f.h!2 John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Craig W. Butler, Director 

Protection Agency 

JUL 0 6 20t6 

Robert A. Kaplan 

Acting Regional Administrator 

Attn.: R-19J 

U.S. EPA, Region 5 

77 West Jackson Blvd. 

Chicago, Illinois 60604-3507 

Re: Request for Approval of the Redesignation Request and Maintenance Plan for the 

Cleveland-Akron-Lorain, OH Area for the 2008 Eight-Hour Ozone Standard 

Dear Acting Administrator Kaplan: 

I am writing to formally request a redesignation to attainment of the Cleveland-Akron-Lorain, 

Ohio area (Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage and Summit) with 

respect to the 2008 eight-hour ozone standard. The enclosed submittal combines the 

redesignation request and the required maintenance plan for this area. 

Ohio Environmental Protection Agency (Ohio EPA) requested a one-year extension request 

for the Cleveland-Akron-Lorain, Ohio area to attain the standard on February 20, 2015 and 

provided U.S. EPA with supplemental information on March 19, 2015. U.S. EPA published 

proposed rulemaking granting the one-year attainment extension on August 27, 2015 (80 FR 

51992). On May 4, 2016 (81 FR 26697) U.S. EPA published a final action approving the oneyear extension request for the Cleveland-Akron-Lorain, Ohio nonattainment area with an 

effective date of June 3, 2016. 

Monitoring of existing air quality indicates that the 2008 National Ambient Air Quality 

Standard (NAAQS) for ozone has been attained throughout this area based on certified 

2013-2015 air quality data. Emissions projections indicate that current controls, existing State 

rules, existing federal rules, and Ohio's PSD program will be more than sufficient to maintain 

the NAAQS indefinitely into the future. These programs will, therefore, constitute the 

attainment and maintenance plan for the Cleveland-Akron-Lorain, Ohio area. 

The enclosed information, compiled by the Ohio EPA, Ohio Department of Transportation, 

the Akron Metropolitan Area Transportation Study, and the Northeast Ohio Areawide 

Coordinating Agency, shows significant emission reductions in point and mobile sources 

since ambient violations have occurred. A significant portion of the improved air quality can 

be attributed to federal programs for the mobile source sector, and the regional reductions 

associated with the transport programs and the implementation of CAIR/CSAPR. 

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

epa.ohio.gov • (614) 644-3020 • (614) 644-3184 (fax) 
The public hearing for this package was held on June 27, 2016, in Cleveland, Ohio and 

public comments were accepted through June 27, 2016 as well. No comments were 

received during the public hearing. 

I am also requesting that this redesignation request be processed by U.S. EPA as 

expeditiously as possible due to the upcoming nonattainment designations for the 2015 ozone 

NAAQS. These designations are scheduled to occur in October 2017 and the ClevelandAkron-Lorain, Ohio area will potentially be designated nonattainment for the 2015 ozone 

NAAQS. It is vital to Ohio and the Cleveland-Akron-Lorain area to reach attainment for the 

2008 ozone NAAQS before this time to avoid trigging any implications under the Clean Air Act 

for areas designated nonattainment for a newer standard but have not been designated back 

to attainment for a standard that has been revoked. 

This submittal consists of one (1) hard copy of the required documentation. An exact duplicate 

electronic version of the submittal in PDF format is available at 

http://www.epa.state.oh.us/dapc/SIP/2008.aspx under the heading "Clean Data Requests, 

Redesignations and Maintenance Plans". 

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

Control at (614) 644-3696. 

Sincerely, 

. Butler 

Director 

enclosures 

cc: Robert Hodanbosi, DAPC 

Jennifer Van Vlerah, DAPC 
REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR

THE CLEVELAND-AKRON-LORAIN, OH

8- HOUR OZONE 

NONATTAINMENT AREA

Ashtabula, Cuyahoga, Geauga, Lake, Lorain, 

Medina, Portage, and Summit Counties, Ohio

Prepared by:

Ohio Environmental Protection Agency

Division of Air Pollution Control

July 2016
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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.......................................................................................................................... 10

Ozone NAAQS.............................................................................................................................. 10

Ambient data quality assured........................................................................................................ 11

Three complete years of data ....................................................................................................... 12

Commitment to continue monitoring............................................................................................. 15

Chapter Four

Emission inventory........................................................................................................................ 16

Base year inventory ...................................................................................................................... 17

Emission projections ..................................................................................................................... 18

Demonstration of maintenance..................................................................................................... 22

Permanent and enforceable emissions reductions ...................................................................... 29

Provisions for future updates ........................................................................................................ 34

Chapter Five

Control measures and regulations................................................................................................ 36

Emission inventories/statements .................................................................................................. 36

Implementation of past SIP revisions ........................................................................................... 36

New source review provisions ..................................................................................................... 46

Assurance of continued controls .................................................................................................. 47

Chapter Six

Contingency measures ................................................................................................................. 48

Commitment to revise plan ........................................................................................................... 48

Commitment for contingency measures ....................................................................................... 48

Potential contingency measures................................................................................................... 49

List of VOC and NOx sources ....................................................................................................... 51

Chapter Seven

Modeling Analysis ......................................................................................................................... 52

Summary of Modeling Results for National Emission Control Strategies in Final Rulemaking ... 52

U.S. EPA Modeling Analysis for Interstate Transport “Good Neighbor” Provision ...................... 52

LADCO Modeling for Eight-Hour Ozone Standard....................................................................... 55

Summary of Existing Modeling Results ........................................................................................ 56

Chapter Eight

Public participation........................................................................................................................ 58
ii

Chapter Nine

Conclusions................................................................................................................................... 59
iii

FIGURES

Figure 1 Map of the Cleveland-Akron-Lorain, OH Nonattainment Area and Monitor 

Locations............................................................................................................... 11

Figure 2 Maximum 8-Hour Concentrations versus Temperate Days ................................ 32

Figure 3 Average Maximum 4th High versus Average Summer Temperatures ................. 33

Figure 4 Average Maximum 4th High versus Average Summer Relative Humidity ............ 34

Figure 5 NOx Emissions from EGUs 2003-2014 ............................................................... 38

TABLES

Table 1 Monitoring Data for Cleveland-Akron-Lorain, OH 2012-2014 and 2013 – 2015.. 13

Table 2 Emission Estimations for On-road Mobile Sources for Ashtabula Co., Ohio....... 18

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

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

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

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

Table 7 Emission Estimations for On-road Mobile Sources for Medina Co., Ohio .......... 19

Table 8 Emission Estimations for On-Road Mobile Sources for Portage Co., Ohio ......... 19

Table 9 Emission Estimations for On-road Mobile Sources for Summit Co., Ohio .......... 20

Table 10 Emission Estimations for On-road Mobile Total Cleveland-Akron-Lorain, OH

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

Table 11 Mobile Vehicle Emission Budget for the Cleveland-Akron-Lorain, OH ................ 20

Table 12 NOx Emission Inventory Ashtabula Co, Ohio....................................................... 22

Table 13 NOx Emission Inventory Cuyahoga Co., Ohio...................................................... 23

Table 14 NOx Emission Inventory Geauga Co., Ohio. ........................................................ 23

Table 15 NOx Emission Inventory Lake Co., Ohio. ............................................................. 23

Table 16 NOx Emission Inventory Lorain Co., Ohio............................................................ 24

Table 17 NOx Emission Inventory Medina Co., Ohio. ......................................................... 24

Table 18 NOx Emission Inventory Portage Co., Ohio ......................................................... 24

Table 19 NOx Emission Inventory Summit Co., Ohio.......................................................... 25

Table 20 NOx Emission Inventory Cleveland-Akron-Lorain, OH, Total............................... 25

Table 21 VOC Emission Inventory Ashtabula Co, Ohio. ..................................................... 25

Table 22 VOC Emission Inventory Cuyahoga Co., Ohio..................................................... 26

Table 23 VOC Emission Inventory Geauga Co., Ohio. ....................................................... 26

Table 24 VOC Emission Inventory Lake Co., Ohio.............................................................. 26

Table 25 VOC Emission Inventory Lorain Co., Ohio. .......................................................... 26

Table 26 VOC Emission Inventory Medina Co., Ohio.......................................................... 27

Table 27 VOC Emission Inventory Portage Co., Ohio......................................................... 27

Table 28 VOC Emission Inventory Summit Co., Ohio. ........................................................ 27

Table 29 VOC Emission Inventory Cleveland-Akron-Lorain, OH, Total.............................. 28

Table 30 Projected Emission Estimates 2014-2030 Cleveland-Akron-Lorain, OH............. 28

Table 31 Combined Comparison of 2011 and 2014 On-road, Non-road and EGU Totals . 30

Table 32 U.S. EPA “Good Neighbor” Provision Modeling Results Average Design Values.54

Table 33 U.S. EPA “Good Neighbor” Current Design Values......................................55

Table 34 LADCO’s Modeling Results for the Cleveland-Akron-Lorain, OH Area. .............. 56
iv

APPENDICES

A Air Quality System (AQS) Data and SLAMS Certification

B Mobile Source Emissions Inventory 

C Public Participation Documentation
v

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1

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE

CLEVELAND-AKRON-LORAIN, OH

OZONE NONATTAINMENT AREA

Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and 

Summit Counties, Ohio

CHAPTER ONE

Introduction

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

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

Plans (SIP’s) to expeditiously attain and maintain the standard. On March 12, 

2008, the United States Environmental Protection Agency (U.S. EPA) revised 

the air quality standard for ozone replacing the 1997 eight-hour standard of

0.08 parts per million (ppm) with a more stringent standard of 0.075 ppm. 

On March 21, 2012 (77 FR 30088), U.S. EPA designated nonattainment areas 

for the 2008 eight-hour ozone standard. Section 107(d)(3)(E) of the CAA 

allows states to request nonattainment areas to be redesignated to attainment 

provided certain criteria are met. The following are the criteria that must be met 

in order for an area to be redesignated from nonattainment to attainment: 

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

ozone standard.

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

under Section 110(k).

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

permanent and enforceable reductions in emissions resulting 

from implementation of the SIP and other federal 

requirements.

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

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

have been met. 

Background

The current Cleveland-Akron-Lorain, OH nonattainment area includes the 

following Counties: Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, 

Portage, and Summit. 

As part of the 1997 eight-hour ozone standard designations, the following 

Counties within the Cleveland-Akron-Lorain, OH area were designated as 

moderate nonattainment pursuant to Subpart 2 of the CAA and, therefore,

were subject to nonattainment area rulemakings: Ashtabula, Cuyahoga, 
2

Geauga, Lake, Lorain, Medina, Portage, and Summit Counties. The 

Cleveland-Akron-Lorain, OH area was redesignated to attainment on 

September 15, 2009 (74 FR 47414) and a revision to the approved motor 

vehicle emissions budgets was approved on March 19, 2013 (78 FR 16785). 

A maintenance plan was approved at that time.

 

As a result of the 2012 ozone designations for the 2008 eight-hour ozone 

standard, U.S. EPA designated the Cleveland-Akron-Lorain, OH area marginal

nonattainment, pursuant to Subpart 2 of the CAA, and the Ohio Environmental 

Protection Agency (Ohio EPA) was required to submit certain nonattainment 

plan elements by July 20, 2014. Ohio EPA submitted those elements on July 

18, 2014 and U.S. EPA published a proposal and direct final action approving 

that submittal on March 10, 2016 (81 FR12626 and 81 FR 12591). The 

approval became effective May 9, 2016. 

Ohio EPA requested a one-year extension request for the Cleveland-AkronLorain, OH area to attain the standard on February 20, 2015 and provided 

U.S. EPA with supplemental information on March 19, 2015. U.S. EPA 

published proposed rulemaking on granting the one-year attainment extension 

on August 27, 2015 (80 FR 51992). On May 4, 2016 (81 FR 26697) U.S. EPA 

published a final action approving the one-year extension request for the 

Cleveland-Akron-Lorain, OH nonattainment area with an effective date of June 

3, 2016. 

This document is intended to support Ohio’s request that the Cleveland-AkronLorain, OH area be redesignated from nonattainment to attainment for the 

eight-hour ozone standard. The Cleveland-Akron-Lorain, OH area has 

recorded three (3) years of complete quality-assured ambient air quality 

monitoring data for the years 2013 through 2015 demonstrating attainment of 

the eight-hour ozone standard. 

Geographical Description

The Cleveland-Akron-Lorain, OH eight-hour ozone nonattainment area is 

located in northeast Ohio and includes the following 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, 2013 through 2015, 

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

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, OH 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, OH area.

i.) Attainment of the standard - CAA Section107 (d)(3)(E)(i)

There are two components involved in making this 

demonstration. The first component relies on ambient air quality 

data. The data that 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. Chapter Three discusses this requirement in 

more detail

The second component relies upon supplemental U.S. EPAapproved air quality modeling. The supplemental modeling is 

not required for ozone nonattainment areas seeking 

redesignation; however, Ohio EPA has incorporated 

photochemical modeling information in Chapter Seven to further

support our request that Ohio’s portion of the nonattainment 

area be redesignated to attainment.

ii.) SIP approval - CAA Section107 (d)(3)(E)(ii)

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 4, 1994 (59 FR 23799), 

March 23, 1995 (60 FR 15235) and May 7, 1996 (61 FR 20458)

and includes the Cleveland-Akron-Lorain, OH area. In addition, 

on July 18, 2014, Ohio EPA submitted a SIP revision for this 

area and U.S. EPA published a proposal and direct final action 

approving that submittal on March 10, 2016 (81 FR 12626 and 

81 FR 12591). The approval became effective May 9, 2016. 

Chapter Five discusses this requirement in more detail.
4

iii.) Permanent and enforceable improvement in air quality - CAA 

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

The state must be able to reasonably attribute the improvement 

in air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures 

that have been adopted and implemented by the state.

On March 6, 2015, U.S. EPA finalized the “Implementation of the 

2008 National Ambient Air Quality Standards for Ozone: State 

Implementation Plan Requirements; Final Rule” (herein referred 

to as “Implementation Rule”). (80 FR 12264) In the 

Implementation Rule, U.S. EPA states “Under CAA section 

182(a), Marginal areas have up to 3 years from the effective 

date of designation to attain the NAAQS, and are not required to 

submit an attainment demonstration SIP.” (80 FR 12268) 

Further, U.S. EPA identifies “An attainment demonstration 

consists of: (1) Technical analyses, such as base year and 

future year modeling of emissions which identifies sources and 

quantifies emissions from those sources that are contributing to 

nonattainment; (2) analyses of future year emissions reductions 

and air quality improvement resulting from existing (i.e., already

adopted or ‘‘on the books’’) national, regional and local 

programs, and potential new local measures needed for 

attainment, including RACM and RACT for the area; (3) a list of 

adopted measures (including RACT) with schedules for

implementation and other means and techniques necessary and 

appropriate for demonstrating attainment as expeditiously as 

practicable but no later than the outside attainment date for the 

area’s classification; and (4) a RACM analysis to determine 

whether any additional RACM measures could advance 

attainment by 1 year.” (80 FR 12268) Therefore, these 

requirements, and specifically, the requirement to adopt specific 

state measures beyond federal measures, are not applicable to 

marginal areas, such as the Cleveland-Akron-Lorain, OH 

nonattainment area. 

Regardless, Ohio has adopted and implemented control 

measures for these counties in the area beyond the federal 

measures in order to comply with the 1997 eight-hour ozone 

standard and Ohio also adopted the initial 1979/1981 statewide 

rules. Historically the Cleveland-Akron-Lorain, OH area was a 

moderate nonattainment area for the one-hour standard and the 

1997 eight-hour standard. These measures and rules remain in 

effect and have assisted the Cleveland-Akron-Lorain, OH area in 

reaching attainment for the 2008 eight-hour ozone standard. 
5

Below is a list of several previously adopted Ohio rules that have 

contributed to reducing ozone in this area: 

 Portable Fuel Containers requirements

 Architectural and Industrial Maintenance (AIM) Coatings 

rules

 Consumer Products rules

 Clean Air Interstate Rule (CAIR)

 Cross State Air Pollution Rule (CSAPR)

 VOC RACT for all current U.S. EPA Control Technique 

Guidelines (CTG)

 NOx RACT

 E-Check

 NOx Sip Call rules

Chapters Four and Five discuss this requirement in more detail.

iv.) Section 110 and Part D requirements - CAA Section107 (d)(3)(E)(v)

For purposes of redesignation, a state must meet all 

requirements of Section 110 and Part D that were applicable 

prior to submittal of the complete redesignation request.

i.) Section 110(a) requirements

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

requirements for a SIP. Section 110(a)(1) generally 

directs states to submit a SIP that provides for 

implementation, maintenance, and enforcement of the air 

quality standards to the U.S. EPA after reasonable notice 

and public hearing. Section 110(a)(2) provides that the 

infrastructure SIP 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 

measures1, 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 

 

1 Other than nonattainment emission limitations and measures which are a part of 

nonattainment area plans and subject to the timing requirements of Section 172 of the CAA.
6

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 27, 2012 infrastructure SIP submission, 

Ohio verified that the State fulfills the requirements of 

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

Subpart 1 of Part D, found in Sections 172-176 of the CAA, sets 

forth the basic nonattainment requirements applicable to all 

areas which are designated nonattainment based on a violation 

of the NAAQS. Subpart 2 of Part D, which includes Section 182 

of the CAA, establishes more specific requirements depending 

on the area’s ozone nonattainment classification. 

The Cleveland-Akron-Lorain, OH area was designated under 

Subpart 2 of Part D as a marginal nonattainment area for ozone 

as part of U. S. EPA “Air Quality Designations for the 2008 

Ozone NAAQS.” (77 FR 30088) Therefore, the ClevelandAkron-Lorain, OH area must meet the applicable requirements 

of both Subpart 1 and Subpart 2 of Part D. The applicable 

Subpart 1 requirements are contained in Section 172(c)(1)-(9) 

and in Section 176. The applicable Subpart 2 requirements are 

contained in Section 182(a) (marginal nonattainment area 

requirements).

ii.) Subpart 1 of Part D - Section 172(c) requirements

Section 172(c)(1) requires the plans for all nonattainment 

areas to provide for the implementation of all RACM as 

expeditiously as practicable and to provide for attainment 

for the national primary ambient air quality standards. As 

discussed above, U.S. EPA’s Implementation Rule did 

not require marginal nonattainment areas to implement 

RACT/RACM. In addition, because attainment has been 

reached in the Cleveland-Akron-Lorain, OH area, no 

additional measures are needed to provide for 

attainment.

The reasonable further progress (RFP) requirement 

under section 172(c)(2) is defined as progress that must 

be made toward attainment. This requirement is not 

relevant for purposes of redesignation because the 

Cleveland-Akron-Lorain, OH area is monitoring 

attainment of the 2008 eight-hour ozone standard. In 

addition, because the Cleveland-Akron-Lorain, OH area

has attained the ozone standard and is no longer subject 
7

to an RFP requirement, the section 172(c)(9) contingency 

measures are not applicable for purposes of 

redesignation.

Section 172(c)(3) requires submission and approval of a 

comprehensive, accurate and current inventory of actual 

emissions. This requirement was superseded by the 

inventory requirement in Section 182(a)(1) discussed 

below.

 

Section 172(c)(4) requires the identification and 

quantification of allowable emissions for major new and 

modified stationary sources in an area, and Section 

172(c)(5) requires source permits for the construction and 

operation of new and modified major stationary sources 

anywhere in the nonattainment area. Ohio has a fully 

approved new source review program which is discussed 

in more detail under Chapter Five. 

Section 172(c)(6) requires the SIP to contain control 

measures necessary to provide for attainment of the 

standard. Because attainment has been reached, no 

additional measures are needed to provide for 

attainment.

Section 172(c)(7) requires the SIP to meet the applicable 

provisions of Section 110(a)(2). The Ohio SIP meets the 

requirements of Section 110(a)(2) for purposes of 

redesignation, as discussed above.

iii.) Subpart 1 of Part D - Section 176(c) requirements

Section 176(c) of the CAA requires states to establish 

criteria and procedures to ensure that Federallysupported or funded activities, including highway projects, 

conform to the air quality planning goals in the applicable 

SIPs. The requirement to determine conformity applies to 

transportation plans, programs and projects developed, 

funded or approved under Title 23 of the U.S. Code and 

the Federal Transit Act (transportation conformity) as well 

as to all other Federally-supported or funded projects 

(general conformity). State conformity revisions must be 

consistent with Federal conformity regulations relating to 

consultation, enforcement, and enforceability, which U.S. 

EPA promulgated pursuant to CAA requirements. 

Ohio EPA established two SIPs for conformity. The rules 
8

in Ohio Administrative Code (OAC) Chapter 3745-101 

contained Ohio’s SIP approved rules for transportation 

conformity, and OAC Chapter 3745-102 contained Ohio’s 

SIP approved rules for general conformity.

Ohio EPA’s transportation conformity rules in OAC 

Chapter 3745-101 were approved as a part of Ohio’s SIP 

on July 31, 2000 (65 FR 34395) and April 27, 2007 (72 

FR 20945). However, Ohio’s transportation conformity 

rules in OAC Chapter 3745-101 were completely 

removed from Ohio’s SIP on March 2, 2015 (80 FR 

11134) when the rules were replaced by a series of 

memorandums of understanding (MOUs) between Ohio 

EPA, U.S.E PA, and the various state and local agencies 

involved in the transportation conformity process. The 

currently effective MOUs are available on Ohio EPA’s 

website at:

http://epa.ohio.gov/dapc/sip/trans_conform.aspx.

Ohio EPA’s general conformity rules in OAC Chapter 

3745-102 were approved as part of Ohio’s SIP on March 

11, 1996 (61 FR 9644). In April, 2010, U.S. EPA 

promulgated changes to 40 CFR 51.851. The language in 

paragraph (a) of the section was changed from “must” to 

“may”, thereby eliminating the requirement for states to 

maintain a general conformity SIP. For this reason, Ohio 

EPA requested, and U.S. EPA granted rescission of 

Ohio’s general conformity SIP. The rules in OAC Chapter

3745-102 were removed from the state SIP on May 26, 

2015 (80 FR 29968). The state SIP was replaced by the 

federal rules in 40 CFR Part 93, subpart B.

iv.) Subpart 2 of Part D - Section 182(a) requirements

Section 182(a)(1) requires the submission of a 

comprehensive emissions inventory. This requirement is 

addressed under Chapter Four.

Section 182(a)(2) requires the submission of certain 

corrections to VOC RACT rules, inspection and 

maintenance programs and permitting programs. These 

corrections were addressed for the Cleveland, OH area

under the one-hour ozone standard and do not need to 

be addressed again under the 2008 eight-hour standard.

Section 182(a)(3)(B) requires the submission of an 
9

emission statement SIP. This requirement is addressed 

under Chapter Five.

v.) Maintenance plans - CAA Section107 (d)(3)(E)(iv)

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

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

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

maintenance plan 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.
10

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 50.15,

has been attained.

Background

There are twelve monitors measuring ozone concentrations in 

this nonattainment area. The monitors are operated by Ohio 

EPA Division of Air Pollution Control, Northeast District Office, 

Department of Public Health Division of Air Quality, Lake County 

General Health District Air Pollution Control and Akron Regional 

Air Quality Management. A listing of the design values based on 

the three-year average of the annual fourth highest daily 

maximum eight-hour average ozone concentrations from 2013

through 2015 certified air quality data is shown in Table 1. The

locations of the monitoring sites for this nonattainment area are 

shown on Figure 1. 
11

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 AQS database, and available for public view.

Demonstration

The Ohio EPA has quality assured all 2013 through 2015 data 

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

Ohio Quality Assurance Manual. Ohio EPA has recorded the data 
12

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

public. 

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

consecutive calendar years of quality assured data.)

Background

The following information is taken from Appendix P, 

“Interpretation of the Primary and Secondary NAAQS for O3” of 

40 CFR Part 58.

Three complete years of ozone monitoring data are required to 

demonstrate attainment at a monitoring site. The eight-hour

primary and secondary ozone ambient air quality standards are 

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

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

average ozone concentrations is less than or equal to 0.075

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

Three significant digits must be carried in the computations.

Because the third decimal digit, in ppm, is truncated, 0.075666* 

ppm is the largest concentration that is less than or equal to 

0.075 ppm. Therefore, for the purposes of this request, values 

below 0.0757 ppm meet the standard. These data handling 

procedures are applied on an individual basis at each monitor in 

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

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

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

annual fourth highest daily maximum eight-hour average ozone 

concentrations is also called the site's design value.

Table 1 shows the monitoring data for 2012 – 2014 and 2013-

2015 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. 
13

Demonstration

Table 1 - Certified Monitoring Data for the Cleveland-AkronLorain, OH area for 2012 – 2014 and 2013 – 2015

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

http://www.epa.gov/aqs

SITE ID COUNTY YEAR %OBS

1

st 2nd 3rd 4th 2012-

2014

2013-

2015 

8-HR 8-HR 8-HR 8-HR AVER. AVER.

39-007-

1001 Ashtabula 2012 98 97 93 81 79

72 69

39-007-

1001 Ashtabula 2013 100 73 73 70 70

39-007-

1001 Ashtabula 2014 100 76 73 70 69

39-009-

1001 Ashtabula 2015 98 83 73 71 70

39-035-

0034 Cuyahoga 2012 98 102 88 86 85

75 69

39-035-

0034 Cuyahoga 2013 98 86 73 70 69

39-035-

0034 Cuyahoga 2014 99 75 74 72 71

39-035-

0034 Cuyahoga 2015 96 70 70 68 67

39-035-

0060 Cuyahoga 2012 98 84 81 74 73

65 62

39-035-

0060 Cuyahoga 2013 95 66 60 58 57

39-035-

0060 Cuyahoga 2014 97 69 68 67 66

39-035-

0060 Cuyahoga 2015 94 67 63 63 63

39-035-

0064 Cuyahoga 2012 98 94 90 87 83

68 63

39-035-

0064 Cuyahoga 2013 97 68 66 66 64

39-035-

0064 Cuyahoga 2014 97 66 62 61 59

39-035-

0064 Cuyahoga 2015 99 68 67 66 66

39-035-

5002 Cuyahoga 2012 99 98 94 89 87

71 66

39-035-

5002 Cuyahoga 2013 99 80 70 65 65

39-035-

5002 Cuyahoga 2014 99 75 64 63 61

39-035-

5002 Cuyahoga 2015 99 74 73 72 72

39-055-

0004 Geauga 2012 100 103 99 83 82 70 67
14

SITE ID COUNTY YEAR %OBS

1

st

2

nd

3

rd

4

th 2012

-

2014

2013-

2015 

8-HR8-HR8-HR8-HR AVER. AVER.

39-055-

0004 Geauga 2013 100 74 70 66 65

39-055-

0004 Geauga 2014 100 77 68 67 65

39-055-

0004 Geauga 2015 100 80

797373

39-085-

0003

Lake 2012 100 10893 9289

78 73

39-851-

0003

Lake 2013 100 8574 72 70

39-085-

0003

Lake 2014 100 79787675

39-085-

0003

Lake 201598 7775 7474

39-085-

0007 Lake 2012 99 97 87 84 83

71 66

39-085-

0007 Lake 2013 100 78 70 69 68

39-085-

0007 Lake 2014 100 73 66 64 62

39-085-

0007 Lake 2015 100 78 72 72 70

39-093-

0018 Lorain 2012

97 8987 8581

69 63

39-093-

0018

Lorain 2013 100 66 636360

39-093-

0018

Lorain 2014 99 68 68 67 67

39-093-

0018

Lorain 2015 99 68 65 64 62

39-103-

0004 Medina 2012 98

90 75 74 74

67 64

39-103-

0004 Medina 2013 100 69 66 66

65

39-103-

0004 Medina 2014 100

72 656564

39-103-

0004 Medina 2015 100 69 65 65 63

39-133-

1001 Portage 2012 95

91 75 75 74

64 61

39-133-

1001 Portage 2013

98 67 61 59 58

39-133-

1001 Portage 2014 99 66 65 63

61

39-133-

1001 Portage 2015 100 68 65 65 64
15

SITE ID COUNTY YEAR %OBS

1

st 2nd 3rd 4th 2012-

2014

2013-

2015 

8-HR 8-HR 8-HR 8-HR AVER. AVER.

39-153-

0020 Summit 2012 100 86 71 70 70

62 61

39-153-

0020 Summit 2013 100 70 64 61 60

39-153-

0020 Summit 2014 100 66 62 59 58

39-153-

0020 Summit 2015 100 68 68 65 65

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

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

with controls for electric generating units (EGUs), both regionally and 

locally. 

Requirement 4 of 4

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

appropriate monitoring network to verify the maintenance of the attainment 

status.

Demonstration

Ohio EPA commits to continue monitoring ozone levels at the 

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

EPA Region V prior to making changes to the existing 

monitoring network, should changes become necessary in the 

future. Ohio EPA will continue to quality assure the monitoring 

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

federal requirements. Connection to a central station and 

updates to the Ohio EPA web site2 will provide real time 

availability of the data and knowledge of any exceedances. Ohio 

EPA will enter all data into AQS on a timely basis in accordance 

with federal guidelines.

 

2 http://www.epa.gov/ttn/chief/emch/index.html
16

CHAPTER FOUR

EMISSION INVENTORY

CAA Section107 (d)(3)(E)(iii), & 107 (d)(3)(E)(v)

U.S. EPA’s Redesignation Guidance requires the submittal of a 

comprehensive inventory of ozone precursor emissions (VOC and NOx) 

representative of the year when the area achieves attainment of the ozone air 

quality standard. Ohio also must demonstrate that the improvement in air 

quality between the year that violations occurred and the year that attainment 

was achieved is based on permanent and enforceable emission reductions. 

Other emission inventory related requirements include a projection of the 

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

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

ozone standard; and a commitment to provide future updates of the inventory 

to enable tracking of emission levels during the 10-year maintenance period.

The emissions inventory development and emissions projection discussion 

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

projections, identifies procedures used by Ohio EPA regarding emissions from 

the counties in the Cleveland-Akron-Lorain, OH area. 

Area, non-road, on-road and point source emissions were compiled as follows:

 Area, non-road, and point source emissions (EGUs, non-EGUs and 

airport related emissions (AIR)) were collected from the data available 

on U.S. EPA’s Emissions Modeling Clearinghouse website3. Using 

Ozone NAAQS Emissions Modeling platform (2011v6.1) data were 

collected together for the 2011 National Emissions Inventory (NEI) year 

and the 2018 and 2025 U.S. EPA-projected inventories. Therefore, 

2011 point emissions are actual reported emissions from the 2011 NEI.

 Because the 2014 NEI is not available at this time, Ohio EPA derived 

2014 actual point emissions (for EGUs and non-EGUs) from state 

inventory databases (e.g., Ohio’s EIS database which serves as the 

basis for the 2014 NEI). 

 Because all emissions from the state inventory database, the NEI and 

the Ozone NAAQS Emissions Modeling platform (2011v6.1) are annual 

totals, tons per summer day were derived according to the U.S. EPA 

guidance document Temporal Allocation of Annual Emissions Using 

EMCH Temporal Profiles, dated April 29, 20024, using the temporal 

allocation references accompanying the 2011v6.1 modeling inventory 

files. These files provide SCC specific profiles that allow annual 

 

3 http://www.epa.gov/ttn/chief/emch/index.html

4 https://www3.epa.gov/ttn/chief/emch/temporal/index.html
17

emission totals to be distributed across various temporal periods, as 

described in the guidance document referenced here. 

 Using the above datasets:

o 2014 emissions for area, non-road and AIR point were derived 

by interpolating between 2011 and 2018. Note that Ohio EPA 

does not require airport related emissions to be reported and 

therefore actual 2014 airport emissions will not be available until 

the 2014 NEI is available. If those emissions differ appreciably 

from the emissions projected using this methodology, Ohio EPA 

will commit to submitting a revised redesignation request and 

maintenance plan.

o 2020 emissions for area, non-road and point (EGU, non-EGU 

and AIR) were derived by interpolating between 2018 and 2025.

o 2030 emissions for area, non-road and point (EGU, non-EGU 

and AIR) were derived using the TREND function in Microsoft 

Excel. If the TREND function resulted in a negative value, the 

emissions were assumed to not change. 

o Mobile source emissions for all years were developed in 

conjunction with the Ohio EPA, Ohio Department of 

Transportation (Ohio DOT), the Akron Metropolitan Area 

Transportation Study (AMATS) and the Northeast Ohio 

Areawide Coordinating Agency (NOACA) and were calculated 

from emission factors produced by U.S. EPA’s 2010 Motor 

Vehicle Emission Simulator (MOVES) software program and 

data extracted from the region’s travel-demand model. 

Appendix B contains detailed methodology and data for mobile 

source emissions for all years. 

o Biogenic emissions are not included in these summaries.

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. 

Periodic inventories, which include emissions from all sectors -

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

three years.
18

Demonstration

The 2011 inventory is used as the nonattainment base year for 

the purpose of this submittal.

5

 The 2014 inventory is used as 

the attainment year inventory for the purposes of comparison. 

These inventories represent a comprehensive, accurate, and 

current inventory of actual emissions from all sources of the 

relevant pollutants in the Cleveland-Akron-Lorain, OH area. 

Emissions of VOC and NOx for 2011 and 2014 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

As discussed above, Ohio EPA prepared a projected emissions 

inventory for the Cleveland-Akron-Lorain, OH area including 

area, non-road, mobile, and point sources for precursors of 

ozone (VOCs and NOx) for the nonattainment area. 

Demonstration

In consultation with U.S. EPA and other stakeholders, Ohio EPA 

selected the year 2030 as the maintenance year for this 

redesignation request. The request also contains projected 

emission inventories for 2020. 

On-Road Mobile Emission Estimations

Tables 2 through 10 contain the results of the emissions analysis 

for the appropriate years. All emissions estimations are 

expressed in tons per summer day (TSD). 

Table 2 - Ashtabula County, Ohio Emission Estimations for 

On-Road Mobile Sources

2011 2014 2020 2030

VOC (TSD) 2.88 2.09 1.38 1.06

NOx (TSD) 6.35 4.22 2.28 1.56

VMT (miles/day) 3,154,204 3,232,705 3,399,487 3,608,559

 

5 On July 18, 2014, Ohio EPA submitted its 2008 base year inventory as required under 

CAA Section 182(a)(1). Ohio EPA is not requesting that inventory be replaced with the 

2011 inventory in this submittal in Ohio’s SIP.
19

Table 3 - Cuyahoga County, Ohio Emission Estimations for 

On-Road Mobile Sources

2011 2014 2020 2030

VOC (TSD) 27.04 17.84 12.18 9.37

NOx (TSD) 50.73 31.72 17.65 12.01

VMT (miles/day) 28,384,168 28,467,810 28,392,560 28,736,592

Table 4 - Geauga County, Ohio Emission Estimations for 

On-Road Mobile Sources

2011 2014 2020 2030

VOC (TSD) 4.76 2.03 1.45 1.11

NOx (TSD) 7.46 3.73 2.20 1.60

VMT (miles/day) 2,559,395 2,650,527 2,718,014 2,919,951

Table 5 - Lake County, Ohio Emission Estimations for 

On-Road Mobile Sources

2011 2014 2020 2030

VOC (TSD) 5.94 4.30 2.85 2.15

NOx (TSD) 11.97 8.05 4.71 3.25

VMT (miles/day) 5,789,656 5,918,927 6,031,050 6,419,270

Table 6 - Lorain County, Ohio Emission Estimations for 

On-Road Mobile Sources

2011 2014 2020 2030

VOC (TSD) 7.80 5.69 3.79 2.86

NOx (TSD) 14.11 10.29 5.76 3.86

VMT (miles/day) 6,968,846 7,133,870 7,237,077 7,689,523

Table 7 – Medina County, Ohio Emission Estimations for OnRoad Mobile Sources

2011 2014 2020 2030

VOC (TSD) 5.41 3.95 2.78 2.22

NOx (TSD) 14.59 10.33 5.85 4.30

VMT (miles/day) 6,169,676 6,370,242 6,688,963 7,281,548

Table 8 – Portage County, Ohio Emission Estimations for OnRoad Mobile Sources

2011 2014 2020 2030

VOC (TSD) 4.48 3.38 2.39 2.00

NOx (TSD) 9.96 6.77 3.93 2.90

VMT (miles/day) 5,137,069 5,270,104 5,882,626 6,360,777
20

Table 9 – Summit County, Ohio Emission Estimations for OnRoad Mobile Sources

2011 2014 2020 2030

VOC (TSD) 13.61 10.07 6.96 6.01

NOx (TSD) 29.19 19.45 11.15 8.62

VMT (miles/day) 15,901,993 16,368,909 17,696,791 18,872,705

Table 10 - Emission Estimation Totals for On-Road Mobile 

 Sources for the Cleveland-Akron-Lorain-OH Area

2011 2014 2020 2030

VOC (TSD) 71.92 49.35 33.78 26.78

NOx (TSD) 144.36 94.56 53.53 38.10

VMT (miles/day) 74,065,007 75,413,094 78,046,568 81,888,925

Motor Vehicle Emission Budget

Table 11 contains the motor vehicle emissions budgets for the

Cleveland-Akron-Lorain, OH area.

Table 11 - Mobile Vehicle Emissions Budget for the ClevelandAkron-Lorain, OH Area

2020

Estimated 

Emissions

2020

Mobile 

Safety 

Margin 

Allocation*

2020

Total 

Mobile 

Budget

2030

Estimated 

Emissions

2030

Mobile 

Safety 

Margin

Allocation*

2030

Total 

Mobile 

Budget

VOC 

(TSD) 33.78 5.07 38.85 26.78 4.02 30.80

NOx 

(TSD) 53.53 8.03 61.56 38.10 5.72 43.82

VMT 

(miles/day) 78,046,568 - - 81,888,925 - -

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

percent of the mobile source emission estimates. 

The above budgets for the Cleveland-Akron-Lorain, OH area, 

agreed upon as part of the interagency consultation process, 

include the emission estimates calculated for 2020 and 2030 

with an additional 15 percent margin of safety allocated to those 

estimates. 

In an effort to accommodate future variations in travel demand 

models and VMT forecast when no change to the network is 

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

reasonable approach to address this variation. Based on this 

discussion, a 15 percent margin of safety allocation was agreed 
21

upon and has been added to the emissions estimates for the 

Cleveland-Akron-Lorain, OH nonattainment area.

The emission estimates are derived from the travel demand 

model and MOVES2010 as described above. All 

methodologies, the latest planning assumptions, and the safety 

margins allocations were determined through the interagency 

consultation process described in the Transportation Conformity 

Memorandum of Understanding (MOU) among NOACA, 

AMATS, Ohio DOT, and Ohio EPA.

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

an acknowledged potential variation in VMT forecast and 

potential estimated mobile source emissions due to expected 

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

total decrease in emissions from all sources is sufficient to 

accommodate this 15 percent allocation of safety margin to 

mobile sources while still continuing to maintain the total 

emissions in the Cleveland-Akron-Lorain, OH area well below 

the 2014 attainment level of emissions. 

 

The 15 percent margin of safety was calculated by taking 15

percent of the mobile source emission estimates. Safety 

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

emissions from all sources in the nonattainment area. The 

actual allocation is less than 15 percent of the total emission 

reduction from all sources as can be seen from Table 30.

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

safety margin allocation translates into:

-An allocation of 5.07TSD for VOC and 8.03TSD for NOx 

for 2020; and

-An allocation of 4.02TSD for VOC and 5.72TSD for NOx 

for 2030. 

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

CFR 93.1016, discussed under “Requirement 3 of 5” below, it is 

evident this allocation is significantly below the total safety 

margin for this area (see Table 30).

 

6

"safety margin" means the amount by which the total projected emissions from all sources 

of a given pollutant are less than the total emissions that would satisfy the applicable 

requirement for reasonable further progress, attainment, or maintenance.
22

The current eight-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 new 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

Maintenance is demonstrated when the future-year (2030) 

projected emission totals are below the 2014 attainment year 

totals.

 

Sectors included in the following tables are: Electrical 

Generating Unit (EGU); Non-Electrical Generating Unit (NonEGU); Non-road Mobile (Non-road); Airport (AIR); Other-Area 

(Area); and On-road Mobile (On-road). 

Demonstration

NOx

Table 12 -Ashtabula County, Ohio NOx Emission Inventory 

Totals (TSD)

Sector 2011 

Base

2014 

Attainment

2020 

Interim

2030 

Maintenance

Safety 

Margin

EGU 4.21 1.26 0.30 0.71

Non-EGU 0.74 0.74 0.73 0.71

AIR 0.00 0.00 0.00 0.00

Non-road 2.89 5.95 1.95 1.36

Area 4.02 3.82 3.40 2.67

On-road 6.35 4.22 2.28 1.56

TOTAL 18.21 15.99 8.66 7.01 8.98
23

Table 13 – Cuyahoga County, Ohio NOx Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030

Maintenance

Safety 

Margin

EGU 2.83 1.10 0.03 0.01

Non-EGU 7.62 7.40 6.43 6.05

AIR 1.67 1.80 2.10 2.68

Non-road 18.83 21.03 11.00 7.66

Area 13.78 13.60 13.10 12.03

On-road 50.73 31.72 17.65 12.01

TOTAL 95.46 76.65 50.31 40.44 36.21

Table 14 - Geauga County, Ohio NOx Emission Inventory

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030

Maintenance

Safety 

Margin

EGU 0.00 0.00 0.00 0.00

Non-EGU 0.02 0.02 0.03 0.03

AIR 0.00 0.00 0.00 0.00

Non-road 1.66 2.89 0.90 0.61

Area 0.87 0.90 0.94 0.95

On-road 7.46 3.73 2.20 1.59

TOTAL 10.01 7.54 4.07 3.18 4.36

Table 15 – Lake County, Ohio NOx Emission Inventory Totals 

(TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 27.27 5.48 2.96 2.96

Non-EGU 1.94 1.81 1.97 1.99

AIR 0.01 0.01 0.01 0.01

Non-road 4.83 6.66 3.20 2.36

Area 4.25 4.12 3.82 3.24

On-road 11.97 8.05 4.71 3.25

TOTAL 50.27 26.13 16.67 13.81 12.32
24

Table 16 - Lorain County, Ohio NOx Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 12.73 10.48 0.04 0.04

Non-EGU 1.84 1.66 1.91 1.92

AIR 0.01 0.01 0.01 0.01

Non-road 6.17 7.40 3.70 2.40

Area 5.04 4.83 4.35 3.49

On-road 14.11 10.29 5.76 3.86

TOTAL 39.90 34.67 15.77 11.72 22.95

Table 17 - Medina County, Ohio NOx Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014 

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.00 0.00 0.01 0.01

Non-EGU 0.20 0.21 0.20 0.27

AIR 0.02 0.02 0.02 0.02

Non-road 2.95 3.07 1.50 0.79

Area 1.98 1.93 1.82 1.58

On-road 14.59 10.33 5.85 4.30

TOTAL 19.74 15.56 9.40 6.97 8.59

Table 18 -Portage, Ohio NOx Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.00 0.00 0.00 0.00

Non-EGU 0.28 0.32 0.29 0.29

AIR 0.00 0.00 0.00 0.00

Non-road 2.66 4.14 1.39 0.79

Area 3.11 2.98 2.69 2.15

On-road 9.96 6.77 3.93 2.90

TOTAL 16.01 14.21 8.30 6.13 8.08
25

Table 19 - Summit County, Ohio NOx Emission Inventory Total 

(TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.00 0.00 0.01 0.01

Non-EGU 1.59 1.33 0.74 0.76

AIR 0.33 0.36 0.44 0.58

Non-road 6.30 6.25 3.13 1.86

Area 5.34 5.28 5.08 4.66

On-road 29.19 19.45 11.15 8.62

TOTAL 42.75 32.67 20.55 16.49 16.18

Table 20 – Cleveland-Akron-Lorain-OH Area NOx Emission 

Inventory Totals (TSD)

NOx 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

Ashtabula 18.21 15.99 8.66 7.01

Cuyahoga 95.46 76.65 50.31 40.44

Geauga 10.01 7.54 4.07 3.18

Lake 50.27 26.13 16.67 13.81

Lorain 39.90 34.67 15.77 11.72

Medina 19.74 15.56 9.40 6.97

Portage 16.01 14.21 8.30 6.13

Summit 42.75 32.67 20.55 16.49

COMBINED 

NOx TOTAL 292.35 223.42 133.73 105.75 117.67

VOC

Table 21 - Ashtabula County, Ohio VOC Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.06 0.01 0.03 0.11

Non-EGU 7.04 6.68 7.04 7.04

AIR 0.00 0.00 0.00 0.01

Non-road 7.35 2.51 4.01 2.18

Area 3.81 3.75 3.66 3.58

On-road 2.88 2.09 1.38 1.06

TOTAL 21.14 15.04 16.12 13.98 1.06
26

Table 22 - Cuyahoga County, Ohio VOC Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.04 0.01 0.00 0.00

Non-EGU 2.77 2.73 2.57 2.49

AIR 0.41 0.43 0.49 0.60

Non-road 24.86 15.42 16.66 14.86

Area 33.36 32.55 31.56 30.93

On-road 27.04 17.84 12.18 9.37

TOTAL 88.48 68.98 63.46 58.25 10.73

Table 23 - Geauga County, Ohio VOC Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.00 0.00 0.00 0.00

Non-EGU 0.04 0.08 0.04 0.04

AIR 0.00 0.00 0.00 0.00

Non-road 3.34 1.32 2.37 2.13

Area 4.14 4.05 3.94 3.87

On-road 4.76 2.03 1.45 1.11

TOTAL 12.28 7.48 7.80 7.15 0.33

Table 24 – Lake County, Ohio VOC Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.32 0.26 0.02 0.02

Non-EGU 0.73 0.80 0.64 0.63

AIR 0.01 0.01 0.01 0.01

Non-road 8.22 4.14 4.56 2.77

Area 6.41 6.30 6.15 6.06

On-road 5.94 4.30 2.85 2.15

TOTAL 21.63 15.81 14.23 11.64 4.17

Table 25 - Lorain County, Ohio VOC Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.09 0.08 0.00 0.00

Non-EGU 2.51 1.97 2.50 2.50

AIR 0.02 0.02 0.02 0.03

Non-road 8.96 5.13 5.36 3.78

Area 7.54 7.37 7.14 6.95

On-road 7.80 5.69 3.79 2.86

TOTAL 26.92 20.26 18.81 16.12 4.14
27

Table 26 - Medina, Ohio VOC Emission Inventory 

Totals (TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.00 0.00 0.00 0.00

Non-EGU 0.64 0.52 0.62 0.63

AIR 0.04 0.04 0.04 0.04

Non-road 3.60 2.33 2.45 2.11

Area 5.23 5.14 5.03 4.97

On-road 5.41 3.95 2.78 2.22

TOTAL 14.92 11.98 10.92 9.97 2.01

Table 27 - Portage County, Ohio VOC Emission Inventory Totals 

(TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.00 0.00 0.00 0.00

Non-EGU 0.91 1.12 0.91 0.89

AIR 0.00 0.00 0.00 0.00

Non-road 4.90 2.12 3.18 2.52

Area 5.92 5.82 5.69 5.61

On-road 4.48 3.38 2.39 2.00

TOTAL 16.21 12.44 12.17 11.02 1.42

Table 28 - Summit County, Ohio VOC Emission Inventory Totals 

(TSD)

Sector 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

EGU 0.00 0.00 0.00 0.00

Non-EGU 1.22 1.04 1.14 1.12

AIR 0.09 0.10 0.11 0.13

Non-road 7.33 4.90 5.09 4.80

Area 14.44 14.19 13.87 13.62

On-road 13.61 10.07 6.96 6.01

TOTAL 36.69 30.30 27.17 25.68 4.62
28

Table 29 – Cleveland-Akron-Lorain-OH Area VOC Emission

Inventory Totals (TSD)

VOC 2011

Base

2014

Attainment

2020

Interim

2030 

Maintenance

Safety 

Margin

Ashtabula 21.14 15.04 16.12 13.98

Cuyahoga 88.48 68.98 63.46 58.25

Geauga 12.28 7.48 7.80 7.15

Lake 21.63 15.81 14.23 11.64

Lorain 26.92 20.26 18.81 16.12

Medina 14.92 11.98 10.92 9.97

Portage 16.21 12.44 12.17 11.02

Summit 13.61 10.07 6.96 6.01

COMBINED 

VOC TOTAL 215.19 162.06 150.47 134.14 27.92

VOC and NOx

Table 30 - Cleveland-Akron-Lorain, OH Area Comparison of 2014 

attainment year and projected emission estimates

(TSD)

2014 2020

2020

Projected 

Decrease

2030

2030

Projected 

Decrease

VOC 162.06 150.47 11.59 134.14 27.92

NOx 223.42 133.73 89.69 105.75 117.67

As shown in the table above, VOC emissions in the 

nonattainment area are projected to decrease by 11.59TSD in 

2020 and 27.92TSD in 2030. In general, emissions for all 

sectors are projected to decline or remain stable. EGU sources

in Ashtabula County) show a slight increase, but this is fractional 

compared to the overall reductions expected. Furthermore, 

Ashtabula, Cuyahoga, Lorain, and Summit Counties show a 

minor increase in regards to air emissions. Again this increase 

does not affect the overall reduction in VOC emissions for the 

area and are likely contributed to slight changes in population 

projections. Cleaner vehicles and fuels are expected to be in 

place in 2018 and will cause an overall drop in VOC emissions.

NOx emissions in the nonattainment area are projected to 

decrease by 89.69TSD in 2020 and 117.67 TSD in 2030. Nonroad and on-road emissions are all projected to decline. Area 

emissions are projected to decline in all counties expect 

Geauga, where a slight increase in emissions is projected. Air 
29

emissions are projected to remain steady or slightly increase in 

Cuyahoga, and Summit Counties. EGU emissions are projected 

to decrease overall for the Cleveland-Akron-Lorain, OH area. 

Geauga, Lake, Lorain, Medina, and Portage are projected to 

have minor increases with non-EGU emissions. However, overall 

non-EGU NOx emissions are decreasing for the ClevelandAkron-Lorain, OH area as a whole. Decreases from U.S. EPA

rules covering EGUs (NOx SIP Call, CAIR and CSAPR), Tier 2 

Motor Vehicle Emissions Standards and Gasoline Sulfur Control 

Requirements7, Highway Heavy-Duty Engine Rule8, and the 

Non-Road Diesel Engine Rule9 are factored into the changes. 

As identified in Table 11 above, an additional mobile budget

margin of safety allocation is being requested for mobile 

emissions. The mobile budget margin of safety allocation

translates into an additional 5.07TSD for VOC and 8.03TSD for 

NOx in the year 2020 and 4.02TSD for VOC and 5.72TSD for 

NOx in the year 2030. U.S. EPA’s conformity regulations allow 

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

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

from 2014 to 2030) to the mobile emissions budgets for future 

conformity. 

- In 2020: 5.07TSD of the 11.59TSD safety margin for 

VOC and 8.03TSD of the 89.69TSD safety margin for 

NOx as a mobile emissions budget safety margin. 

- In 2030: 4.02TSD of the 27.92TSD safety margin for 

VOC and 5.72TSD of the 117.67TSD safety margin for 

NOx as a mobile emissions budget 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.

Background

Ambient air quality data from all monitoring sites indicate that air 

quality met the NAAQS for ozone in 2013 through 2015. U.S. 

EPA’s Redesignation Guidance (p 9) states: “A state may 

generally demonstrate maintenance of the NAAQS by either 

 

7 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm

8 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm

9 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm
30

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 and nonroad diesel engines while reductions in EGU emissions were due 

to implementation of CAIR/CSAPR. 

With respect to EGUs, changes at several facilities have resulted 

in reductions in NOx emissions. Cleveland Electric Illuminating

Co., Eastlake Plant in Lake County (OH) permanently shutdown 

in April of 2015. Prior to the shutdown, EGU NOx emissions had 

dropped from 27.27 TSD to 5.48 TSD (2011 to 2014). The First 

Energy Generation, LLC Lake Shore facility in Cuyahoga County 

(OH) permanently shutdown in April of 2015. Prior to the 

shutdown, EGU NOx emissions had dropped in Cuyahoga

County from 2.83 TSD to 1.10 TSD (2011 to 2014). The First 

Energy Generation, LLC Ashtabula Plant in Ashtabula County 

(OH) shutdown coal fired boilers in April of 2015 and December 

of 2015. Prior to the shutdown, EGU NOx emissions in 

Ashtabula County had dropped from 4.21 TSD to 1.26 TSD 

(2011 to 2014). Even greater reductions than predicted will be 

achieved in these areas due to the shutdown of these facilities. 

 

Reductions achieved are discussed in greater detail under 

Chapter Five.

Table 31 – Cleveland-Akron-Lorain, OH Area Combined 

Comparison of 2011 base year and 2014 attainment 

year EGU, non-road, and on-road reductions

2011 2014

EGU NOx 47.04 18.32

Non-road NOx 46.29 57.39

Non-road VOC 68.56 37.87

On-road VOC 71.92 49.35

On-road NOx 144.36 94.56
31

To further support Ohio’s demonstration that the 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, an 

analysis was performed by Ohio EPA in order to demonstrate 

the improvement in air quality is not based on unusually 

favorable meteorology. 

Ohio EPA analyzed the maximum fourth-high eight-hour ozone 

value for May, June, July, August and September, years 2000 to 

2015. The values were analyzed against average monthly 

temperatures, the number of days with a temperature exceeding 

80° F, and the average relative humidity. While the formation of 

tropospheric ozone is dependent on a large number of 

atmospheric variables, ozone formation is strongly and positively 

correlated with elevated temperatures and humidity. The 

utilization of an extended period of record (2000-2015) should 

eliminate or dampen the influence of other meteorological 

variables affecting ozone formation, such as wind direction and 

wind speed.

Meteorological data for the Cleveland-Akron-Lorain, OH area 

was compiled from monthly local climatological data obtained 

from the National Oceanic and Atmospheric Administration’s 

National Climatic Data Center (NCDC). The data was recorded 

at the meteorological station located at the Cleveland-Hopkins 

International Airport, WBAN 14820. Ohio EPA has previously 

determined that data from this meteorological station is 

representative of meteorological conditions across the 

nonattainment area, and utilizes this same data for New Source 

Review and Prevention of Significant Deterioration air quality

permit modeling applications. Monitor data was compiled from 

the U.S. EPA’s AQS database for the same period.

The first analysis compared the maximum eight-hour ozone 

concentration at each monitor in the Cleveland-Akron-Lorain, OH

area to the number of days where the maximum temperature 

was greater than or equal to 80° F. The results of this analysis 

are shown in Figure 2. 
32

Figure 2 – Maximum eight-hour ozone concentrations versus number 

of days greater than or equal to 80° F for Cleveland

Monitors

The data shown in Figure 2 indicates that while there is some 

correlation between the number of days in which temperatures 

were at or exceeded 80° F, this correlation is not 1 to 1. While 

there is clearly some degree of correlation when comparing one 

year to the next, the same is not observed when examining the 

monitor values and temperature data over the period of study. 

Secondly, a clear trend in decreasing ozone concentrations at all 

monitors is apparent, while no such trend is observed in the 

temperature data. Lastly, there is a clear similarity in the 

recorded ozone values, which is consistent with the regional 

nature of ground-level ozone formation.

To further examine the relationship between meteorological 

factors and ozone concentrations, Ohio EPA examined the 

relationship between average summer temperatures for each 

year of the 2000 to 2015 period and the 4th maximum eight-hour 

ozone concentration. Given the similarity of ozone 

concentrations observed at each monitor (see Figure 2) and the 

regional nature of ozone formation, Ohio EPA conducted this 

analysis using the average 4th maximum eight-hour ozone 

concentration from all monitors in the Cleveland-Akron-Lorain, 

OH area. The results of this analysis are shown in Figure 3.
33

Figure 3 – Average maximum 4th high eight-hour ozone concentrations 

versus average summer temperatures

The data shown in Figure 3 indicates that while there is some 

correlation between average summer temperatures and ozone 

concentrations, this correlation does not exist over the study 

period. The linear regression lines for each data set 

demonstrate that average summer temperatures have increased 

over the 2000 to 2015 period, while average ozone 

concentrations have decreased. The correlation between 

temperature and ozone formation is well established; these data 

serve as strong evidence to suggest that reductions in 

precursors are responsible for the significant reductions in 

elevated ozone concentrations in the Cleveland-Akron-Lorain, 

OH area and not due to unusual or favorable summer 

temperatures. 

Lastly, Ohio EPA analyzed the relationship between average 

summertime relative humidity and average 4th maximum eighthour ozone concentrations in the Cleveland-Akron-Lorain, OH

area. As with the data shown in Figure 3, Ohio EPA considered 

the overall trend in ozone monitors by analyzing the average of 

4

th maximum 8-hour concentrations across all monitors in the 

area. These data are shown in Figure 4.
34

Figure 4 – Average maximum 4th high eight-hour ozone concentrations 

versus average summer relative humidity

The data presented in Figure 4 do not indicate a correlation 

between relative humidity and ozone concentrations, and the 

period of study represents a significant spread of average 

summertime relative humidity. 

 

The analyses of meteorological variables associated with ozone 

formation above further support Ohio’s demonstration that the

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 unusually 

favorable meteorology. The extended study period should 

dampen the effects of minor variations in wind directions and 

wind speeds, and provides a sufficient basis to examine longterm trends in both the meteorological variables and the regional 

ozone concentrations in the Cleveland-Akron-Lorain, OH area.

 

Requirement 5 of 5

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

emission levels, including an annual emission statement from major sources.

Demonstration

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

submit air emissions information annually, in accordance with 

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

Ohio EPA prepares a new periodic inventory for all ozone 

precursor emission sectors every three years. These ozone 

precursor inventories will be prepared for future years as 

necessary to comply with the inventory reporting requirements 
35

established in the CFR. Emissions information will be compared 

to the 2011 base year and the 2030 projected maintenance year 

inventories to assess emission trends, as necessary, and to 

assure continued compliance with the ozone standard.
36

CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4

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). In addition, on July 18, 2014, Ohio EPA submitted a 

SIP revision for this area and U.S. EPA published a proposal 

and direct final action approving that submittal on March 10, 

2016 (81 FR 12626 and 81 FR 12591). The approval was 

effective May 9, 2016. As discussed in Chapter Four 

(Requirement 4), Ohio EPA submits, and commits to submit, 

emission inventories (statements) every three years. 

Requirement 2 of 4

Evidence that control measures required in past ozone SIP revisions have 

been fully implemented.

Background

On October 27, 1998, U.S. EPA promulgated the NOx SIP Call 

requiring 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 promulgated this 

rule in 2001. NOx SIP Call requirements are incorporated into 

permits along with monitoring, recordkeeping, and reporting 

necessary to ensure ongoing compliance. Ohio EPA also has 

an active enforcement program to address violations discovered 

by field office staff. Compliance is tracked through the Clean 

Air Markets data monitoring program. Beginning in 2004, this 

rule accounts for a reduction of approximately 31 percent of all 

NOx emissions statewide compared to previous uncontrolled 

years. The other 21 states also have adopted these rules.

As discussed in detail below, U.S. EPA subsequently replaced 

the NOx SIP Call with CAIR and CSAPR. CSAPR continues to 
37

be implemented and amounts to even further reductions than 

that realized under the NOx SIP Call. 

Section 182(b) contains additional provisions applicable to 

moderate nonattainment areas, for which the Cleveland-AkronLorain, OH area was under the one-hour standard and the 1997 

eight-hour standard. Section 182(b)(3) requires gasoline vapor 

recovery systems for gasoline dispensing stations in the area, 

and Section 182(b)(4) requires motor vehicle inspection and 

maintenance programs, and Section 182(b)(2) requires RACT 

under Section 172(c)(1).

Demonstration

NOx SIP Call

Controls for EGUs under the NOx SIP Call 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 3745-1410 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 stayed in place through 2008, at which time the CAIR 

program superseded it as discussed above. 

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

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

day emissions) stationary internal combustion engines. Ohio 

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

combustion engines, all used in natural gas pipeline 

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

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

anticipated. Completion of the compliance plan occurred by May 

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

The 2007 controlled NOx emissions are 599 tons statewide for 

the ozone season.

 

10 http://www.epa.state.oh.us/dapc/regs/3745-14/3745_14.html
38

As discussed further below, starting January 1, 2009, CAIR 

commenced and emissions covered by this program have 

continued trending downward. 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 implementation of 

CAIR. CAIR’s cap and trade program stayed in place through 

2014, at which time the CSAPR program superseded it.

The following graph depicts the trend in NOx emissions from 

EGUs for the entire nonattainment area:

Figure 5 - NOx Emissions from EGUs – Entire Nonattainment Area 

Electric Generating Units,

2003-2014

VOC RACT

The Cleveland-Akron-Lorain, OH area was required to adopt 

RACT for the following source categories under Section 

182(b)(2) for the one-hour standard and the 1997 eight-hour 

ozone standard: (a) all VOC sources covered by Control 

Technique Guidelines (CTGs) issued between November 15, 

1990 and the date the Cleveland area attained the one-hour 

ozone standard; (b) all VOC sources covered by a CTG issued 

prior to November 15, 1990; and (c) all other major non-CTG 

stationary sources in the Cleveland area. 
39

U.S. EPA approved Ohio EPA’s VOC RACT rules on September 

7, 1994 (59 FR 46182), October 23, 1995 (60 FR 54308), April 

25, 1996 (61 FR 18255), and July 28, 2009 (74 FR 37171). 

RACT rules have been applied to all new sources locating in 

Ohio since that time. RACT requirements are incorporated into 

permits along with monitoring, recordkeeping, and reporting 

necessary to ensure ongoing compliance. Ohio EPA also has 

an active enforcement program to address violations discovered 

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

Chapter 3745-2111.

Gasoline Vapor Recovery Systems

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. However, some 

areas, including Ohio, retained Stage II requirements to provide 

a control method to comply with rate-of-progress emission 

reduction targets. Congress recognized that onboard refueling 

vapor recovery and Stage II would eventually become 

redundant, and actually increase emissions, and provided the 

U.S. EPA authority to allow states to remove Stage II from their 

SIPs after U.S. EPA finds that onboard refueling vapor recovery 

is in widespread use. On May 16, 2012, the U.S. EPA 

determined that onboard refueling vapor recovery technology is 

in widespread use throughout the motor vehicle fleet for 

purposes of controlling motor vehicle refueling emissions. This 

action (77 FR 28772) also provided notice of an upcoming 

guidance document for states to use to prepare a SIP revision to 

remove or phase-out Stage II controls. U.S. EPA published this 

 

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

guidance on August 7, 2012 (EPA-457/B-12-001). The 

guidance noted that since Section 182(b)(3) requirements no 

longer applied, the only requirements for Stage II controls are 

state SIPs (which includes Ohio, as noted above), Section 

184(b)(2) for areas in the ozone transport region (does not apply 

to Ohio), and section 193 for any area that adopted Stage II 

controls prior to November 15, 1990 (does not apply to Ohio). In 

order to remove Stage II control requirements from the SIP, CAA 

Section 110(l) is required to be addressed. Ohio EPA 

conducted this demonstration and submitted the SIP revision 

request to U.S. EPA on July 15, 2015. This demonstration 

included a new requirement for the use of low permeation hoses

which will provide even greater VOC emissions reductions in the 

future.

Motor Vehicle Inspection and Maintenance Program

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 under Section 182(b)(4). 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 continues to be being implemented in this area. 

In addition to the above, there are several measures beyond the 

CAA requirements that have been implemented in this area.

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 were phased in 

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

emission reductions were 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 were

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. 
41

Tier III Emission Standards for Vehicles and Gasoline Sulfur 

Standards

In March 2014, U.S. EPA finalized a federal rule to further 

strengthen Tier II vehicle emission and fuel standards. This rule 

will require automakers to produce cleaner vehicles and 

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

phased in between 2017 and 2025. Tier III requires all 

passenger vehicles to meet an average standard of 0.03 

gram/mile of NOx. Compared to Tier II, the Tier III tailpipe 

standards for light-duty vehicles are expected to reduce NOx 

and VOC emissions by approximately 80%. Tier III vehicle 

standards also include evaporative standards using onboard 

diagnostics that will result in a 50% reduction in VOC emissions 

compared to Tier II reductions. The rule reduces the sulfur 

content of gasoline to 10 ppm, beginning in January 2017.

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 was phased in from 2004 through 2007. This 

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

This rule resulted 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 cut emissions from non-road diesel engines by 

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

in this rule, accounted for 47 percent of diesel particulate matter 

(PM) and 25 percent of NOx from mobile sources nationwide. 

Sulfur levels were reduced in non-road diesel fuel by 99 percent

from previous levels, from approximately 3,000 parts per million 

(ppm) to 15 ppm in 2009. New engine standards took effect, 

based on engine horsepower, starting in 2008.

Non-road Spark-Ignition Engines and Recreational Engine 

Standards

Effective in January 2003, this standard regulates NOx, VOCs, 

and carbon monoxide (CO) for groups of previously unregulated 

non-road engines. This standard applies to all new engines sold 

in the United States and imported after the standards went into 

effect. The standard applies to large spark-ignition engines 
42

(forklifts and airport ground service equipment), recreational 

vehicles (off-highway motorcycles and all-terrain vehicles), and 

recreational marine diesel engines. When all of the non-road 

spark-ignition engines and recreational engine standards are 

fully implemented, an overall 80% reduction in NOx, 72% 

reduction in VOC, and 56% reduction in CO emissions are 

expected by 2020.

Reciprocating Internal Combustion Engine Standards

This new standard, effective in May 2010, regulates emissions of 

air toxics from existing diesel powered stationary reciprocating 

internal combustion engines that meet specific site rating, age, 

and size criteria. These engines are typically used at industrial 

facilities (e.g. power, chemical, and manufacturing plants) to 

generate electricity for compressors and pumps and to produce 

electricity to pump water for flood and fire control during 

emergencies.

The standard applies to stationary diesel engines: (1) that are 

located at a major source of air toxics emissions and that were 

installed prior to June 12, 2006; (2) used at major sources of air 

toxics, having a site rating of less than or equal to 500 

horsepower and were constructed or reconstructed before June 

12, 2006; and (3) used at major sources of air toxics for 

nonemergency purposes, having a site rating of greater than 500 

horsepower and were constructed or reconstructed before 

December 19, 2002.

Operators of existing engines were required to: (1) install 

emission control equipment that would limit air toxics up to 70% 

for stationary non-emergency engines with a site rating greater 

than 300 horsepower; (2) perform emission tests to demonstrate 

engine performance and compliance with rule requirements; and 

(3) burn ultra-low sulfur fuel in stationary non-emergency 

engines with a site rating greater than 300 horsepower. 

The engine standards took effect in 2013. According to U.S. 

EPA estimates, this rule has resulted in emission reductions 

from existing diesel-powered stationary reciprocating internal 

combustion engines of approximately 1,000, 2,800, and 27,000 

tpy of air toxics, fine particles (PM2.5), and CO, respectively.

Category 3 Marine Diesel Engine Standards

This new standard, effective in June 2010, promulgated more 

stringent exhaust emission standards for new large marine 

diesel engines with per-cylinder displacement at or above 30 
43

liters (commonly referred to as Category 3 compression-ignition 

marine engines) as part of a coordinated strategy to address 

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

emission standards are equivalent to those adopted in the 

amendments to Annex VI to the International Convention for the 

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

emission standards apply in two stages: near-term standards, for 

newly built engines, which took effect in 2011 and long-term 

standards requiring an 80% reduction in NOx emissions that will 

begin in 2016.

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

for the production and sale of diesel fuel with up to 1,000 ppm 

sulfur for use in Category 3 marine vessels. The regulations 

generally forbid production and sale of fuels with more than 

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

achieve equivalent emission reductions in other ways.

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

and fuel standards to foreign flagged and in-use vessels that are 

covered by MARPOL Annex VI. When this strategy is fully 

implemented in 2030, U.S. EPA estimates that NOx and PM2.5 

emissions in the U.S. will be reduced by approximately 1.2 

million tpy and 143,000 tpy, respectively.

Clean Air Interstate Rule (CAIR)/Cross State Air Pollution Rule 

(CSAPR)

On May 12, 2005, U.S. EPA published the following regulation: 

“Rule to Reduce Interstate Transport of Fine Particulate Matter 

and Ozone (CAIR); Revisions to Acid Rain Program; Revisions 

to the NOx SIP Call; Final Rule.” This rule established the 

requirement for states to adopt rules limiting the emissions of 

NOx and SO2 and provided a model rule for the states to use in 

developing their rules in order to meet federal requirements. The 

purpose of CAIR was to reduce interstate transport of PM2.5, 

SO2, and ozone precursors (NOx).

CAIR applied to any stationary, fossil fuel-fired boiler or 

stationary, fossil fuel-fired combustion turbine, or a generator 

with a nameplate capacity of more than 25 megawatt electrical 

(MWe) producing electricity for sale. This rule provided annual 

state caps for NOx and SO2 in two phases, with Phase I caps 

for NOx and SO2 taking effect in 2009 and 2010, respectively. 

Phase II caps were to become effective in 2015. U.S. EPA 

allowed limits to be met through a cap and trade program if a 

state chose to participate in the program. SO2 emissions from 
44

power plants in the 28 eastern states, as well as Washington 

D.C subject to CAIR were to be cut by 4.3 million tons from 2003 

levels by 2010 and 5.4 million tons from 2003 levels by 2015. 

NOx emissions were to be cut by 1.7 million tons by 2009 and 

reduced by an additional 1.3 million tons by 2015. In response to 

U.S. EPA’s rulemaking, Ohio submitted a CAIR SIP which was 

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

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

CAIR SIP was approved as a direct final action on September 

25, 2009 (74 FR 48857). Ohio’s rule included annual and 

seasonal NOx trading programs, and an annual SO2 trading 

program. This rule required compliance effective January 1, 

2009.

In July 2008, the D.C. Circuit court vacated CAIR and issued a 

subsequent remand without vacatur of CAIR in December 2008. 

The court then directed U.S. EPA to revise or replace CAIR in 

order to address the deficiencies identified by the court. On July 

6, 2011, U.S. EPA finalized CSAPR as a replacement for CAIR. 

On August 21, 2012, the U.S. Court of Appeals for the D.C. 

Circuit vacated CSAPR and directed U.S. EPA to continue 

administering CAIR “pending the promulgation of a valid 

replacement.” In a subsequent decision on the merits, the Court 

vacated CSAPR based on a subset of petitioners’ claims, but on 

April 29, 2014, the U.S. Supreme Court reversed that decision 

and remanded the case to the D.C. Circuit court for further

proceedings. Throughout the initial round of D.C. Circuit 

proceedings and the ensuing U.S. Supreme Court proceedings, 

the stay remained in place and U.S. EPA has continued to

implement CAIR. In order to allow CSAPR to replace CAIR in an 

equitable and orderly manner while further D.C. Circuit Court 

proceedings were held to resolve petitioner’s remaining claims,

U.S. EPA filed a motion asking the D.C. Circuit Court to lift the 

stay. U.S EPA also asked the court to toll all CSAPR compliance 

deadlines that had not passed as of the date of the stay order by 

three years. On October 23, 2014, the Court granted the U.S. 

EPA’s motion. CSAPR became effective on January 1, 2015, for 

SO2 and annual NOx, and May 1, 2015 for ozone season NOx.

Combined with other final state and U.S. EPA actions, CSAPR 

will reduce power plant SO2 emissions by 73% and NOx 

emissions by 54% from 2005 levels in the CSAPR region, which

includes the states of Indiana, Kentucky, and Ohio.
45

Oil and Natural Gas Industry Standards

This new standard, issued on April 17, 2012, regulates VOC and 

air toxic emissions from hydraulically fractured natural gas wells 

and also includes requirements for several other sources of 

pollution in the oil and natural gas industry that were previously 

unregulated in the United States. U.S. EPA estimates that these 

standards will apply to approximately 11,400 new natural gas 

wells hydraulically fractured each year and an additional 1,400 

existing natural gas wells refractured annually. When these 

standards are fully implemented in 2015, U.S. EPA estimates 

that VOC and air toxic emissions in the U.S. will be reduced by 

approximately 190,000 to 290,000 tpy and 12,000 to 20,000 tpy, 

respectively.

Mercury and Air Toxic Standards

This new standard, effective in April 2012, regulates emissions 

of mercury, acid gases, and non-mercury metallic toxic 

pollutants from new and existing coal and oil-fired EGUs. U.S. 

EPA estimates that this rule will apply to approximately 1,100 

coal-fired and 300 oil-fired EGUs at 600 power plants in the U.S. 

According to U.S. EPA, most facilities will comply with these

standards through a range of strategies, including the use of 

existing emission controls, upgrades to existing emission 

controls, installation of new pollution controls, and fuel switching.

Following promulgation of the rule, U.S. EPA received petitions 

for reconsideration of various provisions of the rule, including 

requests to reconsider the work practice standards applicable 

during startup periods and shutdown periods. U.S. EPA granted 

reconsideration of the startup and shutdown provisions as no 

opportunity to comment was provided to the public regarding the 

work practice requirements contained in the final rule. On 

November 30, 2012, U.S. EPA published a proposed rule 

reconsidering certain new source standards and startup and 

shutdown provisions in MATS. U.S. EPA proposed certain minor 

changes to the startup and shutdown provisions contained in the 

2012 final rule based on information obtained in the petitions for 

reconsideration. On April 24, 2013, U.S. EPA took final action on 

the new source standards that were reconsidered and also the 

technical corrections contained in the November 30, 2012, 

proposed action. U.S. EPA did not take final action on the 

startup and shutdown provisions and, on June 25, 2013, added 

new information and analysis to the docket and reopened the 

public comment period for the proposed revisions. U.S. EPA 

took final action on the remaining topics open for reconsideration 

on November 19, 2014. The compliance date for existing 
46

sources was April 16, 2015, while the compliance date for new 

sources was April 16, 2012.

On November 25, 2014, the U.S. Supreme Court accepted 

several challenges to the rules brought by the utility industry and 

a coalition of nearly two dozen states. On June 29, 2015, the 

U.S. Supreme Court ruled that U.S. EPA did not properly 

account for compliance costs when crafting the MATS rule and 

remanded the decision to the D.C. Circuit Court for 

reconsideration. 

EGUs

As discussed above, several federally enforceable changes at 

EGUs have resulted in reductions in NOx emissions and will 

result in further reductions than projected. Cleveland Electric

Illuminating Co., Eastlake Plant in Lake County (OH) 

permanently shutdown in April of 2015; First Energy Generation, 

LLC Lake Shore facility in Cuyahoga County (OH) permanently 

shutdown in April of 2015; and First Energy Generation, LLC 

Ashtabula Plant in Ashtabula County (OH) shutdown coal fired 

boilers in April of 2015 and December of 2015. 

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

ozone precursors. 

Requirement 3 of 4

Acceptable provisions to provide for new source review.

Background

Ohio has a longstanding and fully implemented New Source 

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

3745-3112. 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 200813 emission inventory, or 

for the closing of which credit was taken in demonstrating 

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

 

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

13 On July 18, 2014, Ohio EPA submitted its 2008 base year inventory as required under 

CAA Section 182(a)(1). 
47

reconstruct without meeting all applicable NSR requirements. 

Once the area is redesignated, Ohio EPA will implement NSR 

through the PSD program.

Requirement 4 of 4

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, OH area, will be submitted to 

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

Ohio, through Ohio EPA’s Legal section and the Ohio Attorney 

General’s Office, 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, OH area.
48

CHAPTER SIX

CONTINGENCY MEASURES

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

Requirement 1 of 4

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

Demonstration

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

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

CAA.

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

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

Demonstration

Ohio hereby commits to adopt and expeditiously implement 

necessary corrective actions in the following circumstances:

Warning Level Response:

A warning level response shall be prompted whenever an annual 

(1-year) fourth high monitored value of 79 ppb occurs in a single 

ozone season within the maintenance area. A warning level 

response will consist of a study to determine whether the ozone 

value indicates a trend toward higher ozone values or whether 

emissions appear to be increasing. The study will evaluate 

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

control measures necessary to reverse the trend taking into 

consideration ease and timing for implementation as well as 

economic and social considerations. Implementation of 

necessary controls in response to a warning level response 

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

event later than 12 months from the conclusion of the most 

recent ozone season (October 31). 

Should it be determined through the warning level study that 

action is necessary to reverse the noted trend, the procedures 

for control selection and implementation outlined under “action 

level response” shall be followed.
49

Action Level Response:

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

average fourth high monitored value of 76 ppb or greater occurs 

within the maintenance area. A violation of the standard (threeyear average fourth high value of 85 ppb or greater) shall also 

prompt an action level response. In the event that the action 

level is triggered and is not found to be due to an exceptional 

event, malfunction, or noncompliance with a permit condition or 

rule requirement, Ohio EPA in conjunction with the metropolitan 

planning organization or regional council of governments, will 

determine additional control measures needed to assure future 

attainment of the NAAQS for ozone. In this case, measures that 

can be implemented in a short time will be selected in order to 

be in place within 18 months from the close of the ozone season 

that prompted the action level. Ohio EPA will also consider the 

timing of an action level trigger and determine if additional, 

significant new regulations not currently included as part of the 

maintenance provisions will be implemented in a timely manner

and will constitute our response.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the 

necessary administrative and legal process. This process will 

include publication of notices, an opportunity for public hearing, 

and other measures required by Ohio law for rulemaking. 

If a new measure/control is already promulgated and scheduled 

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

measure/control is determined to be sufficient to address the 

upward trend in air quality, additional local measures may be 

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

analysis to demonstrate the proposed measures are adequate to 

return the area to attainment.

Requirement 3 of 4

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

event.

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and 

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

measures will be based on cost-effectiveness, emission 

reduction potential, economic and social considerations or other 
50

factors that Ohio EPA deems appropriate. Ohio EPA will solicit 

input from all interested and affected persons in the 

maintenance area prior to selecting appropriate contingency 

measures. Because it is not possible at this time to determine 

what control measures will be appropriate at an unspecified time 

in the future, the list of contingency measures outlined below is 

not exhaustive. 

1) Tighten VOC RACT on existing sources covered by U.S. 

EPA Control Technique Guidelines issued after the 1990 

CAA.

2) Apply VOC RACT to smaller existing sources.

3) One or more transportation control measures sufficient to 

achieve at least half a percent reduction in actual area 

wide VOC emissions. Transportation measures will be 

selected from the following, based upon the factors listed 

above after consultation with affected local governments:

a) trip reduction programs, including, but not limited 

to, employer-based transportation management 

plans, area wide rideshare programs, work 

schedule changes, and telecommuting;

b) traffic flow and transit improvements; and

c) other new or innovative transportation measures 

not yet in widespread use that affected local

governments deem appropriate.

4) Alternative fuel and diesel retrofit programs for fleet 

vehicle operations.

5) Require VOC or NOx emission offsets for new and 

modified major sources.

6) Increase the ratio of emission offsets required for new 

sources.

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

than 100 tons).

8) Adopt additional NOx RACT for existing combustion 

sources.
51

No contingency measure shall be implemented without providing 

the opportunity for full public participation during which the 

relative costs and benefits of individual measures, at the time 

they are under consideration, can be fully evaluated.

Requirement 4 of 4

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

requirements.

Demonstration

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

future controls.

NOx RACT

 EGUs

 other sources less 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

 plastic parts coating

 volatile organic liquid storage

 industrial solvent cleaning

 offset lithography

 industrial surface coating

 other sources greater than 50 tons per year
52

CHAPTER SEVEN

MODELING ANALYSIS

Summary of Modeling Results for National Emission Control Strategies in 

Final Rulemakings

Although U.S. EPA’s Redesignation Guidance does not require modeling for 

ozone nonattainment areas seeking redesignation, extensive modeling has 

been performed covering the Cleveland-Akron-Lorain, OH area to determine 

the effect of national emission control strategies on ozone levels. This area 

includes Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and 

Summit Counties in Ohio. These modeling analyses determined that this area 

was significantly impacted by ozone and ozone precursor transport and 

regional NOx reductions will help the area attain the 2008 eight-hour ozone

standard of 75 ppb in this area.

U.S. EPA Modeling Analysis for Interstate Transport “Good Neighbor” 

Provision

U.S. EPA conducted modeling for the Interstate Transport “Good Neighbor” 

Provision. This analysis was performed in 2014 and included in the “Air Quality 

Modeling Technical Support Document for the 2008 Ozone NAAQS Transport 

Assessment” to assist states in developing “Good Neighbor SIPs,” as required 

by the CAA to address interstate transport of air pollution that affects 

downwind states' ability to attain and maintain the 2008 eight-hour ozone 

standard. Some of the major federal emission strategies included in the 

modeling are: National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) for Reciprocating Internal Combustion Engines (RICE) and 

cement manufacturing plants, the Boiler Maximum Achievable Control

Technology (MACT) rule, the Energy Independence and Security Act (EISA) 

renewable fuel standard mandate, New Source Performance Standards 

(NSPS) for VOC controls, the Mobile Source Air Toxics rule, Tier III Emission 

Standards for Vehicles and Gasoline Sulfur Standards, Emission Standards for 

Locomotives and Marine Compression-Ignition Engines, and the Nonroad

Spark-Ignition Engines and Recreational Engine Standards.

This modeling was conducted to identify monitoring sites that may have 

difficulty attaining the 2008 eight-hour ozone standard in 2018 and identify 

states that were contributing to attainment issues at a given monitoring site. 

The air quality model used for this rulemaking was the Comprehensive Air 

Quality Model with Extensions (CAMx) version 6.10. The modeling domain 

consisted of a 12 kilometer (km) x 12 km coarse grid covering the continental 

United States and portions of Canada and Mexico and 25 vertical layers from 

the surface up through the troposphere to a height of 50 millibars of pressure. 
53

Base year 2011 emissions were modeled. Meteorology from 2011 was created 

using the Weather Research Forecasting (WRF) Model version 3.4 and was 

used for the base case and projected year modeling runs. More detailed

information on the CAMx input file and additional data used for the 

photochemical modeling can be found in U.S. EPA’s “Air Quality Modeling 

Technical Support Document for the 2008 Ozone NAAQS Transport 

Assessment,” dated January 2015.

Table 32 shows the results of U.S. EPA’s “Good Neighbor” Provision modeling 

for ozone impacts at the ozone monitors in the Cleveland-Akron-Lorain, OH

area. The monitor identification number, county, and the 2009 – 2013 eighthour ozone base period average design values that were used to calculate 

2018 projected average design values. Note that the 2009 –2013 average 

design values were calculated by averaging the three 3-year design values 

from 2009 – 2011, 2010 – 2012, and 2011 – 2013.

Model results are used in a relative rather than absolute sense. Relative use of 

the model results calculates the fractional change in maximum concentrations 

based on two different emission scenarios, 2011 NEI emissions and 2018 

projected emissions for this exercise. This fractional change, also known as a 

relative response factor (RRF), can be applied to each monitor’s average base 

period design value to determine ozone impacts. This approach differs from 

using the absolute or actual modeled result, which may show under- or overpredictions with the actual monitored values. The 2009 – 2013 average design 

values were multiplied by the corresponding RRF to determine all 2018 

projected average design values.
54

Table 32- Comparison of Cleveland-Akron-Lorain, OH Area Average 

Design Values with U.S. EPA “Good Neighbor” Provision 

Modeling Results (ppm)

Monitor ID County

Monitored 

Average Design 

Value 2009-

2013

U.S. EPA 

Projected 

Average 

Design Value 

2018

39-007-1001 Ashtabula 0.0773 0.0668

39-035-0034 Cuyahoga 0.0777 0.0639

39-035-0060 Cuyahoga 0.0685 0.0560

39-035-0064 Cuyahoga 0.0700 0.0602

39-035-5002 Cuyahoga 0.0767 0.0630

39-055-0004 Geauga 0.0747 0.0653

39-085-0003 Lake 0.0800 0.0649

39-085-0007 Lake 0.0717 0.0584

39-093-0018 Lorain 0.0717 0.0586

39-103-0004 Medina 0.0690 0.0607

39-133-1001 Portage 0.0683 0.0604

39-153-0020 Summit 0.0720 0.0642

Due to the differences in the base period 2009 – 2013 average design values 

and more current average design values for all of the Cleveland-Akron-Lorain, 

OH area ozone monitors, a comparison of these values, as well as the 2018 

projected average design values taken from the “Good Neighbor” Provision 

was made, and are presented in Table 33. The current average design values 

were calculated by averaging the three 3-year design values from 2010 –

2012, 2011 – 2013, and 2012 – 2014, and 2013 - 2015.

Comparison of the 2009 – 2013 average design values with current 3-year 

average design values for all ozone monitors in the Cleveland-Akron-Lorain, 

OH area show that current average design values are below the average eighthour ozone design values for 2009 – 2013.

Based on the 2009 – 2013 average design values, the 2018 projected average 

design values modeled well below the 2008 eight-hour ozone standard of 75 

ppb. With the exception of the Cuyahoga monitor (39-035-0064) and Lake 

County monitors (39-085-0003 and 39-085-0007), if the modeling was 

conducted with the 2010 – 2014 average design values, the 2018 projected 

average design values would be lower than the current results, further reenforcing maintenance of the standard. Modeling conducted using the 2011-

2015 average design values would result in 2018 projected design values at all 

monitors well below the current results, again further reinforcing maintenance 

of the standard. For the highest monitor in the area (Lake County monitor 39-
55

085-0003), the 2018 projected average design value is 0.0649 ppm, well below 

the level of the 2008 eight-hour ozone standard that demonstrates attainment 

(0.0757 ppm).

Table 33- Comparison of Cleveland-Akron-Lorain, OH Area Current 

Design Values with U.S. EPA “Good Neighbor” Design 

Values (ppm)

Monitor ID County

Monitored 

Average 

Design Value 

2009-2013

Monitored 

Average 

Design Value 

2010-2014

Monitored 

Average 

Design Value 

2011-2015

U.S. EPA 

Projected 

Average 

Design Value 

2018

39-007-1001 Ashtabula 0.0773 0.0753 0.0720 0.0668

39-035-0034 Cuyahoga 0.0777 0.0777 0.0740 0.0639

39-035-0060 Cuyahoga 0.0685 0.0673 0.0647 0.0560

39-035-0064 Cuyahoga 0.0700 0.0707 0.0673 0.0602

39-035-5002 Cuyahoga 0.0767 0.0757 0.0710 0.0630

39-055-0004 Geauga 0.0747 0.0737 0.0700 0.0653

39-085-0003 Lake 0.0800 0.0803 0.0770 0.0649

39-085-0007 Lake 0.0717 0.0723 0.0700 0.0584

39-093-0018 Lorain 0.0717 0.0717 0.0677 0.0586

39-103-0004 Medina 0.0690 0.0690 0.0667 0.0607

39-133-1001 Portage 0.0683 0.0673 0.0640 0.0604

39-153-0020 Summit 0.0720 0.0680 0.0637 0.0642

LADCO Modeling for Eight-Hour Ozone Standard

The LADCO performed photochemical modeling for ozone, which used the 

most recent emissions inventories and model updates. This modeling was

performed to support attainment demonstrations for the five-state LADCO 

region. The photochemical model used by LADCO and Indiana for the eighthour ozone standard analysis is CAMx version 6.11, developed by Environ. 

This model has been accepted by U.S. EPA as an approved air quality model 

for regulatory analysis and attainment demonstrations. Requirements of 40 

CFR 51.112, as well as the “Guidance on the Use of Models and Other 

Analyses in Attainment Demonstrations for the 8-hour Ozone NAAQS” (EPA454/R-05-002, Oct. 2005), are satisfied with the use of CAMx for attainment 

demonstrations. Meteorology from 2011, as well as 2011 base year emissions 

(based on legally enforceable emission controls required by consent decrees, 

state rules, or permit), was used to conduct this modeling. The base period 

average design values for attainment purposes were calculated from the 

periods 2009 – 2011, 2010 – 2012, and 2011 – 2013. The projected year 

modeled was 2018.
56

Table 34 shows that modeled ozone concentrations in the Cleveland-AkronLorain, OH area for 2018 will be below the eight-hour ozone standard of 75 

ppb. As shown in Table 32 above, the current 2011 – 2015 average design 

values decreased from the 2009 – 2013 average design values, thus the 

projected average design values would be lower than the LADCO modeling 

results using the latest average design values. For Lake County monitor 39-

085-0003, the projected average design value was well below the 2008 eighthour ozone standard at 0.0644 ppm. If the LADCO modeling was performed 

using the lower 2011 – 2015 average design value, it is expected that the 2018 

projected average design value would be further below the standard for the 

Lake County monitor, as well as all other monitors in the area.

Table 34- LADCO’s Modeling Results for the Cleveland-Akron-Lorain, 

OH Area (ppm)

Monitor ID County

Monitored 

Average 

Design Value 

2009-2013

Monitored 

Average 

Design Value 

2010-2014

Monitored 

Average 

Design Value 

2011-2015

LADCO 

Projected 

Average Design 

Value 2018

39-007-1001 Ashtabula 0.0773 0.0753 0.0720 0.0663

39-035-0034 Cuyahoga 0.0777 0.0777 0.0740 0.0625

39-035-0060 Cuyahoga 0.0685 0.0673 0.0647 0.0547

39-035-0064 Cuyahoga 0.0700 0.0707 0.0673 0.0612

39-035-5002 Cuyahoga 0.0767 0.0757 0.0710 0.0659

39-055-0004 Geauga 0.0747 0.0737 0.0700 0.0672

39-085-0003 Lake 0.0800 0.0803 0.0770 0.0644

39-085-0007 Lake 0.0717 0.0723 0.0700 0.0586

39-093-0018 Lorain 0.0717 0.0717 0.0677 0.0579

39-103-0004 Medina 0.0690 0.0690 0.0667 0.0632

39-133-1001 Portage 0.0683 0.0673 0.0640 0.0623

39-153-0020 Summit 0.0720 0.0680 0.0637 0.0660

Summary of Existing Modeling Results

U.S. EPA and LADCO modeling shows that national emission control 

measures will bring the Cleveland-Akron-Lorain, OH area into attainment of 

the 2008 eight-hour ozone NAAQS by 2018, if not earlier. Rulemakings to be 

implemented in the next several years will provide assurance that air quality

will continue to meet the standard into the future. U.S. EPA’s modeling support 

for the Interstate Transport “Good Neighbor” Provision show future year design 

values for the Cleveland-Akron-Lorain, OH area will attain the ozone standard 

with 2018 projected average design values below the 2008 eight-hour ozone

standard of 75 ppb. In addition, LADCO’s modeling results continue to show 

2018 projected average design values below the eight-hour ozone standard. 
57

U.S. EPA and LADCO modeling demonstrates that the Cleveland-AkronLorain, OH ozone nonattainment area will attain the 2008 eight-hour ozone 

standard. Future national and local emission control strategies will ensure that 

the area’s attainment will be maintained with an increasing margin of safety 

over time.
58

CHAPTER EIGHT

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in 

the widely distributed county publications.

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

on June 27, 2016 at 2110 East Aurora Road, Twinsburg, Ohio 44087. The 

public comment period closed on June 27, 2016. No testimony was provided 

at the public hearing and no comments were received during the public 

comment period. Appendix C includes a copy of the public notice and 

transcript from the public hearing and comment period.
59

CHAPTER NINE

CONCLUSIONS

The Cleveland-Akron-Lorain, OH ozone nonattainment area has attained the 

2008 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, OH 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, OH ozone 

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

EPA approval of the maintenance plan provisions contained herein. In 

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

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

for areas redesignated for the eight-hour ozone standard.
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