# O hio 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 e ight-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 cha nged 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

,

# ~i**recto r** 

enclosures

cc: Bob Hodanbosi

, DAPC Jennifer Dines, DAPC

50 W est Town stree t

, S uite 70 0 P .O

. Box 1049 Col umbu s, OH 432 1 6

- 1049 6 1 4 1 644 3020 614 I 644 3184 ( fa x)

www

. epa

. o hio

. 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 2012This page left intentionally blanki 

### 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 ........................................................................................... 1 1

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 NO x sources...................................................................................................... 48

Chapter Seven Public participation .......................................................................................................... ............ 49

Chapter Eight Conclusions ................................................................................................................... ............. 50ii 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 .................. 37iii 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 Documentationiv This page left intentionally blank1 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 faili ng to meet the National Ambient Air Quality Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to expeditiously attain and mainta in the standard. In 1997, the United States Environmental Protection Agen cy (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. S upreme Court in Fe bruary 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 t hat 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 Implementat ion Plan (SIP) for the area under Section 110(k). iii) A determination that the improv ement 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 Secti on 110 and Part D requirements have been met.

Background The current Cincinnati-Hamilton nonatta inment 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-Ha milton area were designated as moderate nonattainment for the one-hour ozone standard pursuant to the CAA and,2 therefore, were subject to nonattainm ent area rulemakings: Butler, Clermont, Hamilton, and Warren Counties in Oh io and Boone, Campbell and Kenton Counties in Kentucky. The Ohio por tion 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 des ignations, 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 (NO x ) 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 subm it requests for their respective portions of the Cincinnati-Hamilton area. The Cincinnati-Hamilton area has recorded three (3) years of complete quality-assured ambi ent air quality monitoring data for the years 2007 – 2009 demonstrating attainment of the eight-hour ozone standard.

Geographical Description The Cincinnati-Hamilton ei ght-hour ozone nonattainment area is located in southwest Ohio and includes the follo wing 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 me t the NAAQS for ozone in this basic nonattainment area. The NAAQS attain ment, accompanied by decreases in emission levels discussed in Chapter Four, supports a redesignation to attainment for the Cincinnati-Hamilt on 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 gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Directors. The redesignation request and maintenance plan are based on the redesignation guidance, supplemented with additional guidanc e received from staff of U.S. EPA Region V.

Below is a summary of each redesignat ion 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. T he supplemental modeling is not required for ozone nonattainment areas seeking redesignation; however, in Appendix C and A ppendix D the most recent modeling results showing future attainment and maintenance are provided. Chapter Three discusse s this requirement in more detail and provides the a ttainment 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 discu sses this requirement in more detail.

iii.) Permanent and enforceable im provement in air quality The state must be able to reas onably attribute the improvement in air quality to emission r eductions which are permanent and enforceable. The state should es timate the percent reduction achieved from federal measures as well as control measures that have been adopted and impl emented by the state.4 The Ohio Counties portion of the Cincinnati-Ha milton 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 m easures for these Counties in that area beyond the federal measur es 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)

• NO x Sip Call Rules

Chapters Four and Five discuss this requirement in more detail.

iv.) Section 110 and Part D requirements For purposes of redesignati on, 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 r equirements 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. Sect ion 110(a)(2) provides that the implementation plan submitted by a state must have been adopted by the state afte r reasonable public notice and hearing, and that, among other things, it must include enforceable emission limitat ions and other control measures, means or techniques necessary to meet the requirements of the CAA; pr ovide for establishment and operation of appropriate dev ices, methods, systems and procedures necessary to m onitor ambient air quality; provide for implementation of a source permit program to regulate the modification and construction of any stationary source within the areas covered by the plan; include provisions for the im plementation of Part C, prevention of significant det erioration (PSD) and Part D, NSR permit programs; include criteria for stationary source emission control measures, monitoring, and reporting; include provisions for air quality modeling; and5 provides for public and local agency participation in planning and emission control ru le development. In Ohio’s December 5, 2007 and September 4, 2009 infrastructure SIP submissions, Ohio verified that the Stat e 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, identificat ion of certain emissions increases, and other measur es needed for attainment will not apply for redesignations because they only have meaning for areas not atta ining the standard. The requirements for an emission 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 proc edures, if the state already has these procedures in plac e. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the st ate must commit to follow U.S. EPA’s conformity r egulation upon issuance, as applicable.

v.) Maintenance plans Section 107(d)(3)(E) stipulat es that for an area to be redesignated, U.S. EPA must fu lly approve a maintenance plan that meets the requirement s of Section 175(A). The maintenance plan must constitu te a SIP revision and must provide for maintenance of the rele vant 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 Administra tor 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 MONITORING 1 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 m easuring ozone concentrations in this nonattainment area. Eight of the eleven monitors, located in Ohio, are operated by Ohio EPA Divis ion of Air Pollution Control, Southwest District Office and t he Hamilton County Division of Environmental Services. A listi ng of the design values based on the three-year average of t he annual fourth highest daily maximum eight-hour average oz one concentrations from 2007 through 2009 is shown in Table 1. The locations of the monitoring sites for this nonatta inment 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 assur ed 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 Protec tion 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 ar ea 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 tak en from U.S. EPA's "Guideline on Data Handling Conventions fo r 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 m onitoring site. The eight-hour primary and secondary ozone ambi ent air quality standards are met at an ambient air quality moni toring site when the three-year average of the annual fourth-hi ghest daily maximum eight-hour average ozone concentrations is less than or equal to 0.08 ppm. When this occurs, the site is sa id 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 standar d. These data handling procedures are applied on an indivi dual basis at each monitor in the area. An area is in co mpliance with the eight-hour ozone NAAQS if, and only if, every moni toring site in the area meets the NAAQS. An individual site 's three-year average of the annual fourth highest daily ma ximum 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 t he 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

1 st 2 nd 3 rd 4 th 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 8011 1 st 2 nd 3 rd 4 th 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 tr ended 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 c hanges to the existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet12 the requirements of 40 CF R 58 and all other federal requirements. Connection to a c entral station and updates to the Ohio EPA web site 2 will provide real time availability of the data and knowledge of any exceedances. Ohio EPA will enter all data into AQS on a timely basis in a ccordance with federal guidelines.

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

### CHAPTER FOUR

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

U.S. EPA’s redesignation guidance require s the submittal of a comprehensive inventory of ozone precursor emissions (VOC and NO x ) 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 occu rred and the year that atta inment was achieved is based on permanent and enforceable emi ssion reductions. Other emission inventory related requirements include a pr ojection of the emission inventory to a year at least 10 years following r edesignation; a demons tration that the projected level of emissi ons 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 mob ile (on-road) emi ssions inventory and projections, identifies procedures used by Ohio EPA and the Lake Michigan Air Directors Consortium (LADCO) regarding em issions 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 inventorie s and emissions projections were prepared using similar methodologies. Ohio recogni zes that revisions to the emissions data below may be necessary onc e 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 Oh io, 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 prefe rred databases for SIP development and coincides with nonattainment air quality in the CincinnatiHamilton area.

Periodic inventories, which incl ude emissions from all sectors - mobile, area, non-road, and point sources - are prepared every three years.14 Demonstration The 2005 inventory is used as t he base year for the purpose of this submittal and was submitt ed to U.S. EPA on June 15, 2007 along with the attainment demons tration for this area. The detailed emission inventory informa tion 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 emissi on inventory to a year at least 10 years following redesignation.

Background Ohio EPA prepared a comprehensive inv entory for the Ohio portion of the Cincinnati-Hamilton area including area, mobile, and point sources for precursors of ozone (VOCs and NO x ) 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 ar ea. 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 Report 3 ). 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 th is 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. Departm ent of Commerce Bureau of Economic Analysis (BEA) grow th factors, with some updated local information.

• Mobile source emissions were calculated from MOVES2010-produced emission factors.

3 http://www.ladco.org/tech/emis/r5/repor ts/LADCO%202005%20Base%20Yr%20Growth%20and%2 0Controls%20Report_Final.pdf15 • Point source information was compiled from Ohio EPA’s 2005 annual emissions inv entory database and the 2005 U.S. EPA Air Markets acid rain database 4

.

• 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 wit h two (2) companies to review the base data and ma ke recommendations. One of the contractors also esti mated emissions for three (3) non-road categories not incl uded in U.S. EPA’s non-road model. Emissions were estima ted for aircraft, commercial marine vessels, and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) we re 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 D epartment of Trans portation (Ohio DOT), OKI utilizes a regional tr avel 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 dete rmination of locations where additional travel capacity may be needed and to determine the infrastructure requirements necessa ry to meet that need. It is also used as a tool for air qualit y purposes to estimate the total emissions of pollution caused by vehi cles 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 calcul ate emissions per mile. The product of these is the total am ount 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 tra ffic growth rates for the VMT estimates.

4 http://www.epa.gov/airmarkets/acidrain16 Overview

Emission Factor Model

OKI’s generation of this oz one inventory utilized U.S.EPA’s emissions model MOVES 2010 to develop both running and nonrunning vehicle emission factors for VOC and NO X . Emission factors represent summer week day 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 vehi cle type, 4) fuel formulation reflective of the summer fuel requirements in Southwest Ohio, and 5) VMT distributions by r oad 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 Ve rsion 7.6. The OKI Travel Demand Model is composed of CUBE Voyager programs and a series of FORTRAN programs writt en 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 us es demographic and land use data and capacity and free-flow s peed characteristics for each roadway segment in the network to produce a “loaded” highway network with forecasted traffi c 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 so cioeconomic data items are used in the OKI transportation planning process. Thes e 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 requirement s of the OKI travel demand17 forecasting model are populati on 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 Populati on and Housing. Base year and future year population, househol ds, household vehicles, labor force and employment are devel oped through various methods. All of the variables repr esent the latest OKI planning assumptions. OKI’s Travel De mand Model has been validated to observed traffic volumes for t he 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 estimat ed 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 tr avel demand model. The Ohio DOT uses traffic counts and local tr affic 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 pos t-processing program, IMPACT, uses the loaded highway network to generate VMT by hour, VMT by speed distribution and VMT by fa cility 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 dev eloped by OKI. The main source of the data was the permanent tra ffic 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” condi tions (with traffic volumes) are estimated using techniques from the Highway Capacity Manual. This permits the esti mation of speeds as conditions vary from hour to hour on the di fferent facility types throughout the region. The IMPACT progr am performs the appropriate summation by area and roadway type as well as regional totals. OKI has also developed seasonal conversion factors to adjust18 traffic volumes to summer conditi ons. The factors were derived from local data collected at perm anent traffic counting stations utilizing the average daily traffic monthly conversion factors for June, July and August.

Local Road VMT

Most local roads such as subdivi sion 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 ar e included in the OKI post process by including the traffic l oaded on centroid connectors. In addition, some local road traffic is captured as intra-zonal trips which travel demand models usua lly do not assign to roadway segments. The OKI post process assigns these trips as local road VMT.

Analysis Years

Analysis years for this re vision request include 2005, 2008 (attainment year), 2015 (interim year), and 2020. The travel demand model presents the transpor tation system conditions for each of these years. Model r uns for each future analysis year contain the road network OKI and Ohio DOT expect to exist in July of that year with corres ponding 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 emissi ons 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 6,990,43220 Table 7 – Dearborn County, Indi ana 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 5,215,65521 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-Hamilt on area. For planning purposes, budgets are established for t he 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 Kentucky22 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 inter agency 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 futu re variations in travel demand models and VMT forecast when no change to the network is planned, Ohio EPA consulted wit h U.S. EPA to determine a reasonable approach to address this variation. Based on this discussion, a 15 percent margin of safety allocation was agreed upon and has been added to the emissions estimates for the Ohio and Indiana portions of this nonattainment area.

The above budget for the Kentu cky portion of the area was provided directly by Kentucky as part of the consultation process and also includes a margin of sa fety allocated to the emission estimates calculated for 2015 and 2020 (from Table 12).

The emission estimates are der ived 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 variat ion in VMT forecast and potential estimated mobile sour ce 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 allo cation of safety margin to mobile sources while still continuing to maintain the total emissions in the Cincinnati-Ha milton area well below the 2006 attainment level of emissions.23 The 15 percent margin of safe ty 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 nonattainm ent 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 stat es combined, the mobile budget safety margin allocation translates into:

--An allocation of 7.31 TS D 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 sa fety margin, as defined in 40 CFR 93.101 5 , 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 l onger be applicable either after the effective date of the approved r edesignation or after the effective date of any U.S. EPA ac tion approving a finding that the eight-hour conformity budget included in th is submittal is adequate for transportation conformity purposes, whichever date comes first.

Requirement 3 of 5 A demonstration that t he 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 requirem ent 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 Pr ojections” 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, ar ea, 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 M 6 ).

• For the Ohio portion of t he Cincinnati-Hamilton area, for the 2008 attainment year, emi ssions were grown from the 2005 LADCO modeling inventory, using LADCO’s growth factors, for all sectors exc ept point sources (electrical generating units and non-electr ical generating units). Point source emissions for 2008 were compiled from Ohio EPA’s 2008 annual emissions inv entory database. The 2015 interim year emissions were estimated based on the 2009 and 2018 LADCO modeling inventory, using LADCO’s growth factors, fo r all sectors. The 2020 maintenance year is based on emissions estimates from the 2018 LADCO modeling.

The detailed inventory informati on 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 emissi on inventories are described in Section 5 of Appendix B.

Sectors included in the following tabl es are: Electr ical Generating Unit (EGU-Point); Non-Electric al Generating Unit (Non-EGU); Non-road Mobile (Non-road); Ot her Area (Other); Marine; Aircraft; Rail (MAR); and On-road Mobile (On-road).

6 http://www.ladco.org/tech/emis/current/index.php25 Maintenance is demonstrated w hen the future-year (2020) projected emission totals are below the 2008 attainment year totals.

The emissions data in the t ables below are based on the following data sources

Demonstration

NO x
Table 16 - Butler County, Ohio NO x 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 NO x 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 4.5227 Table 19 - Hamilton County, Ohio NO x 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 NO x 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 12.1328 Table 21 - Dearborn County, Indiana NO x 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 NO x 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 emissions29 Table 23 - Campbell County, Kentucky NO x 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 NO x 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 emissions30 Table 25 - Cincinnati-Hamilton Area NO x 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 10.0931 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 2.2832 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 9.4333 Table 31 - Dearborn County, I ndiana 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 emissions34 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 emissions35 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

NO x 382.64 340.97 41.67 307.94 74.70

As shown in the table abov e, VOC emissions in the nonattainment area are projected to decrease by 60.71 TSD in 2015 and 76.03 TSD in 2020. Point s ources 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.

NO x emissions in the nonattainm ent 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. Decreas es from U.S. EPA rules covering36 Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 8 , Highway Heavy-Duty Engine Rule 9 , and the Non-Road Diesel Engine Rule 10 are factored into the changes.

All projections do not take into account reductions expected from the Clean Air Interstate Rule 11 . 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 project ed decreases above, even in the absence of consideration of reduc tions 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 revisi on 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 bet ween 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-A IR/2005/May/Day-12/a5723a.pdf37 Requirement 4 of 5 A demonstration that improvement in air quality bet ween the year violations occurred and the year attainment wa s achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background Ambient air quality data from all m onitoring sites indicate that air quality met the NAAQS for oz one in 2007-2009. U.S. EPA’s redesignation guidance (p 9) st ates: “A state may generally demonstrate maintenance of the N AAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventor y, or by modeli ng 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. Reduc tions 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 NO x 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 informa tion annually, in accordance with U.S. EPA’s Consolidated Emissi ons Reporting Rule (CERR). Ohio EPA prepares a new peri odic inventory for all ozone precursor emission sectors ever y three years. These ozone38 precursor inventories will be pr epared for future years as necessary to comply with the inventory reporting requirements established in the CFR. Emi ssions information will be compared to the 2005 base year and the 2020 projected maintenance year inventories to assess emissi on 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 im plement 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 requirem ents 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 wh ich U.S. EPA approved on April 25, 1996 (61 FR 18255) and Sept ember 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 wit h monitoring, recordkeeping, and reporting necessary to ensur e ongoing compliance. Ohio EPA also has an active enfor cement program to address violations discovered by field offi ce staff. The Ohio RACT rules are found in OAC Chapter 3745-21 12

. 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 Chapt er 4 (Requirement 4), Ohio EPA submits, and commits to s ubmit, emission inventories (statements) every three years.

12 http://www.epa.state.oh.us/dapc/regs/3745-21/3745_21.html40 Requirement 3 of 5 Evidence that control measures requi red 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 NO x SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial bo ilers, and cement kilns in the eastern United States. Ohio pass ed this rule in 2001. NOx SIP Call requirements are incorpor ated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations disco vered by field office staff. Compliance is tracked thr ough the Clean Air Markets data monitoring program. Beginning in 2004, this rule accounts for a reduction of approximatel y 31 percent of all NO x 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 repl aced the NOx SIP Call for EGUs. National NO x emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 milli on tons in 2018 in 28 states. States were requir ed to submit a CAIR SIP as part of this effort. Ohio submi tted a CAIR SIP which was approved by U.S. EPA on Februar y 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final ac tion on September 25, 2009 (74 FR 48857). As a result of CAIR , U.S. EPA projects that in 2009 emissions of NOx will decrease fr om a baseline of 264,000 tons per year to 91,000 tons per year within Ohio 13

.
On December 23, 2008, U.S. EPA’s CAIR program was remanded without vacatur by t he 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.pdf41 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 st andard. Section 182(b)(3) requires gasoline vapor recovery systems for gasoline dispensing stations in the ar ea and section 182(b)(4) requires motor vehicle inspection and maintenance programs.

Demonstration

U.S. EPA and Ohio EPA performed m odeling that indicated this area would attain the eight -hour ozone standard with the implementation of the NO x SIP Call. Controls for EGUs formally commenced May 31, 2004. Emissions covered by this program have been generally trending downw ard since 1998 with larger reductions occurring in 2002 and 2003. Data taken from the U.S. EPA Clean Air Markets web si te, quantify the gradual NO x reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and t he beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 14 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 NO x 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 NO x 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 addre sses stationary internal combustion engines, all used in natural gas pipeline transmissions. U.S. EPA approved th is revision to the SIP on April 4, 2008. An 82 percent NO x reduction from 1995 levels is anticipated. Completion of the co mpliance plan occurred by May 1, 2006, and the compliance dem onstration began May 1, 2007. The 2007 controlled NO x emissions are 599 tons statewide for the ozone season.

14 http://www.epa.state.oh.us/dapc/regs/3745-14/3745_14.html42 Section 182(b)(3) requires stat es to submit Stage II vapor recovery rules no later than No vember 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 rulemaki ng 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." Fu rthermore, the September 17, 1993, guidance memorandum stat es that once onboard vapor recovery regulations are prom ulgated, 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, purs uant to Section 202(a)(6) of the CAA, Stage II would no longer be required. Stage I and Stage II requirements are still being implem ented in the original one-hour attainment area (excludes Clinton County).

The U.S. EPA's final I/M regulati ons 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-C heck program in this area. In order to transfer the E-Che ck program from the active maintenance plan to a contingen cy plan, alternative emission reduction programs were adopt ed to replace the benefits associated with the E-Che ck program in the one-hour maintenance plan approved at that time. The following programs were implemented in place of t he 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 Re id Vapor Pressure Fuels

. Approved May 25, 2007 (72 FR 29269)

• OAC rule 3745-21-17 - Port able 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 (S UVs). Under this proposal, automakers will be required to se ll cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The f ederal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NO x emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, li ght trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. VOC emission reduc tions will be approximately 12 percent for passenger cars, 18 per cent 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 in cludes low-sulfur diesel fuel standards, which will be phased in fr om 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 NO x from diesel trucks and buses, a large sector of the mobile sources NO x 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 dies el engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard sim ilar to the highway diesel program. The new standards will cut emissions from non-road diesel engines by more than 90 percent. N on-road diesel equipment, as described in this rule, currently accounts for 47 percent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwide. Sulfur levels will be reduced in non-road diesel fuel by 99 percent from cu rrent 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 substant ially 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 fu lly implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-31 15 . The Chapter includes provis ions for the Prevention of Significant Deterioration (PSD) permitting program in OAC rules 3745-31-01 to 3745-31-20. Oh io's PSD program was conditionally approved on October 10, 2001 (66 FR 51570) and received final approval on J anuary 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 m easures will remain in effect after redesignation unless the State demonstr ates through photochemical modeling that the standard can be maintained without one (1) or more control measures.

Demonstration Ohio commits to maintaini ng the aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emissi on limits applicable to VOC and/or NO x sources, as required for ma intenance 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 sect ion, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. Afte r redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in the Cin cinnati-Hamilton area.

15 http://www.epa.state.oh.us/dapc/regs/3745-31/3745_31.html45 

### 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 r equired by Secti on 175(A) of the CAA

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

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

Warning Level Response:

A warning level response sha ll be prompted whenever an annual (1-year) fourth high monitored value of 88 ppb occurs in a single ozone season within the maint enance 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 increasi ng. The study will evaluate whether the trend, if any, is lik ely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and timing fo r implementation as well as economic and social consider ations. Implementation of necessary controls in response to a warning level response trigger will take place as expediti ously 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 t he warning level study that action is necessary to revers e the noted trend, the procedures for control selection and impl ementation 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 val ue of 85 parts per billion (ppb) or greater occurs within the main tenance area. A vi olation of the standard (three-year average four th high value of 85 ppb or greater) shall also prompt an acti on level response. In the event that the action level is trigger ed and is not found to be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropolitan planning organizati on or regional council of governments, will determine additi onal control measures needed to assure future attainment of the NAAQS for ozone. In this case, measures that can be im plemented in a short time will be selected in order to be in place within 18 months from the close of the ozone season t hat 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 ma intenance provisions will be implemented in a timely manner and will constitute our response.

Control Measure Sele ction and Implementation

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

If a new measure/control is already promulgated and scheduled to be implemented at the federal or Stat e level, and that measure/control is determined to be sufficient to address the upward trend in air quality, addi tional local measures may be unnecessary. Furthermore, Ohio will submit to U.S. EPA an analysis to demonstrate the propos ed measures are adequate to return the area to attainment.

Requirement 3 of 4 A list of potential contingency measures that would be implem ented in such an event.

Demonstration Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the select ion is made. The selection of measures will be based on cost -effectiveness, emission reduction potential, economic and soci al considerations or other47 factors that Ohio EPA deems appr opriate. Ohio EPA will solicit input from all interested and affe cted persons in the maintenance area prior to selecting appropr iate 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 meas ures 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 c ontrol 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 innovativ e transportation measures not yet in widespread us e that affected local governments deem appropriate.

5) Alternative fuel and diesel retrofit programs for fleet vehicle operations.

6) Require VOC or NO x emission offsets for new and modified major sources.

7) Increase the ratio of emi ssion offsets required for new

sources.

8) Require VOC or NO x controls on new mi nor 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 indi vidual measures, at the time they are under considerati on, can be fully evaluated.

Requirement 4 of 4 A list of VOC and NO x sources potentially subject to future additional control requirements.

Demonstration The following is a list of VOC and NO x sources potentially subject to future controls.

NO x 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 year49 

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesi gnation 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 pub lic comment period. Appendix E includes a copy of the public notic e from the public hearing and comment period.50 

### CHAPTER EIGHT

CONCLUSIONS

The Cincinnati-Hamilton ozone nonattain ment area has attained the 1997 NAAQS for ozone and complied with the app licable provisions of the 1990 Amendments to the CAA r egarding redesignations of ozone nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepared a redesignation request and ma intenance plan that meet the requirements of Section 110 (a)(1) of the 1990 CAA.

Based on this presentation, the Cinci nnati-Hamilton ozone nonattainment area meets the requirements for redes ignation under the CAA and U.S. EPA guidance. Ohio has performed an anal ysis that shows the air quality improvements are due to permanent and enf orceable measures. Furthermore, because this area is subject to signific ant transport of pollutants, significant regional NO x 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 a ttainment simultaneously with U.S. EPA approval of the maintenance plan pr ovisions 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, Cle rmont, Clinton, Hamilton, and Warren in Ohio. Emission estimates for the Year 20 05, 2008, 2015, 2020, and 2030 developed in support of revision to Ozone Stat e Implementation Plan

April 2012

P repared for the Indiana Department of Environmental Management, the Kentucky Division for Air Quality and the Ohio Environmental Protecti on Agency by

OKI Regional Council of Governments

### Acknowledgments

Title Mobile Source Emissions Inventory for Cincinnati Ozo ne Maintenance Area

Abstract This report was prepared for the Indiana Department of Environmental Management, the Kentucky Division for Air Quality a nd the Ohio Environmental Protection Agency. The Cincinnati Oz one Maintenance area includes a portion of Dearborn County Indiana, the c ounties of Boone, Campbell, Kenton in Kentucky, and the counties of B utler, Clermont, Clinton, Hamilton, and Warren in Ohio. Clinton Cou nty 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 Governme nts 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 cooper atively by the Federal Highway Administration, the Federal Transit Administration, the Commonwealt h 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. D epartment of Transportation. This report does not constitute a standard, specification, or regulat ion.

## 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 o f Environmental Management, the Kentucky Division for Air Quality and the Ohio Environmental Protection Agency. The Cincinnati Ozone Maintenance area includes a portion of Dearborn Coun ty Indiana, the counties of Boone, Campbell, Kenton in Kentucky, and the counties of Butler, Cle rmont, 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 in cludes 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 gen erate 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 an d speed estimates. MOVES emission rates were generated for VOC’s, and NO x .
OKI, as the MPO, is responsible for transportation plann ing and air quality/transportation conformity. Transportation conformity is a mechanism to ensure tha t federal funding and approval are given to those transportation activities that are consistent wit h the air quality goals of the State Implementation Plans (SIPs) for Indiana, Kentucky and Ohio. The SIP s include an inventory of projected emissions from vehicles. One or more of the analysis years in the pr ojected inventory may be designated as the motor vehicle emissions budget (MVEB). This budget establishe s a maximum allowable limit on future emissions from vehicles (mobile sources). OKI’s transpor tation plans and programs must be shown to be in conformity with all SIP provisions. The conf ormity 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 comb ined 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 t o the MVEB’s due uncertainty with growth assumptions utilized in the OKI travel demand model an d 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 a nd 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 Cin cinnati 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 m odel MOVES 2010 to develop emission
factors for VOC and NO X . Table 4 summarizes the settings used in the MOVES ru n 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 fro m OKI travel demand model with EPA’s daily to annual VMT converte r 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 Southwe st Ohio Fuel Supply Default Meteorology Data Local. MOBILE6 converted values for Ohio and Kentucky value s 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 estimat ed 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 pract ice 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 relati onships.

Travel analysis zones are the basic geographic unit fo r estimating travel in the OKI model. The OKI region is subdivided into 1608 traffic analysis zones to perm it detail as well as manageability. A variety of socioeconomic data items are used in the OKI transport ation planning process. These data are used primarily to forecast future travel patterns by servi ng 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 de mand forecasting model are population and employment. From these variables, other characterist ics 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 d ata (2010, 2020 and 2030) in the planning process. Planning data are maintained at the Traffic Analysi s Zone (TAZ) level, and originate in the 2000 Census o f Population and Housing. Base year 2005 and future yea r data for each variable are developed through various methods. More detailed explanation of base yea r and future year data generation for each of the above-mentioned categories of planning data foll ows. 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 Housi ng. Utilizing ArcView GIS, population data at the zonal level for 2000 was derived from the area prop ortion allocation of block level population.

As a tri-state regional planning agency, OKI uses coun ty level projections as prepared by the respective state data centers (Ohio Department of Development Of fice 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 z onal 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 ori ginates 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 b lock 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-co ded in ArcMap, then aggregated to the TAZs. The housing unit totals for each TAZ were converted to ho useholds by applying a vacancy rate, an adjustment for permitted but unbuilt units, and subtra cting 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 proje ctions was accomplished by calculating the number of households for a projected county populati on using ratios of householders to total population by age specific cohorts derived from the 2 000 Census for each analysis year. Disaggregation to TAZs was determined by historical trends, existing an d 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 house hold 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 vehicle s 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 t he fact that, since 2002, the number of vehicles per household has exceeded the number of drivers per h ousehold.



### Labor Force

Base and Future Year Data: The OKI labor force is a function of the population as determined by a labo r force participation ratio (the number of employed p ersons 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 da ta 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 th en applied to the projected county age/sex cohorts and adjusted to eliminate the unemployed to arrive a t a county employed labor force control total. Employed labor force at the zonal level is calculate d 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 Wa ges (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 an d SIC code were geocoded through ArcMap and aggregated to the TAZ level. This data set was suppleme nted by other sources of data to complete the commuting employment picture in the OKI region. Eac h zone’s employment was divided according to the SIC code into three classes (retail, office, indu strial) based upon the potential for generating trips

.
Future Year Data: For future year employment proje ction, calculation was first made of the employment at the regional level. At the regional l evel, employment is a calculation of the region’s employed labor force minus workers who live in the re gion 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 i n the county’s share of the region’s employment and then to the TAZ level. Disaggregation to TAZs wa s 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, e ach TAZ is assigned an area type designation as CBD, Urban, Suburban or Rural based on population a nd employment densities.

Model Calibration
OKI’s Travel Demand Model has been validated to observ ed traffic volumes for the model base year 2005. The modeling network encompasses the entire oz one Maintenance area with the exception of Clinton County, Ohio. The modeling network also inc ludes 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 disc repancies with the ODOT standard of maximum desirable deviation. The comparison shows that the mo del performs at a satisfactory level and all the
errors were under the ODOT curve. Further informati on 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 govern ments, transportation engineering consultants, and OKI. These traffic counts cover nearly 50% perce nt of the links in the OKI portion of the modeling network. The methodology provides consistency with p ast 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 O KI 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. T wo 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 tra ffic distribution and directional split factors for different roadway types as developed by OKI. The mai n source of the data was the permanent traffic counting stations located throughout the OKI region f or the years of 2004-2006. This data was supplemented with data collected at coverage count st ations (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 dif ferent 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 fac tors 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 traffi c monthly conversion factors for June, July and Augu st. Further information on OKI’s IMPACT program is docume nted 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 NoticePublic Notice Ohio Environmental Protection AgencyRedesignation 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 Environment al Protection Agency (U.S. EPA) revise the current main tenance plan for the Cincinnati- Hamilton area, including Butler, Clermont, Clinton, Ha milton, and Warren counties, with respect to the 1997 eight-hour ozone national ambient air qualit y standard (NAAQS). Ohio EPA submitted a redesignation request and maintenance plan fo r 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 Ma y 11, 2010 and November 29, 2010, respectively. Air quality monitoring data collected in the regi on demonstrated attainme nt of the NAAQS and there was evidence that the improved air quality is due to permanent, enforceable emission reductions. In addition, existing requi rements are sufficient to maintain the 1997 eight-hour ozone standard in this ar ea throughout the maintenance period.

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budget s 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 r eplaced 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 involvem ent in SIP related activities. This notice addresses Ohio EPA’s reliance on the emission projec tions as evidence of attainment and maintenance and the commitment to institute contingen cy measures if ambient exceedances or violations trigger the cont ingency plan requirements. Written comments will be received on or before May 31, 2012 at the following address: E-mail: sarah.vanderwiel en@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 fo llows: 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 att end 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 statem ents 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 VanderWi elen, (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 TranscriptDivision of Air Pollution Control

Revised Cincinnati- Hamilton Area Maintena nce 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 comm ent period for the Revised CincinnatiHamilton Area Maintenance Plan Approval for the 1997 Eight-Hour Ozone Standard.

Ohio EPA held a public hearing in Cinci nnati, 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 comment s received during the public comment period. By law, Ohio EPA has authority to consider sp ecific 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.