ATTACHMENT E 
Missing Monitoring Data Imputation Analysis 

Monitoring Site 39-057-0005 Greene County, Ohio

Ohio Environmental Protection Agency 

Lazarus Government Center 

50 West Town Street, Suite 700 

Columbus Ohio 43215 

Prepared by Ohio EPA 

Division of Air Pollution Control 

State Implementation Plan Section 

March 2011 
2 

Dayton-Springfield PM2.5 Nonattainment Area 

Incomplete Monitoring Data Substitution Analysis 

The current Dayton-Springfield nonattainment area is located in southwest Ohio and 

includes the following counties: Clark, Greene, and Montgomery. 

The area has three monitors measuring PM2.5 concentrations, which are operated by 

the Regional Air Pollution Control Agency (RAPCA)1, which is part of the Montgomery 

County Health Department. A listing of the design values based on the three-year 

average of the annual mean concentrations from 2008 through 2010 is shown in Table 

1. The design values calculated for the Dayton-Springfield area shows that the annual 

PM2.5 NAAQS has been attained. 

Table 1 - Monitoring Data for the Dayton-Springfield area for 2008 – 2010 

Average

2008 2009 2010 2008-2010

39-023-0005 Clark 12.7 12.4 13.1 12.7

39-057-0005 Greene 11.6 11.5 13.2 12.1

39-113-0032 Montgomery 13.2 12.4 14.0 13.2

Less than 75% capture in at least one quarter

Annual Standard

Site County Year

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

However, based on Section 107(d)(3)(E)(i) of the Clean Air Act (CAA) the PM2.5 

monitoring has to show that the three-year average of the annual mean values, based 

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

below 15.0/m3. Moreover, in accordance with the CAA Amendments, three complete 

years of monitoring data are required to demonstrate attainment at a monitoring site. In 

addition, U.S. EPA regulations require at least 75% data capture in each quarter of a 

consecutive 3-year period in order for a design value to be valid. 

Table 1 shows that the monitor site in Greene County (site 39-057-0005) did not comply 

with the 75% data capture requirement in 2010. Specifically, the third quarter (July, 

August, and September) of 2010 has only 45% capture. This monitoring site underwent 

roof repairs (reroofing) from 08/12/2010 through 09/29/2010 for a total of 17 missing 1-

in-3 day PM2.5 FRM runs. In 2010 there were scheduled a total of 122 scheduled runs. 

It is important to mention that this site is also the lowest reading site for PM2.5. 

In order to comply with U.S.EPA 75% capture requirements, Ohio EPA prepared a 

statistical analysis using multiple imputations. Imputing missing values for site 39-057-

 

1 RAPCA is a Local Air Agency that contracts with Ohio EPA and receives grants from U.S. EPA to enforce state and 

local air pollution control regulations in the six-county region (Preble, Darke, Miami, Montgomery, Clarke, and 

Greene). 
3 

0005 and then doing an ordinary analysis as if the imputed values were real 

measurements (this approach is usually better than excluding subjects with incomplete 

data). Most methods for accounting for having incomplete data can be complex; the 

bootstrapping method however, is an easy method to implement even though the 

computations can be slow. To use the bootstrap, to correctly estimate variances of 

regression coefficients, one must repeat the imputation process and the model fitting 

perhaps 1000 times using a resampling procedure. 

Multiple imputations use random draws from the conditional distribution of the target 

variable given the other variables. When a regression model is used for imputation, the 

process involves adding a random residual to the “best guess” for missing values, to 

yield the same conditional variance as the original variable. To properly account for 

variability due to unknown values, the imputation will be repeated 1000 times. 

Imputing missing data for Dayton-Springfield PM2.5 nonattainment area 

For simplification purposes we will call Site 39-057-0005 Site A, Site 39-023-0005 Site 

B, and Site 39-113-0032 Site C. 

1. Dayton-Springfield Annual PM2.5 Design Value History 

Table 2 – Historic Design Values for the Dayton-Springfield area from 1999 to 

2010 

Site Site County Annual Design Value 

1999-

2001 

2000-

2002 

2001-

2003 

2002-

2004 

2003-

2005 

2004-

2006 

2005-

2007 

2006-

2008 

2007-

2009 

2008-

2010 

39-057-0005 A Greene 12.4 13.2 13.6 12.3 12.1 12.1

39-023-0005 B Clark 15.6 15.4 14.7 14.2 14.8 14.4 14.8 13.5 13.2 12.7

39-113-0032 C Montgomery 16.0 15.5 15.9 15.2 15.5 14.1 13.7 13.2

 incomplete data (quarter with <75% capture) 

 violating DV 

From Table 2, all three sites have design values (DV) that meet the PM2.5 annual 

standard since 2006-2008 period. However, site A has not proven clean data in 2010 

and therefore it makes the entire nonattainment area non-eligible for redesignation. As 

mentioned before, the lack of clean data in 2010 is due to the low percentage of data 

capture in one or more quarters of 2010. 

Multiple imputations and bootstrapping methods will help to generate the necessary 

missing data to determine 2010 completeness and recalculate the 2008-2010 DV. 

2. Correlation, Quarterly Data Capture, and Data Site Pairing 

Linear regression analyzes the relationship between two variables, X and Y. For each 

subject, there is a known X and Y and we want to find the best straight line through the 

data. The goal of linear regression is to find the line that best predicts Y from X. Linear 
4 

regression does this by finding the line that minimizes the sum of the squares of the 

vertical distances of the points from the line. To determine which site combination (A 

and B or A and C) has the best data (best fit) from which to impute missing data for site 

A we determine the correlation between sites A and B and the correlation between A 

and C. 

The correlation value (R2) is useful because it describes the degree of relationship 

between two variables2 (variables or site concentrations in sites A, B and C). R2 is only 

a descriptive statistics. Roughly speaking, we associate a high value of R2 with a good 

fit of the regression line and associate a low value of R2 with a poor fit. 

The mean of the quarterly data captured (the mean of the percentage captured) will 

allow verifying the central tendency of each site, which will help to determine what site 

(B or C) has a more data completeness to impute for site A. 

Finally, although not as statistically significant as the correlation, or as the mean of the 

percentage captured, pairing the site data seeks to reduce variability in order to make 

more precise comparisons with fewer observations. Pairing the data will help to 

determine which site, B or C, have more data when paired with A. 

Below are the results for sites A vs. B and for sites A vs. C 

 

2 An R2 value of 0.0 means that knowing X does not help to predict Y, there is no linear relationship 

between X and Y. When R2 equals 1.0, all points lie exactly on a straight line with no scatter; knowing X 

predicts Y perfectly. 
Linear Regression and Correlation for Site A vs. Site B 

Regression Statistic

Multiple

R 0.96

R Square 0.92Adjusted

R Square 0.9

Standard Error 1.78Observations 

Coefficients Standard Error t Stat

P‐value Lower 95% Upper 95%

Intercept 0.521517632 0.136976611 3.80734805 0.00015108 0.252646159 0.790389106X Variable 1 0.873190988 0.00882923 98.89775017

0 0.855860087 0.890521889

ANOVA

df SS MS

F Significance

F

Regression 1 31013.99463 31013.99463 9780.764989

0

Residual 809 2565.271907 3.170917067Total 810 33579.26654
Linear Regression and Correlation for Site A vs. Site C 

Regression Statistics

Multiple

R 0.940

R Square 0.885Adjusted

R Square 0.885

Standard Error 2.193Observations 

Coefficients Standard Error t Stat

P‐value Lower 95% Upper 95%

Intercept 0.81715995 0.171189431 4.773425231 2.16082E‐06 0.481116 1.153203844X Variable 1 0.81295687 0.010452417 77.77692926

0 0.792439 0.833474906

ANOVA

df SS MS

F Significance

F

Regression 1 29110.49143 29110.49143 6049.250725

0

Residual 784 3772.802007 4.812247458Total 785 32883.29344
7 

Table 3 - Quarterly Data Capture 

      Monitoring Sites

      A B C Quarterly Data Capture 2003‐2010

2003 Q1 ‐  100% 87%

2003 Q2 ‐  93% 96%

2003 Q3 ‐  100% 100%

2003 Q4 73% 100% 89%

2004 Q1 71% 100% 100%

2004 Q2 93% 100% 90%

2004 Q3 100% 97% 97%

2004 Q4 90% 100% 90%

2005 Q1 97% 100% 100%

2005 Q2 97% 100% 100%

2005 Q3 100% 100% 100%

2005 Q4 100% 90% 97%

2006 Q1 100% 100% 100%

2006 Q2 97% 100% 97%

2006 Q3 94% 100% 100%

2006 Q4 100% 100% 97%

2007 Q1 97% 100% 100%

2007 Q2 93% 100% 100%

2007 Q3 100% 100% 100%

2007 Q4 93% 100% 97%

2008 Q1 97% 97% 93%

2008 Q2 100% 87% 98%

2008 Q3 94% 100% 98%

2008 Q4 100% 100% 95%

2009 Q1 100% 100% 94%

2009 Q2 100% 97% 100%

2009 Q3 100% 100% 90%

2009 Q4 97% 100% 100%

2010 Q1 97% 100% 97%

2010 Q2 100% 100% 100%

2010 Q3 45% 100% 97%

2010 Q4 100% 100% 100%

MEAN 94% 99% 97%

Table 4 - Paired Data Site 

      29 ‐ Quarter look (2003 Q4 ‐ 2010 Q4)   

Site Site pairs Q1 pairs Q2 pairs Q3 pairs Q4 Total

A B 197 199 191 224 811

A C 186 194 188 218 786
8 

The correlation between A and B is 0.9236 and the correlation between A and C is 

0.8853. This shows that the relationship between A and B is stronger than the 

relationship between A and C. From the mean of the quarterly data captured (Table 3), 

we can observe that Site B has more data completeness (99%) than Site C (97%); 

therefore Site B has a more complete data from where to impute for site A. In addition, 

from the data site pairing (Table 4) it can be observed that Site A and B have more 

paired data (in each quarter and in total) to establish a better relationship than Site A 

and Site C. 

Finally, based on the above results, it was determined that Site B has the best data, 

statistically significant (greater correlation, larger data completeness, and larger paired 

data) from which to impute missing data for Site A. Therefore, we will use multiple 

imputations and bootstrapping methods to generate the necessary data from Site B to 

impute on Site A missing values. 

3. Bootstrapping and Imputation 

The bootstrapping method randomly applies real residuals from the linear regression to 

the imputed current-period Site A values. A 1000 bootstrap runs adds a random residual 

to the “best guess” missing values yielding the same conditional variance as the original 

variable. A summary of the bootstrapping statistics is presented in Table 5, where the 

bootstrapping residual is -929.0569514e-6. 

Table 5 - Bootstrapping Summary Statistics 

Average -929.0569514e-6

SD 0.0356

Max 0.103

Min -0.137

Finally to impute the missing data using the bootstrapping residual we use the following 

equation, based on the linear regression from Site A vs. Site B: 

Site A concentration = Intercept + x Variable * Site B concentration + 

bootstrapping residual 

Where: 

Intercept = 0.521517632 (from linear regression) 

x Variable = 0.873190988 (from linear regression) 

Bootstrapping residual = -929.0569514e-6

Site B concentration = values in Site B 

After applying the above equation to all missing data in Site A, we recalculated the 

design values based on the three-year average of the annual mean concentrations for 
9 

all existing years in Site A (Site 39-057-0005). Table 6 shows Site 39-057-0005 before 

and after the imputation of missing data. Also the “new” site (with imputed values) 

shows a “new” passing DV for 2008-2010. 

Table 6 – Comparison Between Original and Imputed Values for Monitor 39-057-

0005 from 2004 to 2010

                           Annual Design Value

   Site Year 2004‐

2006

2005‐

2007

2006‐

2008

2007‐

2009

2008‐

   2004 2005 2006 2007 2008 2009 2010 2010

OLD 39-057-0005 12.1 15.5 11.9 13.3 11.6 11.5 13.2 13.2 13.6 12.3 12.1 12.1

NEW 39-057-0005 11.7 15.2 11.9 13.5 11.6 11.5 12.2 12.9 13.5 12.3 12.2 11.8

   incomplete data (quarter with <75% capture)                     

As we said before, the bootstrapping method randomly applies real residuals from the 

linear regression to the imputed current-period Site A values. A 1,000 bootstrap runs 

provided a 95% confidence interval for the imputed current-period design value. Table 7 

shows that, since the R2

 value between Site A and Site B was strong, predicting its 

relationship almost perfectly (R2

 = 0.9236), there is small variation between DV interval 

(as well as residual intervals) and it was needed to provide at least 3 significant 

decimals to show the different intervals. Table 7 shows that the DV = 11.763 has the 

most occurrences, confirming that the “new” DV 2008-2010 of 11.8, in Table 6, is the 

best guess of imputed data. 

Table 7 - Bootstrapping Residuals and DV Calculations 

Residual Design Value Frequency 

-0.14 11.754 3

-0.115 11.755 3

-0.09 11.757 20

-0.065 11.758 87

-0.04 11.760 179

-0.015 11.761 252

0.01 11.763 262

0.035 11.764 143

0.06 11.766 42

0.085 11.767 9

Ohio EPA believes that the above analysis has generated the most statistically 

significant results yielding to the “best” missing data statistically possible. This analysis 

should also satisfy US EPA requirements in terms of total percentage data capture and 

design values under the PM2.5 annual standard (15.0μg/m3). 

 
10 

References: 

Brownstone, David and Robert Valleta. 2000. Draft for JEP Econometrics Symposium. 

“The bootstrap and multiple imputations”. 

Harrel, Frank E. Jr. 2001. Springer Series in Statistics. “Regression modeling strategies: 

with applications to linear models, logistic regression, and survival analysis”. 

Mooney, Christopher Z., Robert D. Duval, Robert Duval. 1993. Sage Publications Inc. 

“Bootstrapping: a nonparametric approach to statistical inference” Issues 94-95. 
ATTACHMENT F 
Public Notice 

Ohio Environmental Protection Agency 

Redesignation and Maintenance Plan for the Dayton-Springfield 

Annual PM2.5 Nonattainment Area 

Clark, Green, and Montgomery Counties 

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

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

EPA) revise the current air quality designation for the Dayton-Springfield area, including 

Clark, Green, and Montgomery counties to attainment with respect to the 1997 annual 

PM2.5 national ambient air quality standard (NAAQS). Air quality monitoring data 

collected between 2008 and 2010 in the region demonstrate attainment of the NAAQS 

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

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

1997 annual PM2.5 standard in this area at least ten years into the future. 

Computer models show that existing state and federal emission reduction requirements 

are sufficient to attain and maintain the NAAQS in the Dayton-Springfield area. 

Therefore, Ohio EPA proposes to utilize existing emission inventory information and 

projections of future emissions as the demonstration of the ability to maintain the 

NAAQS in the Dayton-Springfield area in the future. 

The Dayton-Springfield area is currently designated as nonattainment for the 1997 

annual PM2.5 standard. As part of an acceptable maintenance plan, Ohio EPA is 

required to develop a contingency plan to provide for additional emission reductions if a 

violation of the NAAQS is monitored after the area has been redesignated. The plan 

which Ohio EPA is proposing to USEPA as part of this redesignation contains 

reductions which will help alleviate any ambient problem until a revised SIP can be 

developed. 

The State of Ohio proposes to: 

1. Request the U.S. EPA redesignate the Dayton-Springfield area to attainment with 

respect to the 1997 annual PM2.5 NAAQS and revise the maintenance plan. This 

request will document that existing enforceable control measures are responsible 

for the observed improvement in air quality. 

2. Designate existing controls as sufficient to maintain the NAAQS into the future. 

3. Commit to the proposed contingency plan. 

These actions must be noticed to allow public comment and to satisfy USEPA 

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

EPA’s reliance on the emission projections as evidence of attainment and maintenance 
and the commitment to institute contingency measures if ambient exceedances or 

violations trigger the contingency plan requirements. Written comments will be received 

on or before INSERT DATE at the following address: 

E-mail: Carolina.Prado@epa.state.oh.us

Mailing address: Carolina Prado 

Ohio Environmental Protection Agency, DAPC 

Lazarus Government Center 

P.O. Box 1049 

Columbus, Ohio 43216-1049 

Phone: (614) 728-1743 

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

redesignation request will be conducted as follows: May 3, 2011 at 1:30 PM, at Ohio 

EPA’s Southwest District Office located at 401 E. Fifth Street in Dayton, Ohio. 

All interested persons are entitled to attend or be represented at the hearing and give 

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

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

the close of business on May 3, 2011 will be considered by Ohio EPA prior to final 

action on this redesignation. Written statements submitted after May 3, 2011 may be 

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

the hearing. 

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

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

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

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

either Carolina Prado, (614) 644-2310, Carolina.Prado@epa.state.oh.us or Jennifer 

Hunter at (614) 644-3696, Jennifer.Hunter@epa.state.oh.us or mailed to Carolina Prado 

or Jennifer Hunter at the above address. 
REGIONAL AIR POLLUTION CONTROL AGENCY

Serving Clark, Darke, Greene, Miami, Montgomery & Preble Counties

117 South Main Street, Dayton, Ohio 45422-1280

(937) 225-4435 - Fax: (937) 225-3486

www.rapca.org

May 3, 2011

Ms. Carolina Prado

Ohio EPA

Lazarus Government Center

P.O. Box 1049

Columbus, Ohio 43216-1049

Dear Ms. Prado:

The Regional Air Pollution Control Agency (RAPCA) appreciates the opportunity to submit comments

on Ohio EPA's preliminary Redesignation Request and Maintenance Plan for the Dayton-Springfield

Annual PM-2.5 Nonattainment Area. RAPCA personnel appreciate very much the time and work effort

Ohio EPA personnel have put into the preparation ofthese recommendations.

Following U.S. EPA guidance document Proceduresfor Processing Requests to Redesignate Areas to

Attainment, Ohio EPA has assessed the following criteria to determine ifredesignation ofthe DaytonSpringfield Area to attainment for the annual PM-2.5 National Ambient Air Quality Standard (NAAQS)

is warranted:

1. Attainment ofthe standard

2. Approved State Implementation Plan

3. Determination that air quality improvement is due to permanent and enforceable reductions in

emissions

4. A fully approved maintenance plan

5. Determination that Section 110 and Part D requirements have been met.

Applying these criteria to the Dayton-Springfield area, Ohio EPA is proposing that the counties of

Montgomery, Greene, and Clark be redesignated to attainment for the annual PM-2.5 NAAQS.

While RAPCA fully supports Ohio EPA's decision to propose redesignation ofthe Dayton-Springfield to

attainment for the annual PM-2.5 NAAQS, a detailed review of emissions data and monitoring data

indicate that the evidence supporting the redesignation request is even stronger than has been stated by

Ohio EPA.

In the main document, tables 17 and 21 list current and projected emission inventories for NOx and S02

in Clark, Greene, and Montgomery Counties. These data in tons per year, along with the STARS2 Title 5

S02 emission inventory for RAPCAjurisdiction are summarized in the following table.
2005 2008 2015 2022

Total NOx 39,234 32,624 20,905 14,390

Total S02 11,232 9,849 9,829 9,556

Title 5 S02 9,074 6,576 --- ---

Approximately 75% ofthe total NOx reduction is attributable to onroad mobile source controls.

However, the S02 inventory is dominated by large stationary sources, and since projections evidently are

based on modeling conducted by staff at the Lake Michigan Air Directors Consortium (LADCO), very

little reductions in S02 emissions are projected. However, Title 5 data show that large decreases in S02

are occurring in RAPCAjurisdiction.

The LADCO modeling technical support document is attached as Appendix D to the redesignation

request. It is dated September 12, 2008 and has projected inventories and modeled ozone and PM-2.5

concentrations for 2009, 2012, and 2018. The modeled concentrations can be compared to the actual

monitored values for 2009.

Annual PM-2.5 at Dayton Library

2005 2009 2012 2018

LADCO model (w/CAIR) 15.5 13.2 12.9 12.4

RAPCA monitor 17.4 12.4 --- ---

Daily PM-2.5 at Dayton Library

2005 2009 2012 2018

LADCO model (w/CAIR) 37.8 30 30 30

RAPCA monitor 45.0 26.8 --- ---

While all ofthe LADCO modeling scenarios (there are three other scenarios less stringent than the

(w/CAIR) scenario) show PM-2.5 design values below the NAAQS in 2009 and into the future for the

Dayton Area, the modeling doesn't appear to capture all ofthe reductions in PM-2.5 concentrations that

are occurring in the Midwest. This issue may be much more important in larger metropolitan areas such

as Cleveland and Chicago.

We repeat our appreciation ofthe time and effort that Ohio EPA personnel put into the preparation of

these preliminary recommendations and we look forward to the opportunity to discuss our comments in a

future meeting. Please address any questions on these comments to either the writer or Andy Roth

Sincerely,

~dPJ

John A. Paul, RAPCA Administrator
Testimony

of

John A. Paul, Administrator

Regional Air Pollution Control Agency

Dayton, Ohio

Regarding Ohio EPA's Proposed Redesignation of

Clark, Greene, and Montgomery Counties

To Attainment for the

Annual National Ambient Air Quality Standard for PM-2.5

May 3, 2011

Pa e 1
Pa e 2

Good afternoon, my name is John A. Paul and I am the Administrator ofthe Regional Air

Pollution Control Agency (RAPCA) of Dayton, Ohio. RAPCA is the local agency responsible

for air pollution control activities in the Ohio counties ofClark, Darke, Greene, Miami,

Montgomery, and Preble.

This testimony is offered in support ofOhio EPA's proposal for redesignation ofClark, Greene,

and Montgomery Counties as attainment ofthe annual National Ambient Air Quality Standard

(NAAQS) for PM-2.5. We commend Ohio EPA for the completeness ofthe redesignation

package, and offer both this testimony and written comments as supplemental support.

The Ohio EPA proposal discusses the five criteria for redesignation from USEPA's Procedures

for Processing Requests to Redesignate Areas to Attainment. RAPCA staffreviewed the

complete OHIO EPA document and offer the following in support.

RAPCA operates four PM-2.5 air quality monitoring stations. Three-year average PM-2.5

concentrations, along with the applicable standards are shown in the following two figures.

"Montgomery" are data from the urban core ofDayton, and represent the highest concentrations

ofPM-2.5 in RAPCAjurisdiction. "Greene" is located in the Village ofYellow Springs, Greene

County, which is downwind ofDayton. "Clark" is located on the roof of a fire station in the City

of Springfield, Clark County, which is an urban location. Our rural upwind site denoted "Preble"

represents PM-2.5 levels transported into RAPCA jurisdiction.

""{/"'''Clark

'""*-Preble

-STANDARD

04·06 05·07 06·08 07·09 08·10
Pa e 3

06-08 07-09 08-10

ontgomery

As can be seen from these graphs, the monitored data are clearly below the standard and are

trending downward. The monitored data clearly show attainment.

We believe these monitored data reflect decreases in both direct emissions ofPM-2.5 and

precursors (802 and N02) from both stationary and mobile sources. These decreases in

emissions are within RAPCA's six counties, as well as state-wide and nation-wide as is shown in

the following figures.

Emissions Inventory - extracted from 2002, 2005, 2008 National Emission Inventory

2002

RAPCA stationary ~'Ources

IIIPM2.5

111802

cNOx

2005
Pa e 4

O+-......

2002

u.s. stationary sourees

2008

IIiPM2.5

-802

f'NOx
2002

RAPCAmobile sources

2005 200S

mPM2.5

IIIS02

i3NOx

Pa e 5

Ohio mobile sow'ces

00 -,----------------------------

450000+----------------

400000

350000 --~--­

300000 -/-----

250000 -t----

200000 -1---

150000

100000-1----

50000

0+-........-

mpM2.5

"'S02

LNOx

2002 2005 2008
Pa e 6

These emissions reductions are due to adopted rules and consent decrees which are enforceable

and projected to produce further reductions into the future. Additional major rules are on

schedule for adoption. Examples ofsuch rules and consent decrees are as follows.

Rules

• Tier II Vehicle and Gasoline sulfur program

• Heavy Duty Diesel Engines rule (includes low sulfur diesel for highway vehicles)

• Clean Air Non-road diesel rule (includes 99% sulfur reduction in non-road diesel fuel:

15ppm in 2010, down from 3,000ppm)

• NOx SIP Call (OAC 3745-14)

• CAIR (OAC 3745-109)

• Federal Transport Rule (anticipated to be finalized this summer)

• Federal EGU MACT Rule (anticipated to be finalized this fall)

• ICI Boiler MACT (recently adopted)

• NOx RACT rule (OAC 3745-110)

Enforcement/Consent Decrees

• Apri12011-TVA

• January 2011 - Northern Indiana Public Service Company

• February 2011 - CEMEX

• July 2010 - Hoosier Energy Rural Electric Cooperative

• May 2010 - American Municipal Power

• Dec 2009 Duke Energy, Gallagher Plant

• Sept 2009 - East Kentucky Power
Pit e 7

• August 2009 - Ohio Edison (First Energy)

• October 2007 - American Electric Power

• July 2007 - East Kentucky Power

• June 2003 - Southem Indiana Gas & Electric

Descriptions for each ofthese enforcement actions, including a copy ofthe consent decrees, are

available at http://cfpub.epagov/compliance/cases/.

We have full confidence that the emissions of direct PM-2.5 and its precursors will continue to

decrease in future years.

In conclusion, RAPCA staff believe the criteria for redesignation to attainment for PM-2.5 have

been clearly met.

• The monitored air quality data show attainment; we believe these data are accurate.

• Reductions in emissions of both direct PM-2.5 and precursors have been significant and

will continue into the future.

• Adoption ofthe federal Transport Rule, EGU MACT, and ICI Boiler MACT, combined

with additional mobile source measures (including diesel fuel improvements) should

assure continued emissions reductions and air quality improvement into the future.

Thus, we fully support this proposal to redesignate Greene, Clark, and Montgomery Counties as

attainment for the annual PM-2.5 National Ambient Air Quality Standard.

Thank you for this opportunity to give this testimony. We appreciate very much the work that

Ohio EPA has accomplished on this proposal. I am happy to answer any questions you might

have.
1

1

2 OHIO EPA PUBLIC HEARING

3 ------------------------------------------------

4 IN THE MATTER OF:

5 REDESIGNATION FOR PM-2.5, DAYTON AREA

6 -------------------------------------------------

7 EPA Hearing held Tuesday, May 3, 2011 at 1:30

8 p.m., at the Ohio EPA, 401 E. Fifth Street, 2nd

9 Floor, Dayton, Ohio before Ms. Erica Wiggins, Ohio

10 EPA Representative.

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

* * * * * *

:r,vr;;1;'J

MAY 1"/ ?Ol1

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
1

2 Wiggins.

MS. WIGGINS: My name is Erika

I am the Ohio EPA's public involvement

2

3 coordinator for the southwest district and I'll be

4 presiding over today's hearing. Thank you for

5 taking the time to attend this hearing in front of

6 the EPA. The purpose of the hearing today is to

7 obtain comments from any interested person

8 regarding Ohio EPA's proposed action.

9 The state of Ohio plans to ask

10 U.S. EPA to officially recognize that air quality

11 in the Dayton area meets the 1997 federal fine

12 particulate standard. Air quality data from the

13 years 2008-2010 show that the Dayton area is

14 meeting the 1997 national fine particulate matter

15 standard. When asking for redesignation, states

16 are required to demonstrate that the metropolitan

17 area will be able to maintain compliance with the

18 fine particulate standard for 10 years. Current

19 national, state and local air pollution controls to

20 limit particulate matter-causing emissions will

21 enable the area to maintain the air quality.

22 These include lower emission from

23 coal burning power plants, additional controls on

24 diesel-powered vehicles and enforcement efforts.

25 The proposed request affects Clark, Greene, and

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
3

1 Montgomery counties.

2 Comments on the redesignation

3 proposal can be submitted until the close of

4 business on today, May 3rd, bye-mail or mail to

5 Carolina Prado or Jennifer Hunter, Division of Air

6 Pollution Control, Ohio EPA, P.O. Box 1049,

7 Columbus, Ohio 43216-1049. You can e-mail comments

8 to carolina.prado@epa.ohio.gov.

9 The proposal is available on line

10 or by calling Ohio EPA's Division of Air Pollution

11 Control at (614) 644-2270. The state of Ohio is

12 proposing to ask U.S. EPA to officially recognize

13 the four-county Dayton area as meeting the federal

14 air quality standard for fine particulate matter.

15 All interested persons are

16 entitled to attend or be represented and to present

17 oral or written comments concerning the proposed

18 action. All written and oral comments received as

19 part of the official record will be considered by

20 the Director of Ohio EPA before the final decision

21 is made. To be included in the official record,

22 written comments must be received by Ohio EPA by

23 close of business May 3, 2011. You may file

24 comments with me today or e-mail to the

25 afore-mentioned address. All written comments

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
4

1 submitted for the record receive the same

2 consideration as oral testimony given today.

3 Written statements submitted after

4 the comment period closes may be considered as time

5 and circumstances permit, but will not be part of

6 the official record of the hearing. If you wish to

7 present oral testimony at this hearing today and

8 have not already signed the registration sheet, do

9 so at this time. The sheet is available at the end

10 of the table. People will be called in the order

11 in which they registered.

12 There is no cross examination of

13 speakers or representatives of Ohio EPA in public

14 hearings of this type. Ohio EPA hearings such as

15 this afford citizens the opportunity to provide

16 comments on the official record. Therefore, we'll

17 not be able to answer questions during the hearing.

18 However, members of Ohio EPA may ask clarifying

19 questions of the person testifying to ensure that

20 the record is as complete and accurate as possible.

21 If you'll pass me that sheet I'll

22 now read the names of those who registered at the

23 hearing and give each person an opportunity to

24 testify. The first person testifying will be John

25 Paul. You can stand if you like or otherwise you

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
5

1 can say your piece.

2 MR. JOHN PAUL: Good afternoon, my

3 name is John A. Paul, I'm the administrator of the

4 Regional Air Pollution Control Agency, RAPCA, of

5 Dayton, Ohio. RAPCA is the local agency

6 responsible for air pollution control activities in

7 the Ohio counties of Clark, Darke, Greene, Miami,

8 Montgomery and Preble. This testimony is offered

9 in support of Ohio EPA's proposal for redesignation

10 of Clark, Greene and Montgomery County as

11 attainment of the, for the annual National Ambient

12 Air Quality Standard for PM-2.5. We commend Ohio

13 EPA for the completeness of the redesignation

14 package and offer both this testimony and written

15 comments as supplemental information.

16 The Ohio EPA proposal discusses

17 the five criteria for redesignation from U.S. EPA's

18 Procedures For Processing Requests to Redesignate

19 Areas to Attainment. RAPCA staff reviewed the

20 complete Ohio EPA document and offer the following

21 in support.

22 RAPCA operates four PM-2.5 air

23 quality monitoring stations. Three-year average

24 PM-2.5 concentrations along with the applicable

25 standards are shown in the following two figures.

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
6

1 Montgomery are data from the urban core of Dayton

2 and represent the highest concentrations of PM-2.5

3 in RAPCA's jurisdiction. Greene is located in the

4 Village of Yellow Springs, Greene County, which is

5 downwind of Dayton. Clark is located on the roof

6 of a fire station in the city of Springfield, Clark

7 County, which is an urban location. Our rural

8 upwind site denoted Preble represents PM-2.5 levels

9 transported into RAPCA jurisdiction.

10 I'll just comment that the chart

11 is there and it shows the various levels and shows

12 those levels, the three-year averages as being

13 below the standard, the last 33-year averages for

14 Montgomery County and all of the three-year

15 averages from Greene, Clark, and Preble Counties.

16 And then the next graph shows the 24-hour PM-2.5

17 and once, again, shows the levels at each of those

18 sites.

19 As can be seen from these graphs,

20 the monitored data are clearly below the standard

21 and are trending downward. The monitored data

22 clearly show attainment. We believe these

23 monitored data reflect decreases in both direct

24 emissions of PM-2.5 and precursors S02 and N02 from

25 both point and mobile sources. These decreases in

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
7

1 emissions are within RAPCA's six counties as we11

2 as state wide and nationwide as is shown in the

3 fo11owing figures.

4 Then we have five different charts

5 that show, in the first one the RAPCA stationary

6 sources and emissions of PM-2.5, S02 and NOx in bar

7 graphs that c1ear1y show again decreasing emissions

8 from 2002 do 2005 and 2008 and then we have a bar

9 chart that shows Ohio stationary sources. Once,

10 again, it's decreasing 2002 to 2005 to 2008 for

11 PM-2.5 and S02 and NOx. We have a graph of u.s.

12 stationary sources across the country, again, shows

13 this downward trend in PM-2.5, S02, and NOx

14 emissions and have two graphs that have two mobi1e

15 sources, RAPCA mobi1e sources and then Ohio, State

16 of Ohio mobi1e source inventory.

17 Again, with mobi1e sources we pay

18 attention to the NOx emissions, and the fina1 graph

19 is showing u.s. mobi1e sources and once again the

20 trend downward especia11y in 2008. These emission

21 reductions are due to adopted ru1es and consent

22 decrees which are enforceab1e and projected to

23 produce further reductions into the future.

24 Additiona1 major ru1es are on

25 schedu1e for adoption. Examp1es of such ru1es and

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
8

1 consent decrees are as follows, and then we list

2 rules which have both been adopted and/or are to be

3 adopted or they have been adopted and being phased

4 in, and we list rules that tier II vehicle and

5 gasoline sulfur program, the heavy duty diesel

6 engine rules that includes low sulfur diesel for

7 highway vehicles. The clean air non-road diesel

8 rule includes a 99 percent sulfur reduction in

9 non-road diesel fuel. 15 parts per million in 2010

10 down from 3,000 parts per million prior to 2010.

11 The NOx SIP call for E.G.U's, the Clean Air

12 Interstate Rule, the federal transport rule which

13 was adopted and then has been adjusted by, is being

14 replaced with the federal transport rule which is

15 anticipated to be finalized this summer; and the

16 federal E.G.U MACT. This is a toxic rule requiring

17 full controls on electric generator units that is

18 anticipated to be finalized this fall.

19 It was recently proposed and

20 published in the Federal Register today. The

21 Industrial Commercial and Institutional Boiler,

22 MACT rule, again, a toxic rule that was recently

23 adopted that will result in further emission

24 reductions from industrial boilers in the area, and

25 then the NOx RACT rule.

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
1 Then a list a number of

9

2 enforcement/consent decrees. These are primarily

3 to new source review violations but they result in

4 best available control technology installed on the

5 sources that are listed here so I have the

6 enforcement consent decrees for TVA, Northern

7 Indiana Public Service, for CEMEX, for Hoosier

8 Energy Rural Electric Cooperative, American

9 Municipal Power, Duke Energy, East Kentucky Power;

10 and the next page, Ohio Edison, American Electric

11 Power, East Kentucky Power and again, Southern

12 Indiana Gas and Electric.

13 These are all consent decrees

14 which are resulting in further controls on electric

15 generating units and descriptions for each of these

16 enforcement actions including a copy of the consent

17 decrees are available at the web site that is

18 listed there.

19 We have full confidence that the

20 emissions of direct PM-2.5 and its precursors will

21 continue to decrease in future years; and in

22 conclusion, RAPCA staff believe that criteria for

23 redesignation to attainment for PM-2.5 have been

24 clearly met. The monitored air quality data show

25 attainment. We believe these data are accurate.

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
10

1 Reductions in emissions of both direct PM-2.5 and

2 precursors have been significant and will continue

3 into the future and adoption of the federal

4 Transport Rule, the E.G.U MACT, the ICI Boiler MACT

5 combined with additional mobile source measures

6 including diesel fuel and improvements should

7 assure continued emissions reductions and air

8 quality improvement into the future.

9 Thus we fUlly support this

10 proposal to redesignate Greene, Clark and

11 Montgomery Counties as attainment for the annual

12 PM-2.5 National Ambient Air Quality Standard.

13 Thank you for this opportunity to give this

14 testimony. We appreciate very much the work that

15 Ohio EPA has accomplished on this proposal. I am

16 happy to answer any questions you might have.

17 MS. WIGGINS: Thank you very much.

18 The next person on my list is Brian Huxtable.

19 BRIAN HUXTABLE: I'm just

20 attending.

21 MS. WIGGINS: Matt Lindsay.

22 MATT LINDSAY: I'm just attending.

23 MS. WIGGINS: And Felicia Graham.

24 FELICIA GRAHAM: I'm attending

25 also.

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
11

1 MS. WIGGINS: Anyone else would

2 like to speak.

3 MICHELE SIMMONS: We are

4 representing the City of Dayton and I would like to

5 make a statement that we are in support of the Ohio

6 EPA designation of Dayton and Springfield area to

7 attainment for the PM-2.5 and revising the

8 maintenance plan for Montgomery County.

9 We think that the existing

10 controls will be sufficient to maintain the NOx and

11 we are willing to commit to the proposed

12 contingency plan that's represented in your public

13 hearing notice here.

14 MS. WIGGINS: Could you state your

15 name and spell it for the record.

16 MICHELE SIMMONS: M-I-C-H-E-L-E,

17 S-I-M-M-O-N-S, and that's with the City of Dayton.

18 MS. WIGGINS: Thank you very much.

19 Anyone else wish to testify? Seeing no one else, I

20 want to remind you that written comments can be

21 submitted through 5 p.m. today and you have an

22 e-mail address that is a best bet to get it there.

23 Thank you everyone for attending. The time now is

24 1:45 p.m. We will wait 15 minutes before

25 adjourning.

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
1

2

12

(WHEREUPON, a recess was taken.)

MS. WIGGINS: The time is now 2

3 o'clock. This hearing is adjourned.

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
13

1

2

3

C E R T I F I CAT E

4 I, Paula A. Blosser, a Registered

5 Professional Reporter and Notary Public do hereby

6 certify that the foregoing is a full, true and

7 correct transcript of my notes taken in the

8 above-styled case and thereafter transcribed by me.

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

~\.O- Paula A. Blosser, RPR

WWW.BRITTONANDASSOCIATES.COM

DAYTON - (937) 228-3370 CINCINNATI - (513) 651-3370
Response to Comments 

PM2.5 Redesignation Request for the 1997 PM2.5 Annual Standard 

for the Dayton-Springfield Area 

Agency Contact for this Package

Division Contact: (Carolina Prado, Division of Air Pollution Control, 614-644-2310, 

Carolina.Prado@epa.state.oh.us) 

Ohio EPA held a public hearing in Dayton, OH on May 3, 2011, regarding the Redesignation 

Request and Maintenance Plan for the Dayton-Springfield PM2.5 Nonattainment Area. This 

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

the associated comment period, which ended on May 3, 2011. Ohio EPA reviewed and 

considered all comments received during the public comment period. 

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

environment and public health. 

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

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

Ohio EPA received a letter and oral testimony from the Regional Air Pollution Control 

Agency (RAPCA) in support of the redesignation request for the 1997 PM2.5 Annual 

Standard for the Dayton-Springfield Area. Besides supporting Ohio EPA’s 

redesignation request, RAPCA presented its own emission and monitoring data 

analysis showing that the evidence supporting the redesignation is stronger than 

what has been determined by Ohio EPA. RAPCA’s support documents can be found 

in this submittal. 

During the public comment period, the Ohio Department of Transportation (ODOT) 

advised Ohio EPA of an error in the MOVES post-processor assumptions utilized to 

generate on-road emissions in the Dayton-Springfield area. ODOT, together with the 

Miami Valley Regional Planning Commission, corrected the errors and re-analyzed 

the mobile emissions using MOVES. The new analysis resulted in an increase in the 

total on-road mobile emissions; however, the effect on the overall area emissions is 

minimal and a 15% safety margin, for transportation conformity purposes, was still 

allocated. Therefore, the final document does contain revised on-road mobile 

emissions numbers as compared to the draft document. 

End of comments