT rules are 

found in 401 KAR Chapter 59.

In addition, KYDAQ promulgated NOx SIP Call rules (401 

KAR 51:150, 51:160, 51:170), CAIR (401 KAR 51:210, 

51:220, 51:230), and NOx RACT rules (401 KAR Chapter 59) 
50

over the past several years. Emissions from EGUs make up a 

significant contribution to Kentucky’s inventory. Beginning in 

2009, Kentucky implemented CAIR which has, and will, 

provide for significant reductions in NOx, PM2.5, and SO2 until 

CSPAR requirements take place which will provide even 

greater reductions.

Reasonable Further Progress, Requirement 2 of 6

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

demonstration SIPs for nonattainment areas to show reasonable further 

progress (RFP). 

Background

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

area which a state projects an attainment date beyond 2010. 

The RFP would provide emission reductions showing linear 

progress between 2002 and 2009. If a state demonstrates 

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

the attainment demonstration to demonstrate achievement of 

RFP.

Demonstration

In Kentucky’s attainment demonstration submitted on 

December 8, 2008, Kentucky demonstrated (using a weight 

of evidence approach) that attainment would be achieved in 

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

submit a separate RFP plan.

EMISSION INVENTORY, Requirement 3 of 6

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

actual emissions.

Background

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

inventory of actual emissions in the area, including the 

requirement for periodic revisions as determined necessary. 

40 CFR 51.1008 requires such inventory to be submitted 

within three years of designation and requires a baseline 

emission inventory for calendar year 2002 or other suitable 

year to be used for attainment planning.

Demonstration

The 2002 comprehensive inventory was submitted to U.S. 

EPA with Kentucky’s PM2.5 attainment demonstration SIP 

submitted on December 3, 2008 (Appendix E, document 

provided electronically on disc). Kentucky updates the 
51

inventory in accordance with U.S. EPA’s CERR rule (i.e. 

emissions statements). As discussed in Chapter 4, 

Provisions for Future Inventory Updates, (Requirement 5), 

KYDAQ submits, and commits to submit, emission 

inventories every three years. 

IMPLEMENTATION OF PREVIOUS SIP REVISIONS, Requirement 4 of 6

Evidence that control measures required in previous PM2.5 SIP revisions 

have been fully implemented.

Background

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

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

result in significant emission reductions from large EGUs, 

industrial boilers, and cement kilns in the eastern United 

States. Kentucky adopted these rules in 2001. NOx SIP Call 

requirements are incorporated into permits along with 

monitoring, recordkeeping, and reporting necessary to 

ensure ongoing compliance. KYDAQ also has an 

enforcement program to address violations. Compliance is 

tracked through the Clean Air Markets data monitoring 

program. Beginning in 2004, this rule accounts for a reduction 

of approximately 31% of all NOx emissions statewide 

compared to previous uncontrolled years. The other 21 states 

also have adopted similar rules.

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

KYDAQ submitted a CAIR SIP to U.S. EPA on July 19, 2007. 

The CAIR SIP was approved as a direct final action on 

October 4, 2007 [74 FR 48857]. The Kentucky administrative 

regulations developed for the CAIR SIP became effective 

December 3, 2007 (401 KAR 51:210, 220, 230). Those 

regulations are still in place.

Emission reductions required by CSAPR will begin January 1, 

2012 under the first phase of compliance for SO2 and annual 

NOx, and May 1, 2012 for ozone season NOx reductions. The 

second phase of SO2 reductions begins January 1, 2014. By 

2014, CSAPR will reduce power plant SO2 emissions by 73% 

from 2005 levels. Power plant NOx emissions will drop 54%.
52

Demonstration

Federal Control Measures

NOx SIP Call Rule

Controls for EGUs under the NOx SIP Call formally 

commenced May 31, 2004. Emissions covered by this 

program have been trending downward since 1998 with 

larger reductions occurring in 2002 and 2003. Data taken 

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

gradual NOx reductions that have occurred in Kentucky as a 

result of Title IV, 1990 CAA Amendments and the beginning 

of the NOx SIP Call Rule. Kentucky developed the NOx

Budget Trading Program rules in 401 KAR Chapter 51 in 

response to the SIP Call. 401 KAR Chapter 51 regulates 

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

based on an 85% reduction of NOx emissions from EGUs 

and a 60% reduction of NOx emissions from non-EGUs, 

compared to historical levels. This cap was in place through 

2008, at which time the CAIR program superseded it as 

discussed above. Chapter 4, demonstration of maintenance, 

discusses the reductions Kentucky has seen as a result of 

CAIR.

On April 21, 2004, U.S. EPA published Phase II of the NOx 

SIP Call that established a budget for large (greater than 1 

ton per day emissions) stationary internal combustion 

engines, and for large utility and industrial boilers. 401 KAR 

51:150 regulates stationary internal combustion engines, and 

401 KAR 51:160 regulates large utility and industrial boilers, 

both were effective February 2, 2006. U.S. EPA approved 

this revision to the SIP on November 23, 2009.

Tier II Emission Standards for Vehicles and Gasoline Sulfur 

Standards

On February 10, 2000, U.S. EPA finalized a federal rule [65 

FR 6698] to significantly reduce emissions from cars and light 

trucks, including sport utility vehicles (SUVs). Under this rule, 

automakers will be required to sell cleaner cars, and 

refineries are required to make cleaner, lower sulfur gasoline. 

The federal rule was phased in between 2004 and 2009. 

U.S. EPA has estimated that NOx emission reductions are 

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. Emission 

reductions of VOC are approximately 12% for passenger 
53

cars; 18% for smaller SUVs, light trucks, and minivans; and 

15% for larger SUVs, vans, and heavier trucks. 

The Tier II rule also reduced the sulfur content of gasoline 

from 300 parts per million (ppm) to 30 ppm in January 2006. 

Most gasoline sold in Kentucky prior to January 2006 had a 

sulfur content of approximately 300 ppm. Sulfur occurs 

naturally in gasoline but interferes with the operation of 

catalytic converters on vehicles resulting in higher NOx

emissions. Low sulfur gasoline was necessary to achieve the 

Tier II vehicle emission standards. 

Heavy-Duty Gasoline and Diesel Highway Vehicle Standards

On October 6, 2000, the U.S. EPA promulgated a rule [65 FR 

59896] that began in 2004 to reduce NOx and VOC emissions 

from heavy-duty gasoline and diesel highway vehicle. A 

second phase of standards and testing procedures began in 

2007 to reduce particulate matter from heavy-duty engines, 

and reduces highway diesel fuel sulfur content to 15 ppm 

since sulfur in fuel damages high efficiency catalytic exhaust 

emission devices. The total program should achieve a 90% 

reduction in particulate matter emissions and a 95% reduction 

in NOx emissions for new engines using low-sulfur diesel, 

compared to existing engines using higher content sulfur 

diesel.

Large Nonroad Diesel Engines Rule

On May 11, 2004, the U.S. EPA promulgated a rule [69 FR 

26222] for large nonroad diesel engines, such as those used 

in construction, agricultural, and industrial equipment, to be 

phased in between 2008 and 2014. The nonroad diesel rule 

also reduced the allowable sulfur in nonroad diesel fuel by 

over 99% by 2010. The U.S. EPA estimated that affected 

nonroad diesel engines currently account for 44% of total 

diesel PM emissions and 12% of total NOx from mobile 

sources nationwide. Nonroad diesel fuel currently averages 

3,400 ppm sulfur. The rule limited nonroad diesel sulfur 

content to 500 ppm in 2006 and 15 ppm in 2010. The 

combined diesel engine rules reduce NOx and PM emissions 

from large nonroad diesel engines by over 90%, compared to 

current nonroad engines using higher-content sulfur diesel.

Nonroad Spark-Ignition Engines and Recreational Engine 

Standard

On November 8, 2002, the U.S. EPA promulgated a rule [67 

FR 68242] that regulate NOx, hydrocarbons (HC) and carbon 
54

monoxide (CO) for groups of previously unregulated nonroad 

engines. The standard applies to all new engines sold in the 

United States and imported after these standards began and 

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 or 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 while Tier 2 

began in 2007. Like the large spark-ignition, recreational 

vehicles contribute to PM levels, as well ozone formation and 

ambient CO. For the off-highway motorcycles and all-terrainvehicles, model year 2006, the new exhaust emissions 

standard was phased-in by 50% and for model years 2007 

and later at 100%. Recreational marine diesel engines over 

37 kilowatts are used in yachts, cruisers, and other types of 

pleasure craft. Recreational marine engines contribute to PM 

levels and ozone formation, especially in marinas. 

Depending on the size of the engine, the standard began to 

be phased-in during 2006. 

When all of the nonroad spark-ignition engines and 

recreational engines standards are fully implemented, an 

overall 72% reduction in HC, 80% reduction in NOx, and 56% 

reduction in CO emissions are expected by 2020. These 

controls will help reduce ambient concentrations of PM2.5, 

CO, and ozone.

Reciprocating Internal Combustion Engine Standard

On May 3, 2010, U. S. EPA promulgated a rule [75 FR 9648] 

to regulate emissions of air toxics from existing diesel 

powered stationary reciprocating internal combustion engines 

that meet specific site rating, age, and size criteria. These 

engines are typically used at industrial facilities (e.g. power, 

chemical, and manufacturing plants) to generate electricity for 

compressors and pumps and to produce electricity to pump 

water for flood and fire control during emergencies. 

The standard applies to stationary diesel engines located at 

an area source of air toxics and constructed or reconstructed 

before June 12, 2006; located at a major source of air toxics, 

having a rating of less than or equal to 500 horsepower, and 

constructed or reconstructed before June 12, 2006; or located 
55

at a major source of air toxics for non-emergency purposes, 

having a rating of greater than 500 horsepower, and 

constructed or reconstructed before December 19, 2002.

Operators of existing engines will be required to: install 

emissions control equipment that will limit air toxics up to 70% 

for stationary non-emergency engines with ratings greater 

than 300 horsepower; perform emission tests to demonstrate 

engine performance and compliance with rule requirements; 

and burn ultra-low sulfur fuel in stationary non-emergency 

engines with a rating greater than 300 horsepower. 

When all of the reciprocating internal combustion engine 

standards are fully implemented in 2013, U.S. EPA estimates 

that emissions from these engines will reduce air toxics by 

approximately 1,000 tpy, PM2.5 by 2,800 tpy; CO by 14,000 

tpy, and VOC by 27,000 tpy.

Category 3 Marine Diesel Engine Standards

On June 29, 2010, the U.S. EPA promulgated a rule [75 FR 

22896] establishing more stringent exhaust emission 

standards for new large marine diesel engines with percylinder displacement at or above 30 liters (commonly 

referred to as Category 3 compression-ignition marine 

engines) as part of a coordinated strategy to address 

emissions from all ships that effect U.S. air quality. These 

emission standards are equivalent to those adopted in the 

amendments to Annex VI to the International Convention for 

the Prevention of Pollution from Ships (MARPOL Annex VI). 

The emission standards apply in two stages. Near-term 

standards for newly built engines will apply beginning in 2011 

and long-term standards requiring an 80% reduction in NOx 

emissions will begin in 2016. 

U.S. EPA is adopting changes to the diesel fuel program to 

allow for the production and sale of diesel fuel with up to 

1,000 ppm sulfur for use in Category 3 marine vessels. The 

regulation forbids production and sale of fuels with more than 

1,000 ppm sulfur for use in most U.S. waters, unless 

operators achieve equivalent emission reductions in other 

ways. U.S. EPA is also adopting provisions to apply some 

emission and fuel standards to foreign-flagged and in-use 

vessels that are covered by MARPOL Annex VI.

When this strategy is fully implemented in 2030, U.S. EPA 

estimates that NOx and PM2.5 emissions in the U.S. will be 
56

reduced by approximately 1.2 million tpy and 143,000 tpy, 

respectively. 

State Control Measures

New Process Operations – 401 KAR 59:010

New Process Operations provides for the control of emissions for 

affected facilities or sources located in nonattainment areas as well 

as attainment areas. This regulation will continue to apply to those 

affected facilities or sources if the area is redesignated to attainment 

or unclassified status, unless a state implementation plan which 

provides for other controls is approved by the U.S. EPA.

RACT/RACM – 401 KAR 50:012

The Kentucky PM2.5 nonattainment/maintenance areas will continue 

to implement the RACT/RACM requirements promulgated by the 

regulation. The analysis in the previously submitted “Kentucky Fine 

Particulate Matter (PM2.5) Attainment Demonstration for the 

Louisville, KY-IN, Cincinnati-Middletown, OH-KY-IN, and 

Huntington-Ashland, WV-KY-OH Nonattainment Areas” (December 

2008) established that these measures contributed to the region 

being able to comply with the PM2.5 NAAQS (1997).

Open burning bans – 401 KAR 63:005

In 2005 Kentucky revised the open burning regulation to prohibit 

most types of burning in PM2.5 nonattainment/maintenance areas 

within Kentucky during the period of May-September.

Fugitive Emissions – 401 KAR 63:010

This regulation provides for the control of fugitive emissions in the 

state.

Clean Air Interstate Rule – 401 KAR 51:210-230

In response to the CAIR, Kentucky developed regulations 401 KAR 

51:210, CAIR NOX annual trading program; 401 KAR 51:220, CAIR 

NOx ozone season trading program; and 401 KAR 51:230, CAIR 

SO2 trading program. These regulations became effective February 

2, 2007. 

Under the rules, Kentucky has caps as follows:

Annual NOx: 83,205 tons for 2009-2014 and 

69,337 tons for 2015 and each year 

thereafter;
57

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 regulations 401 KAR 51:210 and 401 

KAR 51:220. The U.S. EPA determined the SO2 allocations, which 

are based on the acid rain program. This rule does not preclude 

Kentucky from adopting additional emission reduction requirements 

for covered sources if necessary to attain or maintain an ambient air 

quality standard.

The intent of the CAIR program was for national NOx emissions to 

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

2009, and 1.3 million tons in 2018 in 28 eastern states. As a result 

of CAIR, the U.S. EPA projected that in 2009 Kentucky emissions of 

NOx would decrease from a baseline of 176,00 tpy per year without 

CAIR to 107,000 tpy with CAIR. Projections also demonstrated that 

in 2010, emissions of SO2 would decrease from a baseline of 

447,000 tpy without CAIR to 341,000 tpy with CAIR. The U.S. EPA 

projects that by 2015 NOx emissions will decrease further to 77,000 

tpy while emissions of SO2 will decrease to 270,000 tpy within 

Kentucky. (Source: http://www.epa.gov/CAIR/ky.html ) 

As discussed previously, Kentucky did incorporated these expected 

CAIR reductions into the redesignation request inventories and 

projections regarding SO2 and NOx but did not incorporate CAIR 

reductions into the PM2.5 inventory. However, it should also be 

noted that Kentucky’s SIP-approved NOx SIP Call program and 

regulations, and the CAIR program and associated regulations, are 

still in place and providing reductions. Further, the requirements of 

CSAPR will ensure additional emission reductions. All controls 

noted thus far for redesignation are expected to continue into the 

future. Those control measures will continue providing reduction for 

particulate precursors and emissions throughout the maintenance 

period.

In addition to the rule discussed above, various maximum available 

control technology (MACT) rules have or will be promulgated by 

U.S. EPA and adopted by KYDAQ, providing additional particulate 

controls. These include:
58

MACT Controls

RICE MACT

The U.S. EPA published a final rule August 10, 2010 [75 FR 51570] 

that provided national emission standards for hazardous air 

pollutants (NESHAP) for existing stationary spark ignition (SI) 

reciprocating internal combustion engines (RICE). This final rule 

addresses emissions from existing stationary SI engines less than or 

equal to 500 HP located at major sources and all existing stationary 

SI engines located at area sources. Emission control technologies 

that will be installed on stationary RICE units to reduce HAP will also 

reduce CO and VOC, and for rich burn engines will also reduce 

NOx. This final rule is expected to reduce emissions of NOx from 

stationary RICE units located at area sources by 96,000 tons per 

year (tpy) in the year 2013.

Major/Area Boiler MACT

On March 21, 2011, the U. S. EPA finalized a rule [76 FR 15608] 

that will reduce emissions of HAP from new and existing industrial, 

commercial, and institutional boilers and process heaters at major 

source facilities. Additionally the U.S. EPA finalized a similar rule [76 

FR 15554] to reduce emissions of HAP from two area source 

categories: industrial boilers, and commercial and institutional 

boilers. The effective date of May 20, 2011 for both rules was 

delayed [ 76 FR 28662] until such time as judicial review is no longer 

pending or until final reconsideration of the rules is completed, 

whichever is earlier.

Utility MACT

On May 3, 2011 the U.S. EPA proposed a rule that will set 

standards to reduce air pollution from coal and oil-fired power plants 

[76 FR 24976]. All existing sources must comply in three years, but 

individual sources can obtain an additional year if technology cannot 

otherwise be installed in time. The proposed rule establishes 

emission standards for mercury, acid gases (hydrochloric acid (HCl), 

as a surrogate), and non-mercury metallic toxic pollutants (PM as a 

surrogate with alternative surrogate of total metal air toxics). Each 

year this rule will: 

Prevent 91% of the mercury in coal burned in power plants 

from being emitted to the air;

Reduce acid gas emissions from power plants by 91%; and 

Reduce SO2 emissions from power plants by 55 percent.
59

New source review provisions, Requirement 5 of 6

Acceptable provisions to provide for new source review.

Background

Kentucky has a longstanding and fully implemented SIPapproved regulation 401 KAR 51:052 that establishes air 

quality permitting requirements for the construction or 

modification of major stationary sources located within, or 

impacting upon, nonattainment areas. The regulation 

ensures that the construction or modification will not 

contribute significantly to Kentucky’s achievement of 

reasonable further progress of a NAAQS. Similarly, SIPapproved regulation 401 KAR 51:017 establishes air quality 

permitting requirements for the construction or modification of 

major stationary sources located in an area designated 

attainment or unclassifiable. The regulation ensures that the

construction or modification will not significantly deteriorate 

the air quality of the area. 

Demonstration

Any facility that was not listed in the 2005 emission inventory, 

or for the closing of which credit was taken in demonstrating 

attainment, will not be allowed to construct, reopen, modify, 

or reconstruct without meeting all applicable NSR 

requirements. Once the area is redesignated, KYDAQ will 

implement NSR through the PSD program. 

Assurance of continued controls, Requirement 6 of 6

Assure that all existing control measures will remain in effect after 

redesignation unless the State demonstrates through modeling that the 

standard can be maintained without one or more control measures.

Demonstration

Kentucky commits to maintaining the aforementioned control 

measures after redesignation. Kentucky hereby commits that 

any changes to its rules or emission limits applicable to PM2.5, 

SO2, or NOx as required for maintenance of the annual PM2.5

standard in the Huntington-Ashland area, will be submitted to 

U.S. EPA for approval as a SIP revision. 

Kentucky has the legal authority and necessary resources to 

actively enforce any violations of its rules or permit 

provisions. After redesignation, it intends to continue 

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

precursors in the Huntington-Ashland area.
60

CHAPTER SIX – CONTINGENCY MEASURES

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

Commitment to Review Maintenance Plan, Requirement 1 of 4

A commitment to submit a revised plan eight years after redesignation.

Demonstration

Kentucky hereby commits to review its maintenance plan 

eight years after redesignation, as required by Section 175(A) 

of the CAA.

Commitment for Contingency Measures, Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

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

occur.

Demonstration

Kentucky hereby commits to adopt and expeditiously 

implement necessary corrective actions in the following 

circumstances:

In the event that a measured value of the weighted annual 

mean of 15.5 ug/m3per cubic meter or greater occurs in a 

single calendar year in any portion of the maintenance area, 

the state will evaluate existing control measures to determine 

if any further emission reduction measures should be 

implemented at that time.

In the event of a monitored violation of the annual PM2.5

NAAQS in the Huntington-Ashland maintenance area, 

Kentucky commits to adopt, within nine months, one or more 

of the following contingency measures to re-attain the 

standard. All regulatory programs will be implemented within 

18 months after the triggering monitored violation.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the 

necessary administrative and legal process. This process will 

include publication of notices, an opportunity for public 

hearing, and other measures required by Kentucky law for 

rulemaking. 

If a new measure/control is already promulgated and 

scheduled to be implemented at the federal or state level, and 

that measure/control is determined to be sufficient to address 
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the upward trend in air quality, additional local measures may 

be unnecessary. Furthermore, Kentucky will submit to U.S. 

EPA an analysis to demonstrate the proposed measures are 

adequate to return the area to attainment. 

Potential Contingency Measures, Requirement 3 of 4

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

an event.

Demonstration

Contingency measures to be considered will be selected from 

a comprehensive list of measures deemed appropriate and 

effective at the time the selection is made. The selection of 

measures will be based on cost-effectiveness, emission 

reduction potential, economic and social considerations or 

other factors that KYDAQ deems appropriate. KYDAQ will 

solicit input from all interested and affected persons in the 

maintenance area prior to selecting appropriate contingency 

measures. Because it is not possible at this time to 

determine what control measures will be appropriate at an 

unspecified time in the future, the list of contingency 

measures outlined below is not exhaustive.

Implementation of a program to require additional emission 

reductions on stationary sources; 

Implementation of fuel programs, including incentives for 

alternative fuels; 

Restriction of certain roads or lanes, or construction of such 

roads or lanes for use by passenger buses or high-occupancy 

vehicles;

Trip-reduction ordinances;

Employer-based transportation management plans, including 

incentives;

Programs to limit or restrict vehicle use in downtown areas, or 

other areas of emission congestion, particularly during 

periods of peak use; 

Programs for new construction and major reconstructions of 

paths or tracks for use by pedestrians or non-motorized 

vehicles when economically feasible and in the public 

interest;

Diesel reduction emission strategies, including diesel retrofit 

programs.

Kentucky also reserves the right to implement other 

contingency measures if new control programs should be 

developed and deemed more advantageous for the area. No 
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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.

List of PM2.5, SO2, and NOx Requirement 4 of 4

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

control requirements.

Demonstration

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

subject to future controls.

ICI Boilers;

EGUs;

process heaters;

internal combustion engines;

combustion turbines;

other sources greater than 100 tons per year;

fleet vehicles;

concrete manufacturers;

aggregate processing plants
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CHAPTER SEVEN – PUBLIC PARTICIPATION

Kentucky published notification for a public hearing and solicitation for 

public comment concerning the draft redesignation petition and 

maintenance plan in the Ashland Daily Independent newspaper and on the 

Division for Air Quality’s website. 

The public hearing to receive comments on the redesignation request was 

scheduled for December 22, 2011 at the Ashland-Boyd County Health 

Department, 2916 Holt Street, Ashland, Kentucky. The public hearing was 

cancelled after this agency received no request to conduct the hearing. 

Written comments were received during the public comment period.

Appendix F includes a copy of the public notice, certification of publication, 

and the statement of consideration.
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CHAPTER EIGHT - CONCLUSIONS

The Huntington-Ashland annual PM2.5 nonattainment area has attained the 

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

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

nonattainment areas. U.S EPA published the clean data determination on 

September 7, 2011, noting the area has attained the NAAQS by its 

applicable attainment date of April 5, 2010. Documentation to that effect is 

contained in Appendix A. The Kentucky Division for Air Quality has 

prepared a redesignation request and maintenance plan that meet the 

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

Based on this presentation, the Huntington-Ashland annual PM2.5 

nonattainment area meets the requirements for redesignation under the 

CAA and U.S. EPA guidance. KYDAQ has performed an analysis that 

demonstrates the air quality improvements are due to permanent and 

enforceable measures. Furthermore, since this area is subject to 

significant transport of pollutants, significant regional SO2 and NOx

reductions will ensure continued compliance (maintenance) with the 

standard with an increasing margin of safety.

The Commonwealth of Kentucky hereby requests that the HuntingtonAshland annual PM2.5 nonattainment area be redesignated to attainment 

simultaneously with U.S. EPA approval of the maintenance plan provisions 

contained herein.