Ohio Environmental 

Protection Agency 

Governor 

Lt. Governor 

Director 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Blvd. R-19J 

Chicago, Illinois 60604-3507 

JUN 2 9 2012 

Re: Request for Review and Approval of the Revised Cincinnati - Hamilton Area 

Maintenance Plan Approval for the 1997 Eight-Hour Ozone Standard 

Dear Administrator Hedman: 

I am writing to formally request review and approval of a revision to the maintenance 

plan for the Ohio portion of the Cincinnati-Hamilton, OH-IN-KY area (Butler, Clermont, 

Clinton, Hamilton and Warren Counties in Ohio; Dearborn Township in Indiana; and 

Boone, Campbell, and Kenton Counties in Kentucky) with respect to the 1997 eight-hour 

ozone standard. Ohio EPA submitted a redesignation request and maintenance plan for 

this area on December 14, 2009 and a request to revise the maintenance plan on July 

6, 2010. Subsequently, U.S. EPA approved these requests on May 11, 2010 (FR 26118) 

and November 29, 2010 (FR 72954), respectively. 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile 

emission projections and conformity budgets based on emission rates generated from 

U.S. EPA's latest mobile emissions model, the Motor Vehicle Emission Simulation 

(MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA's 

official emission factor model. The area is still attaining and maintaining the 1997 8-hour 

ozone standard and the point, area and non-road emissions have not changed 

significantly and did not need to be updated for this submittal. 

If you have any questions, please contact Jennifer Dines in our Division of Air Pollution 

Control at (614) 644-3696. 

Sincerely, 

~irecto r enclosures 

cc: Bob Hodanbosi, DAPC 

Jennifer Dines, DAPC 

50 West Town street, Suite 700 

P.O. Box 1049 

Columbus, OH 43216-1049 

614 1 644 3020 

614 I 644 3184 (fax) 

www.epa .ohio.gov 
 

REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR 

THE CINCINNATI-HAMILTON, OH-KY-IN 

8- HOUR OZONE 

NONATTAINMENT AREA 

Butler, Clermont, Clinton, Hamilton, 

 and Warren Counties, Ohio 

Prepared by: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

December 2009 

Revised July 2010, June 2012
 

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i 

TABLE OF CONTENTS 

Chapter One 

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

Background ................................................................................................................................... 1 

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

Status of air quality ....................................................................................................................... 2 

Chapter Two 

Requirements for redesignation .................................................................................................... 3 

Chapter Three 

Ozone monitoring .......................................................................................................................... 7 

Ozone NAAQS .............................................................................................................................. 7 

Ambient data quality assured ........................................................................................................ 8 

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

Commitment to continue monitoring ........................................................................................... 11 

Chapter Four 

Emission inventory ...................................................................................................................... 13 

Base year inventory .................................................................................................................... 13 

Emission projections ................................................................................................................... 14 

Demonstration of maintenance ................................................................................................... 23 

Permanent and enforceable emissions reductions ..................................................................... 37 

Provisions for future updates ...................................................................................................... 37 

Chapter Five 

Control measures and regulations .............................................................................................. 39 

Marginal nonattainment areas to implement RACT .................................................................... 39 

Emission inventories/statements ................................................................................................ 39 

Implementation of past SIP revisions .......................................................................................... 40 

New source review provisions ................................................................................................... 44 

Assurance of continued controls ................................................................................................. 44 

Chapter Six 

Contingency measures ............................................................................................................... 45 

Commitment to revise plan ......................................................................................................... 45 

Commitment for contingency measures ..................................................................................... 45 

Potential contingency measures ................................................................................................. 46 

List of VOC and NOx sources...................................................................................................... 48 

Chapter Seven 

Public participation ...................................................................................................................... 49 

Chapter Eight 

Conclusions ................................................................................................................................ 50 
ii 

FIGURES 

Figure 1 Cincinnati-Hamilton Basic Nonattainment Area..................................................... 8 

TABLES 

Table 1 Monitoring Data for Cincinnati-Hamilton 2007 – 2009 ......................................... 10 

Table 2 Emission Estimations for On-road Mobile Sources for Butler Co., Ohio ............. 19 

Table 3 Emission Estimations for On-road Mobile Sources for Clermont Co., Ohio ........ 19 

Table 4 Emission Estimations for On-road Mobile Sources for Clinton Co., Ohio ............ 19 

Table 5 Emission Estimations for On-road Mobile Sources for Hamilton Co., Ohio ......... 19 

Table 6 Emission Estimations for On-road Mobile Sources for Warren Co., Ohio ........... 19 

Table 7 Emission Estimations for On-road Mobile Sources for Dearborn Co., Indiana .... 20 

Table 8 Summary of Ohio and Indiana Emission Estimations for On-Road Mobile 

Sources ............................................................................................................... 20 

Table 9 Emission Estimations for On-road Mobile Sources for Boone Co., Kentucky ..... 20 

Table 10 Emission Estimations for On-road Mobile Sources for Campbell Co., Kentucky 20 

Table 11 Emission Estimations for On-road Mobile Sources for Kenton Co., Kentucky .... 20 

Table 12 Summary of Kentucky Emission Estimations for On-Road Mobile Sources ........ 21 

Table 13 Emission Estimations for On-road Total Cincinnati-Hamilton Sources ................ 21 

Table 14 Mobile Vehicle Emission Budget for Ohio and Indiana ....................................... 21 

Table 15 Mobile Vehicle Emission Budget for Kentucky .................................................... 22 

Table 16 NOx Emission Inventory Butler Co, Ohio. ........................................................... 25 

Table 17 NOx Emission Inventory Clermont Co., Ohio. ..................................................... 26 

Table 18 NOx Emission Inventory Clinton Co., Ohio. ......................................................... 26 

Table 19 NOx Emission Inventory Hamilton Co., Ohio. ...................................................... 27 

Table 20 NOx Emission Inventory Warren Co., Ohio. ........................................................ 27 

Table 21 NOx Emission Inventory Dearborn Co., Indiana. ................................................. 28 

Table 22 NOx Emission Inventory Boone Co., Kentucky ................................................... 28 

Table 23 NOx Emission Inventory Campbell Co., Kentucky. ............................................. 29 

Table 24 NOx Emission Inventory Kenton Co., Kentucky. ................................................. 29 

Table 25 NOx Emission Inventory Cincinnati-Hamilton, Total ............................................ 30 

Table 26 VOC Emission Inventory Butler Co, Ohio. ........................................................... 30 

Table 27 VOC Emission Inventory Clermont Co., Ohio. ..................................................... 31 

Table 28 VOC Emission Inventory Clinton Co., Ohio. ........................................................ 31 

Table 29 VOC Emission Inventory Hamilton Co., Ohio. ..................................................... 32 

Table 30 VOC Emission Inventory Warren Co., Ohio. ....................................................... 32 

Table 31 VOC Emission Inventory Dearborn Twp., Indiana. .............................................. 33 

Table 32 VOC Emission Inventory Boone Co., Kentucky ................................................... 33 

Table 33 VOC Emission Inventory Campbell Co., Kentucky. ............................................. 34 

Table 34 VOC Emission Inventory Kenton Co., Kentucky. ................................................. 34 

Table 35 VOC Emission Inventory Cincinnati-Hamilton, Total ........................................... 35 

Table 36 Projected Emission Estimates 2008-2020 Cincinnati-Hamilton........................... 35 

Table 37 Combined Comparison of 2005 and 2008 On-road and EGU Totals .................. 37 

 
iii 

APPENDICES 

A Air Quality System (AQS) Data 

B Ohio 2005 SIP Base Year Inventory Discussion 

C “Mobile Source Emissions Inventory for the Cincinnati Ozone Nonattainment Area” 

D LADCO Technical Support Document 

E Public Participation Documentation 
iv 

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1 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 

CINCINNATI-HAMILTON, OHIO 

OZONE NONATTAINMENT AREA 

Butler, Clermont, Clinton, Hamilton, and Warren Counties, Ohio 

CHAPTER ONE 

Introduction 

The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air 

Quality Standard (NAAQS) for ozone to develop State Implementation Plans 

(SIP’s) to expeditiously attain and maintain the standard. In 1997, the United 

States Environmental Protection Agency (U.S. EPA) revised the air quality 

standard for ozone replacing the 1979 one-hour standard with an eight-hour 

ozone standard set at 0.08 parts per million (ppm). The standard was 

challenged legally and upheld by the U.S. Supreme Court in February of 2001. 

On April 30, 2004, U.S. EPA designated 134 nonattainment areas for the eighthour ozone standard. 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 eight-hour 

ozone 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. 

 

Background 

The current Cincinnati-Hamilton nonattainment area includes the following 

Counties: Butler, Clermont, Clinton, Hamilton, and Warren in Ohio; Dearborn 

(partial nonattainment of Lawrenceburg Township only) in Indiana; and Boone, 

Campbell, and Kenton in Kentucky. 

As part of the 1990 CAA Amendments re-evaluation, the following Counties 

within the Cincinnati-Hamilton area were designated as moderate 

nonattainment for the one-hour ozone standard pursuant to the CAA and, 
2 

therefore, were subject to nonattainment area rulemakings: Butler, Clermont, 

Hamilton, and Warren Counties in Ohio and Boone, Campbell and Kenton 

Counties in Kentucky. The Ohio portion of the Cincinnati-Hamilton area was 

redesignated to attainment on June 19, 2000 (65 FR 37879). Clinton County, 

Ohio was designated as a transitional nonattainment area. Clinton County was 

redesignated to attainment on March 21, 1996 (61 FR 11560). A maintenance 

plan was approved at those times. 

As a result of the 2004 ozone designations, U.S. EPA designated the 

Cincinnati-Hamilton area basic nonattainment for the eight-hour standard, and 

Ohio EPA was required to develop a plan to reduce volatile organic 

compounds (VOCs) and nitrogen oxides (NOx) emissions to meet the federal 

eight-hour air quality standard for ozone by June 2009. 

This document is intended to support Ohio’s request that the Ohio portions of 

the Cincinnati-Hamilton area be redesignated from nonattainment to attainment 

for the eight-hour ozone standard. In addition, the States of Kentucky and 

Indiana also intend to submit requests for their respective portions of the 

Cincinnati-Hamilton area. The Cincinnati-Hamilton area has recorded three (3) 

years of complete quality-assured ambient air quality monitoring data for the 

years 2007 – 2009 demonstrating attainment of the eight-hour ozone standard. 

Geographical Description

The Cincinnati-Hamilton eight-hour ozone nonattainment area is located in 

southwest Ohio and includes the following Counties of: Butler, Clermont, 

Clinton, Hamilton, and Warren in Ohio; Dearborn (partial nonattainment of 

Lawrenceburg Township only) in Indiana; and Boone, Campbell, and Kenton in 

Kentucky. This area is shown in Figure 1 under Chapter Three. 

 Status of Air Quality 

Ozone monitoring data for the most recent three (3) years, 2007 through 2009, 

demonstrate that the air quality has met the NAAQS for ozone in this basic 

nonattainment area. The NAAQS attainment, accompanied by decreases in 

emission levels discussed in Chapter Four, supports a redesignation to 

attainment for the Cincinnati-Hamilton area based on the requirements in 

Section 107(d)(3)(E) of the CAA. 
3 

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 V. 

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

Cincinnati-Hamilton area. 

i.) Attainment of the standard 

 There are two components involved in making this 

demonstration. The first component relies on ambient air quality 

data. The data that are used to demonstrate attainment should 

be the product of ambient monitoring that is representative of the 

area of highest concentration. The data should be collected and 

quality-assured in accordance with 40 CFR 58 and recorded in 

the Air Quality System (AQS) in order for it to be available to the 

public for review. 

 The second component relies upon supplemental U.S. EPAapproved air quality modeling. The supplemental modeling is not 

required for ozone nonattainment areas seeking redesignation; 

however, in Appendix C and Appendix D the most recent 

modeling results showing future attainment and maintenance are 

provided. Chapter Three discusses this requirement in more 

detail and provides the attainment demonstration. 

ii.) SIP approval 

 The SIP for the area must be fully approved under Section 

110(k) and must satisfy all the requirements that apply to the 

area. Ohio’s SIP was approved on May 9, 1994 (59FR23799) 

and March 23, 1995 (60FR15235) and includes the CincinnatiHamilton area. Chapter Five discusses this requirement in more 

detail. 

iii.) Permanent and enforceable improvement in air quality 

 The state must be able to reasonably attribute the improvement 

in air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures 

that have been adopted and implemented by the state. 
4 

The Ohio Counties portion of the Cincinnati-Hamilton area was 

designated moderate nonattainment for ozone as part of the 

1990 CAA Amendments re-evaluation. As a result, Ohio has 

adopted and implemented control measures for these Counties 

in that area beyond the federal measures and the initial 

1979/1981 Statewide rules. In addition, Ohio EPA has adopted 

several rules recently that will have an impact Statewide on 

ozone emissions in the future: 

• Portable Fuel Containers requirements 

• Architectural and Industrial Maintenance (AIM) Coatings 

rules 

• Consumer Products rules 

• Clean Air Interstate Rule (CAIR) 

• NOx Sip Call Rules 

 Chapters Four and Five discuss this requirement in more detail. 

iv.) Section 110 and Part D requirements 

 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. 

 Part D consists of general requirements applicable to all areas 

which are designated nonattainment based on a violation of the 

NAAQS. 

 i.) Section 110(a) requirements 

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

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

the implementation plan submitted by a state must have 

been adopted by the state after reasonable public notice 

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

enforceable emission limitations and other control 

measures, means or techniques necessary to meet the 

requirements of the CAA; provide for establishment and 

operation of appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 

provide for implementation of a source permit program to 

regulate the modification and construction of any 

stationary source within the areas covered by the plan; 

include provisions for the implementation of Part C, 

prevention of significant deterioration (PSD) and Part D, 

NSR permit programs; include criteria for stationary 

source emission control measures, monitoring, and 

reporting; include provisions for air quality modeling; and 
5 

provides for public and local agency participation in 

planning and emission control rule development. In Ohio’s 

December 5, 2007 and September 4, 2009 infrastructure 

SIP submissions, Ohio verified that the State fulfills the 

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

 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. 

 ii.) 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. 

v.) Maintenance plans 

 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 must constitute a SIP revision and must 

provide for maintenance of the relevant NAAQS in the area for at 

least 10 years after redesignation. Section 175 (A) further states 

that the plan shall contain such additional measures, if any, as 

may be necessary to ensure such maintenance. 

In addition, the maintenance plan shall contain such contingency 

measures as the Administrator deems necessary to ensure 

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

the contingency measures must include a requirement that the 

state will implement all measures contained in the nonattainment 

SIP prior to redesignation. 
6 

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. 
7 

CHAPTER THREE 

OZONE MONITORING1

CAA Section107 (d)(3)(E)(i) 

Requirement 1 of 4 

A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, has 

been attained. 

Background

 There are eleven monitors measuring ozone concentrations in 

this nonattainment area. Eight of the eleven monitors, located in 

Ohio, are operated by Ohio EPA Division of Air Pollution Control, 

Southwest District Office and the Hamilton County Division of 

Environmental Services. A listing of the design values based on 

the three-year average of the annual fourth highest daily 

maximum eight-hour average ozone concentrations from 2007 

through 2009 is shown in Table 1. The locations of the 

monitoring sites for this nonattainment area are shown on Figure 

1. 

 

1 The draft version of this redesignation request primarily contains data through the end of 

August and has not been fully quality assured. However, all data will be incorporated and 

quality assured, as described in the text of this document, prior to official submittal to U.S. 

EPA. Ohio EPA does not believe the data as provided in this draft will change appreciably.
8 

Demonstration

 

Figure 1 Map of the Cincinnati-Hamilton, OH nonattainment area 

and monitor locations 

 Requirement 2 of 4 

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

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

public view. 

Demonstration

The Ohio Environmental Protection Agency (Ohio EPA) has quality 

assured all data shown in Appendix A in accordance with 40 CFR 58.10 

and the Ohio Quality Assurance Manual. Ohio EPA has recorded the 

data in the AQS database and, therefore, the data are available to the 

public. 
9 

Requirement 3 of 4 

A showing that the three-year average of the fourth highest values, based on 

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

below 85 parts per billion (ppb). (This showing must rely on three complete, 

consecutive calendar years of quality assured data.) 

 

Background

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

Data Handling Conventions for the eight-hour ozone National 

Ambient Air Quality Standard (NAAQS)," U.S. EPA-454/R-98-

017, December 1998. 

Three complete years of ozone monitoring data are required to 

demonstrate attainment at a monitoring site. The eight-hour 

primary and secondary ozone ambient air quality standards are 

met at an ambient air quality monitoring site when the three-year 

average of the annual fourth-highest daily maximum eight-hour 

average ozone concentrations is less than or equal to 0.08 ppm. 

 When this occurs, the site is said to be in attainment. Three 

significant digits must be carried in the computations. Because 

the third decimal digit, in ppm, is rounded, 0.084 ppm is the 

largest concentration that is less than or equal to 0.08 ppm. 

Therefore, for the purposes of this request, the eight-hour 

standard is considered to be 0.085 ppm. Values 

below 0.085 ppm meet the standard, values equal to or greater 

than 0.085 ppm exceed the standard. These data handling 

procedures are applied on an individual basis at each monitor in 

the area. An area is in compliance with the eight-hour ozone 

NAAQS if, and only if, every monitoring site in the area meets 

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

annual fourth highest daily maximum eight-hour average ozone 

concentrations is also called the site's design value. 

Table 1 shows the monitoring data for 2007 – 2009 that were 

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

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

area. Please note that the standard is measured in ppm while the 

commonly used unit is ppb. For the remainder of this document, 

ppb will be used. 
10 

Demonstration

Table 1 Monitoring Data for the Cincinnati-Hamilton, OH area for 

2007 – 2009 

 

Data source: U.S. EPA Air Quality System (AQS) 

http://www.epa.gov/ttn/airs/airsaqs/index.htm

    1st 2nd 3rd 4th 2007-2009 

SITE 

ID 

COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE

39-017-

0004 Butler Hamilton 2007 100 97 96 91 91 78 

39-017-

0004 Butler Hamilton 2008 99 89 75 72 71 

39-017-

0004 Butler Hamilton 2009 98 79 78 74 73 

39-017-

1004 Butler Middletown 2007 100 104 97 95 91 82 

39-017-

1004 Butler Middletown 2008 96 91 87 82 79 

39-017-

1004 Butler Middletown 2009 100 78 76 76 76 

39-025-

0022 Clermont Batavia 2007 98 93 92 90 86 75 

39-025-

0022 Clermont Batavia 2008 97 72 71 71 71 

39-025-

0022 Clermont Batavia 2009 99 71 71 69 69 

39-027-

1002 Clinton Wilmington 2007 99 91 89 85 82 76 

39-027-

1002 Clinton Wilmington 2008 96 87 80 77 76 

39-027-

1002 Clinton Wilmington 2009 96 73 72 71 70 

39-061-

0006 Hamilton Cincinnati 2007 96 100 92 91 89 82 

39-061-

0006 Hamilton Cincinnati 2008 96 93 89 87 86 

39-061-

0006 Hamilton Cincinnati 2009 98 80 76 75 72 

39-061-

0010 Hamilton Cleves 2007 99 93 91 88 86 76 

39-061-

0010 Hamilton Cleves 2008 96 85 79 78 77 

39-061-

0010 Hamilton Cleves 2009 80 69 66 65 65 

39-061-

0040 Hamilton Cincinnati 2007 99 97 93 88 86 80 
11 

    1st 2nd 3rd 4th 2007-2009 

SITE 

ID 

COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE

39-061-

0040 Hamilton Cincinnati 2008 100 86 83 81 80 

39-061-

0040 Hamilton Cincinnati 2009 99 77 76 74 74 

39-165-

0007 Warren Lebanon 2007 100 103 89 88 88 82 

39-165-

0007 Warren Lebanon 2008 95 92 87 84 82 

39-165-

0007 Warren Lebanon 2009 100 80 80 78 77 

21-015-

0003 Boone Not in City 2007 100 81 79 78 78 68 

21-015-

0003 Boone Not in City 2008 98 65 64 64 64 

21-015-

0003 Boone Not in City 2009 98 69 67 65 64 

21-037-

3002 Campbell 

Highland 

Heights 2007 100 95 92 88 86 76 

21-037-

3002 Campbell 

Highland 

Heights 2008 99 84 83 75 75 

21-037-

3002 Campbell 

Highland 

Heights 2009 100 75 72 70 68 

21-117-

0007 Kenton Covington 2007 100 93 89 85 85 77 

21-117-

0007 Kenton Covington 2008 99 80 77 74 73 

21-117-

0007 Kenton Covington 2009 99 76 75 75 74 

Highest Average 82 ppb 

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, both regionally and locally. 

Requirement 4 of 4 

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

appropriate monitoring network to verify the maintenance of the attainment 

status. 

Demonstration

 Ohio EPA commits to continue monitoring ozone levels at the 

Ohio sites indicated in Figure 1. Ohio EPA will consult with U.S. 

EPA Region V prior to making changes to the existing monitoring 

network, should changes become necessary in the future. Ohio 

EPA will continue to quality assure the monitoring data to meet 
12 

the requirements of 40 CFR 58 and all other federal 

requirements. Connection to a central station and updates to the 

Ohio EPA web site2

 will provide real time availability of the data 

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

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

 

2

 www.epa.state.oh.us/dapc/ 
13 

CHAPTER FOUR 

EMISSION INVENTORY

CAA Section107 (d)(3)(E)(iii) 

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

inventory of ozone precursor emissions (VOC and NOx) representative of the 

year when the area achieves attainment of the ozone air quality standard. 

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

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

based on permanent and enforceable emission reductions. Other emission 

inventory related requirements include a projection of the emission inventory to 

a year at least 10 years following redesignation; a demonstration that the 

projected level of emissions is sufficient to maintain the ozone standard; and a 

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

emission levels during the 10-year maintenance period. 

The emissions inventory development and emissions projection discussion 

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

projections, identifies procedures used by Ohio EPA and the Lake Michigan Air 

Directors Consortium (LADCO) regarding emissions from Ohio’s portion of the 

Counties in the Cincinnati-Hamilton area. Specific emissions data are provided 

for all Counties, including those in Ohio, Kentucky and Indiana. Indiana and 

Kentucky emissions data were obtained directly from Indiana and Kentucky, 

respectively. All of these inventories and emissions projections were prepared 

using similar methodologies. Ohio recognizes that revisions to the emissions 

data below may be necessary once Kentucky and Indiana prepare a 

redesignation request and maintenance plan for their portion of the 

nonattainment area. Mobile emissions inventories and projections for all 

Counties were prepared by the Ohio, Kentucky, Indiana Council of 

Governments (OKI). 

Requirement 1 of 5 

A comprehensive emission inventory of the precursors of ozone completed 

for the base year. 

Background

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

reporting program. The 2005 periodic inventory has been 

identified as one of the preferred databases for SIP development 

and coincides with nonattainment air quality in the CincinnatiHamilton area. 

Periodic inventories, which include emissions from all sectors - 

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

three years. 
14 

Demonstration

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

this submittal and was submitted to U.S. EPA on June 15, 2007 

along with the attainment demonstration for this area. The 

detailed emission inventory information for the Ohio portion of 

the Cincinnati-Hamilton area is provided in Appendix B. 

Emissions of VOC and NOx for 2005 are identified under 

Requirement Three of this Chapter. 

Requirement 2 of 5 

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

redesignation. 

Background

Ohio EPA prepared a comprehensive inventory for the Ohio portion of 

the Cincinnati-Hamilton area including area, mobile, and point sources 

for precursors of ozone (VOCs and NOx) for base year 2005. The 2005 

inventory was submitted to U.S. EPA on June 15, 2007 as part of the 

attainment demonstration for this area. The information below describes 

the procedures Ohio EPA used to generate the 2005 base year 

inventory and to develop SIP-ready modeling inventories and future 

year projections (Pechan Report3

). The report by Pechan generated 

future year estimates of annual emissions for each source sector using 

accepted growth surrogates. These inventories were provided to the 

LADCO and have been processed to develop summer-day emissions 

for use in the air quality analyses. These processed modeling 

inventories have been identified as the correct iteration of the inventory 

for use in the redesignation. In this document, references to LADCO 

include the Midwest Regional Planning Organization. Note, the on-road 

mobile source sector was addressed by specific modeling as discussed 

below. 

• Area sources were taken from the Ohio 2005 periodic 

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

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

Economic Analysis (BEA) growth factors, with some 

updated local information. 

• Mobile source emissions were calculated from 

MOVES2010-produced emission factors. 

 

3

http://www.ladco.org/tech/emis/r5/reports/LADCO%202005%20Base%20Yr%20Growth%20and%2

0Controls%20Report_Final.pdf 
15 

• Point source information was compiled from Ohio EPA’s 

2005 annual emissions inventory database and the 2005 

U.S. EPA Air Markets acid rain database4. 

• Biogenic emissions are not included in these summaries. 

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

National Mobile Inventory Model (NMIM) 2002 

application. To address concerns about the accuracy of 

some of the categories in U.S. EPA’s non-road emissions 

model, LADCO contracted with two (2) companies to 

review the base data and make recommendations. One 

of the contractors also estimated emissions for three (3) 

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

model. Emissions were estimated for aircraft, commercial 

marine vessels, and railroads. Recreational motorboat 

population and spatial surrogates (used to assign 

emissions to each county) were significantly updated. The 

populations for the construction equipment category were 

reviewed and updated based upon surveys completed in 

the midwest, and the temporal allocation for agricultural 

sources also was updated. 

 

Demonstration

On-Road Emission Estimations 

In coordination with the Ohio Department of Transportation (Ohio 

DOT), OKI utilizes a regional travel demand forecast model to 

simulate traffic in the area and to forecast traffic flows for given 

growth expectations. The model has been validated to observed 

traffic volumes for the model base year 2005. The model is 

primarily used as a long range planning tool to evaluate the 

transportation system including determination of locations where 

additional travel capacity may be needed and to determine the 

infrastructure requirements necessary to meet that need. It is 

also used as a tool for air quality purposes to estimate the total 

emissions of pollution caused by vehicles in the area. The travel 

demand forecasting model is used to predict the total daily 

vehicle miles traveled (VMT), and a U.S. EPA computer program 

called MOVES2010 is used to calculate emissions per mile. The 

product of these is the total amount of pollution emitted by the 

on-road vehicles for the area. Clinton County is outside the area 

covered by the regional travel demand model. The Ohio DOT 

uses traffic counts and local traffic growth rates for the VMT 

estimates. 

 

4 http://www.epa.gov/airmarkets/acidrain 
16 

Overview 

Emission Factor Model 

OKI’s generation of this ozone inventory utilized U.S.EPA’s 

emissions model MOVES 2010 to develop both running and nonrunning vehicle emission factors for VOC and NOX. Emission 

factors represent summer weekday travel. Local parameters 

utilized as input to MOVES include 1) average July 

meteorological data, 2) vehicle type and age data as provided by 

the Ohio DOT, 3) VMT by vehicle type, 4) fuel formulation 

reflective of the summer fuel requirements in Southwest Ohio, 

and 5) VMT distributions by road type and average speeds from 

the OKI Travel Demand Model. 

OKI Travel Demand Model 

Vehicle miles traveled and vehicle hours were estimated using 

the OKI Travel Demand Model Version 7.6. The OKI Travel 

Demand Model is composed of CUBE Voyager programs and a 

series of FORTRAN programs written by OKI. It is a state of the 

practice model that uses the standard 4 phase sequential 

modeling approach of trip generation, distribution, modal choice 

and assignment. The model uses demographic and land use 

data and capacity and free-flow speed characteristics for each 

roadway segment in the network to produce a “loaded” highway 

network with forecasted traffic volumes with revised speeds 

based on specified speed/capacity relationships. 

Travel analysis zones are the basic geographic unit for 

estimating travel in the OKI model. The OKI region is subdivided 

into 1608 traffic analysis zones to permit detail as well as 

manageability. A variety of socioeconomic data items are used 

in the OKI transportation planning process. These data are used 

primarily to forecast future travel patterns by serving as 

independent variables in OKI trip generation equations. The 

following categories of planning data are utilized: 

• Population (household and group quarter) 

• Households 

• Household vehicles 

• Employment (by employment category and zone of work) 

• Labor force participation (by zone of residence) 

• Area type 

The principal data requirements of the OKI travel demand 
17 

forecasting model are population and employment. From these 

variables, other characteristics including households, labor force, 

and personal vehicles may be derived. 

OKI utilizes both base year (2005) and future year data (2015, 

2020, and 2030) in the planning process. Planning data are 

maintained at the Traffic Analysis Zone (TAZ) level, and originate 

in the 2000 Census of Population and Housing. Base year and 

future year population, households, household vehicles, labor 

force and employment are developed through various methods. 

 All of the variables represent the latest OKI planning 

assumptions. OKI’s Travel Demand Model has been validated to 

observed traffic volumes for the model base year 2005. The 

modeling network also includes Greene, Miami and Montgomery 

counties in Ohio and the remainder of Dearborn County Indiana. 

 The difference between estimated vehicle miles traveled (VMT) 

and 2005 observed VMT is less than 1%. The modeling network 

encompasses the entire ozone maintenance area with the 

exception of Clinton County, Ohio. Clinton County is outside the 

area covered by the regional travel demand model. The Ohio 

DOT uses traffic counts and local traffic growth rates for the VMT 

estimates in Clinton County. 

OKI incorporates a variety of sources of local data to both 

improve and confirm the accuracy of VMT, as well as other 

travel-related parameters. Free flow speeds used on the 

highway and transit networks are based on travel time studies 

performed locally. The OKI post-processing program, IMPACT, 

uses the loaded highway network to generate VMT by hour, VMT 

by speed distribution and VMT by facility type. These tables are 

then included as input into MOVES. The VMT by hour tables 

utilize hourly traffic distribution and directional split factors for 

different roadway types as developed by OKI. The main source 

of the data was the permanent traffic counting stations located 

throughout the OKI region for the years of 2004-2006. This data 

was supplemented with data collected at coverage count stations 

(locations with counts taken on only one-two days). The stations 

were classified by area type: urban and rural, and functional 

classification: freeway, arterial and collector. Speeds 

representing various “loaded” conditions (with traffic volumes) 

are estimated using techniques from the Highway Capacity 

Manual. This permits the estimation of speeds as conditions 

vary from hour to hour on the different facility types throughout 

the region. The IMPACT program performs the appropriate 

summation by area and roadway type as well as regional totals. 

OKI has also developed seasonal conversion factors to adjust 
18 

traffic volumes to summer conditions. The factors were derived 

from local data collected at permanent traffic counting stations 

utilizing the average daily traffic monthly conversion factors for 

June, July and August. 

Local Road VMT 

Most local roads such as subdivision streets are not explicitly 

modeled in a travel demand model. Local roads within each 

traffic analysis zone are represented by centroid connectors. 

Local road VMT and speeds are included in the OKI post 

process by including the traffic loaded on centroid connectors. In 

addition, some local road traffic is captured as intra-zonal trips 

which travel demand models usually do not assign to roadway 

segments. The OKI post process assigns these trips as local 

road VMT. 

Analysis Years 

Analysis years for this revision request include 2005, 2008 

(attainment year), 2015 (interim year), and 2020. The travel 

demand model presents the transportation system conditions for 

each of these years. Model runs for each future analysis year 

contain the road network OKI and Ohio DOT expect to exist in 

July of that year with corresponding socioeconomic forecasts for 

that year. 

 

On-Road Mobile Emission Estimations 

Tables 2 through 13 contain the results of the emissions analysis for 

the appropriate years. All emissions estimations are expressed in 

tons per summer day (TSD). 
19 

Table 2 - Butler County, Ohio Emission Estimations for 

 On-Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 16.70 17.12 8.72 6.68 

NOx (TSD) 27.76 23.15 14.53 11.36 

VMT (miles/day) 7,804,476 8,133,554 8,721,511 9,277,916 

Table 3 - Clermont County, Ohio Emission Estimations for 

 On-Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 11.13 11.41 5.81 4.45 

NOx (TSD) 18.50 15.42 9.68 7.57 

VMT (miles/day) 5,391,578 5,599,530 5,810,859 6,181,573 

Table 4 - Clinton County, Ohio Emission Estimations for 

 On-Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 2.92 2.51 1.37 0.93 

NOx (TSD) 6.53 5.50 3.01 1.86 

VMT (miles/day) 1,956,501 1,939,190 2,215,886 2,349,923 

Table 5 - Hamilton County, Ohio Emission Estimations for 

 On-Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 49.03 50.26 25.59 19.61 

NOx (TSD) 81.49 67.95 42.65 33.35 

VMT (miles/day) 23,170,766 23,481,421 25,598,858 27,231,982 

Table 6 - Warren County, Ohio Emission Estimations for 

 On-Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 12.59 12.90 6.57 5.03 

NOx (TSD) 20.92 17.44 10.95 8.56 

VMT (miles/day) 6,263,010 6,464,217 6,571,210 6,990,432 
20 

Table 7 – Dearborn County, Indiana Emission Estimations for 

On-Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 1.31 1.35 0.69 0.53 

NOx (TSD) 2.18 1.82 1.14 0.89 

VMT (miles/day) 599,761 613,027 686,339 730,126 

Table 8 – Summary of Ohio and Indiana Emission Estimations 

for On-Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 93.68 95.55 48.75 37.23 

NOx (TSD) 157.38 131.28 81.96 63.59 

VMT (miles/day) 45,186,092 46,230,939 49,604,663 52,761,952 

Table 9 - Boone County, Kentucky Emission Estimations for OnRoad Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 9.71 6.37 3.50 2.27 

NOx (TSD) 30.88 21.32 12.16 7.22 

VMT (miles/day) 4,186,006 4,355,527 4,712,497 5,129,347 

Table 10 - Campbell County, Kentucky Emission Estimations for 

On-Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 5.62 3.69 2.03 1.31 

NOx (TSD) 17.87 12.34 7.04 4.18 

VMT (miles/day) 2,437,698 2,495,174 2,727,746 2,969,033 

Table 11 - Kenton County, Kentucky Emission Estimations for 

On-Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 9.87 6.47 3.56 2.31 

NOx (TSD) 31.40 21.68 12.36 7.34 

VMT (miles/day) 4,182,042 4,197,027 4,791,791 5,215,655 
21 

Table 12 – Summary of Kentucky Emission Estimations for On- 

 Road Mobile Sources 

 2005 2008 2015 2020 

VOC (TSD) 25.20 16.53 9.09 5.89 

NOx (TSD) 80.15 55.34 31.56 18.74 

VMT (miles/day) 10,805,746 11,047,728 12,232,034 13,314,035 

Table 13 - Emission Estimation Totals for On-Road Mobile 

 Sources for the Cincinnati-Hamilton Area 

 2005 2008 2015 2020 

VOC (TSD) 118.88 112.08 57.84 43.12 

NOx (TSD) 237.53 186.62 113.52 82.33 

VMT (miles/day) 55,991,838 57,278,667 61,836,697 66,075,987 

Motor Vehicle Emission Budget 

Table 14 and Table 15 contain the motor vehicle emissions 

budgets for the Cincinnati-Hamilton area. For planning purposes, 

budgets are established for the combined Ohio and Indiana 

portions and for the separate Kentucky portion. 

Table 14 - Mobile Vehicle Emissions Budget for Ohio and 

Indiana 

 

2015 Estimated 

Emissions 

2015 

Mobile 

Safety 

Margin 

Allocation*

2015 Total 

Mobile 

Budget 

2020 Estimated 

Emissions 

2020 

Mobile 

Safety 

Margin 

Allocation*

2020 Total 

Mobile 

Budget 

VOC (TSD) 48.75 7.31 56.06 37.23 5.58 42.81 

NOx (TSD) 81.96 12.29 94.25 63.59 9.54 73.13 

VMT 

(miles/day) 49,604,663 - - 52,761,952 - - 

*The 15 percent margin of safety was calculated by taking 15 

percent of the mobile source emission estimates. 

Table 15 - Mobile Vehicle Emissions Budget for Kentucky 
22 

 

2015 

Estimated 

Emissions 

2015 

Mobile 

Safety 

Margin 

Allocation 

2015 

Total 

Mobile 

Budget 

2020 

Estimated 

Emissions 

2020 

Mobile 

Safety 

Margin 

Allocation 

2020 

Total 

Mobile 

Budget 

VOC (TSD) 9.09 1.36 10.45 5.89 0.88 6.77 

NOx (TSD) 31.56 4.73 36.29 18.74 2.81 21.55 

VMT 

(miles/day) 12,232,034 - - 13,314,035 - - 

The above budgets for the Ohio and Indiana portion of the area, 

agreed upon as part of the interagency consultation process, 

include the emission estimates calculated for 2015 and 2020 

(from Table 8) with an additional 15 percent margin of safety 

allocated to those estimates. 

In an effort to accommodate future variations in travel demand 

models and VMT forecast when no change to the network is 

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

reasonable approach to address this variation. Based on this 

discussion, a 15 percent margin of safety allocation was agreed 

upon and has been added to the emissions estimates for the 

Ohio and Indiana portions of this nonattainment area. 

The above budget for the Kentucky portion of the area was 

provided directly by Kentucky as part of the consultation process 

and also includes a margin of safety allocated to the emission 

estimates calculated for 2015 and 2020 (from Table 12). 

The emission estimates are derived from the travel demand 

model and MOVES2010 as described above under the expected 

OKI 2030 Long Range Plan. All methodologies, the latest 

planning assumptions, and the safety margins allocations were 

determined through the interagency consultation process 

described in the Transportation Conformity Memorandum of 

Understanding (MOU) among OKI, Ohio DOT, and Ohio EPA. 

A 15 percent margin of safety is appropriate because: 1) there is 

an acknowledged potential variation in VMT forecast and 

potential estimated mobile source emissions due to expected 

modifications to TDM and mobile emissions models; and 2) the 

total decrease in emissions from all sources is sufficient to 

accommodate this 15 percent allocation of safety margin to 

mobile sources while still continuing to maintain the total 

emissions in the Cincinnati-Hamilton area well below the 2006 

attainment level of emissions. 
23 

 

The 15 percent margin of safety was calculated by taking 15 

percent of the mobile source emission estimates. Safety margin, 

as defined by the conformity rule, looks at the total emissions 

from all sources in the nonattainment area. The actual allocation 

is less than 15 percent of the total emission reduction from all 

sources as can be seen from Table 36. 

In summary, for all three states combined, the mobile budget 

safety margin allocation translates into: 

--An allocation of 7.31 TSD for VOC and 12.29 TSD for 

NOx for 2015; and 

-An allocation of 5.58 TSD for VOC and 9.54 TSD for NOx 

for 2020. 

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

CFR 93.1015

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

evident this allocation is significantly below the total safety 

margin for this area (see Table 36). 

The current one-hour budgets will no longer be applicable either after 

the effective date of the approved redesignation or after the effective 

date of any U.S. EPA action approving a finding that the eight-hour 

conformity budget included in this submittal is adequate for 

transportation conformity purposes, whichever date comes first. 

Requirement 3 of 5 

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

the ozone standard. 

Background

In consultation with U.S. EPA, Ohio EPA selected the year 2020 

as the maintenance year for this redesignation request. This 

document contains projected emissions inventories for 2015 and 

2020. 

Emission projections for the Cincinnati-Hamilton area were 

performed using the following approaches: 

 

5 "safety margin" means the amount by which the total projected emissions 

from all sources of a given pollutant are less than the total emissions that 

would satisfy the applicable requirement for reasonable further progress, 

attainment, or maintenance.
24 

• As performed by OKI, mobile source emission projections 

are based on the U.S. EPA MOVES2010 model. The 

analysis is described in more detail in Appendix C. All 

projections were made in accordance with “Procedures 

for Preparing Emissions Projections” U.S. EPA-45/4-91-

019. 

• Emissions inventories are required to be projected to 

future dates to assess the influence growth and future 

controls will have. LADCO has developed growth and 

control files for point, area, and non-road categories. 

These files were used to develop the future-year 

emissions estimates used in this document. This was 

done so the inventories used for redesignation are 

consistent with modeling performed in the future. 

Appendix D contains LADCO’s technical support 

document detailing the analysis used to project emissions 

(Base M6

). 

• For the Ohio portion of the Cincinnati-Hamilton area, for 

the 2008 attainment year, emissions were grown from the 

2005 LADCO modeling inventory, using LADCO’s growth 

factors, for all sectors except point sources (electrical 

generating units and non-electrical generating units). 

Point source emissions for 2008 were compiled from Ohio 

EPA’s 2008 annual emissions inventory database. The 

2015 interim year emissions were estimated based on the 

2009 and 2018 LADCO modeling inventory, using 

LADCO’s growth factors, for all sectors. The 2020 

maintenance year is based on emissions estimates from 

the 2018 LADCO modeling. 

The detailed inventory information for the Ohio portion of the 

Cincinnati-Hamilton area for 2005 is in Appendix B. Emission 

trends are an important gauge for continued compliance with the 

ozone standard. Therefore, Ohio EPA performed an initial 

comparison of the inventories for the base year and maintenance 

years. Mobile source emission inventories are described in 

Section 5 of Appendix B. 

Sectors included in the following tables are: 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). 

 

6

 http://www.ladco.org/tech/emis/current/index.php 
25 

Maintenance is demonstrated when the future-year (2020) 

projected emission totals are below the 2008 attainment year 

totals. 

The emissions data in the tables below are based on the 

following data sources 

Demonstration

NOx

Table 16 - Butler County, Ohio NOx Emission Inventory 

Totals (TSD)7

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

3.88 2.87 2.86 2.95 

Non-EGU 12.03 10.53 13.29 13.22 

Non-road 7.76 6.55 4.06 3.01 

Other 2.15 2.18 2.19 2.19 

MAR 2.49 2.34 1.85 1.63 

On-road 27.76 23.15 14.53 11.36 

TOTAL 56.07 47.62 38.78 34.36 13.26 

 

7

 Ohio EPA has revised the Butler County, Ohio NOx Emissions Inventory to incorporate 

the total emissions reduction credits available and used to offset the allowed emissions of a 

major source modified within the maintenance area that will begin operating during the 

maintenance period. The total emissions included for this facility is 479.57 tons per year 

(assumed TSD = TPY/365). The emissions increase does not significantly impact the safety 

margin for this area or prevent the area from maintaining the standard in future years. 
26 

Table 17 - Clermont County, Ohio NOx Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 42.96 22.61 50.07 51.49 

Non-EGU 0.15 0.18 0.16 0.16 

Non-road 4.07 3.48 2.21 1.67 

Other 1.65 1.67 1.67 1.67 

MAR 0.96 0.74 0.55 0.50 

On-road 18.50 15.42 9.68 7.57 

TOTAL 68.29 44.10 64.34 63.06 -18.96 

Table 18 - Clinton County, Ohio NOx Emission Inventory 

Totals (TSD) 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 

Non-EGU 0.00 0.00 0.00 0.00 

Non-road 2.21 1.96 1.34 1.07 

Other 0.42 0.43 0.43 0.43 

MAR 0.05 0.05 0.05 0.06 

On-road 6.53 5.50 3.01 1.86 

TOTAL 9.21 7.94 4.83 3.42 4.52 
27 

Table 19 - Hamilton County, Ohio NOx Emission Inventory Totals (TSD) 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 15.23 12.92 28.32 29.13 

Non-EGU 6.72 6.17 7.39 7.56 

Non-road 16.08 13.28 8.04 5.89 

Other 5.19 5.27 5.30 5.30 

MAR 4.49 3.93 3.14 2.84 

On-road 81.49 67.95 42.65 33.35 

TOTAL 129.20 109.52 94.84 84.07 25.45 

Table 20 - Warren County, Ohio NOx Emission Inventory 

Totals (TSD)

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 

Non-EGU 2.68 3.14 2.70 2.70 

Non-road 5.84 4.94 3.01 2.19 

Other 1.15 1.17 1.17 1.17 

MAR 0.26 0.25 0.21 0.19 

On-road 20.92 17.44 10.95 8.56 

TOTAL 30.85 26.94 18.04 14.81 12.13 

 
28 

Table 21 - Dearborn County, Indiana NOx Emission Inventory 

(TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 Maintenance Safety 

Margin 

EGU Point 25.31 27.34 25.30 26.03 

Non-EGU 5.09 3.21 5.12 5.19 

Non-road 

* 

1.26 1.14 0.78 0.65 

Other 0.26 0.26 0.27 0.27 

On-road 2.18 1.82 1.14 0.89 

TOTAL 34.10 33.77 32.61 33.03 0.74 

*MAR emissions are included in the Non-road emissions 

 

 

Table 22 - Boone County, Kentucky NOx Emission Inventory 

Totals (TSD) 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

23.80 23.15 24.97 26.35 

Non-EGU 0.14 0.12 0.11 0.12 

Non-road 

* 

12.96 11.02 9.77 9.48 

Other 4.99 5.02 5.03 5.03 

On-road 30.88 21.32 12.16 7.22 

TOTAL 72.77 60.63 52.04 48.20 12.43 

*MAR emissions are included in the Non-road emissions
29 

Table 23 - Campbell County, Kentucky NOx Emission Inventory 

Total (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

0.00 0.00 0.00 0.00 

Non-EGU 0.00 0.02 0.02 0.03 

Nonroad* 

6.33 5.34 4.57 4.34 

Other 1.41 1.32 1.30 1.30 

On-road 17.87 12.34 7.04 4.18 

TOTAL 25.61 19.02 12.93 9.85 9.17 

*MAR emissions are included in the Non-road emissions

Table 24 - Kenton County, Kentucky NOx Emission Inventory 

 Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

0.00 0.00 0.00 0.00 

Non-EGU 0.04 0.03 0.03 0.03 

Nonroad* 

8.43 7.33 6.15 5.75 

Other 4.17 4.06 4.02 4.02 

On-road 31.40 21.68 12.36 7.34 

TOTAL 44.04 33.10 22.56 17.14 15.96 

*MAR emissions are included in the Non-road emissions
30 

Table 25 - Cincinnati-Hamilton Area NOx Emission Inventory 

Totals (TSD)

NOx 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

 

Butler 56.07 47.62 38.78 34.36 

Clermont 68.29 44.10 64.34 63.06 

Clinton 9.21 7.94 4.83 3.42 

Hamilton 129.20 109.52 94.84 84.07 

Warren 30.85 26.94 18.04 14.81 

Dearborn 34.10 33.77 32.61 33.03 

Boone 72.77 60.63 52.04 48.20 

Campbell 25.61 19.02 12.93 9.85 

Kenton 44.04 33.10 22.56 17.14 

COMBINED 

NOx TOTAL 470.14 382.64 340.97 307.94 74.70 

 

VOC 

Table 26 - Butler County, Ohio VOC Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety Margin 

EGU 

Point 

0.03 0.03 0.02 0.02 

Non-EGU 3.64 2.77 4.25 4.56 

Non-road 6.73 5.54 4.85 4.71 

Other 11.96 10.31 9.76 9.76 

MAR 0.15 0.14 0.10 0.09 

On-road 16.70 17.12 8.72 6.68 

TOTAL 39.21 35.91 27.70 25.82 10.09 
31 

Table 27 - Clermont County, Ohio VOC Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

0.49 0.27 0.52 0.53 

Non-EGU 0.24 0.09 0.26 0.27 

Non-road 4.31 3.66 3.11 2.95 

Other 6.98 6.05 5.74 5.74 

MAR 0.02 0.02 0.02 0.01 

On-road 11.13 11.41 5.81 4.45 

TOTAL 23.17 21.50 15.46 13.95 7.55 

Table 28 - Clinton County, Ohio VOC Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

0.00 0.00 0.00 0.00 

Non-EGU 0.00 0.00 0.00 0.00 

Non-road 1.73 1.60 1.20 1.02 

Other 3.24 2.85 2.72 2.72 

MAR 0.04 0.05 0.06 0.06 

On-road 2.92 2.51 1.37 0.93 

TOTAL 7.93 7.01 5.35 4.73 2.28 
32 

Table 29 - Hamilton County, Ohio VOC Emission Inventory 

Totals (TSD) 

Sector 2005 Base 2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 0.28 0.24 0.31 0.31 

Non-EGU 2.66 2.85 2.97 3.12 

Non-road 17.25 14.47 12.55 12.06 

Other 33.04 28.80 27.38 27.38 

MAR 0.20 0.19 0.15 0.13 

On-road 49.03 50.26 25.59 19.61 

TOTAL 102.46 96.81 68.95 62.61 34.20 

Table 30 - Warren County, Ohio VOC Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

0.00 0.00 0.00 0.00 

Non-EGU 0.53 0.82 0.57 0.57 

Non-road 4.78 4.09 3.38 3.14 

Other 8.40 7.30 6.94 6.94 

MAR 0.01 0.01 0.01 0.01 

On-road 12.59 12.90 6.57 5.03 

TOTAL 26.31 25.12 17.47 15.69 9.43 
33 

Table 31 - Dearborn County, Indiana VOC Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

0.33 0.35 0.44 0.46 

Non-EGU 2.91 3.23 3.51 3.69 

Non-road 0.82 0.74 0.62 0.60 

Other 2.07 2.42 1.79 1.79 

On-road 1.31 1.35 0.69 0.53 

TOTAL 7.44 8.09 7.05 7.07 1.02 

*MAR emissions are included in the Non-road emissions 

Table 32 - Boone County, Kentucky VOC Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

0.17 0.17 0.18 0.19 

Non-EGU 2.40 2.64 2.86 3.01 

Nonroad* 

5.43 5.07 4.55 4.36 

Other 8.13 8.41 8.50 8.50 

On-road 9.71 6.37 3.50 2.27 

TOTAL 25.84 22.66 19.59 18.33 4.33 

*MAR emissions are included in the Non-road emissions 
34 

Table 33 - Campbell County, Kentucky VOC Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

0.00 0.00 0.00 0.00 

Non-EGU 0.25 0.28 0.30 0.31 

Nonroad* 

1.76 1.51 1.29 1.22 

Other 4.77 4.34 4.20 4.20 

On-road 5.62 3.69 2.03 1.31 

TOTAL 12.40 9.82 7.82 7.04 2.78 

*MAR emissions are included in the Non-road emissions 

Table 34 - Kenton County, Kentucky VOC Emission Inventory 

Totals (TSD) 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point 

0.00 0.00 0.00 0.00 

Non-EGU 1.20 1.17 1.31 1.42 

Nonroad* 

2.33 1.95 1.76 1.73 

Other 8.53 7.88 7.66 7.66 

On-road 9.87 6.47 3.56 2.31 

TOTAL 21.93 17.47 14.29 13.12 4.35 

*MAR emissions are included in the Non-road emissions 
35 

Table 35 - Cincinnati-Hamilton Area VOC Emission Inventory 

Totals (TSD) 

VOC 2005 Base 2008 

Attainment 2015 Interim 2020 

Maintenance 

Safety 

Margin 

Butler 39.21 35.91 27.70 25.82 

Clermont 23.17 21.50 15.46 13.95 

Clinton 7.93 7.01 5.35 4.73 

Hamilton 102.46 96.81 68.95 62.61 

Warren 26.31 25.12 17.47 15.69 

Dearborn 7.44 8.09 7.05 7.07 

Boone 25.84 22.66 19.59 18.33 

Campbell 12.40 9.82 7.82 7.04 

Kenton 21.93 17.47 14.29 13.12 

COMBINED 

VOC TOTAL 266.69 244.39 183.68 168.36 76.03 

VOC and NOx 

 Table 36 - Cincinnati-Hamilton Area Comparison of 2008 

attainment year and projected emission estimates 

(TSD) 

 2008 2015 

2015 

Projected 

Decrease 

2020 

2020 

Projected 

Decrease 

VOC 244.39 183.68 60.71 168.36 76.03 

NOx 382.64 340.97 41.67 307.94 74.70 

As shown in the table above, VOC emissions in the 

nonattainment area are projected to decrease by 60.71 TSD in 

2015 and 76.03 TSD in 2020. Point sources in the Kentucky area 

show a slight increase due to expectations that the population 

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

expected to be in place in 2009 and 2018, and they cause an 

overall drop in VOC emissions. 

NOx emissions in the nonattainment area are projected to 

decrease by 41.67 TSD in 2015 and 74.70 TSD in 2020. Again, 

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

show a slight increase due to expectations that the population 

will grow in this area. Decreases from U.S. EPA rules covering 
36 

Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur 

Control Requirements8, Highway Heavy-Duty Engine Rule9, and 

the Non-Road Diesel Engine Rule10 are factored into the 

changes. 

All projections do not take into account reductions expected from 

the Clean Air Interstate Rule11. In many cases, Ohio utilities 

subject to CAIR have already, or will be installing controls and 

reducing NOx emissions beyond those projected for EGU’s 

above. 

As can be seen from the projected decreases above, even in the 

absence of consideration of reductions resulting from CAIR, the 

area will be able to maintain the standard. 

As identified in Table 14 and Table 15 above, an additional 

mobile budget margin of safety allocation is being requested for 

mobile emissions. The mobile budget margin of safety allocation 

translates into an additional 7.31 TSD for VOC and 12.29 TSD 

for NOx in the year 2015 and 5.58 TSD for VOC and 9.54 TSD 

for NOx in the year 2020. U.S. EPA’s conformity regulations 

allow for allocation, through a revision to the SIP, of all or some 

portion of the overall area’s safety margin (emission reductions 

from 2008 to 2020) to the mobile emissions budgets for future 

conformity. As identified in Table 14 and Table 15 above, the 

mobile budget margin of safety allocation and the total budget is 

distributed separately between Kentucky (alone) and 

Ohio/Indiana (combined). For the entire area, Ohio, Indiana and 

Kentucky chose to allocate: 

- In 2015: 7.31 TSD of the 60.71 TSD safety margin for 

VOC and 12.29 TSD of the 41.67 TSD safety margin for 

NOx as a mobile emissions budget safety margin. 

- In 2020: 5.58 TSD of the 76.03 TSD safety margin for 

VOC and 9.54 TSD of the 78.34 TSD safety margin for 

NOx as a mobile emissions budget safety margin. 

 

8 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 9 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 10 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 11 http://www.epa.gov/fedrgstr/EPA-AIR/2005/May/Day-12/a5723a.pdf 
37 

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 ozone in 2007-2009. 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 VOC and NOx emissions 

have contributed to the attainment of the eight-hour ozone standard. 

Some of these reductions were due to the application of tighter federal 

standards on new vehicles. Reductions achieved are discussed in 

greater detail under Chapter Five. 

Table 37 - Cincinnati-Hamilton Area Combined Comparison of 

2005 base year and 2008 attainment year on-road 

reductions 

 2005 2008 

On-road VOC 118.88 112.08 

On-road NOx 237.53 186.62 

Requirement 5 of 5 

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

the emission levels, including an annual emission statement from major 

sources. 

Demonstration

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

submit air emissions information annually, in accordance with 

U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). 

Ohio EPA prepares a new periodic inventory for all ozone 

precursor emission sectors every three years. These ozone 
38 

precursor inventories will be prepared for future years as 

necessary to comply with the inventory reporting requirements 

established in the CFR. Emissions information will be compared 

to the 2005 base year and the 2020 projected maintenance year 

inventories to assess emission trends, as necessary, and to 

assure continued compliance with the ozone standard. 
39 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

CAA Section107 (d)(3)(E)(ii), 107(d)(3)(iv) & 107(d)(3)(E)(v) 

Requirement 1 of 5

Section 182(a) of the 1990 Clean Air Act Amendments requires states with 

marginal nonattainment areas to implement RACT under Section 172(b). 

Background

Section 182(b) of the 1990 Clean Air Act Amendments requires 

states with moderate nonattainment areas to submit a SIP to 

correct, or add, RACT requirements under Section 172(b) (as in 

effect immediately before the enactment of the Clean Air Act 

Amendments of 1990). 

Demonstration

As required under the 1-hour ozone standard, Ohio EPA 

submitted VOC RACT rules which U.S. EPA approved on April 

25, 1996 (61 FR 18255) and September 7, 1994 (59 FR 46182). 

 

Statewide RACT rules have been applied to all new sources 

locating in Ohio since that time. RACT requirements are 

incorporated into permits along with monitoring, recordkeeping, 

and reporting necessary to ensure ongoing compliance. Ohio 

EPA also has an active enforcement program to address 

violations discovered by field office staff. The Ohio RACT rules 

are found in OAC Chapter 3745-2112. 

Requirement 2 of 5

Section 182(a)(3)(B) requires states to submit emissions statements. 

Background

Section 182(a)(3)(B) requires states to submit emissions 

statements within two years of the enactment of the Clean Air 

Act Amendments and then every three years thereafter. 

Demonstration

Ohio EPA submitted its emissions statement SIP on March 18, 

1994 which was approved by U.S. EPA on October 13, 1995 (59 

FR 51863). As discussed in Chapter 4 (Requirement 4), Ohio 

EPA submits, and commits to submit, emission inventories 

(statements) every three years. 

 

12 http://www.epa.state.oh.us/dapc/regs/3745-21/3745_21.html 
40 

Requirement 3 of 5

Evidence that control measures required in past ozone SIP revisions have 

been fully implemented. 

Background

In addition to the historic RACT requirements and those 

mentioned above, the U.S. EPA NOx SIP Call required 22 states 

to pass rules that would result in significant emission reductions 

from large EGUs, industrial boilers, and cement kilns in the 

eastern United States. Ohio passed this rule in 2001. NOx SIP 

Call requirements are incorporated into permits along with 

monitoring, recordkeeping, and reporting necessary to ensure 

ongoing compliance. Ohio EPA also has an active enforcement 

program to address violations discovered by field office staff. 

Compliance is tracked through the Clean Air Markets data 

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

reduction of approximately 31 percent of all NOx emissions 

statewide compared to previous uncontrolled years. The other 21 

states also have adopted these rules. 

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

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

eastern states and the District of Columbia to significantly reduce 

emissions of NOx. CAIR replaced the NOx SIP Call for EGUs. 

National NOx emissions will be cut from 4.5 million tons in 2004, 

to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 

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

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

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

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

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

FR 48857). As a result of CAIR, U.S. EPA projects that in 2009 

emissions of NOx will decrease from a baseline of 264,000 tons 

per year to 91,000 tons per year within Ohio13. 

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

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

mentioned above, Ohio EPA has not incorporated these 

expected CAIR reductions into this redesignation request. It 

should also be noted that Ohio’s SIP-approved NOx SIP Call 

program and regulations are still in place. Ohio EPA is currently 

in the process of revising these regulations to provide a “back 

stop” for the reinstatement of the NOx SIP Call program in the 

 

13 http://www.epa.gov/cair/pdfs/0053-2228.pdf 
41 

event the CAIR program, or an equivalent, is no longer 

implemented by U.S. EPA. 

Section 182(b) contains additional provisions applicable to 

moderate nonattainment areas, for which the Cincinnati-Hamilton 

area was under the one-hour standard. Section 182(b)(3) 

requires gasoline vapor recovery systems for gasoline 

dispensing stations in the area and section 182(b)(4) requires 

motor vehicle inspection and maintenance programs. 

Demonstration

U.S. EPA and Ohio EPA performed modeling that indicated this 

area would attain the eight-hour ozone standard with the 

implementation of the NOx SIP Call. Controls for EGUs formally 

commenced May 31, 2004. Emissions covered by this program 

have been generally trending downward since 1998 with larger 

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

EPA Clean Air Markets web site, quantify the gradual NOx

reductions that have occurred in Ohio as a result of Title IV of the 

1990 CAA Amendments and the beginning of the NOx SIP Call 

Rule. Ohio developed the NOx Budget Trading Program rules in 

OAC Chapter 3745-1414 in response to the SIP Call. OAC 

Chapter 3745-14 regulates EGUs and certain non-EGUs under a 

cap and trade program based on an 85 percent reduction of NOx 

emissions from EGUs and a 60 percent reduction of NOx

emissions from non-EGUs, compared to historical levels. This 

cap will stay in place through 2008, at which time the CAIR 

program will supersede it as discussed above. 

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

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

day emissions) stationary internal combustion engines. Ohio 

EPA’s OAC rule 3745-14-12 addresses stationary internal 

combustion engines, all used in natural gas pipeline 

transmissions. U.S. EPA approved this revision to the SIP on 

April 4, 2008. An 82 percent NOx reduction from 1995 levels is 

anticipated. Completion of the compliance plan occurred by May 

1, 2006, and the compliance demonstration began May 1, 2007. 

The 2007 controlled NOx emissions are 599 tons statewide for 

the ozone season. 

 

14 http://www.epa.state.oh.us/dapc/regs/3745-14/3745_14.html 
42 

Section 182(b)(3) requires states to submit Stage II vapor 

recovery rules no later than November 15, 1992. The U.S. EPA 

partially approved and partially disapproved Ohio's SIP revision 

for implementation of Stage II on October, 20, 1994 (59 FR 

52911). As stated in that rulemaking action, with the exception of 

paragraph 3745-21-09 (DDD)(5), U.S. EPA considers Ohio's 

Stage II program to fully satisfy the criteria set forth in the 

September 17, 1993, U.S. EPA guidance document for such 

programs entitled "Enforcement Guidance for Stage II Vehicle 

Refueling Control Programs." Furthermore, the September 17, 

1993, guidance memorandum states that once onboard vapor 

recovery regulations are promulgated, the Stage II regulations 

are no longer applicable for moderate ozone nonattainment 

areas. The U.S. EPA promulgated onboard vapor recovery rules 

in February 1994. Therefore, pursuant to Section 202(a)(6) of the 

CAA, Stage II would no longer be required. Stage I and Stage II 

requirements are still being implemented in the original one-hour 

attainment area (excludes Clinton County). 

The U.S. EPA's final I/M regulations in 40 CFR Part 85 require 

the states to submit a fully adopted I/M program by November 

15, 1993. U.S. EPA approved Ohio's enhanced I/M program (ECheck), on April 4, 1995 (60 FR 16989) and January 6, 1997 (62 

FR 646). The E-check program is no longer being implemented 

in this area. On November 3, 2005, Ohio EPA submitted a 

request for replacement of the E-Check program in this area. In 

order to transfer the E-Check program from the active 

maintenance plan to a contingency plan, alternative emission 

reduction programs were adopted to replace the benefits 

associated with the E-Check program in the one-hour 

maintenance plan approved at that time. The following programs 

were implemented in place of the E-Check program and are still 

being implemented today in the original one-hour attainment 

area (excludes Clinton County): 

• OAC rule 3745-21-09(O)(2)(e) - Vapor pressure limit for 

cold cleaning degreasing operations. Approved July 28, 

2009 (74 FR 37171) 

• OAC rule 3745-21-18 - Mobile equipment refinishing 

emission reduction via high transfer efficiency spray 

guns. Approved July 28, 2009 (74 FR 37171) 

• OAC Chapter 3745-72 - Low Reid Vapor Pressure Fuels.

Approved May 25, 2007 (72 FR 29269)

• OAC rule 3745-21-17 - Portable Fuel Containers.

Approved October 14, 2009 (74 FR 52691)
43 

Tier II Emission Standards for Vehicles and Gasoline Sulfur 

Standards 

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

significantly reduce emissions from cars and light trucks, 

including sport utility vehicles (SUVs). Under this proposal, 

automakers will be required to sell cleaner cars, and refineries 

will be required to make cleaner, lower sulfur gasoline. This rule 

will apply nationwide. The federal rules will phase in between 

2004 and 2009. U.S. EPA has estimated that NOx emission 

reductions will be approximately 77 percent for passenger cars, 

86 percent for smaller SUVs, light trucks, and minivans, and 65 

to 95 percent reductions for larger SUVs, vans, and heavier 

trucks. VOC emission reductions will be approximately 12 

percent for passenger cars, 18 percent for smaller SUVs, light 

trucks, and minivans, and 15 percent for larger SUVs, vans, and 

heavier trucks. 

Heavy-Duty Diesel Engines 

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

Duty Engines, a program which includes low-sulfur diesel fuel 

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

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

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

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

inventory. 

Clean Air Non-road Diesel Rule 

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

Rule. This rule applies to diesel engines used in industries such 

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

cleaner fuel standard similar to the highway diesel program. The 

new standards will cut emissions from non-road diesel engines 

by more than 90 percent. Non-road diesel equipment, as 

described in this rule, currently accounts for 47 percent of diesel 

particulate matter (PM) and 25 percent of NOx from mobile 

sources nationwide. Sulfur levels will be reduced in non-road 

diesel fuel by 99 percent from current levels, from approximately 

3,000 parts per million (ppm) now to 15 ppm in 2009. New 

engine standards take effect, based on engine horsepower, 

starting in 2008. 

Together, these rules will substantially reduce local and regional 

sources of ozone precursors. 
44 

Requirement 4 of 5

Acceptable provisions to provide for new source review. 

Background

Ohio has a longstanding and fully implemented New Source 

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

3745-3115. The Chapter includes provisions for the Prevention of 

Significant Deterioration (PSD) permitting program in OAC rules 

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

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

received final approval on January 22, 2003 (68FR 2909) by 

U.S. EPA as part of the SIP. 

Demonstration

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

the closing of which credit was taken in demonstrating 

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

reconstruct without meeting all applicable NSR requirements. 

Once the area is redesignated, Ohio EPA will implement NSR 

through the PSD program. 

Requirement 5 of 5

Assure that all existing control measures will remain in effect after 

redesignation unless the State demonstrates through photochemical modeling 

that the standard can be maintained without one (1) or more control measures. 

Demonstration

Ohio commits to maintaining the aforementioned control 

measures after redesignation. Ohio hereby commits that any 

changes to its rules or emission limits applicable to VOC and/or 

NOx sources, as required for maintenance of the ozone standard 

in the Cincinnati-Hamilton area, will be submitted to U.S. EPA for 

approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal section, 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 ozone 

precursors in the Cincinnati-Hamilton area. 

 

15 http://www.epa.state.oh.us/dapc/regs/3745-31/3745_31.html 
45 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4

A commitment to submit a revised plan eight (8) years after redesignation. 

Demonstration

Ohio hereby commits to review its maintenance plan eight (8) 

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

CAA. 

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

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

Demonstration

Ohio hereby commits to adopt and expeditiously implement 

necessary corrective actions in the following circumstances: 

Warning Level Response: 

A warning level response shall be prompted whenever an annual 

(1-year) fourth high monitored value of 88 ppb occurs in a single 

ozone season within the maintenance area. A warning level 

response will consist of a study to determine whether the ozone 

value indicates a trend toward higher ozone values or whether 

emissions appear to be increasing. The study will evaluate 

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

control measures necessary to reverse the trend taking into 

consideration ease and timing for implementation as well as 

economic and social considerations. Implementation of 

necessary controls in response to a warning level response 

trigger will take place as expeditiously as possible, but in no 

event later than 12 months from the conclusion of the most 

recent ozone season (October 31). 

Should it be determined through the warning level study that 

action is necessary to reverse the noted trend, the procedures 

for control selection and implementation outlined under “action 

level response” shall be followed. 
46 

Action Level Response: 

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

average fourth high monitored value of 85 parts per billion (ppb) 

or greater occurs within the maintenance area. A violation of the 

standard (three-year average fourth high value of 85 ppb or 

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

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

exceptional event, malfunction, or noncompliance with a permit 

condition or rule requirement, Ohio EPA in conjunction with the 

metropolitan planning organization or regional council of 

governments, will determine additional control measures needed 

to assure future attainment of the NAAQS for ozone. In this 

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

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

of the ozone season that prompted the action level. Ohio EPA 

will also consider the timing of an action level trigger and 

determine if additional, significant new regulations not currently 

included as part of the maintenance provisions will be 

implemented in a timely manner and will constitute our response. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the 

necessary administrative and legal process. This process will 

include publication of notices, an opportunity for public hearing, 

and other measures required by Ohio law for rulemaking. 

If a new measure/control is already promulgated and scheduled 

to be implemented at the federal or State level, and that 

measure/control is determined to be sufficient to address the 

upward trend in air quality, additional local measures may be 

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

analysis to demonstrate the proposed measures are adequate to 

return the area to attainment. 

Requirement 3 of 4

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

event. 

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and 

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

measures will be based on cost-effectiveness, emission 

reduction potential, economic and social considerations or other 
47 

factors that Ohio EPA deems appropriate. Ohio EPA will solicit 

input from all interested and affected persons in the maintenance 

area prior to selecting appropriate contingency measures. 

Because it is not possible at this time to determine what control 

measures will be appropriate at an unspecified time in the future, 

the list of contingency measures outlined below is not 

exhaustive. 

1) Implementation of an enhanced I/M program (E-Check) in 

Butler, Clermont, Hamilton and Warren Counties. 

2) Tighten or adopt VOC RACT on existing sources covered 

by U.S. EPA Control Technique Guidelines issued after 

the 1990 CAA. 

3) Apply VOC RACT to smaller existing sources. 

4) One or more transportation control measures sufficient to 

achieve at least half a percent reduction in actual areawide 

VOC emissions. Transportation measures will be selected 

from the following, based upon the factors listed above 

after consultation with affected local governments: 

a) trip reduction programs, including, but not limited 

to, employer-based transportation management 

plans, areawide rideshare programs, work 

schedule changes, and telecommuting; 

b) traffic flow and transit improvements; and 

c) other new or innovative transportation measures 

not yet in widespread use that affected local 

governments deem appropriate.

5) Alternative fuel and diesel retrofit programs for fleet 

vehicle operations. 

6) Require VOC or NOx emission offsets for new and 

modified major sources. 

7) Increase the ratio of emission offsets required for new 

sources. 

8) Require VOC or NOx controls on new minor sources (less 

than 100 tons). 
48 

9) Adopt NOx RACT for existing combustion sources. 

No contingency measure shall be implemented without providing 

the opportunity for full public participation during which the 

relative costs and benefits of individual measures, at the time 

they are under consideration, can be fully evaluated. 

Requirement 4 of 4 

A list of VOC and NOx sources potentially subject to future additional control 

requirements. 

Demonstration

The following is a list of VOC and NOx sources potentially subject to 

future controls. 

NOx RACT 

• EGUs 

• asphalt batching plants 

• industrial/commercial and institutional boilers 

• process heaters 

• internal combustion engines 

• combustion turbines 

• other sources greater than 100 tons per year 

VOC RACT 

• synthetic organic compound manufacturing 

• organic compound batch processes 

• wood manufacturing 

• industrial wastewater 

• aerospace industry 

• bakeries 

• plastic parts coating 

• volatile organic liquid storage 

• industrial solvent cleaning 

• offset lithography 

• industrial surface coating 

• other sources greater than 50 tons per year 
49 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in 

the widely distributed county publications. 

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

on May 31, 2012 at Southwest Ohio Air Quality Agency located at 250 William 

Howard Taft Road, Cincinnati, Ohio. The public comment period closed on 

May 31, 2012. No testimony was provided at the public hearing and no 

comments were received during the public comment period. Appendix E 

includes a copy of the public notice from the public hearing and comment 

period. 
50 

CHAPTER EIGHT 

CONCLUSIONS

The Cincinnati-Hamilton ozone nonattainment area has attained the 1997 

NAAQS for ozone and complied with the applicable provisions of the 1990 

Amendments to the CAA regarding redesignations of ozone nonattainment 

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

prepared a redesignation request and maintenance plan that meet the 

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

Based on this presentation, the Cincinnati-Hamilton ozone nonattainment area 

meets the requirements for redesignation under the CAA and U.S. EPA 

guidance. Ohio has performed an analysis that shows the air quality 

improvements are due to permanent and enforceable measures. Furthermore, 

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

regional NOx reductions will ensure continued compliance (maintenance) with 

the standard with an increasing margin of safety. 

The State of Ohio hereby requests that the Cincinnati-Hamilton ozone 

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

EPA approval of the maintenance plan provisions contained herein. In 

addition, the State of Ohio requests that this maintenance plan satisfy the 

requirements of CAA Section 175A (b), for subsequent plan revisions required 

for areas redesignated for the one-hour ozone standard. 
This page left intentionally blank
Appendix A-1 

Air Quality System (AQS) Data 
Appendix A-2 

SLAMS letter 
Appendix B-1 

Ohio 2005 SIP Base Year 

Inventory Discussion 
Appendix C-1 

Mobile Source Emissions 

Inventory for the Cincinnati 

Ozone Nonattainment Area 
Mobile Source Emissions Inventory 

for Cincinnati Ozone Maintenance 

Area – MOVES emissions model 

Includes a portion of Dearborn County, Indiana, the counties of Boone, Campbell, 

Kenton in Kentucky, and the counties of Butler, Clermont, Clinton, Hamilton, and 

Warren in Ohio. Emission estimates for the Year 2005, 2008, 2015, 2020, and 

2030 developed in support of revision to Ozone State Implementation Plan 

April 2012 

Prepared for the Indiana Department of Environmental Management, the Kentucky Division 

for Air Quality and the Ohio Environmental Protection Agency by 

OKI Regional Council of Governments

Acknowledgments 

Title Mobile Source Emissions Inventory for Cincinnati Ozone Maintenance Area 

Abstract This report was prepared for the Indiana Department of Environmental 

Management, the Kentucky Division for Air Quality and the Ohio 

Environmental Protection Agency. The Cincinnati Ozone Maintenance area 

includes a portion of Dearborn County Indiana, the counties of Boone, 

Campbell, Kenton in Kentucky, and the counties of Butler, Clermont, 

Clinton, Hamilton, and Warren in Ohio. Clinton County is outside of OKI’s 

MPO area with emission estimates prepared by the Ohio Department of 

Transportation. This report includes emission estimates for the years 2005, 

2008, 2015, 2020 and 2030 was generated to support a revision to the SIPs 

for the 8-hour Ozone standard. EPA’s Motor Vehicle Emission Simulation 

(MOVES) 2010 was used to generate the emission rates. 

Date April 2012 

Agency Ohio-Kentucky-Indiana Regional Council of Governments 

 Mark Policinski, Executive Director 

 Robert Koehler, P.E., Deputy Director 

 

Project Manager Andrew J. Reser, AICP 

Project Staff Harikishan Perugu, PTP 

 Larry Buckler 

 

 

The preparation of this document was financed cooperatively by the Federal Highway Administration, 

the Federal Transit Administration, the Commonwealth of Kentucky Transportation Cabinet, the Ohio 

Department of Transportation, and the units of local and county government in the OKI region. The 

opinions, findings, and conclusions expressed in this document are those of the OKI Regional Council of 

Governments and are not necessarily those of the U.S. Department of Transportation. This report does 

not constitute a standard, specification, or regulation. 

5

 OKI Ozone Mobile Source Emissions Inventory Using EPA MOVES, April 2012 

MOBILE Source Emissions Inventory for the 

Cincinnati Ozone Maintenance area 

This report was prepared for the Indiana Department of Environmental Management, the Kentucky 

Division for Air Quality and the Ohio Environmental Protection Agency. The Cincinnati Ozone 

Maintenance area includes a portion of Dearborn County Indiana, the counties of Boone, Campbell, 

Kenton in Kentucky, and the counties of Butler, Clermont, Clinton, Hamilton, and Warren in Ohio. 

Clinton County Ohio is outside OKI’s MPO boundaries. The Ohio Department of Transportation prepares 

emission estimates for Clinton County. This report includes emission estimates for the years 2005, 2008, 

2015, 2020 and 2030 generated to support the SIPs for the 8-hour ozone standard. EPA’s Motor Vehicle 

Emissions Simulator (MOVES) 2010 model was used to generate the vehicle emission rates. In 

December 2009, MOVES replaced MOBILE6.2 as the EPA’s official emission factor model. The OKI travel 

demand model version 7.6 was used to generate VMT and speed estimates. MOVES emission rates 

were generated for VOC’s, and NOx. 

OKI, as the MPO, is responsible for transportation planning and air quality/transportation conformity. 

Transportation conformity is a mechanism to ensure that federal funding and approval are given to 

those transportation activities that are consistent with the air quality goals of the State Implementation 

Plans (SIPs) for Indiana, Kentucky and Ohio. The SIPs include an inventory of projected emissions from 

vehicles. One or more of the analysis years in the projected inventory may be designated as the motor 

vehicle emissions budget (MVEB). This budget establishes a maximum allowable limit on future 

emissions from vehicles (mobile sources). OKI’s transportation plans and programs must be shown to 

be in conformity with all SIP provisions. The conformity process is a quantitative analysis, using 

U.S.EPA’s vehicle emissions software (currently MOVES), demonstrating that forecasted regional vehicle 

emissions do not exceed the established budget. 

Table 1 shows daily mobile source emissions for the combined Indiana and Ohio portions of the 

Maintenance area, including Clinton County. Table 2 shows daily mobile source emissions for the 

Kentucky portion of the Maintenance area. Separate MVEB’s are typically designated for these two 

areas. An additional safety margin should be added to the MVEB’s due uncertainty with growth 

assumptions utilized in the OKI travel demand model and MOVES. Daily mobile source emissions for 

each county are shown in Table 3. 
6

 OKI Ozone Mobile Source Emissions Inventory Using EPA MOVES, April 2012 

Table 1 

Mobile Source Emissions Inventory for the Indiana and Ohio Portions of the Cincinnati Ozone 

Maintenance Area (tons per day) 

 2005 2008 2015 2020 2030

VOC 93.68 95.54 48.75 37.24 31.81

NOx 157.38 131.28 81.95 63.59 56.48

 

Table 2 

Mobile Source Emissions Inventory for the Kentucky Portion of the Cincinnati Ozone 

Maintenance Area (tons per day) 

 2005 2008 2015 2020 2030

VOC 25.20 16.53 9.08 5.89 4.53

NOx 80.14 55.34 31.55 18.75 14.37

 
7

 OKI Ozone Mobile Source Emissions Inventory Using EPA MOVES, April 2012 

Table 3 

Mobile Source Emissions by State/County for the Cincinnati Ozone Maintenance Area (tpd) 

State 2005 2008 2015 2020 2030

Indiana 

Dearborn NA 

VMT 599,761 613,027 686,339 730,126 800,277

VOC 1.36 1.38 0.71 0.54 0.46

NOx 2.28 1.90 1.19 0.92 0.82

Ohio 

Butler 

VMT 7,804,476 8,133,554 8,721,511 9,277,916 10,169,344

VOC 17.24 17.58 8.97 6.85 5.85

NOx 28.96 24.16 15.08 11.70 10.39

Clermont 

VMT 5,391,578 5,599,530 5,810,859 6,181,573 6,775,503

VOC 11.49 11.72 5.98 4.57 3.90

NOx 19.30 16.10 10.05 7.80 6.93

Hamilton 

VMT 23,170,766 23,481,421 25,598,858 27,231,982 29,848,450

VOC 50.60 51.61 26.33 20.12 17.18

NOx 85.01 70.92 44.27 34.35 30.51

Warren 

VMT 6,263,010 6,464,217 6,571,210 6,990,432 7,662,077

VOC 12.99 13.25 6.76 5.16 4.41

NOx 21.82 18.20 11.36 8.82 7.83

OKI OH/IN Total

VMT 43,229,591 44,291,749 47,388,777 50,412,029 55,255,652

VOC 93.68 95.54 48.75 37.24 31.81

NOx 157.38 131.28 81.95 63.59 56.48

Clinton, OH 

VMT 1,956,501 1,939,190 2,215,886 2,349,923 2,736,782

VOC 2.92 2.51 1.37 0.93 0.71

NOx 6.53 5.50 3.01 1.86 1.28

OH/IN VOC Total 96.60 98.05 50.12 38.17 32.52

OH/IN NOx Total 163.90 136.78 84.96 65.45 57.76

Kentucky 2005 2008 2015 2020 2030

Boone 

VMT 4,186,006 4,355,527 4,712,497 5,129,347 5,802,955

VOC 9.71 6.37 3.50 2.27 1.75

NOx 30.88 21.32 12.16 7.22 5.54

Campbell 

VMT 2,437,698 2,495,174 2,727,746 2,969,033 3,358,939

VOC 5.62 3.69 2.03 1.31 1.01

NOx 17.87 12.34 7.04 4.18 3.20
8

 OKI Ozone Mobile Source Emissions Inventory Using EPA MOVES, April 2012 

Kenton 

VMT 4,182,042 4,197,027 4,791,791 5,215,655 5,900,597

VOC 9.87 6.47 3.56 2.31 1.77

NOx 31.40 21.68 12.36 7.34 5.63

OKI KY Total 

VMT 10,805,746 11,047,728 12,232,034 13,314,036 15,062,492

VOC 25.20 16.53 9.08 5.89 4.53

NOx 80.14 55.34 31.55 18.75 14.37

NA Area Total 

VOC 121.80 114.58 59.21 44.06 37.05

NOx 244.05 192.12 116.51 84.20 72.13

Mobile Source Emission Forecast Process 

Emission Factor Model 

OKI’s conformity assessment utilized U.S.EPA’s emissions model MOVES 2010 to develop emission 

factors for VOC and NOX. Table 4 summarizes the settings used in the MOVES run specification file. 

Table 5 lists the data used in the MOVES County-Data Manager. Further technical details on the use of 

MOVES are found in the appendix to the OKI report “Mobile Source Emissions Inventory for Cincinnati 

PM2.5 Nonattainment Area”, revised December 2010. 

Table 4 

MOVES RunSpec Parameter Settings

MOVES 2010a, default database 20100829

Scale County, Emission Rates

Time Span Time aggregation = Hour

July weekday, July meteorological data 

All hours of day selected 

Weekdays only 

Geographic Bounds Two Custom Domains 1) 4 Ohio counties and 

Lawrenceburg IN, 2) 3 Kentucky counties 

Vehicles/Equipment All source types, gasoline and diesel

Road Type All road types including off-network

Pollutants and Processes All Ozone categories, Total Energy Consumption 

Strategies Modified AVFT strategy file to reflect 0% CNG 

buses in the transit fleet 

General Output Units= grams, joules and miles

Output Emissions Time = hour, Location =county, on-road emission 

rates by road type and source use type. 

Advanced Performance none
9

 OKI Ozone Mobile Source Emissions Inventory Using EPA MOVES, April 2012 

Table 5 

County Data Manager Data Source

Source Type Population Local and default. Local data from KYTC (2011) and ODOT (2010) 

from motor vehicle registration data. Default data used for source 

types 41, 61 and 62. 

Vehicle Type VMT Local and default. HPMSVTypeYear VMT=daily VMT from OKI travel 

demand model with EPA’s daily to annual VMT converter applied. 

monthVMTFraction = default. dayVMTFraction=default,

hourVMTFraction=local. 

I/M Programs Default modified to reflect discontinued I/M program in 2006

Fuel Formulation Modified to reflect low RVP fuel program in Southwest Ohio

Fuel Supply Default

Meteorology Data Local. MOBILE6 converted values for Ohio and Kentucky values from 

Kentucky Division for Air Quality. 

Ramp Fraction Local. OKI travel demand model.

Road Type Distribution Local. OKI travel demand model.

Age Distribution Local and default. Local data from KYTC (2011) and ODOT (2010) 

from motor vehicle registration data. Default data used for source 

types 41, 61 and 62. 

Average Speed Distribution Local. OKI travel demand model.

OKI Travel Demand Model 

Vehicle miles traveled and vehicle hours were estimated using the OKI Travel Demand Model Version 

7.6. The OKI Travel Demand Model is composed of CUBE Voyager programs and a series of FORTRAN 

programs written by OKI. It is a state of the practice model that uses the standard 4 phase sequential 

modeling approach of trip generation, distribution, modal choice and assignment. The model uses 

demographic and land use data and capacity and free-flow speed characteristics for each roadway 

segment in the network to produce a “loaded” highway network with forecasted traffic volumes with 

revised speeds based on specified speed/capacity relationships. 

Travel analysis zones are the basic geographic unit for estimating travel in the OKI model. The OKI region

is subdivided into 1608 traffic analysis zones to permit detail as well as manageability. A variety of 

socioeconomic data items are used in the OKI transportation planning process. These data are used 

primarily to forecast future travel patterns by serving as independent variables in OKI trip generation 

equations. The following categories of planning data are utilized: 

• Population (household and group quarter) 

• Households 

• Household vehicles 

• Employment (by employment category and zone of work) 

• Labor force participation (by zone of residence) 

• Area type 
10 OKI Ozone Mobile Source Emissions Inventory Using EPA MOVES, April 2012 

The principal data requirements of the OKI travel demand forecasting model are population and 

employment. From these variables, other characteristics including households, labor force, and personal 

vehicles may be derived. Chapter 5 of OKI 2030 Regional Transportation Plan 2008 Update provides a 

complete demographic overview of the region. 

OKI utilizes both base year (2005) and future year data (2010, 2020 and 2030) in the planning process. 

Planning data are maintained at the Traffic Analysis Zone (TAZ) level, and originate in the 2000 Census of 

Population and Housing. Base year 2005 and future year data for each variable are developed through 

various methods. More detailed explanation of base year and future year data generation for each of 

the above-mentioned categories of planning data follows. All of the variables represent the latest OKI 

planning assumptions. 

Population 

Base and Future Year Data: Population data for base year 2005 and future years 2010, 2020 and 2030 

originate with the 2000 Census of Population and Housing. Utilizing ArcView GIS, population data at the 

zonal level for 2000 was derived from the area proportion allocation of block level population. 

As a tri-state regional planning agency, OKI uses county level projections as prepared by the respective 

state data centers (Ohio Department of Development Office of Strategic Research, Kentucky State Data 

Center and Indiana Business Research Center) as control totals. The most current projections (years 

2005 to 2030) were released by the Ohio and Indiana state data centers in 2003 and the Kentucky State 

Data Center in 2004. Population projections at the zonal level are calculated by multiplying household 

size by the projected zonal households. Household size is factored so that, in each county, the sum of 

the zonal populations equals the control total. 

Households 

Base Year Data: Household data for base year 2005 originates with the 2000 Census of Population and 

Housing. Utilizing the geographic information system ArcMap, household data at the zonal level for 2000 

was derived from the area proportion allocation of block level households. Year 2000 household data 

was updated to 2005 with residential building permits issued between January 2000 and December 

2004. The residential building locations were geo-coded in ArcMap, then aggregated to the TAZs. The 

housing unit totals for each TAZ were converted to households by applying a vacancy rate, an 

adjustment for permitted but unbuilt units, and subtracting demolitions (where data was available). 

These households were then added to the year Census 2000 zonal household total to arrive at 2005 

households for each TAZ. 

Future Year Data: The preparation of household projections was accomplished by calculating the 

number of households for a projected county population using ratios of householders to total 

population by age specific cohorts derived from the 2000 Census for each analysis year. Disaggregation 

to TAZs was determined by historical trends, existing and future land use, topography, flood plain 

information, availability of land, local knowledge and other factors. 
11 OKI Ozone Mobile Source Emissions Inventory Using EPA MOVES, April 2012 

Household Vehicles 

Base and Future Year Data: Base and future year household vehicle data were obtained from the 2000 

Census of Population and Housing. The 2000 Census is the only source of household vehicle data 

available at the block group level. Average vehicles per household were calculated for block groups then 

applied to the TAZs associated with each block group. The 2005, 2010, 2020 and 2030 vehicles per 

household level was held at the 2000 level based on the fact that, since 2002, the number of vehicles 

per household has exceeded the number of drivers per household. 

Labor Force 

Base and Future Year Data: The OKI labor force is a function of the population as determined by a labor 

force participation ratio (the number of employed persons in the labor force per persons 16 and over). 

Household data for base year 2005 originates with the 2000 Census of Population and Housing. Utilizing 

the geographic information system ArcMap, household data at the zonal level for 2000 was derived 

from the area proportion allocation of block group level employed labor force. The labor force 

projections for 2005, 2010, 2020 and 2030 were based on the most recent projections of national labor 

force participation rates by age and sex cohorts from the U.S. Department of Labor, Bureau of Labor 

Statistics for each of those years. These rates were then applied to the projected county age/sex cohorts 

and adjusted to eliminate the unemployed to arrive at a county employed labor force control total. 

Employed labor force at the zonal level is calculated by multiplying the labor force participation rate by 

the zonal population. The labor force participation rate is adjusted so that, in each county, the sum of 

the zonal labor force counts equals the control total. 

Employment 

Base Year Data: Quarterly Census of Employment and Wages (QCEW or ES202) data for 2005 was 

utilized as the primary tool to calculate employment at the zonal level. Individual business records 

containing physical location, number of employees and SIC code were geocoded through ArcMap and 

aggregated to the TAZ level. This data set was supplemented by other sources of data to complete the 

commuting employment picture in the OKI region. Each zone’s employment was divided according to 

the SIC code into three classes (retail, office, industrial) based upon the potential for generating trips. 

Future Year Data: For future year employment projection, calculation was first made of the 

employment at the regional level. At the regional level, employment is a calculation of the region’s 

employed labor force minus workers who live in the region but commute out to work, plus workers who 

live outside the region but commute in to work. The regional total was disaggregated first to the county 

level based on historic trends and expected changes in the county’s share of the region’s employment 

and then to the TAZ level. Disaggregation to TAZs was determined by historical trends, existing and 

future land use, topography, flood plain information, availability of land, local knowledge and other 

factors. 
12 OKI Ozone Mobile Source Emissions Inventory Using EPA MOVES, April 2012 

Area Type 

Base and Future Year Data: For each analysis year, each TAZ is assigned an area type designation as 

CBD, Urban, Suburban or Rural based on population and employment densities. 

Model Calibration 

OKI’s Travel Demand Model has been validated to observed traffic volumes for the model base year 

2005. The modeling network encompasses the entire ozone Maintenance area with the exception of 

Clinton County, Ohio. The modeling network also includes Greene, Miami and Montgomery counties in 

Ohio and the remainder of Dearborn County Indiana. The difference between estimated vehicle miles 

traveled (VMT) and 2005 observed VMT is less than 1%. A highway screenline analysis compares the 

screenline observed and simulated traffic volume discrepancies with the ODOT standard of maximum 

desirable deviation. The comparison shows that the model performs at a satisfactory level and all the 

errors were under the ODOT curve. Further information can be found in OKI’s 2007 report, “OKI/MVRPC 

Travel Demand Model Methodology/ Validation Report”. For the calibration, OKI used over 3000 traffic 

counts collected through 2006 by the Ohio Department of Transportation (ODOT), the Kentucky 

Transportation Cabinet, many county and local governments, transportation engineering consultants, 

and OKI. These traffic counts cover nearly 50% percent of the links in the OKI portion of the modeling 

network. The methodology provides consistency with past emission inventory and conformity analysis 

work performed by OKI. 

Local Inputs and Post-Model Processing 

OKI incorporates a variety of sources of local data to both improve and confirm the accuracy of VMT, as 

well as other travel-related parameters. Free flow speeds used on the highway and transit networks are 

based on travel time studies performed locally. The OKI post-processing program, IMPACT, uses the 

loaded highway network to generate VMT by hour, VMT by speed distribution and VMT by facility type. 

These tables are then included as input into MOVES. Two separate sets of VMT tables are generated: 

one for the four Ohio counties plus Dearborn County Indiana, and a second for the three Kentucky 

counties. The VMT by hour tables utilize hourly traffic distribution and directional split factors for 

different roadway types as developed by OKI. The main source of the data was the permanent traffic 

counting stations located throughout the OKI region for the years of 2004-2006. This data was 

supplemented with data collected at coverage count stations (locations with counts taken on only onetwo days). The stations were classified by area type: urban and rural, and functional classification: 

freeway, arterial and collector. Speeds representing various “loaded” conditions (with traffic volumes) 

are estimated using techniques from the 1997 Highway Capacity Manual. This permits the estimation of 

speeds as conditions vary from hour to hour on the different facility types throughout the region. The 

IMPACT program performs the appropriate summation by area and roadway type as well as regional 

totals. OKI has also developed seasonal conversion factors to adjust traffic volumes to summer 

conditions. The factors were derived from local data collected at permanent traffic counting stations 

during 1994-1997 utilizing the average daily traffic monthly conversion factors for June, July and August. 

Further information on OKI’s IMPACT program is documented in the report, “Travel Demand Model 
13 OKI Ozone Mobile Source Emissions Inventory Using EPA MOVES, April 2012 

Summary Reporting and Impact Summary Reporting: OKI/MVRPC Travel Demand Model User’s Guide”, 

OKI 2003.
Appendix D-1 

LADCO Technical Support 

Document (Version IV, April 

25, 2008, FINAL) 

{available at 

http://www.ladco.org/reports/general/) 
Appendix D-2 

LADCO Technical Support · 

Document (Supplement, 

Without CAIR Mod.eling, 

September 12, 2008, FINAL) 

(available at 

http://www.ladco.org/reports/general/) 
Appendix E-1 

Public Notice 
Public Notice 

Ohio Environmental Protection Agency 

Redesignation and Maintenance Plan for the Ohio Portion of the CincinnatiHamilton Ozone Basic Nonattainment Area 

Butler, Clermont, Clinton, Hamilton, and Warren Counties 

Notice is hereby given that the Director of the Ohio Environmental Protection Agency, 

(Ohio EPA) is requesting that the United States Environmental Protection Agency (U.S. 

EPA) revise the current maintenance plan for the Cincinnati-Hamilton area, including 

Butler, Clermont, Clinton, Hamilton, and Warren counties, with respect to the 1997 

eight-hour ozone national ambient air quality standard (NAAQS). Ohio EPA submitted a 

redesignation request and maintenance plan for this area on December 14, 2009 and a 

request to revise the maintenance plan on July 6, 2010. Subsequently, U.S. EPA 

approved these requests on May 11, 2010 and November 29, 2010, respectively. Air 

quality monitoring data collected in the region demonstrated attainment of the NAAQS 

and there was evidence that the improved air quality is due to permanent, enforceable 

emission reductions. In addition, existing requirements are sufficient to maintain the 

1997 eight-hour ozone standard in this area throughout the maintenance period. 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile 

emission projections and conformity budgets based on emission rates generated from 

U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation 

(MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s 

official emission factor model. 

These actions must be noticed to allow public comment and to satisfy U.S. EPA 

requirements for public involvement in SIP related activities. This notice addresses 

Ohio EPA’s reliance on the emission projections as evidence of attainment and 

maintenance and the commitment to institute contingency measures if ambient 

exceedances or violations trigger the contingency plan requirements. Written comments 

will be received on or before May 31, 2012 at the following address: 

E-mail: sarah.vanderwielen@epa.state.oh.us

Mailing address: Sarah VanderWielen 

Ohio Environmental Protection Agency, DAPC 

Lazarus Government Center 

P.O. Box 1049 

Columbus, Ohio 43216-1049 

Phone: (614) 728-1743 

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this 

redesignation request will be conducted as follows: May 31, 2012 at 3:00 P.M., at 

Southwest Ohio Air Quality Agency located at 250 William Howard Taft Road, 

Cincinnati, Ohio. 
All interested persons are entitled to attend or be represented at the hearings and give 

written or oral comments on these changes. All oral comments presented at the 

hearing, and all written statements submitted at the hearing or to the above address by 

the close of business on May 31, 2012 will be considered by Ohio EPA prior to final 

action on this redesignation. Written statements submitted after May 31, 2012 may be 

considered as time and circumstances permit, but will not be part of the official record of 

the hearing. 

This redesignation and maintenance request is available on Ohio EPA DAPC’s Web 

page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx. 

Questions regarding accessing the web site should be directed to Arunee Niamlarb at 

614-728-1342; other questions or comments about this document should be directed to 

either Sarah VanderWielen, (614)-644-3632, sarah.vanderwielen@epa.state.oh.us or 

Jennifer Dines at (614) 644-3696, Jennifer.dines@epa.state.oh.us or mailed to Sarah 

VanderWielen or Jennifer Dines at the above address. 
Appendix E-2 

Public Comments and Public 

Hearing Transcript 





Division of Air Pollution Control 

Revised Cincinnati- Hamilton Area Maintenance Plan Approval for the 1997 EightHour Ozone Standard 

Agency Contact for this Package

Sarah VanderWielen, Division of Air Pollution Control, (614) 644-3632, 

sarah.vanderwielen@epa.state.oh.us

No comments were received during the comment period for the Revised CincinnatiHamilton Area Maintenance Plan Approval for the 1997 Eight-Hour Ozone Standard. 

Ohio EPA held a public hearing in Cincinnati, OH on May 31, 2012, regarding the 

Redesignation Request and Maintenance Plan for the Columbus Ozone Nonattainment Area. 

This document summarizes the comments and questions received at the public hearing and 

during the associated comment period, which ended on May 31, 2012. 

Ohio EPA reviewed and considered all comments received during the public comment period. 

By law, Ohio EPA has authority to consider specific issues related to protection of the 

environment and public health. 

In an effort to help you review this document, the questions are grouped by topic and 

organized in a consistent format. The name of the commenter follows the comment in 

parentheses.