John R. Kaslch, Governor 

Mary Taylor, Lt. Governor 

Scott J. Nally, Director 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Blvd. R-19J 

Chicago, Illinois 60604-3507 

SEP 29 2012 

oct a~ ao'a. 

Re: Request for Review and Approval of the Revised Cleveland-Akron-Lorain Area 

Maintenance Plan Approval for the 1997 Eight-Hour Ozone Standard 

.Dear Administrator Hedman: 

· l am ·Writing to formally request review and approval of a revision to the maintenance 

plan for the Ohio portion of the Cleveland-Akron-Lorain area (Ashtabula, Cuyahoga, 

Geauga, Lake, Lorain, Medina, Portage, and· Summit Counties) with respect to the 1997 

eight-hour ozone standard. Ohio EPA submitted a redesignation request and 

maintenance plan for this area on March 17, 2009. U.S. EPA approved this requests on 

September 15,2009 (74 FR47414). 

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 Vehicie Emission Simulation 

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

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

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

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

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

Control at (614) 644-3696. 

Sincerely, 

~21y, Director 

enclosures 

cc: Bob Hodanbosi, DAPC 

Jennifer Dines, DAPC 

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 

www.epa.ohio.gov • (614) 644-3020 • (614} 644-3184 (fax) 
 

REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR 

THE CLEVELAND-AKRON-LORAIN 

OZONE 

NONATTAINMENT AREA 

Prepared by: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

March 2009 

Revised October 2012
 

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 i 

TABLE OF CONTENTS 

Chapter One 

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

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

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

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

Chapter Two 

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

Chapter Three 

Ozone monitoring .......................................................................................................................... 6 

Ambient data quality assured ........................................................................................................ 7 

Three complete years of data ....................................................................................................... 8 

Commitment to continue monitoring ........................................................................................... 10 

Chapter Four 

Emission inventory ...................................................................................................................... 12 

Base year inventory .................................................................................................................... 12 

Emission projections ................................................................................................................... 12 

Demonstration of maintenance ................................................................................................... 18 

Permanent and enforceable emissions reductions ..................................................................... 27 

Provisions for future updates ...................................................................................................... 28 

Chapter Five 

Control measures and regulations .............................................................................................. 30 

Moderate area VOC RACT ......................................................................................................... 30 

Moderate area 15 percent reasonable further progress ............................................................. 31 

Emission inventories/statements ................................................................................................ 32 

Implementation of past SIP revisions .......................................................................................... 32 

New source review provisions ................................................................................................... 35 

Assurance of continued controls ................................................................................................. 36 

Chapter Six 

Contingency measures ............................................................................................................... 37 

Commitment to revise plan ......................................................................................................... 37 

Commitment for contingency measures ..................................................................................... 37 

Potential contingency measures ................................................................................................. 38 

List of VOC and NOx sources...................................................................................................... 40 

Chapter Seven 

Public participation ...................................................................................................................... 41 

Chapter Eight 

Conclusions ................................................................................................................................ 42 
 ii 

FIGURES 

Figure 1 Cleveland - Akron - Lorain Moderate Nonattainment Area .................................... 7 

TABLES 

Table 1 Monitoring Data for Cleveland - Akron - Lorain 2006 – 2008 ................................ 9 

Table 2 Emission Estimations for On-road Mobile Sources for Ashtabula Co. ................ 16 

Table 3 Emission Estimations for On-road Mobile Sources for Cuyahoga Co. ................ 16 

Table 4 Emission Estimations for On-road Mobile Sources for Geauga Co. .................... 16 

Table 5 Emission Estimations for On-road Mobile Sources for Lake Co. ......................... 17 

Table 6 Emission Estimations for On-road Mobile Sources for Lorain Co. ...................... 17 

Table 7 Emission Estimations for On-road Mobile Sources for Medina Co. ..................... 17 

Table 8 Emission Estimations for On-road Mobile Sources for Portage Co. .................... 17 

Table 9 Emission Estimations for On-road Mobile Sources for Summit Co. .................... 17 

Table 10 Emission Estimations for On-road Total Cleveland -Akron -Lorain Sources ....... 17 

Table 11 Mobile Vehicle Emission Budget ......................................................................... 18 

Table 12 VOC Emission Inventory Ashtabula Co. .............................................................. 20 

Table 13 VOC Emission Inventory Cuyahoga Co. ............................................................. 20 

Table 14 VOC Emission Inventory Geauga Co. ................................................................. 21 

Table 15 VOC Emission Inventory Lake Co. ...................................................................... 21 

Table 16 VOC Emission Inventory Lorain Co. .................................................................... 22 

Table 17 VOC Emission Inventory Medina Co. .................................................................. 22 

Table 18 VOC Emission Inventory Portage Co. ................................................................. 22 

Table 19 VOC Emission Inventory Summit Co. ................................................................. 23 

Table 20 VOC Emission Inventory Cleveland - Akron - Lorain Total .................................. 23 

Table 21 NOx Emission Inventory Ashtabula Co. ............................................................... 24 

Table 22 NOx Emission Inventory Cuyahoga Co. ............................................................... 24 

Table 23 NOx Emission Inventory Geauga Co. .................................................................. 24 

Table 24 NOx Emission Inventory Lake Co. ....................................................................... 25 

Table 25 NOx Emission Inventory Lorain Co. ..................................................................... 25 

Table 26 NOx Emission Inventory Medina Co. ................................................................... 25 

Table 27 NOx Emission Inventory Portage Co. .................................................................. 26 

Table 28 NOx Emission Inventory Summit Co. ................................................................... 26 

Table 29 NOx Emission Inventory Cleveland - Akron - Lorain Totals ................................. 26 

Table 30 Projected Emission Estimates 2006-2020 Cleveland - Akron - Lorain ................ 27 

Table 31 Combined Comparison of 2004 and 2006 On-road and EGU Totals .................. 28 

 

APPENDICES 

A Air Quality System (AQS) Data 

B Ohio 2002 SIP Base Year Inventory Discussion 

C NOACA Mobile Methodology and Results 

D LADCO Technical Support Document 

E Public Participation Documentation 
 iii 

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 1 

REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR THE CLEVELAND-AKRON-LORAIN, OHIO 

OZONE NONATTAINMENT AREA 

CHAPTER ONE 

Introduction 

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

Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to 

expeditiously attain and maintain the standard. In 1997, the United States Environmental 

Protection Agency (U.S. EPA) revised the air quality standard for ozone replacing the 1979 

one-hour standard with an eight-hour ozone standard set at 0.08 parts per million (ppm). 

The standard was challenged legally and upheld by the U.S. Supreme Court in February of 

2001. 

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

standard. Since that time, U.S. EPA has reclassified nine of the 134 original nonattainment 

areas to the next lower classification. Section 107(d)(3)(E) of the CAA allows states to 

request nonattainment areas to be redesignated to attainment provided certain criteria are 

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

from nonattainment to attainment: 

i) A determination that the area has attained the eight-hour ozone 

standard.

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

Section 110(k).

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

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

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

met. 

 

Background 

The Cleveland - Akron - Lorain nonattainment area includes the following Counties: 

Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and Summit. As part of 

the 1990 CAA Amendments re-evaluation, the Counties within the Cleveland - Akron - 

Lorain area were designated as moderate nonattainment for the one-hour ozone standard 

and, therefore, were subject to nonattainment area rulemakings. The Cleveland - Akron - 

Lorain area was redesignated to attainment with respect to the one-hour ozone standard on 

May 7, 1996 (61FR20458). As a result of the 2004 ozone designations, U.S. EPA 

designated the Cleveland - Akron - Lorain area moderate nonattainment for the eight-hour 

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

compounds (VOCs) and nitrogen oxides (NOx) emissions and to demonstrate that the area 
 2 

will meet the federal eight-hour air quality standard for ozone by June 15, 2010. As part of 

the requirement, a 15 percent Rate of Progress (ROP) Plan was also required showing 

emissions would be reduced by 15 percent by June 15, 2009. 

This document is intended to support Ohio’s request that the Cleveland - Akron - Lorain 

area be redesignated from nonattainment to attainment for the eight-hour ozone standard. 

The Cleveland - Akron – Lorain area has recorded three (3) years of complete quality 

assured ambient air quality monitoring data for the years 2006 -- 2008 demonstrating 

attainment of the eight-hour ozone standard. 

 Geographical Description

 The Cleveland - Akron - Lorain eight-hour ozone nonattainment area is located in 

northeastern Ohio and includes the Counties of Ashtabula, Cuyahoga, Geauga, Lake, 

Lorain, Medina, Portage, and Summit . This area is shown in Figure 1 under Chapter 

Three. 

 Status of Air Quality 

Ozone monitoring data for the most recent three (3) years, 2006 through 2008, 

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

nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels 

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

Akron - Lorain area based on the requirements in Section 107(d)(3)(E) of the CAA. 
 3 

CHAPTER TWO 

Requirements for Redesignation 

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

Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued 

September 4, 1992, to Regional Air Directors. The redesignation request and maintenance 

plan are based on the redesignation guidance, supplemented with additional guidance 

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

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

Akron - Lorain 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. EPA-approved air 

quality modeling. The supplemental modeling is not required for ozone 

nonattainment areas seeking redesignation; however, in Appendix C and 

Appendix D the most recent modeling results showing future attainment and 

maintenance are provided. Chapter Three discusses this requirement in 

more detail and provides the attainment demonstration. 

ii.) SIP approval: 

 The SIP for the area must be fully approved under Section 110(k) and must 

satisfy all the requirements that apply to the area. Ohio’s SIP was approved 

on May 9, 1994 (59FR23799), March 23, 1995 (60FR15235), and May 7, 

1996 (61FR20458) and includes the Cleveland - Akron - Lorain area. 

Chapter Five discusses this requirement in more detail. 

iii.) Permanent and enforceable improvement in air quality; 

 The state must be able to reasonably attribute the improvement in air quality 

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

well as control measures that have been adopted and implemented by the 

state. 

 The Cleveland - Akron - Lorain area was designated moderate nonattainment 

for ozone as part of the 1990 CAA Amendments re-evaluation. As a result, 

Ohio has adopted and implemented control measures for these Counties in 
 4 

that area beyond the federal measures and the initial 1979/1981 Statewide 

rules. Chapters Four and Five discuss this requirement in more detail. 

iv.) Section 110 and Part D requirements: 

 For purposes of redesignation, a state must meet all requirements of Section 

110 and Part D that were applicable prior to submittal of the complete 

redesignation request. 

 Part D consists of general requirements applicable to all areas which are 

designated nonattainment based on a violation of the NAAQS. 

 i.) Section 110(a) requirements 

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

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

submitted by a state must have been adopted by the state after 

reasonable public notice and hearing, and that, among other things, it 

must include enforceable emission limitations and other control 

measures, means or techniques necessary to meet the requirements 

of the CAA; provide for establishment and operation of appropriate 

devices, methods, systems and procedures necessary to monitor 

ambient air quality; provide for implementation of a source permit 

program to regulate the modification and construction of any 

stationary source within the areas covered by the plan; include 

provisions for the implementation of Part C, prevention of significant 

deterioration (PSD) and Part D, NSR permit programs; include criteria 

for stationary source emission control measures, monitoring, and 

reporting; include provisions for air quality modeling; and provides for 

public and local agency participation in planning and emission control 

rule development. In Ohio’s December 5, 2007 infrastructure SIP 

submission, Ohio verified that the State fulfills the requirements of 

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

 ii.) Section 172(c) requirements 

 This Section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for an 

emission inventory will be satisfied by the inventory requirements of 

the maintenance plan. Chapters Four and Five discuss this 

requirement in more detail. 

 iii.) Conformity 
 5 

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

consistent with Section 176(c)(4) conformity requirements. The 

redesignation request should include conformity procedures, if the 

state already has these procedures in place. If a state does not have 

conformity procedures in place at the time that it submits a 

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

conformity regulation upon issuance, as applicable. 

v.) Maintenance plans: 

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

must fully approve a maintenance plan that meets the requirements of 

Section 175(A). The maintenance plan must constitute a SIP revision and 

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

10 years after redesignation. Section 175 (A) further states that the plan 

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

ensure such maintenance. 

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

violation of the NAAQS. At a minimum, the contingency measures must 

include a requirement that the state will implement all measures contained in 

the nonattainment SIP prior to redesignation. 

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. 
 6 

CHAPTER THREE 

OZONE MONITORING

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

Requirement 1 of 4 

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

attained. 

Background

 There are eleven monitors measuring ozone concentrations in this 

nonattainment area. These monitors are operated by Ohio EPA Division of 

Air Pollution Control, Northeast District Office, Cleveland Division of Air 

Quality, Lake County General Health District, and Akron Regional Air Quality 

Management District. A listing of the design values based on the three-year 

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

ozone concentrations from 2006 through 2008 are shown in Table 1. The

locations of the monitoring sites for this nonattainment area are shown on 

Figure 1. 
 7 

Demonstration

 Figure 1 Map of the Cleveland - Akron - Lorain, OH nonattainment area 

and monitor locations. 

Requirement 2 of 4 

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

U.S. EPA air quality system (AQS) database, and available for public view. 

Demonstration

The Ohio Environmental Protection Agency (Ohio EPA) has quality assured all data 

shown in Appendix A in accordance with 40 CFR 58.10 and the Ohio Quality 

Assurance Manual. Ohio EPA has recorded the data in the AQS database and 

therefore data are available to the public. 
 8 

Requirement 3 of 4 

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

monitoring sites in the area or its affected downwind environs, are below 85 parts per billion 

(ppb). (This showing must rely on three (3) complete, consecutive calendar years of quality 

assured data.) 

 

Background

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

Handling Conventions for the eight-hour ozone National Ambient Air Quality 

Standard (NAAQS)," U.S. EPA-454/R-98-017, December 1998. 

Three (3) complete years of ozone monitoring data are required to 

demonstrate attainment at a monitoring site. The eight-hour primary and 

secondary ozone ambient air quality standards are met at an ambient air 

quality monitoring site when the three-year average of the annual fourthhighest daily maximum eight-hour average ozone concentrations is less than 

or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. 

Three (3) significant digits must be carried in the computations. Because the 

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

that is less than or equal to 0.08 ppm. Therefore, for the purposes of this 

request, the eight-hour standard is considered to be 0.085 ppm. Values 

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

ppm exceed the standard. These data handling procedures are applied on 

an individual basis at each monitor in the area. An area is in compliance with 

the eight-hour ozone NAAQS if, and only if, every monitoring site in the area 

meets the NAAQS. An individual site's three (3)-year average of the annual 

fourth highest daily maximum eight-hour average ozone concentrations is 

also called the site's design value. 

Table 1 shows the monitoring data for 2006 – 2008 that were retrieved from 

the U.S. EPA AQS. The air quality design value for the area is the highest 

design value among all sites in the area. Please note that the standard is 

measured in ppm while the commonly used unit is ppb. For the remainder of 

this document, ppb will be used. 
 9 

Demonstration

 Table 1 Monitoring Data for the Cleveland - Akron - Lorain, OH area 

 For 2006 – 2008 

 

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

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

 1st 2nd 3rd 4th 2006-2008 

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

39-007-

1001 Ashtabula Conneaut 2006 99 99 99 90 86 

84 

39-007-

1001 Ashtabula Conneaut 2007 99 98 95 92 92 

39-007-

1001 Ashtabula Conneaut 2008 97 81 81 78 75 

39-035-

0034 Cuyahoga Cleveland 2006 97 79 77 77 74 

78 

39-035-

0034 Cuyahoga Cleveland 2007 98 84 84 83 80 

39-035-

0034 Cuyahoga Cleveland 2008 98 88 85 84 81 

39-035-

0064 Cuyahoga Berea 2006 100 72 71 71 68 

74 

39-035-

0064 Cuyahoga Berea 2007 97 103 95 87 83 

39-035-

0064 Cuyahoga Berea 2008 98 87 81 77 72 

39-035-

5002 Cuyahoga Mayfield 2006 98 90 85 83 81 

81 

39-035-

5002 Cuyahoga Mayfield 2007 98 86 84 82 80 

39-035-

5002 Cuyahoga Mayfield 2008 98 90 87 86 83 

39-055-

0004 Geagua Cleveland 2006 100 76 72 71 70 

73 

39-055-

0004 Geagua Cleveland 2007 100 71 69 68 68 

39-055-

0004 Geagua Cleveland 2008 100 88 83 82 82 

39-085-

0003 Lake Eastlake 2006 98 88 84 83 83 

78 

39-085-

0003 Lake Eastlake 2007 98 79 76 75 74 

39-085-

0003 Lake Eastlake 2008 99 84 84 84 78 

39-085-

3002 Lake Painsville 2006 100 80 76 75 75 76 
 10 

 1st 2nd 3rd 4th 2006-2008 

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

39-085-

3002 Lake Painsville 2007 100 93 84 82 79 

39-085-

3002 Lake Painsville 2008 100 81 77 77 76 

39-093-

0018 Lorain Sheffield 2006 99 77 72 69 69 

74 

39-093-

0018 Lorain Sheffield 2007 99 84 82 79 78 

39-093-

0018 Lorain Sheffield 2008 99 88 76 76 75 

39-103-

0003 Medina Cleveland 2006 98 76 75 74 73 

72 

39-103-

0003 Medina Cleveland 2007 100 73 71 70 69 

39-103-

0003 Medina Cleveland 2008 99 80 79 77 75 

39-133-

1001 Portage Akron 2006 99 80 79 74 70 

74 

39-133-

1001 Portage Akron 2007 96 90 85 85 84 

39-133-

1001 Portage Akron 2008 99 75 71 69 69 

39-153-

0020 Summit Akron 2006 100 82 80 77 77 

82 

39-153-

0021 Summit Akron 2007 100 97 92 90 90 

39-153-

0022 Summit Akron 2008 100 91 81 80 80 

Highest Average 84 ppb 

The area's design values have trended downward as emissions have 

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

for EGUs, both regionally and locally. 

Requirement 4 of 4 

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

monitoring network to verify the maintenance of the attainment status. 

Demonstration

 Ohio EPA commits to continue monitoring ozone levels at the sites 

indicated in Figure 1. Ohio EPA will consult with U.S. EPA Region V prior 

to making changes to the existing monitoring network, should changes 

become necessary in the future. Ohio EPA will continue to quality assure 

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

federal requirements. Connection to a central station and updates to the 
 11 

Ohio EPA web site1 will provide real time availability of the data and 

knowledge of any exceedances. Ohio EPA will enter all data into AQS on a 

timely basis in accordance with federal guidelines. 

 

1

 www.epa.state.oh.us/dapc/ 
 12 

CHAPTER FOUR 

EMISSION INVENTORY

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

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

of ozone precursor emissions (VOC and NOx) representative of the year when the area 

achieves attainment of the ozone air quality standard. Ohio also must demonstrate that 

the improvement in air quality between the year that violations occurred and the year that 

attainment was achieved is based on permanent and enforceable emission reductions. 

Other emission inventory related requirements include a projection of the emission 

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

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

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

levels during the 10-year maintenance period. 

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 2002 periodic inventory has been identified as one of the 

preferred data bases for SIP development and coincides with 

nonattainment air quality in the Cleveland - Akron - Lorain area. 

Periodic inventories, which include emissions from all sectors - mobile, 

area, non-road, and point sources - are prepared every three (3) years. 

Demonstration

The 2002 inventory is used as the base year for the purpose of this 

submittal and was submitted to U.S. EPA on June 15, 2007 along with the 

attainment demonstration for this area. The detailed emission inventory 

information for the Columbus area is provided in Appendix B. Emissions of 

VOC and NOx for 2002 are identified under Requirement Three of this 

Chapter. 

Requirement 2 of 5 

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

Background

Ohio EPA prepared a comprehensive inventory for the Cleveland - Akron - Lorain 

area including area, mobile, and point sources for precursors of ozone (VOCs and 

NOx) for base years 2002 and 2005. The 2002 inventory was submitted to U.S. 

EPA on June 15, 2007 and then supplemented on February 22, 2008 with the 
 13 

2005 inventory, as part of the attainment demonstration for this area. The 

information below describes the procedures Ohio EPA used to generate the 2002 

base year inventory and to develop SIP-ready modeling inventories and future 

year projections (Pechan Report2

) based on a 2005 base year inventory. The 

report by Pechan generated future year estimates of annual emissions for each 

source sector using accepted growth surrogates. The on-road mobile source 

sector was addressed by specific modeling as addressed below. These 

inventories were provided to the Lake Michigan Air Directors Consortium (LADCO) 

and have been processed to develop summer day emissions for use in the air 

quality analyses. These processed modeling inventories have been identified as 

the correct iteration of the inventory for use in the redesignation. In this document, 

references to LADCO include the Midwest Regional Planning Organization. 

• Area sources were taken from the Ohio 2005 periodic inventory 

submitted to U.S. EPA. These projections were made from the U.S. 

Department of Commerce Bureau of Economic Analysis (BEA) 

growth factors, with some updated local information. 

• Mobile source emissions were calculated from MOVES2010 

produced emission factors. 

• Point source information was compiled from Ohio EPA’s 2005 

annual emissions inventory database and the 2005 U.S. EPA Air 

Markets acid rain database3

. 

• Biogenic emissions are not included in these summaries. 

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

Mobile Inventory Model (NMIM) 2002 application. To address 

concerns about the accuracy of some of the categories in U.S. 

EPA’s non-road emissions model, LADCO contracted with two (2) 

companies to review the base data and make recommendations. 

One of the contractors also estimated emissions for three (3) nonroad categories not included in U.S. EPA’s non-road model. 

Emissions were estimated for aircraft, commercial marine vessels, 

and railroads. Recreational motorboat population and spatial 

surrogates (used to assign emissions to each county) were 

significantly updated. The populations for the construction 

equipment category were reviewed and updated based upon 

surveys completed in the midwest, and the temporal allocation for 

agricultural sources also was updated. 

 

 

 

2 

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

eport_Final.pdf 

3 http://www.epa.gov/airmarkets/acidrain 
 14 

Demonstration 

On-Road Emission Estimations 

In coordination with the Ohio Department of Transportation (ODOT) and the 

Akron Metropolitan Area Transportation Study (AMATS), the Northeast 

Ohio Areawide Coordinating Agency (NOACA) utilizes a regional travel 

demand forecast model to simulate traffic in the area and to forecast traffic 

flows for given growth expectations. The model is primarily used as a long 

range planning tool to evaluate the transportation system including 

determination of locations where additional travel capacity may be needed 

and to determine the infrastructure requirements necessary to meet that 

need. It is also used as a tool for air quality purposes to estimate the total 

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

forecasting model is used to predict the total daily vehicle miles traveled 

(VMT), and a U.S. EPA computer program called MOVES2010 is used to 

calculate emissions rates. The product of these is the total amount of 

pollution emitted by the on-road vehicles for the area. In areas outside the 

regional travel demand model, traffic counts and Cleveland-Akron-Lorain 

Ohio traffic growth rates are used for the HPMS-based VMT estimates. 

Overview 

Broadly described, MOVES2010 is used to generate “emission factors”, 

which are the average emissions per vehicle-mile (grams/vehicle-mile) and 

the average emissions per vehicle-hour (grams/vehicle-hour) for the ozone 

precursors, NOx and VOC. The MOVES2010 model includes a number of 

variables that affect the emission factors. These variables have national 

default values, some of which require modification to reasonably reflect 

local conditions. Some of these variables are discussed here. The vehicle 

fleet (vehicles on the road) age and the source type have a major effect on 

the emission factors. The source types are traveling on road types 

(MOVES2010 road types are Rural Restricted Access, Rural Unrestricted 

Access, Urban Restricted Access, and Urban Unrestricted Access). The 

vehicle speeds also affect the emission factor values. Meteorological 

conditions such as air temperature and humidity have a significant effect on 

emission factors. Emission factors produced by MOVES2010 can also 

include the effect of emission reduction strategies such as vehicle 

inspection and maintenance programs, regulation of fuels, etc. These 

MOVES2010 inputs are estimated using the best available data. 

These inputs are reviewed and agreed to by U.S. EPA and transportation 

agencies in a formal interagency consultation process. Emission factors 

are multiplied by VMT from the travel demand model to estimate the total 

vehicle emissions. 
 15 

The emission factors from MOVES2010 can be used with the travel 

demand model information by combining the disaggregate emission rates 

with VMT, and source type population for each road type, source type and 

hour of day, and then sum them up to get the total emissions for the area. 

The method, used by ODOT, is to aggregate the emission rates by two 

source types (cars & trucks), then applying VMT and source type 

population, thereby reducing the intensive processes. In the first step 

emission factors are broadly classified into total vehicles, cars and trucks 

by pollutant, by average speed, road type and hour of day. Then the hourly 

link volumes generated from travel demand model are combined with 

emission factors for each network link for each hour. The on-road vehicle 

emissions for the area is the sum of all individual link-hour emissions. 

Vehicle-based emissions are obtained by the combination of corresponding 

emission factors and source type population. Intrazonal emissions are 

computed using a separate method to account for those trips that use local 

roads to travel within a zone. Intrazonal VMT is combined with 

corresponding emission factors to get intrazonal emissions. Total emissions 

are sum of on-road vehicle emissions, vehicle-based emissions and 

intrazonal emissions. 

Automated programs, using FORTRAN and CUBE scripting, were 

developed by ODOT to generate total emissions. The process uses data 

on daily and directional traffic distributions as well as more up to date 

volume/delay functions from the 2000 Highway Capacity Manual (HCM). 

This process also handles the newer model network formats and 

MOVES2010 generated emission factors. The Cleveland - Akron - Lorain 

area analysis uses an approach similar to ODOT’s. 

MOVES2010 input and output files are provided in Appendix C. 

Best Available Data 

Most current vehicle age distribution data, temperature data, fuel properties 

data, source type distribution data, and I/M data provided by ODOT’s ATRs 

and WIMs, NOAA, ODPS, and Ohio EPA were used by the ODOT for 

generating emission factors. Likewise, the most current transportation 

planning data available from NOACA and AMATS and most current ODOT 

count data were used by ODOT for the emissions estimates. 

Analysis Years 

Analysis years for this redesignation request include 2002, 2006 

(attainment year), 2012 (interim budget year), and 2020 to meet the 

requirements specified by the CAA and U.S. EPA. The travel demand 

model presents the transportation system conditions for each of these 

years. Model runs for each future analysis year contain the road network 
 16 

NOACA, AMATS, and ODOT of that year with corresponding 

socioeconomic forecasts for that year. 

Local Road VMT 

Most local roads such as subdivision streets are not explicitly modeled in a 

travel demand model. These local roads are represented as fictitious 

roadways called centroid connectors. Local road traffic is captured as 

intra-zonal trips which travel demand models usually do not assign to 

roadway segments. The ODOT post process includes these trips as local 

road VMT. 

 

Emission Estimations 

Tables 2 through 9 contain the results of the emissions analysis for the 

appropriate years. 

Table 2 - Ashtabula County Emission Estimations for On-Road Mobile 

Sources

 2002 2006 2012 2020 

VMT (miles/day) 3,178,599 3,075,258 3,177,975 3,399,487 

VOC (tons/day) 5.00 4.17 2.59 1.38 

NOx (tons/day) 11.29 9.04 5.20 2.28 

Table 3 - Cuyahoga County Emission Estimations for On-Road Mobile 

Sources

2002 2006 2012 2020 

VMT (miles/day) 29,297,006 29,378,875 29,404,954 29,696,610 

VOC (tons/day) 62.92 48.61 26.65 13.60 

NOx (tons/day) 128.84 104.67 61.07 33.73 

Table 4 - Geauga County Emission Estimations for On-Road Mobile 

Sources

2002 2006 2012 2020 

VMT (miles/day) 2,567,692 2,698,563 2,775,615 2,996,643 

VOC (tons/day) 6.06 5.10 2.88 1.74 

NOx (tons/day) 13.47 11.85 7.63 5.37 
 17 

Table 5 - Lake County Emission Estimations for On-Road Mobile Sources

2002 2006 2012 2020 

VMT (miles/day) 5,738,319 5,889,045 5,965,888 6,212,829 

VOC (tons/day) 13.28 10.87 6.33 3.42 

NOx (tons/day) 29.59 25.93 16.62 10.62 

Table 6 - Lorain County Emission Estimations for On-Road Mobile 

Sources

2002 2006 2012 2020 

VMT (miles/day) 6,972,908 7,088,351 7,121,863 7,338,790 

VOC (tons/day) 16.56 13.59 8.02 4.28 

NOx (tons/day) 34.23 29.89 19.15 12.01 

Table 7 - Medina County Emission Estimations for On-Road Mobile 

Sources

2002 2006 2012 2020 

VMT (miles/day) 5,888,243 6,165,358 6,391,366 6,990,097 

VOC (tons/day) 12.34 10.52 6.51 3.73 

NOx (tons/day) 36.39 32.52 21.53 14.98 

Table 8 - Portage County Emission Estimations for On-Road Mobile 

Sources

2002 2006 2012 2020 

VMT (miles/day) 4,782,788 5,186,076 5,494,912 5,872,599 

VOC (tons/day) 8.26 6.95 4.39 2.37 

NOx (tons/day) 17.17 14.83 8.81 3.89 

Table 9 - Summit County Emission Estimations for On-Road Mobile 

Sources

2002 2006 2012 2020 

VMT (miles/day) 15,788,738 16,213,278 16,501,142 18,086,124 

VOC (tons/day) 30.58 21.78 13.53 7.02 

NOx (tons/day) 60.43 45.49 24.57 11.35 

Table 10 - Emission Estimation Totals for On-Road Mobile Sources for the 

 Cleveland - Akron - Lorain Area

2002 2006 2012 2020 

VOC (tons/day) 155.00 121.59 70.90 37.54 

NOx (tons/day) 331.41 274.22 164.58 94.23 
 18 

Motor Vehicle Emission Budget 

Table 11 contains the motor vehicle emissions budget for the Cleveland - Akron 

- Lorain area. 

Table 11 - Mobile Vehicle Emissions Budget for the Cleveland - Akron – 

Lorain Area 

 2012 2020 

VOC (tons/day) 81.54 43.17 

NOx (tons/day) 189.27 108.36 

The above budget includes the emission estimates calculated for 2012 and 

2020 with an additional 15 percent margin of safety. The emission 

estimates are derived from the Tranplan travel demand model and 

MOVES2010 as described above under the expected NOACA and AMATS 

2030 Long Range Plans and known projects in the areas not included 

within either MPO’s jurisdiction. The additional 15 percent translates into 

an additional 5.63 tons/day for VOC and 14.13 tons/day for NOx for 2020. 

All methodologies, the latest planning assumptions, and the safety margins 

were determined through the interagency consultation process described in 

the Transportation Conformity Memorandum of Understanding (MOU) 

among NOACA, AMATS, ODOT, and Ohio EPA. 

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

effective date of the approved redesignation or after the effective date of 

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

budget included in this submittal is adequate for transportation conformity 

purposes whichever date comes first.

Requirement 3 of 5 

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

standard. 

Background

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

maintenance year for this redesignation request. This document contains 

projected emissions inventories for 2012 and 2020. 

Emission projections for the Cleveland - Akron - Lorain area were 

performed using the following approaches: 

• As performed by NOACA, mobile source emission projections are 

based on the U.S. EPA MOVES2010 model. The analysis is 
 19 

described in more detail in Appendix C. All projections were made 

in accordance with “Procedures for Preparing Emissions 

Projections” U.S. EPA-45/4-91-019. 

• Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. LADCO 

has developed growth and control files for point, area, and non-road 

categories. These files were used to develop the future-year 

emissions estimates used in this document. This was done so the 

inventories used for redesignation are consistent with modeling 

performed in the future. Appendix D contains LADCO’s technical 

support document detailing the analysis used to project emissions. 

The 2006 attainment year was grown from the 2005 LADCO 

modeling inventory using LADCO’s growth factors. The 2020 

maintenance year was grown from the 2018 LADCO modeling 

inventory using LADCO’s growth factors. 

The detailed inventory information for the Cleveland - Akron - Lorain area 

for 2002 is in Appendix B. Emission trends are an important gauge for 

continued compliance with the ozone standard. Therefore, Ohio EPA 

performed an initial comparison of the inventories for the base year and 

maintenance years. Mobile source emission inventories are described in 

Section 5 of Appendix B. 

Sectors included in the following tables are: Electrical Generating Unit 

(EGU-Point); Non-Electrical Generating Unit (Non-EGU); Non-road Mobile 

(Non-road); Other Area (Other); Marine; Aircraft; Rail (MAR); and On-road 

Mobile (On-road). 

Maintenance is demonstrated when the future-year (2020) projected 

emission totals are below the 2006 attainment year totals. 

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

sources: 

All On-Road Data 

 source: NOACA Transportation and Modeling Department 

All Other Data 

source: Midwest Regional Planning Organization (MRPO) and 

Lake Michigan Air Directors Consortium (LADCO) Web site 

(2002 from Base K and all other years from Base M):

http://www.ladco.org/tech/emis/
 20 

Demonstration

 VOC 

 Table 12 Ashtabula County VOC Emission Inventory Totals for Base 

 Year 2002, Estimated 2006, and Projected 2012 and 2020 (tons 

 per day) 

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 0.08 0.00 0.00 0.00 

Non-EGU 5.50 0.94 0.96 1.15 

Non-road 9.53 8.94 6.40 6.40 

Other 3.31 5.89 5.09 4.66 

MAR 0.24 0.25 0.19 0.11 

On-road 5.00 4.17 2.59 1.38 

TOTAL 23.66 20.19 15.23 13.70 6.49 

 Table 13 Cuyahoga County VOC Emission Inventory Totals for Base 

 Year 2002, Estimated 2006, and Projected 2012 and 2020 (tons 

 per day)

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 0.06 0.00 0.00 0.00 

Non-EGU 2.13 3.68 4.28 5.26 

Non-road 39.01 39.70 30.24 30.24 

Other 46.90 44.14 37.04 35.21 

MAR 0.94 0.92 0.84 0.72 

On-road 62.92 48.61 26.65 13.60 

TOTAL 151.96 137.05 99.05 85.03 52.02 
 21 

Table 14 Geauga County VOC Emission Inventory Totals for Base Year 

2002, Estimated 2006, and Projected 2012 and 2020 (tons per day) 

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point n/a n/a n/a n/a 

Non-EGU 0.00 0.00 0.00 0.01 

Non-road 3.98 4.87 3.48 3.48 

Other 8.26 9.96 10.03 11.15 

MAR 0.00 0.00 0.00 0.00 

On-road 6.06 5.10 2.88 1.74 

TOTAL 18.30 19.93 16.39 16.38 3.55 

Table 15 Lake County VOC Emission Inventory Totals for Base Year 

2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

day)

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 0.31 0.02 0.02 0.01 

Non-EGU 0.18 0.80 0.86 0.95 

Non-road 13.22 10.97 8.30 8.30 

Other 9.01 9.06 7.43 6.83 

MAR 0.13 0.16 0.12 0.05 

On-road 13.28 10.87 6.33 3.42 

TOTAL 36.13 31.88 23.06 19.56 12.32 

 
 22 

Table 16 Lorain County VOC Emission Inventory Totals for Base Year 

2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

day)

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 0.33 0.22 0.21 0.18 

Non-EGU 2.11 2.96 3.20 3.53 

Non-road 13.21 12.79 9.51 9.51 

Other 11.96 11.45 9.91 9.51 

MAR 0.25 0.24 0.18 0.10 

On-road 16.56 13.59 8.02 4.28 

TOTAL 44.42 41.25 31.03 27.11 14.14 

 

Table 17 Medina County VOC Emission Inventory Totals for Base Year 

2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

day)

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point n/a n/a n/a n/a 

Non-EGU 0.20 0.79 0.88 1.00 

Non-road 3.90 5.24 3.58 3.85 

Other 6.18 7.40 6.49 6.32 

MAR 0.06 0.05 0.04 0.03 

On-road 12.34 10.52 6.51 3.73 

TOTAL 22.68 24.00 17.50 14.93 9.07 

 

Table 18 Portage County VOC Emission Inventory Totals for Base Year 

2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

day)

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point n/a n/a n/a n/a 

Non-EGU 0.61 0.95 1.12 1.39 

Non-road 4.98 7.36 5.10 5.10 

Other 6.45 6.19 5.19 4.78 

MAR 0.12 0.13 0.10 0.10 

On-road 8.26 6.95 4.39 2.37 

TOTAL 20.42 21.58 15.90 13.74 7.84 
 23 

Table 19 Summit County VOC Emission Inventory Totals for Base Year 

2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

day)

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point n/a n/a n/a n/a 

Non-EGU 1.13 1.27 1.38 1.58 

Non-road 9.01 12.21 8.91 8.91 

Other 18.61 18.17 15.00 14.17 

MAR 0.14 0.15 0.13 0.09 

On-road 30.58 21.78 13.53 7.02 

TOTAL 59.47 53.58 38.95 31.77 21.81 

Table 20 Cleveland - Akron – Lorain Area VOC Emission Inventory 

Totals for Base Year 2002, Estimated 2006, and Projected 2012 

and 2020 (tons per day) 

VOC 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

Ashtabula 5.00 4.17 2.59 1.38 

Cuyahoga 62.92 48.61 26.65 13.60 

Geauga 6.06 5.10 2.88 1.74 

Lake 13.28 10.87 6.33 3.42 

Lorain 16.56 13.59 8.02 4.28 

Medina 12.34 10.52 6.51 3.73 

Portage 8.26 6.95 4.39 2.37 

Summit 30.58 21.78 13.53 7.02 

COMBINED VOC 

TOTAL 155.00 121.59 70.90 37.54 84.05 

 

 

NOx
 24 

Table 21 Ashtabula County NOx Emission Inventory Totals for Base 

Year 2002, Estimated 2006, and Projected 2012 and 2020 (tons 

per day) 

Sector 2002 

Base 

2006 

Attainment

2012 Interim 2020 

Maintenance 

Safety 

Margin 

EGU 

Point 10.69 3.87 3.91 3.91 

Non-EGU 0.77 0.65 0.83 1.16 

Non-road 1.96 3.47 2.71 1.79 

Other 0.51 0.85 0.86 0.86 

MAR 7.03 5.24 4.12 3.01 

On-road 11.29 9.04 5.20 2.28 

TOTAL 32.25 23.12 17.63 13.01 10.11 

 

Table 22 Cuyahoga County NOx Emission Inventory Totals for Base 

Year 2002, Estimated 2006, and Projected 2012 and 2020 

(tons per day) 

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 5.13 5.88 6.50 6.50 

Non-EGU 5.63 7.68 7.08 7.79 

Non-road 26.39 26.15 19.00 11.12 

Other 5.90 13.83 14.01 14.09 

MAR 13.89 10.46 8.79 7.04 

On-road 128.84 104.67 61.07 33.73 

TOTAL 185.78 168.67 116.45 80.27 88.40 

 

 Table 23 Geauga County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

 day) 

Sector 

2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point n/a n/a n/a n/a 

Non-EGU n/a n/a n/a n/a 

Non-road 2.07 2.58 1.81 0.97 

Other 0.44 1.01 1.01 1.00 

MAR 0.00 0.00 0.00 0.00 

On-road 13.47 11.85 7.63 5.37 

TOTAL 15.98 15.44 10.45 7.34 8.10 
 25 

 Table 24 Lake County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

 day) 

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 71.16 36.33 33.99 27.74 

Non-EGU 1.20 1.15 0.82 0.83 

Non-road 4.55 6.01 4.59 3.06 

Other 0.97 2.30 2.32 2.33 

MAR 3.72 2.98 2.40 1.72 

On-road 29.59 25.93 16.62 10.62 

TOTAL 111.19 74.70 60.74 46.30 28.40 

 

 Table 25 Lorain County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

 day) 

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point 56.94 25.00 23.92 21.04 

Non-EGU 1.74 2.31 2.01 2.40 

Non-road 6.93 8.05 5.86 3.63 

Other 0.77 2.66 2.69 2.70 

MAR 6.67 4.79 3.88 2.81 

On-road 34.23 29.89 19.15 12.01 

TOTAL 107.28 72.70 57.51 44.59 28.11 

 

 Table 26 Medina County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

 day)

Sector 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point n/a n/a n/a n/a 

Non-EGU 0.08 0.26 0.15 0.16 

Non-road 2.69 4.13 2.92 1.40 

Other 0.76 1.57 1.58 1.59 

MAR 1.33 0.89 0.76 0.56 

On-road 36.39 32.52 21.53 14.98 

TOTAL 41.25 39.37 26.94 18.69 20.68 

 

Table 27 Portage County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

 day)
 26 

Sector 2002 Base 2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU Point n/a n/a n/a n/a 

Non-EGU 0.00 0.22 0.19 0.23 

Non-road 3.07 3.84 2.70 1.33 

Other 0.77 1.52 1.53 1.53 

MAR 2.61 2.41 2.06 1.49 

On-road 17.17 14.83 8.81 3.89 

TOTAL 23.62 22.82 15.29 8.47 14.35 

Table 28 Summit County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2006, and Projected 2012 and 2020 (tons per 

 day)

Sector 2002 Base 2006 

Attainment

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

EGU 

Point n/a n/a n/a n/a 

Non-EGU 3.64 3.23 1.68 1.64 

Non-road 9.31 9.30 6.30 2.85 

Other 2.37 5.51 5.58 5.61 

MAR 2.22 2.03 1.75 1.28 

On-road 60.43 45.49 24.57 11.35 

TOTAL 77.97 65.56 39.88 22.73 42.83 

Table 29 Cleveland - Akron – Lorain Area NOx Emission Inventory 

Totals for Base Year 2002, Estimated 2006, and Projected 

2012 and 2020 (tons per day) 

NOx 2002 

Base 

2006 

Attainment 

2012 

Interim 

2020 

Maintenance 

Safety 

Margin 

Ashtabula 11.29 9.04 5.20 2.28 

Cuyahoga 128.84 104.67 61.07 33.73 

Geauga 13.47 11.85 7.63 5.37 

Lake 29.59 25.93 16.62 10.62 

Lorain 34.23 29.89 19.15 12.01 

Medina 36.39 32.52 21.53 14.98 

Portage 17.17 14.83 8.81 3.89 

Summit 60.43 45.49 24.57 11.35 

COMBINED NOx 

TOTAL 331.41 274.22 164.58 94.23 179.99 
 27 

Table 30 Cleveland - Akron – Lorain Area Comparison of 2006 

attainment year and 2020 projected emission estimates (tons 

per day, summer) 

2006 2020 Projected 

Decrease 

VOC 121.59 37.54 84.05 

NOx 274.22 94.23 179.99 

As shown in the table above, VOC emissions in the nonattainment area are 

projected to decrease by 84.05 tons/day. Point sources show a slight 

increase due to expectations that the population will grow in this area; 

however, cleaner vehicles and fuels are expected to be in place in 2009 

and 2018 and they cause an overall drop in VOC emissions. 

NOx emissions in the nonattainment area are projected to decrease by 

179.99 tons/day. Again, area source emissions and point sources, show a 

slight increase due to expectations that the population will grow in this area. 

Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions 

Standards and Gasoline Sulfur Control Requirements4

, Highway HeavyDuty Engine Rule5

 , Non-Road Diesel Engine Rule6, and the Clean Air 

Interstate Rule7 are factored into the changes. 

As identified in Table 11 above, an additional 15 percent margin of 

safety is being requested for mobile emissions. The additional 15 

percent translates into an additional 5.63 tons/day for VOC and 14.13 

tons/day for NOx for 2020. U.S. EPA’s conformity regulations allow for 

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

overall area’s safety margin (emission reductions from 2006 to 2020) 

to the mobile emissions budgets for future conformity. Ohio chose to 

allocate 5.63 tons/day of the 84.05 tons/day safety margin for VOC 

and 14.13 tons/day of the 179.99 tons/day safety margin for NOx as a 

mobile emissions budget 15% safety margin. 

Requirement 4 of 5 

A demonstration that improvement in air quality between the year violations occurred and 

the year attainment was achieved is based on permanent and enforceable emission 

reductions and not on temporary adverse economic conditions or unusually favorable 

meteorology. 

 

4 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 5 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 6 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 7 http://www.epa.gov/fedrgstr/EPA-AIR/2005/May/Day-12/a5723a.pdf 
 28 

Background

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

the NAAQS for ozone in 2006-2008. U.S. EPA’s redesignation guidance (p 

9) states: “A state may generally demonstrate maintenance of the NAAQS by 

either showing that future emissions of a pollutant or its precursors will not 

exceed the level of the attainment inventory, or by modeling to show that the 

future mix of sources and emissions rates will not cause a violation of the 

NAAQS.” 

Demonstration

Permanent and enforceable reductions of VOC and NOx emissions have 

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

these reductions were due to the application of tighter federal standards on 

new vehicles. Also, Title IV of the CAA and the NOx SIP Call required the 

reduction of NOx emissions from utility sources. Reductions achieved are 

discussed in greater detail under Chapter Five. 

Table 31 Cleveland - Akron – Lorain Area Combined Comparison of 

2002 base year and 2006 attainment year on-road and EGU 

reductions 

All On-Road Data 

 source: NOACA Transportation and Modeling Department 

All Other Data source: Midwest Regional Planning Organization (MRPO) and 

Lake Michigan Air Directors Consortium (LADCO) Web site (Base M): 

 http://www.ladco.org/tech/emis/

 

2002 2006 

On-road VOC 155.00 121.59 

On-road NOx 331.41 274.22 

EGU NOx 143.92 71.08 

Requirement 5 of 5 

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

levels, including an annual emission statement from major sources. 

Demonstration

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

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

Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic 

inventory for all ozone precursor emission sectors every three (3) years. 

These ozone precursor inventories will be prepared for future years as 

necessary to comply with the inventory reporting requirements established in 

the CFR. Emissions information will be compared to the 2002 base year and 
 29 

the 2020 projected maintenance year inventories to assess emission trends, 

as necessary, and to assure continued compliance with the ozone standard. 
 30 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 6 

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

nonattainment areas to implement RACT under Section 172(c)(1). 

Background

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

moderate nonattainment areas to implement RACT under Section 172(c)(1) 

with respect to the following: 

i.) Each category of VOC sources in the area covered by a Control 

Technology Guideline (CTG) document issued between November 

15, 1990, and the date of attainment; 

ii.) All VOC sources in the area covered by any CTG issued before 

November 15, 1990; and 

iii.) All other major stationary sources of VOCs that are located in the 

area. 

Demonstration

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

RACT rules covering the second and third categories. The U.S. EPA 

approved Ohio's VOC RACT rules on April 25, 1996 (61 FR 18255), 

September 7, 1994 (59 FR 46182), and October 23, 1995 (60 FR 54308). 

With respect to the first category, EPA issued CTGs for five source 

categories in September 2006 and three additional source categories in 

September 2007. Areas classified as moderate and above were required to 

submit VOC RACT for the source categories covered by these CTGs, by 

September 2007 and September 2008, respectively. Ohio EPA is in the 

process of adopting all VOC RACT requirements under OAC Chapter 3745-

21 as required under the first category as part of a rulemaking that will be 

finalized and submitted as a SIP revision in conjunction with this 

redesignation request. 

RACT requirements are incorporated into permits along with monitoring, 

recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio 

EPA also has an active enforcement program to address violations 
 31 

discovered by field office staff. The Ohio RACT rules are found in OAC 

Chapter 3745-218

. 

Requirement 2 of 6

CAA Section 182(b) requires plan provisions for reasonable further progress for moderate 

nonattainment areas that include a 15 percent reduction in VOC and NOx emissions. 

Background

Section 182(b)(1) requires reductions as part of a 15 percent rate of progress 

(ROP) demonstration. The requirement for NOx emission reductions can be 

waived if it is determined to not contribute to attainment. However, it was 

determined that NOx emission reductions would be necessary for Ohio. 

As explained in a memorandum from John S. Seitz, Director, Office of Air 

Quality Planning and Standards, entitled “Reasonable Further Progress, 

Attainment Demonstration, and Related Requirements for Ozone 

Nonattainment Areas Meeting the Ozone National Ambient Air Quality 

Standards,” dated May 10, 1995, U.S. EPA interprets the provisions 

regarding attainment demonstrations to not require SIP submittals if an 

ozone nonattainment area subject to those requirements is monitoring 

attainment of the ozone standard. The Cleveland-Akron-Lorain area is 

monitoring attainment; however, Ohio EPA submitted an attainment 

demonstration on June 15, 2007 (supplemented February 22, 2008) which is 

summarized below. 

Demonstration

The Cleveland-Akron-Lorain area implemented state rules identified in their 

1994 15 percent ROP demonstration as part of the one-time CAAA 

requirements. These measures include the region’s Motor Vehicle Inspection 

and Maintenance (I/M) Program (E-Check), Stage II vapor recovery from 

gasoline nozzles, enforcement cases, the original architectural coatings rule, 

and removal of the 100 ton per year cut-off for VOC RACT requirements in 

the rural portion of the nonattainment area (including Stage I Vapor 

Recovery). While the March 14, 1994, 15 percent ROP plan submittal was 

not explicitly approved, these rules were assumed to be in place as part of 

the maintenance plan approved as part of the one-hour redesignation on May 

7, 1996. 

In addition to the 1994 15 percent ROP, Ohio implemented NOx RACT rules9

effective December 22, 2007. Ohio’s rule has compliance dates of 

December 22, 2009 and December 22, 2010. These rules were submitted to 

U.S. EPA for consideration as a revision to the SIP on January 10, 2008. 

 

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

9 http://www.epa.state.oh.us/dapc/regs/3745-110/3745_110.html 
 32 

In addition to the above, Ohio also implemented the following control 

strategies as part of the attainment demonstration: 

 

- Portable fuel containers10: Ohio’s rule has a compliance date of 

July 1, 2007. This rule was approved into the SIP on March 30, 

2007. 

- Architectural and industrial maintenance (AIM) coatings11: Ohio’s 

rule has a compliance date of January 1, 2009. This rule was not 

submitted for SIP approval due to impending changes to the 

corresponding federal rules, per agreement with U.S. EPA. 

- Consumer and commercial products12: Ohio’s rule has compliance 

dates of March 15, 2008 and January 1, 2009. These rules were 

submitted to U.S. EPA for consideration as a revision to the SIP on 

October 4, 2007. 

Requirement 3 of 6

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

Background

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

two years of the enactment of the Clean Air Act Amendments and then every 

three years thereafter. 

Demonstration

Ohio EPA submitted its emissions statement SIP on March 18, 1994 which 

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

discussed in Chapter Four (Requirement Four), Ohio EPA submits, and 

commits to submit, emission inventories (statements) every three years. 

Requirement 4 of 6

Evidence that control measures required in past ozone SIP revisions have been fully 

implemented. 

Background

In addition to the historic RACT requirements and those mentioned above, 

the U.S. EPA NOx SIP Call required 22 states to pass rules that would result 

in significant emission reductions from large EGUs, industrial boilers, and 

cement kilns in the eastern United States. Ohio passed this rule in 2001. NOx 

 

10 http://www.epa.state.oh.us/dapc/regs/3745-21/21_17.pdf 11 http://www.epa.state.oh.us/dapc/regs/3745-113/3745_113.html 

12 http://www.epa.state.oh.us/dapc/regs/3745-112/3745_112.html 
 33 

SIP Call requirements are incorporated into permits along with monitoring, 

recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio 

EPA also has an active enforcement program to address violations 

discovered by field office staff. Compliance is tracked through the Clean Air 

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

reduction of approximately 31 percent of all NOx emissions statewide 

compared to previous uncontrolled years. The other 21 states also have 

adopted these rules. 

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

2009, U.S. EPA’s CAIR rule requires EGUs in 28 eastern states and the 

District of Columbia to significantly reduce emissions of NOx. CAIR will 

replace the NOx SIP Call for EGUs. National NOx emissions will be cut from 

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

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

of this effort. Ohio submitted a CAIR SIP which was approved by U.S. EPA 

on February 1, 2007. U.S. EPA projects that in 2009 emissions of NOx will 

decrease from a baseline of 264,000 tons per year to 91,000 tons per year 

within Ohio13. 

Section 182(b) contains additional provisions applicable to moderate 

nonattainment areas. Section 182(b)(3) requires gasoline vapor recovery 

systems for gasoline dispensing stations in the area and section 182(b)(4) 

requires motor vehicle inspection and maintenance programs. 

Demonstration

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

attain the eight-hour ozone standard with the implementation of the NOx SIP 

Call. Controls for EGUs formally commenced May 31, 2004. Emissions 

covered by this program have been generally trending downward since 1998 

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

EPA Clean Air Markets web site, quantify the gradual NOx reductions that 

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

and the beginning of the NOx SIP Call Rule. Ohio developed the NOx Budget 

Trading Program rules in OAC Chapter 3745-1414 in response to the SIP 

Call. OAC Chapter 3745-14 regulates EGUs and certain non-EGUs under a 

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

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

compared to historical levels. This cap will stay in place through 2008, at 

which time the CAIR program will supersede it as discussed above. 

 

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

14 http://www.epa.state.oh.us/dapc/regs/3745-14/3745_14.html 
 34 

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

establishes a budget for large (greater than 1 ton per day emissions) 

stationary internal combustion engines. Ohio EPA’s OAC rule 3745-14-12 

addresses stationary internal combustion engines, all used in natural gas 

pipeline transmissions. U.S. EPA approved this revision to the SIP on April 4, 

2008. An 82 percent NOx reduction from 1995 levels is anticipated. 

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

compliance demonstration began May 1, 2007. The 2007 controlled NOx 

emissions is 599 tons statewide for the ozone season. 

Section 182(b)(3) requires states to submit Stage II vapor recovery rules no 

later than November 15, 1992. The U.S. EPA partially approved and partially 

disapproved Ohio's SIP revision for implementation of Stage II on October, 

20, 1994 (59 FR 52911). As stated in that rulemaking action, with the 

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

Stage II program to fully satisfy the criteria set forth in the September 17, 

1993, U.S. EPA guidance document for such programs entitled "Enforcement 

Guidance for Stage II Vehicle Refueling Control Programs." Furthermore, the 

September 17, 1993, guidance memorandum states that once onboard vapor 

recovery regulations are promulgated, the Stage II regulations are no longer 

applicable for moderate ozone nonattainment areas. The U.S. EPA 

promulgated onboard vapor recovery rules in February 1994. Therefore, 

pursuant to Section 202(a)(6) of the CAA, Stage II would no longer be 

required. 

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

submit a fully adopted I/M program by November 15, 1993. U.S. EPA 

approved Ohio's enhanced I/M program (E-Check), on April 4, 1995 (60 FR 

16989) and January 6, 1997 (62 FR 646). 

The E-check program and Stage I and Stage II requirements are still being 

implemented. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards 

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

emissions from cars and light trucks, including sport utility vehicles (SUVs). 

Under this proposal, automakers will be required to sell cleaner cars, and 

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

will apply nationwide. The federal rules will phase in between 2004 and 

2009. U.S. EPA has estimated that NOx emission reductions will be 

approximately 77 percent for passenger cars, 86 percent for smaller SUVs, 

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

vans, and heavier trucks. VOC emission reductions will be approximately 12 

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

minivans, and 15 percent for larger SUVs, vans, and heavier trucks. 
 35 

Heavy-Duty Diesel Engines 

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

program which includes low-sulfur diesel fuel standards, which will be phased 

in from 2004 through 2007. This rule applies to heavy-duty gasoline and 

diesel trucks and buses. This rule will result in a 40 percent reduction in NOx

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

inventory. 

Clean Air Non-road Diesel Rule 

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

applies to diesel engines used in industries such as construction, agriculture, 

and mining. It also contains a cleaner fuel standard similar to the highway 

diesel program. The new standards will cut emissions from non-road diesel 

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

in this rule, currently accounts for 47 percent of diesel particulate matter (PM) 

and 25 percent of NOx from mobile sources nationwide. Sulfur levels will be 

reduced in non-road diesel fuel by 99 percent from current levels, from 

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

engine standards take effect, based on engine horsepower, starting in 2008. 

Together, these rules will substantially reduce local and regional sources of 

ozone precursors. 

Requirement 5 of 6

Acceptable provisions to provide for new source review. 

Background

Ohio has a long standing and fully implemented New Source Review (NSR) 

program. This is addressed in OAC Chapter 3745-3115. The Chapter 

includes provisions for the Prevention of Significant Deterioration (PSD) 

permitting program in OAC rules 3745-31-01 to 3745-31-20. Ohio's PSD 

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

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

part of the SIP. 

Demonstration

Any facility that is not listed in the 2002 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. 

 

15 http://www.epa.state.oh.us/dapc/regs/3745-31/3745_31.html 
 36 

Requirement 6 of 6

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

State demonstrates through photochemical modeling that the standard can be maintained 

without one (1) or more control measures. 

Demonstration

Ohio commits to maintaining the aforementioned control measures after 

redesignation. Ohio hereby commits that any changes to its rules or 

emission limits applicable to VOC and/or NOx sources, as required for 

maintenance of the ozone standard in the Cleveland - Akron - Lorain area, 

will be submitted to U.S. EPA for approval as a SIP revision. 

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

necessary resources to actively enforce any violations of its rules or permit 

provisions. After redesignation, it intends to continue enforcing all rules that 

relate to the emission of ozone precursors in the Cleveland - Akron - Lorain 

area. 
 37 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4

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

Demonstration

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

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

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency control 

measures in response to exceeding specified predetermined levels (triggers) or in the event 

that future violations of the ambient standard occurs. 

Demonstration

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

Warning Level Response: 

A warning level response shall be prompted whenever an annual (1-year) 

fourth high monitored value of 88 ppb occurs in a single ozone season within 

the maintenance area. A warning level response will consist of a study to 

determine whether the ozone value indicates a trend toward higher ozone 

values or whether emissions appear to be increasing. The study will evaluate 

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

necessary to reverse the trend taking into consideration ease and timing for 

implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

later than 12 months from the conclusion of the most recent ozone season 

(September 30). 

Should it be determined through the warning level study that action is 

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

and implementation outlined under action level response shall be followed. 

Action Level Response: 

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

fourth high monitored value of 85 parts per billion (ppb) or greater occurs 

within the maintenance area. A violation of the standard (three-year average 

fourth high value of 85 ppb or greater) shall also prompt an action level 
 38 

response. In the event that the action level is triggered and is not found to be 

due to an exceptional event, malfunction, or noncompliance with a permit 

condition or rule requirement, Ohio EPA in conjunction with the metropolitan 

planning organization or regional council of governments, will determine 

additional control measures needed to assure future attainment of the 

NAAQS for ozone. In this case, measures that can be implemented in a 

short time will be selected in order to be in place within 18 months from the 

close of the ozone season that prompted the action level. Ohio EPA will also 

consider the timing of an action level trigger and determine if additional, 

significant new regulations not currently included as part of the maintenance 

provisions will be implemented in a timely manner and will constitute our 

response. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the necessary 

administrative and legal process. This process will include publication of 

notices, an opportunity for public hearing, and other measures required by 

Ohio law for rulemaking. 

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

implemented at the federal or State level, and that measure/control is 

determined to be sufficient to address the upward trend in air quality, 

additional local measures may be unnecessary. Furthermore, Ohio will 

submit to U.S. EPA an analysis to demonstrate the proposed measures are 

adequate to return the area to attainment. 

Requirement 3 of 4

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

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the time 

the selection is made. The selection of measures will be based on costeffectiveness, emission reduction potential, economic and social 

considerations or other factors that Ohio EPA deems appropriate. Ohio EPA 

will solicit input from all interested and affected persons in the maintenance 

area prior to selecting appropriate contingency measures. Because it is not 

possible at this time to determine what control measure will be appropriate at 

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

below is not exhaustive. 
 39 

1) Lower Reid vapor pressure gasoline program. 

2) Tighten RACT on existing sources covered by U.S. EPA Control 

Technique Guidelines issued in response to the 1990 CAA. 

3) Apply VOC RACT to smaller existing sources. 

4) One or more transportation control measures sufficient to achieve at 

least half a percent reduction in actual areawide VOC emissions. 

Transportation measures will be selected from the following, based 

upon the factors listed above after consultation with affected local 

governments: 

a) trip reduction programs, including, but not limited to, employerbased transportation management plans, areawide rideshare 

programs, work schedule changes, and telecommuting; 

b) traffic flow and transit improvements; and 

c) other new or innovative transportation measures not yet in 

widespread use that affects local governments deemed 

appropriate.

5) Alternative fuel and diesel retrofit programs for fleet vehicle 

operations. 

6) Require VOC or NOx emission offsets for new and modified major 

sources. 

7) Require VOC or NOx emission offsets for new and modified minor 

sources. 

8) Increase the ratio of emission offsets required for new sources. 

9) Require VOC or NOx controls on new minor sources (less than 100 

tons). 

10) Adopt NOx RACT for existing combustion sources. 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

benefits of individual measures, at the time they are under consideration, can 

be fully evaluated. 
 40 

Requirement 4 of 4

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

requirements. 

Demonstration

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

controls. 

NOx RACT 

• EGUs 

• asphalt batching plants 

• industrial/commercial and institutional boilers 

• process heaters 

• internal combustion engines 

• combustion turbines 

• other sources greater than 100 tons per year 

VOC RACT 

• architectural and industrial maintenance coatings 

• automobile refinishing shops 

• cold cleaner degreasers 

• synthetic organic compound manufacturing 

• organic compound batch processes 

• wood manufacturing 

• industrial wastewater 

• aerospace industry 

• bakeries 

• plastic parts coating 

• volatile organic liquid storage 

• industrial solvent cleaning 

• offset lithography 

• industrial surface coating 

• other sources greater than 50 tons per year 
 41 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment 

concerning the draft redesignation petition and maintenance plan in a widely distributed 

newspaper in the area. 

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

23, 2012, at 3:30pm at 2110 East Aurora Road Twinsburg, Ohio. The public comment 

period closed on October 23, 2012. No comments were received during the public 

comment period and no testimony was provided at the hearing. Appendix E includes a 

copy of the public notice and hearing transcript. 
 42 

CHAPTER EIGHT 

CONCLUSIONS

The Cleveland - Akron – Lorain ozone nonattainment area has attained the 1997 NAAQS 

for ozone and complied with the applicable provisions of the 1990 Amendments to the CAA 

regarding redesignations of ozone nonattainment areas. Documentation to that effect is 

contained herein. Ohio EPA has prepared a redesignation request and maintenance plan 

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

Based on this presentation, the Cleveland - Akron – Lorain ozone nonattainment area 

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

has performed an analysis that shows the air quality improvements are due to permanent 

and enforceable measures. Furthermore, because this area is subject to significant 

transport of pollutants, significant regional NOx reductions will ensure continued compliance 

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

The State of Ohio hereby requests that the Cleveland - Akron – Lorain ozone 

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

of maintenance plan provisions contained herein. In addition, the State of Ohio requests 

that this maintenance plan satisfy the requirements of CAA Section 175A (b), for 

subsequent plan revisions required for areas redesignated for the one-hour ozone 

standard, as was the case with the Cleveland - Akron – Lorain ozone nonattainment area. 
This page left intentionally blank
Technical Memorandum 

Northeast Ohio (AMATS, NOACA, Ashtabula) 

1997 8-hr Ozone NAAQS Maintenance SIP Inventory 

Mobile Source Emissions (VOC and NOx) 

September 2012 

By AMATS, NOACA and ODOT 

In Coordination with the Ohio Environmental Protection Agency 

 
Table of Contents 

1. Overview ............................................................................................................... 1 

2. Urban Travel Demand Models ............................................................................. 5

3. Emission Factor Generation ................................................................................. 5

4. Post Processing ................................................................................................... 21

5. Multiple MPO Coordination Issues .................................................................... 23

Appendix A Interagency Consultation Documentation 

Appendix B Post Processing Default Distributions 
1 

1. Overview 

This memorandum is intended to document the USEPA MOVES based mobile source air quality 

analyses performed by the Ohio Department of Transportation (ODOT) for the Akron 

Metropolitan Area Transportation Study (AMATS) and Ashtabula county areas, and by the 

Northeast Ohio Areawide Coordinating Agency for the counties of Cuyahoga, Geauga, Lake, 

Lorain and Medina in its area. These analyses were conducted in support of Ohio EPA’s intent 

to update State Implementation Plan (SIP) maintenance budgets for the 1997 8-hr Ozone 

NAAQS. 

The designated maintenance area in northeast Ohio for the 1997 8-hr Ozone NAAQS includes 

the counties of Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and Summit; and Ashtabula. 

Ohio EPA intends to submit a SIP update to USEPA using the Motor Vehicle Emission 

Simulator (MOVES). 

The inventories include county based, annual totals of Volatile Organic Compounds (VOC’s) 

and Oxides of Nitrogen (NOX) for the base year 2002, attainment year 2006, the interim budget 

year 2012, and the maintenance budget year 2020. 

Latest Planning Assumptions 

These ozone inventory runs meet the latest planning assumption requirement. As discussed in 

Section 2 of this report, the travel forecast modeling processes used to develop vehicle miles of 

travel (VMT) for the AMATS and NOACA areas is calibrated using the latest population and 

land use data available and are validated using corresponding traffic count data. Currently, the 

travel demand models are validated to year 2005. 

U.S. EPA’s most recent emissions software, MOVES, is used for all mobile source emission 

analyses with MOVES input and output needs being established at various interagency 

consultation meetings and e-mails between January 2012 and April 2012 (See Appendix A). It 

was also established that annual emission estimates would be based on a single-season approach. 

The emissions estimates are expressed in tons per day. 

Finally, the regional emissions analysis includes emissions for Volatile Organic Compounds 

(VOCs), and Oxides of Nitrogen (NOX). 
2 

On Road Mobile Source Emissions Inventory Summary Tables 1 to 4 present a summary of emissions by county as well as the entire maintenance area for VOCs, and NO

2002, 2006, 2012, and 2020. They also include average summer day VMT’s. The remainder of this document foassumptions behind the analyses. 

Table 1 – Northeast Ohio On-Road Mobile Source Emissions 

2002 Base 

COUNTY VOC (tons/day) NOx (tons/day) Daily VMT (miles/dAshtabula 5.00 11.29 3,178Cuyahoga 62.92 128.84 29,297Geauga 6.06 13.47 2,567Lake 13.28 29.59 5,738Lorain 16.56 34.23 6,972Medina 12.34 36.39 5,888Portage 8.26 17.17 4,782Summit 30.58 60.43 15,788

TOTAL 155.00 331.42 74,214
3 

Table 2 – Northeast Ohio On-Road Mobile Source Emissions 

2006 Attainment 

COUNTY VOC (tons/day) NOx (tons/day) Daily VMT (miles/daAshtabula 4.17 9.04 3,075,2Cuyahoga 48.61 104.67 29,378,8Geauga 5.10 11.85 2,698,5Lake 10.87 25.93 5,889,0Lorain 13.59 29.89 7,088,3Medina 10.52 32.52 6,165,3Portage 6.95 14.83 5,186,0Summit 21.78 45.49 16,213,2

TOTAL 121.59 274.21 75,694,8

Table 3 – Northeast Ohio On-Road Mobile Source Emissions 

2012 Interim 

COUNTY VOC (tons/day) NOx (tons/day) Daily VMT (miles/daAshtabula 2.59 5.20 3,120,7Cuyahoga 26.65 61.07 31,395,9Geauga 2.88 7.63 2,796,3Lake 6.33 16.62 6,329,0Lorain 8.02 19.15 7,294,9Medina 6.51 21.53 6,268,8Portage 4.39 8.81 5,108,0Summit 13.53 24.57 15,612,5

TOTAL 70.90 164.56 77,926,4
4 

Table 4 – Northeast Ohio On-Road Mobile Source Emissions 

2020 Maintenance 

COUNTY VOC (tons/day) NOx (tons/day) Daily VMT (miles/daAshtabula 1.38 2.28 3,335,6Cuyahoga 13.60 33.73 35,342,8Geauga 1.74 5.37 3,090,9Lake 3.42 10.62 7,227,2Lorain 4.28 12.01 8,238,1Medina 3.73 14.98 7,564,9Portage 2.37 3.89 5,499,2Summit 7.02 11.35 16,443,6

TOTAL 37.55 94.22 86,742,7
5 

2. Urban Travel Demand Models

NOACA maintains a PC-based regional travel demand forecasting model on the Citilabs CUBE 

platform for use in its urban transportation planning process. This model employs the traditional 

four step modeling process to project existing and future traffic volumes and travel patterns on 

the regional transportation networks. The four step process consists of trip generation, trip 

distribution, mode split, and route assignment. Output from the model is link-by-link directional 

volumes for four time periods: AM peak, Midday, PM peak, and Night and is added together to 

create 24-hour traffic volumes for the existing or future regional transportation networks. 

The Ohio Department of Transportation (ODOT) holds the transportation model for the AMATS 

area. AMATS prepares and submits networks for its planning area to ODOT. ODOT prepares 

networks for Ashtabula County. ODOT's modeling is also run on a PC-based CUBE platform. 

These models are uniquely suited to perform emission analyses. The modeling process identifies 

growth in vehicle miles of travel and changes in regional travel patterns resulting from the 

projects that are proposed in these areas’ transportation plans and programs. 

Detailed information about NOACA’s travel demand forecast model can be found here: 

http://www.noaca.org/traveldemandmemo.pdf

Landuse and Socio-economic Data 

The areas’ socio-economic model variables reflect the current and expected future regional land 

uses as best known to staff. 

Socio-economic variables were developed for all areas based on 2000 Census data and 2030 

county-level Ohio Department of Development population projections. Minor adjustments to 

2005 data have been made in an effort to have this data correspond to 2005 estimates released by 

the US Census Bureau. 

 

Until new 2010 Census based projections are developed by the Ohio Department of 

Development (ODOD), the current data represents the best available for this effort. 

3. Emission Factor Generation

Using MOVES, emission factor files were generated for base year 2002, attainment year 2006, 

interim year 2012, and maintenance year 2020. Assumptions for these runs include an I/M 

program in all but Ashtabula Township. Programs and corresponding MOVES parameters were 

developed in consultation with OEPA. 
6 

Technical Details 

Table 5 summarizes the settings used in the MOVES run specification file and the MOVES 

County-Data Manager. All inputs for the region’s analyses are included in the CD provided to 

Ohio EPA as part of this document submittal. Further information about specific inputs that are 

not using default values is also discussed below. 

Table 5 – MOVES Inputs 

RunSpec Parameter Settings 

MOVES Version 2010/08/26 

Scale County 

MOVES Modeling Technique Emission Factor Method 

Rates per Distance 

Rates per Vehicle 

Time Span Time Aggregation: Hour 

1 Month representing average annual temperatures 

All hours of day selected 

16 speed bins 

Weekdays only 

Geographic Bounds Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage 

and Summit Counties 

Vehicles/Equipment All related source types, gasoline and diesel; CNG-Transit 

Buses for base year 2002 & attainment year 2006 

Road Type All road types including off-network 

Pollutants and Processes Total Gaseous Hydrocarbons, Non-Methane Hydrocarbons, 

Volitile Organic Compounds, NOx

Strategies Alternative Vehicle Fuels and Technologies for interim year 

2012, and maintenance year 2020 to offset impact of CNG 

General Output Units = grams, joules and miles 

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

type and source use type. 

Advance Performance None 

County Data Manager Sources 

Source Type Population Combination of local and default data 

Local BMV Vehicle Registration Total 

Local BMV population for motorcycle (11), moped (11), bus 

(41, 42,43), mobile home (54), house vehicle (54) 

MOVES default fractions for the rest (21,31,32,51,52,53,61,62) 

Future year growth rate based on TFM’s household growth rates. 
7 

Vehicle Type VMT Travel Demand Forecast Model’s daily VMT 

EPA annual VMT converter 

Hourly VMT fractions - ODOT Hourly Percentage 

I/M Program I/M program information supplied by Ohio EPA 

Fuel Formulation Default 

Fuel Supply Default 

Metereology Data Local data obtained from NOAA National Climatic Data Center. 

Data will consist of monthly high and low temperatures and 

daily relative humidity for 2006. 

Ramp Fraction Travel Demand Forecast Model 

Road Type Distribution ODOT’s 2006 DVMT by FC 

Age Distribution Local data ODOT from 2009 motor vehicle registration 

The same age distribution will be used for all analysis years 

Average Speed Distribution Default as a place holder 

Zone Activity Default with necessary modification as prescribed in MOVES 

userguide. 
8 

Temperature and Relative Humidity 

Temperatures used for the single season approach are representative of 12 months in 2006 based 

on NOAA data from the National Climate Data Center website. The month of July was used as 

the representative month. Data for Cleveland Hopkins International Airport (CLE) was used for 

NOACA’s area. Data for Akron-Canton Airport (CAK) was used for AMATS and Ashtabula 

Areas. To get the correct fomat for MOVES, the data was entered into a spreadsheet provided 

by EPA which was designed to convert Mobile6 data to MOVES. The average annual hourly 

temperature and relative humidity distribution profile for Cuyahoga, Lake, Lorain, and Medina 

Counties can be seen in Table 6a. Table 6b portrays the data for Portage and Summit Counties; 

and Ashtabula. 

Table 6a – Temperature and Relative Humidity Data for NOACA portion of area

Hour Average Temperature 

Average 

Relative Humidity 

1 71.0 77.0 

2 70.0 79.0 

3 69.0 81.0 

4 68.0 82.0 

5 68.0 83.0 

6 68.0 83.0 

7 71.0 78.0 

8 74.0 72.0 

9 77.0 65.0 

10 80.0 60.0 

11 81.0 56.0 

12 82.0 55.0 

13 82.0 54.0 

14 83.0 51.0 

15 83.0 50.0 

16 83.0 50.0 

17 82.0 51.0 

18 82.0 52.0 

19 80.0 56.0 

20 78.0 60.0 

21 75.0 66.0 

22 74.0 69.0 

23 72.0 73.0 

24 71.0 76.0 

 
9 

Table 6b – Temperature and Relative Humidity Data for AMATS portion of area

Hour Average Temperature Average 

Relative Humidity 

1 44.90333333 76 

2 43.77166667 78 

3 42.8825 79 

4 42.23583333 81 

5 41.75083333 82 

6 41.185 83 

7 40.7 82 

8 41.10416667 79 

9 43.52916667 74 

10 47.40916667 71 

11 51.37 68 

12 54.765 63 

13 57.75583333 61 

14 59.3725 58 

15 59.93833333 56 

16 60.1 55 

17 59.69583333 57 

18 58.56416667 60 

19 56.62416667 65 

20 54.11833333 69 

21 51.6125 71 

22 49.43 73 

23 47.89416667 74 

 
10 

Ramp Fraction 

Ramp fractions were derived using the base year travel demand model VHT fractions. Ramp 

fractions can be seen in Table 7. Base year fractions were kept the same for future years. 

Table 7 – Ramp Fractions 

County roadTypeID roadDesc rampFraction 

Ashtabula 2 Rural Restricted Access 0.010 

4 Urban Restricted Access 0.180 

Cuyahoga 2 Rural Restricted Access 0 

4 Urban Restricted Access 0.116 

Geauga 2 Rural Restricted Access 0.061 

4 Urban Restricted Access 0.061 

Lake 2 Rural Restricted Access 0.092 

4 Urban Restricted Access 0.092 

Lorain 2 Rural Restricted Access 0.107 

4 Urban Restricted Access 0.107 

Medina 2 Rural Restricted Access 0.058 

4 Urban Restricted Access 0.058 

Portage 2 Rural Restricted Access 0.010 

4 Urban Restricted Access 0.180 

Summit 2 Rural Restricted Access 0.010 

4 Urban Restricted Access 0.009 
11 

Source Type Population Source type population is based on a combination of local and MOVES default data. Local data was obtained froMotor Vehicles Motor Vehicle Registrations by county and vehicle type for the base year 2002 & attainment yeadefault source type population data was obtained from the national level MOVES inventory runs for each county

OBMV’s vehicle registration data was used as a control total for all source type population and a sub total for IntTransit Bus (42), and School Bus (43). The same data was also used to assign source type population of Motorcy

Home (54). For the rest of source types 21, 31, 32, 51, 52, 53, 61 and 62, the fraction of each source type from thdata was used and adjusted to match up the control total for source type population. Future year source type growtravel demand model’s annual household growth rate from year 2005 to year 2022 for corresponding analysis yesource type population for the analyzed counties in 2006. 

Table 8 – Source Type Population for year 2006 

sourceTypeID sourceTypeName Cuyahoga Geauga Lake Lorain Medina Portage Su

11 Motorcycle 25,638 3,931 8,082 10,893 7,097 7,194 121 Passenger Car 561,351 50,481 118,570 146,537 87,913 84,557 2631 Passenger Truck 367,186 35,709 78,318 97,335 60,304 60,467 1832 Light Commercial Truck 122,671 11,930 26,165 32,518 20,146 2,425 41 Intercity Bus 377 14 65 32 16 33 42 Transit Bus 208 8 36 17 9 17 43 School Bus 2,595 95 446 217 113 199 51 Refuse truck 307 47 72 91 72 64 52 Single Unit Short-haul Truck 17,525 2,669 4,094 5,177 4,114 2,664 53 Single Unit Long-haul Truck 1,894 288 442 559 445 340 54 Motor Home 4,916 1,385 2,100 4,399 2,628 2,549 61 Comb Short-haul Truck 3,781 496 1,058 1,098 1,358 1,289 62 Comb Long-haul Truck 4,073 535 1,139 1,182 1,463 1,483 
12 

I/M Program 

I/M program information was supplied by Ohio EPA. The I/M program was applied to all 

analysis years for every geography with the exception of Ashtabula County. The I/M program 

MOVES inputs reflect: 

1) ASM 2525 Phase-in Cutpoints, for model years up to 1995 

2) Evaporative Gas Cap Check, for model years up to 1995 

3) Evaporative System OBD Check, for model years 1996 & newer 

4) Exhaust OBD Check, for model years 1996 & newer 

The compliance rate and failure rates are obtained from Ohio EPA and compliance factors are 

calculated. These are applied to Cuyahoga, Geauga, Lake, Lorain, Medina, Portage & Summit 

counties and for all model years. 

Vehicle Age Distribution 

Vehicle age distribution information was derived using ODPS vehicle registration data (2009). 

The data was given to OEPA who supplied a VIN decoder that allowed ODOT to create 

correctly formatted MOVES inputs. A different age distribution file is used for each county. 

Table 9 provides a sample distribution for Cuyahoga County. The distributions for other areas 

can be found in the electronic input submittals. The same age distributions were used for all 

analysis years. 
13 

Table 9 – Vehicle Age Distribution for 

Cuyahoga County 

yearid

sourcetypei d ageidageFractio n

2006 11 30 0.106925

2006 11 29 0.018783

2006 11 28 0.026115

2006 11 27 0.014845

2006 11 26 0.011632

2006 11 25 0.01317

2006 11 24 0.014596

2006 11 23 0.00998

2006 11 22 0.007536

2006 11 21 0.009369

2006 11 20 0.009074

2006 11 19 0.008758

2006 11 18 0.010636

2006 11 17 0.013827

2006 11 16 0.017312

2006 11 15 0.021

2006 11 14 0.02272

2006 11 13 0.021951

2006 11 12 0.02582

2006 11 11 0.03761

2006 11 10 0.044965

2006 119 0.05413

2006 118 0.060081

2006 117 0.075515

2006 116 0.063725

2006 115 0.066418

2006 114 0.076963

2006 113 0.068658

2006 112 0.044852

2006 111 0.021362

2006 110 0.001675

2006 21 30 0.031927

2006 21 29 0.001002

2006 21 28 0.001082

2006 21 27 0.001608

2006 21 26 0.002483

2006 21 25 0.003053

2006 21 24 0.003691

2006 21 23 0.005082

2006 21 22 0.006714

2006 21 21 0.010246

2006 21 20 0.013223

2006 21 19 0.017294

2006 21 18 0.023152

2006 21 17 0.028475

2006 21 16 0.034352

2006 21 15 0.044328

2006 21 14 0.040195

2006 21 13 0.048119

2006 21 12 0.050547

2006 21 11 0.056333

2006 21 10 0.057401

2006 219 0.054497

2006 218 0.058427

2006 217 0.059745

2006 216 0.059884

2006 215 0.060329

2006 214 0.058016

2006 213 0.060513

2006 212 0.05262

2006 211 0.04119

2006 210 0.014472

2006 31 30 0.002999

2006 31 29 0.000209

2006 31 28 0.000285

2006 31 27 0.000524

2006 31 26 0.000797

2006 31 25 0.001189

2006 31 24 0.001723

2006 31 23 0.002477

2006 31 22 0.003177

2006 31 21 0.00491

2006 31 20 0.006233

2006 31 19 0.008686

2006 31 18 0.011764

2006 31 17 0.02159

2006 31 16 0.026281

2006 31 15 0.03281
14 

2006 31 14 0.031973

2006 31 13 0.036449

2006 31 12 0.043884

2006 31 11 0.049373

2006 31 10 0.053384

2006 319 0.052496

2006 318 0.068594

2006 317 0.073487

2006 316 0.079743

2006 315 0.092016

2006 314 0.082702

2006 313 0.07979

2006 312 0.07549

2006 311 0.04345

2006 310 0.011516

2006 32 30 0.006296

2006 32 29 0.000508

2006 32 28 0.000914

2006 32 27 0.001219

2006 32 26 0.002844

2006 32 25 0.002945

2006 32 24 0.002945

2006 32 23 0.004367

2006 32 22 0.005078

2006 32 21 0.008531

2006 32 20 0.010358

2006 32 19 0.009851

2006 32 18 0.014522

2006 32 17 0.024576

2006 32 16 0.03727

2006 32 15 0.054737

2006 32 14 0.036458

2006 32 13 0.043668

2006 32 12 0.041637

2006 32 11 0.048746

2006 32 10 0.055753

2006 329 0.040317

2006 328 0.038997

2006 327 0.03788

2006 326 0.029349

2006 325 0.029958

2006 324 0.086016

2006 323 0.091398

2006 322 0.13923

2006 321 0.063166

2006 320 0.030466

2006 41 30 0.002855

2006 41 29 0.001428

2006 41 28 0.001428

2006 41 27 0.001428

2006 41 26 0.000714

2006 41 25 0.00571

2006 41 240

2006 41 23 0.003569

2006 41 22 0.009279

2006 41 21 0.003569

2006 41 20 0.007852

2006 41 19 0.010707

2006 41 18 0.017131

2006 41 17 0.009993

2006 41 16 0.009279

2006 41 15 0.0207

2006 41 14 0.019986

2006 41 13 0.0207

2006 41 12 0.024982

2006 41 11 0.042827

2006 41 10 0.071378

2006 419 0.06424

2006 418 0.059957

2006 417 0.097787

2006 416 0.114918

2006 415 0.063526

2006 414 0.114918

2006 413 0.086367

2006 412 0.044254

2006 411 0.068522

2006 4100

2006 42 30 0.010638

2006 42 290

2006 42 280

2006 42 270

2006 42 26 0.005319
15 

2006 42 250

2006 42 240

2006 42 230

2006 42 220

2006 42 21 0.005319

2006 42 200

2006 42 190

2006 42 180

2006 42 170

2006 42 16 0.021277

2006 42 15 0.005319

2006 42 14 0.010638

2006 42 13 0.005319

2006 42 12 0.047872

2006 42 11 0.079787

2006 42 10 0.026596

2006 429 0.058511

2006 428 0.079787

2006 427 0.079787

2006 426 0.079787

2006 425 0.074468

2006 424 0.170213

2006 423 0.074468

2006 422 0.12766

2006 421 0.037234

2006 4200

2006 43 30 0.000585

2006 43 290

2006 43 280

2006 43 27 0.001171

2006 43 26 0.001171

2006 43 25 0.005855

2006 43 24 0.002342

2006 43 23 0.007611

2006 43 22 0.008197

2006 43 21 0.005855

2006 43 20 0.008197

2006 43 19 0.014052

2006 43 18 0.007611

2006 43 17 0.009368

2006 43 16 0.009953

2006 43 15 0.011124

2006 43 14 0.010539

2006 43 13 0.044496

2006 43 12 0.050937

2006 43 11 0.088993

2006 43 10 0.104801

2006 439 0.067916

2006 438 0.100703

2006 437 0.058548

2006 436 0.050351

2006 435 0.052693

2006 434 0.052693

2006 433 0.0726

2006 432 0.049766

2006 431 0.059719

2006 430 0.042155

2006 51 30 0.014851

2006 51 29 0.002475

2006 51 280

2006 51 270

2006 51 260

2006 51 25 0.002475

2006 51 24 0.00495

2006 51 23 0.012376

2006 51 220

2006 51 21 0.00495

2006 51 20 0.00495

2006 51 19 0.00495

2006 51 18 0.007426

2006 51 17 0.012376

2006 51 16 0.024752

2006 51 15 0.066832

2006 51 14 0.044554

2006 51 13 0.027228

2006 51 12 0.044554

2006 51 11 0.027228

2006 51 10 0.044554

2006 519 0.044554

2006 518 0.059406

2006 517 0.09901

2006 516 0.032178
16 

2006 515 0.071782

2006 514 0.128713

2006 513 0.071782

2006 512 0.094059

2006 511 0.04703

2006 5100

2006 52 30 0.014851

2006 52 29 0.002475

2006 52 280

2006 52 270

2006 52 260

2006 52 25 0.002475

2006 52 24 0.00495

2006 52 23 0.012376

2006 52 220

2006 52 21 0.00495

2006 52 20 0.00495

2006 52 19 0.00495

2006 52 18 0.007426

2006 52 17 0.012376

2006 52 16 0.024752

2006 52 15 0.066832

2006 52 14 0.044554

2006 52 13 0.027228

2006 52 12 0.044554

2006 52 11 0.027228

2006 52 10 0.044554

2006 529 0.044554

2006 528 0.059406

2006 527 0.09901

2006 526 0.032178

2006 525 0.071782

2006 524 0.128713

2006 523 0.071782

2006 522 0.094059

2006 521 0.04703

2006 5200

2006 53 30 0.096774

2006 53 290

2006 53 280

2006 53 270

2006 53 26 0.064516

2006 53 25 0.032258

2006 53 24 0.032258

2006 53 23 0.032258

2006 53 22 0.064516

2006 53 21 0.032258

2006 53 20 0.064516

2006 53 19 0.032258

2006 53 180

2006 53 17 0.032258

2006 53 16 0.064516

2006 53 15 0.032258

2006 53 14 0.193548

2006 53 13 0.096774

2006 53 12 0.064516

2006 53 110

2006 53 100

2006 5390

2006 5380

2006 5370

2006 536 0.032258

2006 5350

2006 5340

2006 5330

2006 5320

2006 5310

2006 530 0.032258

2006 54 30 0.155541

2006 54 29 0.007973

2006 54 28 0.012568

2006 54 27 0.014595

2006 54 26 0.023378

2006 54 25 0.021622

2006 54 24 0.02473

2006 54 23 0.024865

2006 54 22 0.026486

2006 54 21 0.028514

2006 54 20 0.023649

2006 54 19 0.017838

2006 54 18 0.023514

2006 54 17 0.027568
17 

2006 54 16 0.032432

2006 54 15 0.037838

2006 54 14 0.032973

2006 54 13 0.034054

2006 54 12 0.036351

2006 54 11 0.045

2006 54 10 0.045811

2006 549 0.032297

2006 548 0.034595

2006 547 0.037027

2006 546 0.038378

2006 545 0.039054

2006 544 0.039595

2006 543 0.034595

2006 542 0.028784

2006 541 0.014865

2006 540 0.003514

2006 61 30 0.026394

2006 61 29 0.001795

2006 61 28 0.001969

2006 61 27 0.0027

2006 61 26 0.004162

2006 61 25 0.005771

2006 61 24 0.007714

2006 61 23 0.007951

2006 61 22 0.01355

2006 61 21 0.017698

2006 61 20 0.017692

2006 61 19 0.018667

2006 61 18 0.023951

2006 61 17 0.030517

2006 61 16 0.044041

2006 61 15 0.043611

2006 61 14 0.038558

2006 61 13 0.047786

2006 61 12 0.044426

2006 61 11 0.056475

2006 61 10 0.062624

2006 619 0.052544

2006 618 0.054525

2006 617 0.065875

2006 616 0.064946

2006 615 0.065997

2006 614 0.06129

2006 613 0.052723

2006 612 0.042316

2006 611 0.018436

2006 610 0.003296

2006 62 30 0.001821

2006 62 290

2006 62 280

2006 62 27 0.00091

2006 62 26 0.000759

2006 62 25 0.002731

2006 62 24 0.001517

2006 62 23 0.001972

2006 62 22 0.00349

2006 62 21 0.005159

2006 62 20 0.0044

2006 62 19 0.003945

2006 62 18 0.007131

2006 62 17 0.016083

2006 62 16 0.021393

2006 62 15 0.028827

2006 62 14 0.034593

2006 62 13 0.025338

2006 62 12 0.059172

2006 62 11 0.080413

2006 62 10 0.107419

2006 629 0.075861

2006 628 0.04582

2006 627 0.047944

2006 626 0.099833

2006 625 0.090882

2006 624 0.057047

2006 623 0.112729

2006 622 0.017145

2006 621 0.038993

2006 620 0.006676
18 

Road Type Distribution 

Road type distribution is based on the ODOT’s 2006 daily vehicle miles of travel (DVMT) by 

functional classification (FC). These inputs vary by county. A sample road type distribution 

input for Cuyahoga County can be seen in Table 10. Cuyahoga County does not contain rural 

road types 2 and 3. The distributions for other areas can be found in the electronic input 

submittals. 

 

Table 10 – Road Type Distribution for Cuyahoga County 

sourceTypeI

D 

roadTypeI

D 

roadTypeVMTFract

ion 

11 1 0

11 2 0

11 3 0

11 4 0.47072

11 5 0.52928

21 1 0

21 2 0

21 3 0

21 4 0.47072

21 5 0.52928

31 1 0

31 2 0

31 3 0

31 4 0.47072

31 5 0.52928

32 1 0

32 2 0

32 3 0

32 4 0.47072

32 5 0.52928

41 1 0

41 2 0

41 3 0

41 4 0.47072

41 5 0.52928

42 1 0

42 2 0

42 3 0

42 4 0.47072

42 5 0.52928

43 1 0

43 2 0

43 3 0

43 4 0.47072

43 5 0.52928

51 1 0

51 2 0

51 3 0

51 4 0.47072

51 5 0.52928

52 1 0

52 2 0

52 3 0

52 4 0.47072

52 5 0.52928

53 1 0

53 2 0

53 3 0

53 4 0.47072

53 5 0.52928

54 1 0

54 2 0

54 3 0

54 4 0.47072

54 5 0.52928

61 1 0

61 2 0

61 3 0

61 4 0.47072

61 5 0.52928

62 1 0

62 2 0

62 3 0

62 4 0.47072

62 5 0.52928
19 

Vehicle Type VMT and VMT Fractions

VMT by MOVES vehicle types is subdivided into four sections namely HPMS base year VMT, 

monthly VMT fractions, daily VMT fractions and hourly VMT fractions. For NOACA’s 

counties, HPMS base year VMT was derived by using the converter tool, US EPA’s AADVMT 

Calculator_HPMS.xls. The converter takes average annual daily VMT (AADVMT) and 

generates MOVES input data based on default factors. AADVMT is computed by using total 

daily VMT obtained from travel demand model and fractioning it with the MOVES default 

distance travelled by each source type to come up vehicle type VMTs. The same method was 

used to generate data for other analysis years. 

ODOT uses weigh in motion (WIM) data to develop inputs for the counties it models. The 

inputs for each geographic area can be seen in the supplied input files. Sample HPMS VMT for 

2006 is provided in Table 11. 

Table 11 – Yearly HPMS VMT for 2006 

HPMS 

VType ID Cuyahoga Geauga Lake Lorain 

10 36,279,066 3,579,545 7,368,124 8,813,331 

20 5,393,830,829 465,757,651 1,063,615,481 1,285,052,331 

30 3,355,271,802 313,217,056 667,810,586 811,206,625 

40 13,433,997 2,917,998 3,199,949 4,083,872 

50 207,639,389 30,311,606 45,080,548 55,677,744 

60 308,438,715 38,801,503 79,624,414 81,166,499 

HPMS 

VType 

ID 

Medina Portage Summit Ashtabula 

10 8,039,568 7,033,066 22,040,247 4,172,818 

20 1,054,314,702 1,254,291,780 3,930,704,234 744,189,232 

30 687,173,536 387,008,969 1,212,810,142 229,617,950 

40 5,307,954 3,955,747 12,396,534 2,347,001 

50 60,452,301 29,243,117 91,642,188 17,350,359 

60 136,727,415 69,428,531 217,575,389 41,192,939 
20 

Output Emission Factors 

Table 12 shows the first record in a MOVES sample output (rate per distance) emission file for 

year 2006. For any given month, day of week, hour of the day, pollutant, and process; the rate 

per distance varies by road type, and speed bin. Rates per distance emissions are applied to link 

and intrazonal VMT. 

Table 12 – Sample Emission File (Rate per Distance) for year 2006 

Heading: MOVESScenarioID MOVESRunID yearID monthID dayID hourID 

Record: Cuyahoga 1 2006 7 5 1 

Heading: linkID pollutantID processID sourceTypeID SCC fuelTypeID 

Record: 9.9E+08 87 11 54 0 

Heading: modelYearID roadTypeID avgSpeedBinID temperature relHumidity ratePerDistance 

Record: 0 5 3 68 82 0.02331 

Table 13 shows the first record in a MOVES sample output (rate per vehicle) emission file for 

year 2006. The rate per vehicle varies for any combinations of month, day of week, hour of the 

day, pollutant, and process. Rates per vehicle emissions are applied to the vehicle souce type 

population. 

Table 13 – Sample Emission File (Rate per Vehicle) for year 2006 

Heading: MOVESScenarioID MOVESRunID yearID monthID dayID 

Record: Cuyahoga 1 2006 7 5 

Heading: hourID zoneID pollutantID processID sourceTypeID 

Record: 1 990180 1 2 11 

Heading: SCC fuelTypeID modelYearID temperature ratePerVehicle 

Record: 0 0 71 0.002892 

Table 14 shows the first record in a MOVES sample output (rate per profile) emission file for 

year 2006. The rate per vehicle varies for any combinations of month, day of week, hour of the 

day, pollutant, and process. Rates per vehicle emissions are applied to the vehicle source type 

population. 

Table 14 – Sample Emission File (Rate per Profile) for year 2006 

Heading: MOVESScenarioID MOVESRunID yearID monthID dayID 

Record: Cuyahoga 1 9.9E+09 2006 5 

Heading: hourID pollutantID processID sourceTypeID SCC 

Record: 1 12 11 

Heading: fuelTypeID modelYearID temperature ratePerVehicle 

Record: 0 0 71 0.008215 

All output files are available in the electronic submittal. 
21 

4. Post Processing

Total emissions were computed with the aid of several custom programs by ODOT. The process 

uses data on daily and directional traffic distributions as well as more up to date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process, described below and 

illustrated in Figure 4, also uses rewritten code able to handle the newer model network formats 

and MOVES generated emission factors. 

First step (movessource.exe) aggregates the emission factors. Rate per profile and rate per 

vehicle files are combined during this process. The resultant emission factor files contain 

emission factors broadly classified into total vehicles, cars and trucks by pollutant, by average 

speed, road type and hour of day. 

The second step in the the process involves running ODOT postcms.exe to calculate hourly link 

volumes based on the percentage of the daily volume (travel demand model output) determined 

by a link’s facility and area type. Link speeds from the travel demand model are not used in the 

analysis. The speeds are estimated as a post-process to the model based on HCM methods using 

a link’s volume-to-capacity ratio and link group code. The daily to hourly volume conversion 

percentages and speed tables can be seen in Appendix B. 

The third step (movesnet.exe) uses a combination of the MOVES emission factors and the hourly 

link volumes that are output of the postcms.exe program. The hourly volumes are multiplied by 

the MOVES emission factor for the corresponding hour of day, speed bin, and roadtype to 

calculate emissions for every network link for each hour. The final link on road vehicle 

emissions for the area is the sum of all individual link-hour emissions. 

The fourth step, (movesveh.exe), calculates vehicle-based emissions for each source type for 

each hour of the day. The vehicle source type is based on a combination of local and default 

data. The final vehicle emissions for each county are the sum of all individual hourly emissions 

for all vehicle types. 

Intrazonal trips do not get loaded onto the network, so the fifth step in the process requires a 

separate method to account for those trips that use local roads to travel within a zone. The 

movesintra.exe program uses intrazonal trips to estimate VMT using the area in square miles and 

intrazonal trips of each zone. The zone is assumed circular and the radius of the circle is used as 

the average trip length for these intrazonal trips. Intrazonal emissions are then calculated by 

combining MOVES generated emissions with estimated intrazonal VMT. The emission rates are 

the same as those used to calculated link based emissions. 

The final step is to summarize link, vehicle, and intrazonal emissions for each county, pollutant, 

and analyzed year. Summary emissions for each pollutant, county, and scenario year in 

northeast Ohio were previously displayed in tables 1-4. 
22 

Figure 4 – Emission Calculation Process

MOV

TFM

ODOT

CMAQ

NOACA

AQ

ODOT

MOVESNET

ODOT

MOVESINTRA

Emission Factors

Rate/Vehicle

24HR NET

Speed 

Calculator

LNKGRP

CMAQ NET

CMAQ Report

HOURLY.CSV

Intrazonal Trips 24HR Vehicle Trips 4 Periods Vehicle Trip Matrices

4 Periods 

Assigned NET

VHT

VMT

4 Congested 

SPEED

TAZ Area (Sq.mi)

2. ODOT’s CMAQ POS-PROCESSO T R

3. INTRASOZNAL TRIP CALCULATION 4. ODOT’s MOVES

POST-PROCESSOR

1. NOACA AQPOST-PROCESSOR

Ramp Fractions

Average

Speed Distribution

Road Type 

VMT fractions

Vehicle Type

Annual VMTs

Fuel supply & 

formulation

I/M Program

Age Distribution

Meteorology

Zone Activity Source Type Population

Emission Factors

Rate/Profile

MOVESSOURCE

ODOT

ODOT

MOVESVEH
23 

5. Multiple MPO Coordination Issues

AMATS, NOACA, ODOT, and OEPA have a long history of working together in air quality 

issues. All parties have had an opportunity to review and approve this summary document. 
Appendix A 

Interagency Consultation Documentation 
From: Brunello, Nino [mailto:Nino.Brunello@dot.state.oh.us] 

Sent: Friday, April 20, 2012 7:57 AM 

To: B Davis 

Cc: V Nemalapuri; E Kang 

Subject: RE: Ozone Summer Day Factors 

Yes, there is a way to adjust only the VMT. The Cube application GUI offers a growth factor selection of 

either 1.00 or 1.08. The application then generates a script to be executed where the adjustment factor is a 

variable. That variable can overwritten or hard-coded in the script.

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

Nino Brunello, P.E. 

Modeling & Forecasting Section 

Division of Planning 

Ohio Department of Transportation 

(614) 752-5742

From: B Davis [mailto:BDavis@mpo.noaca.org] 

Sent: Thursday, April 19, 2012 3:22 PM 

To: Durham, William F; krodi@eastgatecog.org; Brunello, Nino; PJividen@AkronOhio.gov; 

CBaker@akronohio.gov; Jeff Dutton; NGILL@morpc.org; aramirez@mvrpc.org; Saleem Salameh; 

tmazur@lacrpc.com; smapel@lcounty.com; randy.durst@movrc.org; sschmid@clarkcountyohio.gov; 

mikepap@bhjmpc.org; David Gedeon; rsharma@belomar.org

Cc: Dines, Jennifer; Morris.Patricia@epamail.epa.gov; Moore, Dave; Byram, Mark; John Getchey; Lisa 

Pompeo 

Subject: RE: Ozone Summer Day Factors 

 

NOACA concurs with the adjustment.

Any chance there is a way to adjust VMT without adjusting vehicle population? Excess evaporative 

emissions don’t belong in the photochemical grid models that are often one use for the outputs of these 

analyses. I guess the grid modelers could reduce evaporatives by 8% before they plug them in.

Bill Davis 

NOACA 

(216)-241-2414, Ext. 251

From: Durham, William F [mailto:William.F.Durham@wv.gov] 

Sent: Thursday, April 19, 2012 2:48 PM 

To: Kathleen Rodi; Brunello, Nino; PJividen@AkronOhio.gov; CBaker@akronohio.gov; Jeff Dutton; B 

Davis; NGILL@morpc.org; aramirez@mvrpc.org; Saleem Salameh; tmazur@lacrpc.com; 

smapel@lcounty.com; randy.durst@movrc.org; sschmid@clarkcountyohio.gov; mikepap@bhjmpc.org; 

David Gedeon; rsharma@belomar.org

Cc: Dines, Jennifer; Morris.Patricia@epamail.epa.gov; Moore, Dave; Byram, Mark; John Getchey; Lisa 

Pompeo 

Subject: RE: Ozone Summer Day Factors 

 

Nino:

I don’t object to factoring the vehicle population up, but I’m not sure the factor should be as high as the one 

historically used for VMT. The vehicle pop characterizes the vehicles operating in the domain, which 

relates to starts and diurnal/evap emissions. Factoring the vehicle pop up does seem to capture the increases 

in actual summer starts

but it may also artificially inflate the evap emissions. That may be O.K. as long as we’re conscious of it.

Fred

From: Kathleen Rodi [mailto:krodi@eastgatecog.org] 

Sent: Thursday, April 19, 2012 2:40 PM 
To: Brunello, Nino; PJividen@AkronOhio.gov; CBaker@akronohio.gov; Jeff Dutton; Bill Davis; Nick Gill 

(NGILL@morpc.org); aramirez@mvrpc.org; Saleem Salameh; Lima (tmazur@lacrpc.com); 

smapel@lcounty.com; 'randy.durst@movrc.org' (randy.durst@movrc.org); sschmid@clarkcountyohio.gov; 

mikepap@bhjmpc.org; David Gedeon; rsharma@belomar.org

Cc: Durham, William F; Dines, Jennifer; Patricia Morris (Morris.Patricia@epamail.epa.gov) 

(Morris.Patricia@epamail.epa.gov); Moore, Dave; Byram, Mark; John Getchey; Lisa Pompeo 

Subject: RE: Ozone Summer Day Factors 

 

We concur with the adjustment.

Kathleen

From: Brunello, Nino [mailto:Nino.Brunello@dot.state.oh.us] 

Sent: Thursday, April 19, 2012 2:30 PM 

To: PJividen@AkronOhio.gov; CBaker@akronohio.gov; Jeff Dutton; Bill Davis; Nick Gill 

(NGILL@morpc.org); aramirez@mvrpc.org; Saleem Salameh; Lima (tmazur@lacrpc.com); 

smapel@lcounty.com; 'randy.durst@movrc.org' (randy.durst@movrc.org); sschmid@clarkcountyohio.gov; 

mikepap@bhjmpc.org; David Gedeon; rsharma@belomar.org; Kathleen Rodi 

Cc: Fred Durham; Dines, Jennifer; Patricia Morris (Morris.Patricia@epamail.epa.gov) 

(Morris.Patricia@epamail.epa.gov); Moore, Dave; Byram, Mark 

Subject: FW: Ozone Summer Day Factors 

 

All:

After discussions with ODOT, OEPA, WVDEP, and USEPA, we are of the opinion that there needs to be 

an additional seasonal factor for summer when calculating ozone pollutants.

There is currently an adjustment for increasing average daily VMT (+ 8%) which was used in previously 

when using Moblie6 to generate emission factors. With MOVES, there is a vehicle component used in 

addition to VMT, so there needs to be an adjustment from average number of vehicles to the number of 

vehicles in summer day. We propose to use the same 8% increase.

We need to have an inter-agency agreement on this, and would prefer to do it via email (to make it easier 

on all of us). Please respond with your approval and/or questions.

Thanks,

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

Nino Brunello, P.E. 

Modeling & Forecasting Section 

Division of Planning 

Ohio Department of Transportation 

(614) 752-5742

From: Dines, Jennifer 

Sent: Thursday, April 12, 2012 9:04 AM 

To: Brunello, Nino; Durham, William F 

Cc: Moore, Dave 

Subject: RE: Ozone Summer Day Factors 

 

Nino and Fred, talked to Pat and she agrees that BOTH VMT and number of vehicles should have the 1.08 

factor applied.

Pat suggested we should have consultation on this. I told her ODOT is taking the lead on this project and 

I’d let Dave know........she says email is fine.

Thanks,
Jennifer Dines

Manager, State Implementation Plan and Rulemaking Section

Division of Air Pollution Control

Ohio Environmental Protection Agency

Wk (614) 644-3696 

Fax (614) 644-3681

From: Brunello, Nino 

Sent: Monday, April 09, 2012 12:59 PM 

To: Dines, Jennifer; Durham, William F 

Subject: RE: Ozone Summer Day Factors 

 

Jennifer/Fred,

There is another item that needs to be discussed. Since we now calculate emission rates for both VMT and 

number of vehicles, does there need to be a summer adjustment factors for vehicles as well? This was not 

done with MOBILE, so we have nothing to follow. If I had to guess, I would think that there would be an 

increase, but I couldn’t guess as to how many or what factor to use. Maybe just use 1.08 in absence of 

anything better? Thoughts?

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

Nino Brunello, P.E. 

Modeling & Forecasting Section 

Division of Planning 

Ohio Department of Transportation 

(614) 752-5742

 

From: Durham, William F [mailto:William.F.Durham@wv.gov] 

Sent: Friday, April 06, 2012 8:50 AM 

To: Brunello, Nino 

Cc: Dines, Jennifer 

Subject: Ozone Summer Day Factors 

 

Nino: 

I spoke with Jenn this morning and outlined the issue of Summer day VMT v. Average daily VMT. 

We agreed that Pat Morris may be able to shed some light on the question. 

Jenn & my calendars are open next Mon. and Tues. afternoon. Please give me a call & I’ll patch Jenn in. 

Fred 

**************************************************************************************

************** 

From: E Kang 

Sent: Tuesday, February 21, 2012 12:10 PM 

To: R Eckner; B Davis; G Grano 

Cc: V Nemalapuri 

Subject: Using truck vmts for MOVES post-processing 

Needs for truck model improvement and validation followed by truck counts can be discussed in two 

different context: SIP/Conformity and freight planning. 

1) OZONE SIP 
During a conference call with Nino last Friday, he notified us that ODOT’s MOVES post-processors are 

able to handle Vehicle class VMTs in two ways: 1) separate Auto and Truck VMTs, 2) combined VMTs as 

we did for PM SIP. 

In terms of using separate VMTs, Nino asked me the confidence level of truck vmts from model and 

suggested to test both ways. This will be the first time to test Truck VMTs with a purpose . 

 

From: V Nemalapuri 

Sent: Tuesday, February 07, 2012 10:16 AM 

To: nino.brunello@dot.state.oh.us

Cc: B Davis; G Grano; E Kang 

Subject: FW: 8-Hour Ozone SIP Budget Revisions 

Good Morning Nino,

 

We need to get started on ozone SIP budget revisions as mentioned in Dave Moore’s email. How about a 

kick off meeting? Let me know your availability. 

 

Thanks,

Vijay Krishna Nemalapuri

Northeast Ohio Areawide Coordinating Agency (NOACA)

1299 Superior Ave., Cleveland OH 44114

(216) 241-2414 x321

vnemalapuri@mpo.noaca.org

 

 

From: Moore, Dave [mailto:Dave.Moore1@dot.state.oh.us] 

Sent: Monday, January 30, 2012 9:18 AM 

To: aramirez@mvrpc.org; Andy Reser ; B Davis; Bob Muransky ; Curtis Baker ; Jeff Dutton ; 

krodi@eastgatecog.org; Lamar Daniel; Leigh Oesterling ; mhill@lcounty.com1; mikepap@bhjmpc.org; 

Nick Gill ; Phyllis Jividen ; Randy Durst; Saleem Salameh (ssalameh@intelos.net); 

sschmid@clarkcountyohio.gov; Thom Mazur ; henry@tmacog.org

Cc: Dines, Jennifer; Oesterling, Leigh; Byram, Mark; Brunello, Nino; Giaimo, Greg; Phinney, Scott; 

Granato, Sam; Anderson, Rebekah 

Subject: 8-Hour Ozone SIP Budget Revisions 

 

All, 

 

The current Ohio Ozone SIP budgets were developed using US EPA’s MOBILE software. Effective 

March 2, 2012 US EPA’s AQ software of record will be MOVES. Post March 2nd all new SIP and 

Transportation Conformity actions will be required to use MOVES. In order to assure ongoing positive 

Ohio MPO T-Plan/TIP conformity actions, the Ohio Ozone SIP budgets need updated to reflect MOVES 

outputs. 

 

Updating the Ozone SIP budgets to MOVES requires new MOVES based mobile emission inventories for 

the SIP attainment year and budget years, consistent with the attached pdf. Please contact your ODOT CO 

travel demand modeling liaison to coordinate needed transportation network, modeling runs, and emission 

factor post processing to establish these new SIP mobile emission inventories. Our goal is to submit the 

new inventories and documentation to OEPA on or before April 1, 2012. 

 

We have a working agreement with OEPA to establish SIP budgets, assuming sufficient safety margin is 

available, at 15% above the emission inventory. As you are developing the new MOVES based budget 

year inventories, it may be a good idea to compare the resulting inventories plus 15% to MOVES based TPlan interim and horizon year emissions as a check to assure positive future year conformity findings. 

 
Thanks 

DM 

************************************************************************************* 

-----Original Message----- 

From: Moore, Dave [mailto:Dave.Moore1@dot.state.oh.us] 

Sent: Friday, January 06, 2012 1:30 PM 

To: Byram, Mark; Brunello, Nino; Giaimo, Greg; Granato, Sam; Dines, Jennifer; aramirez@mvrpc.org; 

Andy Reser ; B Davis; Bob Muransky ; Curtis Baker ; Jeff Dutton ; krodi@eastgatecog.org; Lamar Daniel; 

Leigh Oesterling ; mhill@lcounty.com1; mikepap@bhjmpc.org; Nick Gill ; Phyllis Jividen ; Randy Durst; 

Saleem Salameh (ssalameh@intelos.net); sschmid@clarkcountyohio.gov; Thom Mazur ; 

henry@tmacog.org

Subject: FW: Ozone SIP updates 

All, 

See Pat Morris' message below regarding updating the Ohio Ozone SIP MOBILE based budgets to 

MOVES. Recall that MOVES is required to be used for SIP development and conformity determinations, 

effective March 2, 2012. A number of Ohio MPOs have quadrennial T-Plan/conformity determinations 

due in August, 2012. The existing Ozone SIP budgets need updated (US EPA Approval) to MOVES prior 

to initiating the conformity process on the Plan Updates. 

In order to provide sufficient lead time for OEPA and US EPA to complete their respective SIP Update 

processes and still provide plenty of time for the MPO conformity process, we collectively need get going, 

yesterday. 

Thanks 

DM 

-----Original Message----- 

From: Patricia Morris [mailto:Morris.Patricia@epamail.epa.gov] 

Sent: Thursday, January 05, 2012 11:18 AM 

To: Moore, Dave; Dines, Jennifer 

Subject: Ozone SIP updates 

Dave and Jen, 

 Something that was helpful to Indiana was a table of years that need to be updated for each of the 

Indiana ozone areas. 

I can put together a table for the Ohio areas too. 

There are several ways to update the ozone SIPs with MOVES budgets. One is to simply replace the 

MOBILE6 budgets with MOVES budgets in the old approved maintenance plan SIP. This requires that the 

monitored attainment year in the SIP and the budget years are modeled and replaced with MOVES 

emissions. For example, I have looked at Canton's approved ozone SIP (it is on the OEPA website) and 

2004 is the attainment year in the SIP and 2009 and 2018 are budget years. These are the years that would 

need new MOVES emissions numbers. You need to have the 2004 attainment year included so that safety 

margin can be allocated to the budget years. 

Question 7 of the Policy Guidance on the Use of MOVES2010 for State Implementation Plan 

Development, Transportation Conformity, and Other Purposes (PDF) (17 pp, 148K, EPA-420-B-09-046, 

December 2009) gives details of what needs to be addressed in the SIP revision. 

This type of a revision could be processed at our office in about 90 days from formal submission. 
Another option is do the the full 8-year maintenance plan update required by the Clean Air Act. Eight 

years after formal redesignation to attainment, a new maintenance plan is needed to extend the maintenance 

time frame out another 10 years. This update would not only update the earlier budgets with MOVES but 

would provide for 10 more years of maintenance. It would need to examine and project point and area 

source emissions. OAQPS has guidance on maintenance plan updates. 

This type of submittal would take up to 18 months to process at our office. 

I will start work on putting together a table of all the Ohio ozone areas and the years in the approved ozone 

maintenance plan, for each area, that will need to be modeled for the update to MOVES. 

Pat 

Patricia Morris 

Environmental Scientist 

USEPA Region 5 

(312) 353-8656 

morris.patricia@epa.gov
Appendix B 

Post Processing Default Distributions 
HOUR 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 

21 22 23 PCTADT URB FWY 0.9 0.6 0.5 0.6 0.9 2.2 5.2 7.3 6.4 5.2 4.9 5.1 5.3 5.5 6.1 7.2 8.0 2.9 2.2 1.5 URB ART 0.7 0.4 0.3 0.3 0.6 1.5 3.5 5.7 5.5 5.1 5.3 6.2 6.5 6.4 6.8 7.6 8.2 3.0 1.9 1.3 RUR FWY 1.4 1.1 0.9 1.0 1.3 2.2 3.7 5.2 5.4 5.4 5.6 5.6 5.7 6.0 6.5 7.1 7.5 3.2 2.5 2.0 RUR ART 0.8 0.5 0.4 0.5 1.0 2.4 4.8 6.2 5.5 5.3 5.5 5.8 6.0 6.0 6.7 7.6 8.1 2.8 1.9 1.3 PCTADT TRK URB FWY 2.1 1.9 1.8 2.0 2.4 3.0 3.9 4.6 5.3 6.0 6.3 6.4 6.4 6.4 6.3 5.8 5.2 3.1 2.8 2.4 URB ART 1.1 0.9 1.0 1.2 1.6 2.3 3.9 5.9 6.9 6.7 7.1 7.6 7.4 7.2 7.4 7.2 6.0 1.9 1.5 1.3 RUR FWY 2.6 2.2 2.1 2.3 2.6 3.1 3.5 4.0 4.5 5.1 5.6 5.8 5.8 5.8 5.8 5.6 5.3 3.8 3.5 3.1 RUR ART 1.5 1.3 1.4 1.6 2.2 3.0 4.2 5.3 6.1 6.7 7.0 7.1 7.0 6.9 6.8 6.3 5.5 2.3 2.1 1.7 PCTDIR URB FWY 38 40 40 46 56 64 70 70 68 62 58 52 52 52 50 46 38 42 42 40 URB ART 44 46 44 48 54 62 66 68 64 56 54 52 50 50 50 46 40 46 46 46 RUR FWY 44 46 48 54 60 68 68 64 58 54 52 50 50 52 52 48 42 44 46 44 RUR ART 40 42 44 48 58 66 72 68 60 56 54 50 50 50 50 46 40 44 44 44 LOS E VC 0 0.625 1.25 1.875 2.5 3.125 3.75 4.375 5 5.625 6.25 6.875 7.5 8.125 8.75 9.375 10 10.13.125 13.75 14.375 SPEEDVC curve1 75 75 75 75 75 75 74.9 74.8 74.6 74.2 73.5 72.3 70.5 67.8 64.2 59.5 54 423.7 19.2 15.5 curve2 70 70 70 70 70 70 70 69.9 69.8 69.6 69.2 68.4 67.1 65.1 62.2 58.2 53 22.2 17.6 13.8 curve3 65 65 65 65 65 65 65 65 65 64.9 64.8 64.4 63.8 62.6 60.5 57 52 416.7 12.1 8.6 curve4 60 60 60 60 60 60 60 60 60 59.9 59.8 59.6 59.1 58.2 56.7 54.3 50.8 421.3 16.2 12.2 curve5 55 55 55 55 55 55 55 55 55 55 55 54.9 54.7 54.3 53.6 52.3 50 421.9 16.1 11.5 curve6 60 60 60 60 60 60 60 60 59.9 59.8 59.7 59.4 59.1 58.5 57.7 56.5 55 541.1 37.3 33.4 curve7 55 55 55 55 55 55 55 55 54.9 54.9 54.7 54.5 54.2 53.8 53.1 52.2 50.9 439 35.7 32.2 curve8 50 50 50 50 50 50 50 50 49.9 49.9 49.8 49.6 49.4 49 48.5 47.7 46.7 436.8 33.9 30.9 
curve9 45 45 45 45 45 45 45 45 45 44.9 44.8 44.7 44.4 44.1 43.6 43 42.1 4

33.1 30.5 27.8 curve10 50 50 50 50 49.9 49.8 49.7 49.4 49 48.4 47.5 46.5 45.1 43.5 41.7 39.6 37.3 324.9 22.6 20.4 curve11 50 50 50 50 50 49.9 49.7 49.4 48.9 48 46.7 44.9 42.5 39.6 36.2 32.6 28.7 12.9 10.8 9 curve12 50 50 50 50 50 49.9 49.8 49.6 49.1 48.2 46.8 44.5 41.4 37.5 32.9 28 23.1 17.2 5.7 4.5 curve13 40 40 40 40 40 40 39.9 39.8 39.5 39.2 38.6 37.8 36.7 35.3 33.5 31.4 29 216.1 13.9 12 curve14 40 40 40 40 40 39.9 39.8 39.6 39.1 38.5 37.5 36.1 34.3 32.1 29.4 26.5 23.5 210.7 9 7.6 curve15 40 40 40 40 40 39.9 39.7 39.4 38.8 37.9 36.5 34.7 32.3 29.5 26.4 23.2 20 8.2 6.8 5.6 curve16 35 35 35 35 35 34.9 34.8 34.5 34 33.2 32.1 30.5 28.5 26.1 23.5 20.6 17.9 17.4 6.1 5.1 curve17 35 35 35 35 35 34.9 34.7 34.4 33.9 33.1 32 30.3 28.3 25.8 23.1 20.3 17.5 17.2 5.9 4.9 curve18 35 35 35 35 35 34.9 34.6 34.2 33.5 32.4 30.9 28.8 26.3 23.4 20.4 17.4 14.6 15.4 4.4 3.6 curve19 30 30 30 30 30 29.9 29.8 29.5 29 28.2 27.1 25.6 23.7 21.5 19.1 16.6 14.2 5.6 4.6 3.8 curve20 30 30 30 30 30 29.9 29.7 29.4 28.9 28.1 26.9 25.3 23.4 21.1 18.6 16.1 13.6 15.3 4.3 3.6 curve21 30 30 30 30 30 29.9 29.7 29.3 28.7 27.7 26.2 24.4 22.1 19.6 17 14.4 12 4.4 3.6 2.9 VC RATIO TO LOS CONVERSION (VALUE SHOWN IS LOWER LIMIT FOR THAT LOS)(URBAN ROADS USE SPEED BREAKS BELOW FOR LOS DETERMINATION) (ALL USE THE BASE VC'S  BASE RUR2 FWY A 0.00 0.00 0.00 B 0.30 0.00 0.25 C 0.50 0.10 0.40 D 0.70 0.30 0.60 E 0.90 0.50 0.80 F 1.00 1.00 1.00 F+ 1.10 1.10 1.10 F++ 1.30 1.30 1.30 SPEED VC RATIO BREAKS FOR URBAN STREETS (HIGHEST SPEED FOR GIVEN LOS & FF SPEED) FFS B C D E F >47 42. 34. 27. 21. 16. >37 35. 28. 22. 17. 13. >32 30. 24. 18. 14. 10. <33 25. 19. 13. 9. 7. LEVEL OF SERVICE THRESHOLD BY AREA NUM LOS DEFINITION 1 F CINCINNATI,CLEVELAND,COLUMBUS CENTRAL MPO COUNTIES (CUY,FRA,HAM) 2 E OTHER TMA MPOS (AKRON,CANTON,DAYTON,TOLEDO,YOUNGSTOWN + NON-CENTRAL COUNTIES FROM 1) 3 E OTHER MPOS & PARTS OF AREAS 1 & 2 OUTSIDE URBANIZED AREA 4 E RURAL NON MPO COUNTIES 
PEAK SPREADING MODEL INFO (SET MAX ITERATIONS TO 0 TO DISABLE PEAK SPREADING) 

MAX VC RATIO FWY: 1.30 MAX VC RATIO ART: 1.30 MAX ITERATIONS : 1000 TRUCK PCE: 2.0 AQ SEASON FACTOR: 1.08 MODEL CLASS PARAMETERS (MAX 4 CLASSES, HOURS 0-23 W/ NO OVERLAP IN CLASS, ALLOCATE ENTIRE CLASS AS TRUCK(1) OR NOT(0)) CLS TRK 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 CLS BEG 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 CLS END 23 23 0 0 0 0 0 0 0 0 0 0 0 0 0 0 CLS NUM 1 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 
Public Notice 

Ohio Environmental Protection Agency 

Redesignation and Maintenance Plan for the Ohio Portion of the Cleveland-AkronLorain Ozone Basic Nonattainment Area 

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

Counties 

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

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

EPA) revise the current maintenance plan for the Cleveland-Akron-Lorain area, 

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

Counties, with respect to the 1997 eight-hour ozone national ambient air quality 

standard (NAAQS). Ohio EPA submitted a redesignation request and maintenance plan 

for this area on March 7, 2009 Subsequently, U.S. EPA approved this requests on 

September 15, 2009. Air quality monitoring data collected in the region demonstrated 

attainment of the NAAQS and there was evidence that the improved air quality is due to 

permanent, enforceable emission reductions. In addition, existing requirements are 

sufficient to maintain the 1997 eight-hour ozone standard in this area throughout the 

maintenance period. 

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

emission projections and conformity budgets based on emission rates generated from 

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

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

official emission factor model. 

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

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

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

maintenance and the commitment to institute contingency measures if ambient 

exceedances or violations trigger the contingency plan requirements. Written comments 

will be received on or before October 23, 2012 at the following address: 

E-mail: erica.fetty@epa.state.oh.us

Mailing address: Erica Fetty 

Ohio Environmental Protection Agency, DAPC 

Lazarus Government Center 

P.O. Box 1049 

Columbus, Ohio 43216-1049 

Phone: (614) 644-2310 

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

redesignation request will be conducted as follows: October 23 at 3:30 P.M., at 

Northeast Ohio Air Quality Agency located at 2110 East Aurora Road Twinsburg, Ohio. 
All interested persons are entitled to attend or be represented at the hearings and give 

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

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

the close of business on October 23, 2012 will be considered by Ohio EPA prior to final 

action on this redesignation. Written statements submitted after October 23, 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 Erica Fetty, (614)-644-2310, Erica.Fetty@epa.state.oh.us or Jennifer Dines at 

(614) 644-3696, Jennifer.Dines@epa.state.oh.us or mailed to Erica Fetty or Jennifer 

Dines at the above address. 
1 

2 

3 

OHIO ENVIRONMENTAL PROTECTION AGENCY 

PUBLIC HEARING 

4 - - - - - - - - - - - - - - - -

5 In re: 

6 Redesignation and 

Maintenance Plan for the 

7 Ohio Portion of the Cleveland, 

Akron, Lorain Ozone Basic 

8 Nonattainment Area 

9 - - - - - - - - - - - -

10 

11 

12 Transcript of proceedings before the Ohio 

13 Environmental Protection Agency, taken at the Ohio 

14 EPA Office, 2110 E. Aurora Road, Twinsburg, Ohio, 

15 on Tuesday, October 23, 2012, commencing at 

16 3:30p.m. 

17 

18 

19 APPEARANCES: 

20 Mary McCarron, Ohio EPA Public Interest Center 

21 

22 

23 riJ:":Uco V f'.\.; 

24 OCT 2 f! 2012 

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PROCEEDINGS 

MS. McCARRON: My name lS Mary 

McCarron. I am the public involvement manager 

for Ohio Environmental Protection Agency's 

Public Interest Center. I will be presiding 

over today's hearing. 

The purpose of the hearing today is to 

obtain comments from any interested person 

regarding Ohio EPA's proposed action. 

The State of Ohio is requesting that 

U.S. EPA revise the current maintenance plan 

for the Cleveland, Akron, Lorain area, 

including Ashtabula, Cuyahoga, Geauga, Lake 

Lorain, Medina, Portage and Summit Counties, 

with respect to the 1997 eight-hour ozone 

national ambient air quality standard. 

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 2010. In December 

2009, MOVES replaced MOBILE6.2 as the U.S. 

EPA's official emission factor model. 

All interested persons are entitled to 
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P\Jbe3 

attend or be represented, and to present oral 

and/or written comments concerning the 

proposed action. All written and oral 

comments received as part of the official 

record will be considered by the director of 

Ohio EPA. 

To be included in the official record, 

written comments must be received by Ohio EPA 

by close of business, today, October 23, 2012. 

No one is present at this time. We 

will go off the record until 4:00. 

(Recess taken. ) 

MS. McCARRON: The time is now 4:00 

and this hearing is adjourned. 

(Hearing concluded at 4:00p.m.) 
1 State of Ohio, 

SS: 

2 County of Cuyahoga. 

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C E R T I F I C A T E 

This certifies that the foregoing is a true 

and correct transcript of the proceedings had 

before the State of Ohio, Environmental 

Protection Agency, taken at the Ohio EPA 

Office, 2110 E. Aurora Road, Twinsburg, 

Ohio,on Tuesday, October 23, 2012, commencing 

at 3:30p.m. 

In Re: 

Redesignation and Maintenance Plan for Ozone 

Basic Nonattainment Area, Cleveland, Akron, 

Lorain 

COURT REPORTER 

FINCUN-MANCINI COURT REPORTERS 

1801 East Ninth Street 

Suite 1720 

Cleveland, Ohio 44114 

(216) 696-2272 

(216) 696-2275 FAX