IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue

Governor Indianapolis, Indiana 46204

(317) 232-8603

Thomas W. Easterly Toll Free (800) 451-6027

Commissioner www.idem.IN.gov

January 25, 2011

Ms. Susan Hedman

Regional Administrator

U.S. Environmental Protection Agency

Region 5

77 West Jackson Boulevard

Chicago, IL 60604-3950

Re: Request for Redesignation Petition and

Maintenance Plan for the Indiana Portion

(Lawrenceburg Township, Dearborn

County) ofthe Cincinnati-Hamilton, OHKY-IN Fine Particle Nonattainment Area

Dear Ms. Hedman:

The Indiana Department of Environmental Management (IDEM) submits a Redesignation

Petition and Maintenance Plan for the Indiana portion (Lawrenceburg Township, Dearborn

County) ofthe Cincinnati-Hamilton, OH-KY-IN Area, which was designated as nonattainment of

the annual standard for fine particles on April 5,2005. IDEM conducted a public hearing

concerning the Redesignation Petition and Maintenance Plan on January 5, 2011, and the public

comment period concluded on January 7, 2011.

This submittal documents the public review process, including a detailed summary of and

response to substantive comments.

The attached document consists ofthe following:

Redesignation Petition alUl Maintenance Plan

• A formal request that the Indiana Portion (Lawrenceburg Township, Dearborn County) of

the Cincinnati-Hamilton, OH-KY-IN Area be redesignated to attainment and reclassified

as maintenance. It contains and meets the requirements set forth in Section 107 ofthe

Clean Air Act and in U.S. EPA Redesignation Guidance.

• A maintenance year of 2021 is established and 2015 is analyzed as an interim year.

• The appendices ofthe document contain historical air quality trend data, projected

emission inventory data and thorough documentation ofthe mobile emissions analysis.

• A summary of, and response to, all comments.

Recycled Paper $ An Equal Opportunity Employer Please Recycle 0
Ms. Hedman, Page 2

Motor Vehicle Emissiolls Blldgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget for

2010 and 2021. The Ohio-Kentucky-Indiana Regional Council of Governments (OKI)'s

travel demand forecasting model and the United States Environmental Protection Agency

(U.S. EPA)'s software program referred to as Motor Vehicle Emission Simulator

(MOVES) were used to determine emissions for the annual fine particle nonattainment

area.

• A conservative margin ofsafety was applied to the 20 I0 and 2021 projected emissions.

• The travel demand model was updated with the best available assumptions.

• Vehicle registration data gathered from the Indiana Bureau of Motor Vehicles were used to

replace the MOVES default vehicle age distribution.

IDEM requests that the U.S. EPA proceed with review and approval ofthis submittal. If

you have any questions or need additional information, please contact Scott Deloney, Chief, Air

Programs Branch, at (317) 233-5694.

Sincerely,

pB.~r

Keith Baugues

Assistant Commissioner

Office of Air Quality

KB/sadlskr

Enclosures:

Request for Redesignation Petition and Maintenance Plan for the Indiana Portion

(Lawrenceburg Township, Dearborn County) ofthe Cincinnati-Hamilton, OH-KY-IN Fine

Particle Nonattainment Area

Cc: John Mooney, U.S. EPA Region 5 (wI enclosures)

John Summerhays, U.S. EPA Region 5 (wI enclosures)

Cheryl Newton, U.S. EPA Region 5 (no enclosures)

Pat Morris, U.S. EPA Region 5 (no enclosures)

Scott Deloney, IDEM (no enclosures)

Christine Pedersen, IDEM (no enclosures)

Sarah Raymond, IDEM (wI enclosures)
REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN 

UNDER THE ANNUAL NATIONAL 

AMBIENT AIR QUALITY 

STANDARD FOR FINE PARTICLES 

For the Indiana Portion 

of the 

Cincinnati – Hamilton, OH-KY-IN 

Nonattainment Area for Fine Particles

Lawrenceburg Township, Dearborn County, 

Indiana

Prepared By: 

The Indiana Department of Environmental Management 

 January 2011
This page intentionally left blank

ii
TABLE OF CONTENTS 

1.0 INTRODUCTION....................................................................................................................1 

1.1 Background ................................................................................................................................1 

1.2 Geographical Description ..........................................................................................................2 

1.3 Status of Air Quality ..................................................................................................................3 

2.0 REQUIREMENTS FOR REDESIGNATION ......................................................................3 

2.1 General .......................................................................................................................................3 

2.2 Fine Particles Monitoring ..........................................................................................................4 

2.3 Emission Inventory ....................................................................................................................4 

2.4 Modeling Demonstration ...........................................................................................................4 

2.5 Controls and Regulations ...........................................................................................................5 

2.6 Corrective Actions for Potential Future Violations of the Fine Particles Standard ...................5 

3.0 FINE PARTICLES MONITORING .....................................................................................5 

3.1 Fine Particles Monitoring Network ...........................................................................................5 

3.2 Ambient Fine Particles Monitoring Data ...................................................................................7

3.3 Quality Assurance ....................................................................................................................10 

3.4 Continued Monitoring ..............................................................................................................10 

4.0 EMISSION INVENTORY ....................................................................................................10 

4.1 Emission Trends .......................................................................................................................11 

4.2 Base Year Inventory ................................................................................................................22 

4.3 Emission Projections ................................................................................................................23 

4.4 Demonstration of Maintenance ................................................................................................29 

4.5 Permanent and Enforceable Emission Reductions ..................................................................29 

4.6 Provisions for Future Updates .................................................................................................30 

5.0 MOBILE SOURCE EMISSIONS BUDGET ......................................................................30 

5.1 Onroad Emission Estimates .....................................................................................................30 

5.2 Overview ..................................................................................................................................30 

5.3 Emission Estimates ..................................................................................................................31 

6.0 CONTROL MEASURES AND REGULATIONS ..............................................................33 

6.1 Reasonably Available Control Technology (RACT) ...............................................................33 

6.2 Implementation of Past SIP Revisions .....................................................................................33 

6.3 Nitrogen Oxides (NOx) Rule ....................................................................................................33 

6.4 Measures Beyond Clean Air Act SIP Requirements ...............................................................34 

6.5 Controls to Remain in Effect ...................................................................................................38 

6.6 New Source Review Provisions ...............................................................................................38 

iii 
7.0 MODELING AND METEOROLOGY................................................................................39 

7.1 Summary of Modeling Results to Support Rulemakings ........................................................39 

7.2 LADCO’s Round 5 Particulate Source Apportionment Results ..............................................43 

7.3 Summary of Existing Modeling Results ..................................................................................46 

7.4 Meteorological Analysis for Southeastern Indiana ..................................................................46 

7.4.1 Surface Air Conditions Present during High Fine Particles Concentrations Days ...............46 

7.4.2 Upper Air Conditions Present during High Fine Particles Concentration Days ...................47 

7.4.3 Analyses of Atmospheric Conditions for Fine Particles Build-Up .......................................47 

7.5 Summary of Air Quality Index Days in Southeastern Indiana ................................................48 

7.6 Summary of Meteorological Analysis for Southeastern Indiana .............................................49 

8.0 CORRECTIVE ACTIONS ...................................................................................................49 

8.1 Commitment to Revise Plan ....................................................................................................49 

8.2 Commitment for Contingency Measures .................................................................................49 

8.3 Contingency Measures .............................................................................................................50 

9.0 PUBLIC PARTICIPATION ................................................................................................51 

10.0 CONCLUSIONS ..................................................................................................................51 

FIGURES

Figure 3.1 Cincinnati Basic Nonattainment Area ............................................................................6 

CHARTS

Chart 7.1 Regional/Emission Sector PSAT Results at Murray Road in Hamilton County ...........44 

Chart 7.2 Species Modeled Contributions to Murray Road PM2.5 Monitor ..................................45 

Chart 7.3 Species Modeled Contributions to Seymour & Vine St. PM2.5 Monitor .......................45 

Chart 7.4 Species Modeled Contributions to 101 West 8th Street PM2.5 Monitor .........................45 

Chart 7.5 Species Modeled Contributions to University College PM2.5 Monitor..........................46 

Chart 7.6 Distribution of PM2.5 Concentration Days on the AQI Levels of Health Concern ........48 

iv 
TABLES

Table 1.1 National Ambient Air Quality Standards for Fine Particles ............................................2 

Table 3.1 Monitoring Data for the Cincinnati Area (Annual Average and 2007 – 2009 

Design Values ..................................................................................................................................7 

Table 4.1 Comparison of 2008 Estimated and 2021 Projected Emission Estimates 

Lawrenceburg Township, Dearborn County, Indiana (Tons Per Year) .........................................28 

Table 4.2 Comparison of 2008 Estimated and 2021 Projected Emission Estimates 

Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area (Tons Per Year) ...........................29 

Table 5.1 Emission Estimations for Onroad Mobile Sources for the Cincinnati-Hamilton 

OH-KY-IN PM2.5 Nonattainment Area ..........................................................................................31 

Table 5.2 Mobile Source Emission Budgets for the Ohio and Indiana Portions of the 

Cincinnati PM2.5 Nonattainment Area ............................................................................................31 

Table 6.1 Trends in EGU NOx Emissions Statewide in Indiana....................................................34 

Table 7.1 Transport Rule Modeling Results from U.S. EPA - 2010 .............................................40 

Table 7.2 LADCO’s Round 6 Modeling Results for the Cincinnati Area .....................................42 

Table 7.3 Ranking and Percentage of Highest Number of Days at AQI Levels of Health 

Concern ..........................................................................................................................................49 

GRAPHS

Graph 3.1 Design Values for the Cincinnati Area for Fine Particles, 2003 through 2009 .............9 

Graph 3.2 Cincinnati Area Annual Fine Particles Trends, 2005 through 2009 ...............................9 

Graph 4.1 Dearborn County, IN NOx Point Source Emission Trends, 2005 and 2008 .................11 

Graph 4.2 Dearborn County, IN SO2 Point Source Emission Trends, 2005 and 2008 ..................12 

Graph 4.3 Dearborn County, IN PM2.5 Point Source Emission Trends, 2005 and 2008 ...............12 

Graph 4.4 Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area NOx Point 

Source Emission Trends, 2005 and 2008 .......................................................................................13

Graph 4.5 Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area SO2 Point 

Source Emission Trends, 2005 and 2008 .......................................................................................13

Graph 4.6 Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area Direct PM2.5 

Point Source Emission Trends, 2005 and 2008 .............................................................................14 

Graph 4.7 NOx Emission Trends, All Sources in Dearborn County, IN, 2005 and 

2008-With CAIR ............................................................................................................................16 

Graph 4.8 SO2 Emission Trends, All Sources in Dearborn County, IN, 2005 and 

2008-With CAIR ............................................................................................................................16 

Graph 4.9 Direct PM2.5 Emission Trends, All Sources in Dearborn County, IN, 2005 

and 2008-With CAIR .....................................................................................................................17 

Graph 4.10 NOx Emission Trends, All Sources in Entire Cincinnati-Hamilton, 

OH-KY-IN Nonattainment Area, 2005 and 2008-With CAIR ......................................................17 

v 
Graph 4.11 SO2 Emission Trends, All Sources in Entire Cincinnati-Hamilton, 

OH-KY-IN Nonattainment Area, 2005 and 2008-With CAIR ......................................................18 

Graph 4.12 Direct PM2.5 Emission Trends, All Sources in Entire Cincinnati-Hamilton, 

OH-KY-IN Nonattainment Area, 2005 and 2008-Without CAIR .................................................18 

Graph 4.13 Lawrenceburg Township, Dearborn County, Indiana NOx Emissions from 

EGUs, 1999 to 2009 .......................................................................................................................20 

Graph 4.14 Entire Cincinnati-Hamilton OH-KY-IN Nonattainment Area NOx Emissions 

from EGUs, 1999 to 2009 ..............................................................................................................21 

Graph 4.15 Lawrenceburg Township, Dearborn County, Indiana SO2 Emissions from 

EGUs, 1999 to 2009 .......................................................................................................................21 

Graph 4.16 Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area SO2 Emissions 

from EGUs, 1999 to 2009 ..............................................................................................................22 

Graph 4.17 Comparison of 2008, 2015 and 2021 Projected NOx Emissions, 

Lawrenceburg Township, Dearborn County, Indiana-With CAIR ................................................24 

Graph 4.18 Comparison of 2008, 2015 and 2021 Projected SO2 Emissions, 

Lawrenceburg Township, Dearborn County, Indiana-With CAIR ................................................25 

Graph 4.19 Comparison of 2008, 2015 and 2021 Projected Direct PM2.5 Emissions, 

Lawrenceburg Township, Dearborn County, Indiana-With CAIR ................................................25 

Graph 4.20 Comparison of 2008, 2015 and 2021 Projected SO2, NOx and Direct 

PM2.5 Emissions, Lawrenceburg Township, Dearborn county, Indiana-With CAIR ....................26 

Graph 4.21 Comparison of 2008, 2015 and 2021 Projected NOx Emissions for the 

Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area-With CAIR ..................................26 

Graph 4.22 Comparison of 2008, 2015 and 2021 Projected SO2 Emissions for the 

Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area-With CAIR ..................................27 

Graph 4.23 Comparison of 2008, 2015 and 2021 Projected Direct PM2.5 Emissions 

for the Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area-Without CAIR .................27 

Graph 4.24 Comparison of 2008, 2015 and 2021 Projected SO2, NOx and Direct 

PM2.5 Emissions for the Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment 

Area-(NOx and SO2 With CAIR, PM2.5 Without CAIR) ...............................................................28 

Graph 7.1 PM2.5 Design Value Trends for Cincinnati Area: 1999 - 2009 .....................................41 

Graph 7.2 Modeling Results (without CAIR) for the Cincinnati Area PM2.5 Monitors ................43 

vi 
APPENDICES

A Air Quality System (AQS) and Indiana Department of Environmental Management 

(IDEM) Monitor Data Values for the Cincinnati-Hamilton OH-KY-IN Nonattainment 

Area (2000-2009) 

B Nitrogen Oxides (NOx), Sulfur Dioxides (SO2) and Direct Fine Particulate Matter (PM2.5) 

Point Source Emissions (2005 and 2008) for the Cincinnati-Hamilton, OH-KY-IN 

Nonattainment Area 

C Nitrogen Oxides (NOx), Sulfur Dioxides (SO2) and Direct Fine Particulate Matter (PM2.5) 

(2005 and 2008) Emission Trends, All Sources, Entire Cincinnati-Hamilton, OH-KY-IN 

Nonattainment Area 

D Nitrogen Oxides (NOx) and Sulfur Dioxides (SO2) Emissions from Electric Generating 

Units, Lawrenceburg Township, Dearborn County, Indiana and Entire CincinnatiHamilton, OH-KY-IN Nonattainment Area 

E 2008 Base Year Emissions Inventory and 2015 and 2021 Projected Emissions Inventory 

for Nitrogen Oxides (NOx), Sulfur Dioxides (SO2) and Direct Fine Particulate Matter 

(PM2.5) in Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area 

F Mobile Source Input/Output Calculation Files 

G Indiana Department of Environmental Management (IDEM) Area Source Inventory 

Standard Operating Procedure 

H Lake Michigan Air Directors Consortium Emission Estimates Technical Support 

Document 

I Lake Michigan Air Directors Consortium (LADCO) Round 5 Modeling Technical 

Support Document (Round 5 Photochemical Modeling Based on “Base M” Emissions 

inventory, revised version of “Base K”) 

J Public Participation Process Documents 

vii 

1 

REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN 

UNDER THE ANNUAL NATIONAL AMBIENT AIR 

QUALITY STANDARD FOR FINE PARTICLES 

CINCINNATI-HAMILTON OH-KY-IN AREA 

1.0 INTRODUCTION

 

This document supports Indiana’s request that Lawrenceburg Township in Dearborn County, 

Indiana, which is part of the Cincinnati-Hamilton OH-KY-IN fine particles nonattainment area 

(herein referred to as the Cincinnati area), be redesignated from nonattainment to attainment of 

the 1997 annual standard for fine particles. There are no monitors for fine particles in the 

Indiana portion of the Cincinnati area. However, because the Cincinnati area has recorded three 

years of quality assured ambient air quality monitoring data for the years 2007 through 2009, 

demonstrating attainment with the annual standard for fine particles, the Indiana portion of the 

Cincinnati area is eligible for redesignation. 

Section 107 of the Clean Air Act (CAA) establishes specific requirements to be met in order for 

an area to be considered for redesignation, including: 

(a) A determination that the area has attained the annual standard for fine particles. 

(b) An approved State Implementation Plan (SIP) for the area under Section 110(k). 

(c) 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.

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

(e) A determination that all Section 110 and Part D requirements have been met. 

A maintenance plan provides for the continued attainment of the air quality standard by an area 

for a period of ten years after the United States Environmental Protection Agency (U.S. EPA) 

has formally redesignated the area to attainment. The plan also provides assurances that even if 

there is a subsequent exceedance of the air quality standard, measures in the maintenance plan 

will prevent any future occurrences through contingency measures that would be triggered. 

This document addresses each of these requirements, and provides additional information to 

support continued compliance with the annual standard for fine particles. 

1.1 Background

The CAA requires states with areas designated nonattainment of the applicable National 

Ambient Air Quality Standard (NAAQS) for fine particles to develop SIPs to expeditiously 

attain and maintain the standard. In 1997, U.S. EPA set daily and annual air quality standards 

for fine particles (PM2.5), as shown in Table 1.1. The standards were legally challenged and 

upheld by the U.S. Supreme Court in February of 2001. In 1999, Indiana began monitoring for 
2 

fine particle concentrations. The U.S. EPA designated areas in Indiana under the fine particle 

standards on December 17, 2004, as attainment, nonattainment, or unclassifiable, with an 

effective date of April 5, 2005. 

Table 1.1 

National Ambient Air Quality Standards for Fine Particles 

Annual 24-Hour 

1997 Fine Particles 

Standard (PM2.5) 

15 μg/m3

Annual arithmetic mean, 

averaged over three years 

65 μg/m3

24-hour average, 98th percentile, 

averaged over three years 

2006 Fine Particles 

Standard (PM2.5) 

15 μg/m3

Annual arithmetic mean, 

averaged over three years 

35 μg/m3

24-hour average, 98th percentile, 

averaged over three years 

Note: The Cincinnati area meets the 1997 and 2006 24-hour NAAQS for fine particles. Since this area is 

solely designated nonattainment under the 1997 annual standard for fine particles, this document only 

addresses the annual standard. 

On December 17, 2004, based on 2001 through 2003 monitoring data, U.S. EPA designated the 

Cincinnati-Hamilton OH-KY-IN area as nonattainment of the annual standard for fine particles, 

and subject to CAA, Part D, Title 1, Section 172 of Subpart 1 requirements, including the 

development of a plan to reduce nitrogen oxides (NOx), sulfur dioxide (SO2), and direct PM2.5

emissions and a demonstration that the area will meet the annual standard for fine particles by 

April 5, 2010. In order to satisfy these requirements, Indiana submitted an attainment 

demonstration to U.S. EPA on April 3, 2008, demonstrating that with the combination of clean 

air measures and the implementation of local and federally required control measures, air quality 

in the nonattainment area would meet the annual NAAQS for fine particles by April 5, 2010, and 

provide for an ample margin of safety. The Cincinnati-Hamilton OH-KY-IN area monitors have 

met the annual NAAQS for fine particles since the end of 2009. 

There were no monitors in the Cincinnati-Hamilton OH-KY-IN fine particles nonattainment area 

that violated the 1997 24-hour standard for fine particles and or currently violates the 2006 24-

hour standard for fine particles. As a result, the Cincinnati-Hamilton OH-KY-IN fine particles 

nonattainment area was designated nonattainment solely under the 1997 annual standard. 

Therefore, this document pertains only to the 1997 annual standard for fine particles. 

 The Cincinnati-Hamilton OH-KY-IN fine particles nonattainment area, as defined in Section 1.2, 

has not previously been subject to nonattainment area rulemakings for fine particles. However, 

the area had been subject to nonattainment area rulemakings under the 1-hour and the 8-hour 

ozone standards. The 1-hour ozone standard was revoked on June 15, 2005, and the Cincinnati 

area was redesignated to attainment of the 1997 ozone standard on May 11, 2010. 

 

 1.2 Geographical Description

The entire Cincinnati fine particles nonattainment area consists of: Lawrenceburg Township in 

Dearborn County, Indiana; Butler, Clermont, Hamilton, and Warren counties, Ohio; Boone, 

Campbell, and Kenton counties, Kentucky; and contains such cities as Cincinnati, Hamilton, and 
3 

Middletown, all in Ohio. This area is depicted in Figure 3.1. 

The agencies responsible for assuring the fine particles nonattainment area complies with the 

CAA requirements are: 

 The Ohio Environmental Protection Agency (Ohio EPA), which is responsible for 

Butler, Clermont, Clinton, Hamilton, and Warren counties, Ohio. 

 The Kentucky Department for Environmental Protection, (KDEP) which is 

responsible for Boone, Campbell, and Kenton counties, Kentucky. 

 The Indiana Department of Environmental Management (IDEM), which is 

responsible for Lawrenceburg Township, Dearborn County, Indiana. 

These three state agencies have worked cooperatively with U.S. EPA Regions IV and V to 

address attainment planning issues. 

Although the three agencies, in the three states, have worked together on a comprehensive plan 

for the multi-state nonattainment areas, each state is required to make a separate submittal for its 

portion of the planning components to U.S. EPA. Attainment demonstrations are SIP submittals 

and U.S. EPA action on them is taken separately. As such, this submittal only covers 

Lawrenceburg Township in Dearborn County, Indiana. 

 1.3 Status of Air Quality

 Monitoring data for fine particles for the three years, 2007 through 2009, demonstrates that air 

quality has met the annual NAAQS for fine particles in the Cincinnati area. This fact, 

accompanied by the permanent and enforceable reductions in emission levels discussed in 

Section 4.0, justifies a redesignation to attainment for the Indiana portion of the CincinnatiHamilton, OH-KY-IN nonattainment area based on Section 107(d)(3)(E) of the CAA. 

2.0 REQUIREMENTS FOR REDESIGNATION

2.1 General

Section 110 and Part D of the CAA list a number of requirements that must be met by 

nonattainment areas prior to consideration for redesignation to attainment. In addition, U.S. EPA 

has published detailed guidance in a document entitled Procedures for Processing Requests to 

Redesignate Areas to Attainment, issued September 4, 1992, to Regional Air Directors. This 

document is hereafter referred to as “Redesignation Guidance.” This Request for Redesignation 

and Maintenance Plan is based on the Redesignation Guidance, supplemented with additional 

guidance received from staff of the Air Planning and Maintenance Section of U.S. EPA Region 

V. The specific requirements for redesignation are listed below. 
4 

2.2 Fine Particles Monitoring 

1) A demonstration that the annual standard for fine particles, as published in 40 

CFR 50.13, has been attained. Fine particles monitoring data must show that 

violations of the annual ambient standard are no longer occurring. 

 

2) Ambient monitoring data quality assured in accordance with 40 CFR 58.15, 

recorded in the U.S. EPA Air Quality System (AQS) database, and available for 

public view. 

3) A showing that the three-year average of annual values, based on data from all 

monitoring sites in the area or its affected downwind environs, do not exceed 15.0 

micrograms per cubic meter (μg/m3

). This showing must rely on three complete, 

consecutive calendar years of quality assured data. 

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

appropriate monitoring network to verify the maintenance of the standard. 

2.3 Emission Inventory 

1) A comprehensive emission inventory of direct PM2.5 and the precursors of fine 

particles completed for the base year (2008 in this case). 

2) A projection of the emission inventory to a year at least ten years following 

redesignation. 

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

annual standard for fine particles. 

4) 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. 

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

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

2.4 Modeling Demonstration 

While no modeling is required for redesignating nonattainment areas, IDEM has evaluated the 

results of federal control-case modeling to demonstrate that compliance with the standard will be 

maintained. 
5 

2.5 Controls and Regulations 

1) A U.S. EPA-approved SIP control strategy that includes Reasonably Available 

Control Technology (RACT) requirements for existing stationary sources covered 

by Control Technology Guidelines (CTG) and non-CTG RACT for all major 

sources. 

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

implemented. 

 

3) Acceptable provisions to provide for new source review. 

4) Assurances that existing controls will remain in effect after redesignation, unless 

the state demonstrates through photochemical modeling that the standard can be 

maintained without one or more controls. 

5) If appropriate, a commitment to adopt a requirement that all transportation plans 

conform with and are consistent with the SIP. 

2.6 Corrective Actions for Potential Future Violations of the Fine Particles Standard

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

2) 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. 

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

event. 

4) A list of Nitrogen Oxides (NOx), Sulfur Dioxide (SO2) and direct PM2.5 sources 

potentially subject to future controls. 

3.0 FINE PARTICLES MONITORING

3.1 Fine Particles Monitoring Network

There are currently 12 Federal Reference Method monitors measuring fine particle 

concentrations for the Cincinnati area. Fine particle monitors are located in Campbell and 

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

There are no monitors for fine particles in the Indiana portion of the Cincinnati nonattainment 

area. The highest levels of fine particle concentrations have been typically monitored at the 

Seymour and Vine Street monitor (39-0061-0014) in Hamilton County, Ohio. The locations of 

the monitoring sites for the Cincinnati area are shown in Figure 3.1. A listing of the monitor 

readings from 2007 through 2009, is shown in Table 3.1 and Appendix A. The monitor readings 
6 

were retrieved from the U.S. EPA’s Air Quality System (AQS). 

The Wilwood and Winneste Ave. monitors in Ohio were discontinued on December 31, 2005. 

The Alexandria Park monitor in Kentucky was discontinued on December 31, 2006. The Hook 

Field Airport monitor in Ohio was discontinued on December 31, 2007. Therefore, these 

discontinued monitors are not shown in Figure 3.1. 

Figure 3.1 

Cincinnati Basic Nonattainment Area 

!

!

!

!

!

!

!

!

!

! !

!

μ Date: 5/17/2010

Map Projection: UTM Zone 16 N

Map Datum: NAD83

0 10 5 mi

0 10 5 km

University College

ID# 21-117-0007

W. 8th St.

ID# 39-061-0042

Nilles Rd. 

ID# 39-017-0016

Southeast St. 

ID# 39-165-0007

Murray Rd.

ID# 39-061-8001

Howard Taft

ID# 39-061-0040

Grooms Rd. 

ID# 39-061-0006

Sherman Ave.

ID# 39-061-7001

Bonita & St. John

ID# 39-017-0003

Seymour & Vine St. 

ID# 39-061-0014

John Hill Rd.

ID# 21-037-3002

Clermont Dr.

ID# 39-025-0022

Legend

! PM 2.5 Monitors

State Boundary

Attainment Area

Nonattainment Area

Butler

Hamilton

Warren

Kenton

Lawrenceburg

Township Clermont

Boone Campbell
7 

3.2 Ambient Fine Particles Monitoring Data

The following information summarizes U.S. EPA's "Guideline on Data Handling Conventions 

for the annual fine particles NAAQS," U.S. EPA-454/R-99-008, April 1999. Three complete 

years of fine particles monitoring data are required to demonstrate attainment at a monitoring 

site. The annual ambient air quality standard for fine particles is met at an ambient air quality 

monitoring site when the three-year average of the annual average of fine particle concentrations 

is less than or equal to 15.0 μg/m3. When this occurs, the site is said to be in attainment. While 

calculating design values, three significant digits must be carried in the computations, with final 

values rounded to the nearest 0.1 μg/m3. Decimals 0.05 or greater are rounded up, and those less 

than 0.05 are rounded down, so that 15.049 μg/m3 is the largest concentration that is less than or 

equal to 15.0 μg/m3

. Values at or below 15.0 μg/m3meet the standard. Values equal to or 

greater than 15.1 μg/m3 exceed the standard. 

Data handling procedures are applied on an individual basis at each monitor in the area. An 

individual site’s three-year average of the annual average fine particles concentration is also 

called the site’s design value. An area is in compliance with the annual NAAQS for fine 

particles only if all monitoring sites meet the NAAQS. The air quality design value for the area 

is the highest design value among all sites in the area. Table 3.1 shows the annual fine particle 

values by site and the 2007 through 2009 design values for the 12 active fine particle monitoring 

sites in the Cincinnati area. 

Table 3.1 

Monitoring Data for the Cincinnati Area (Annual Average and 2007-2009 Design Values) 

SITE ID STATE COUNTY SITE NAME YEAR 

Annual 

Average 

(μg/m3) 

2007-2009 

Average 

(μg/m3) 

21-037-3002 Kentucky Campbell John Hill Rd. 2007 14.36 

12.51 

21-037-3002 Kentucky Campbell John Hill Rd. 2008 11.83 

21-037-3002 Kentucky Campbell John Hill Rd. 2009 11.34 

21-117-0007 Kentucky Kenton Univ. College 2007 14.20 

12.41 

21-117-0007 Kentucky Kenton Univ. College 2008 11.99 

21-117-0007 Kentucky Kenton Univ. College 2009 11.04 

39-017-0003 Ohio Butler Bonita & St. John 2007 15.41 

13.93 

39-017-0003 Ohio Butler Bonita & St. John 2008 13.69 

39-017-0003 Ohio Butler Bonita & St. John 2009 12.68 

39-017-0016 Ohio Butler Niles Rd. 2007 14.94 

13.92 

39-017-0016 Ohio Butler Niles Rd. 2008 13.75 

39-017-0016 Ohio Butler Niles Rd. 2009 13.08 

39-017-1004 Ohio Butler Hook Fld. Airport 2007 14.63 

N/A 

39-017-1004 Ohio Butler Hook Fld. Airport 2008 

39-017-1004 Ohio Butler Hook Fld. Airport 2009 

39-025-0022 Ohio Clermont Clermont Dr. 2007 14.01 

12.26 

39-025-0022 Ohio Clermont Clermont Dr. 2008 11.75 

39-025-0022 Ohio Clermont Clermont Dr. 2009 11.01 
8 

39-061-0006 Ohio Hamilton Grooms Rd. 2007 14.63 

13.07 

39-061-0006 Ohio Hamilton Grooms Rd. 2008 12.48 

39-061-0006 Ohio Hamilton Grooms Rd. 2009 12.11 

39-061-0014 Ohio Hamilton Seymour & Vine St. 2007 16.59 

15.04 

39-061-0014 Ohio Hamilton Seymour & Vine St. 2008 15.12 

39-061-0014 Ohio Hamilton Seymour & Vine St. 2009 13.40 

39-061-0040 Ohio Hamilton Howard Taft 2007 15.09 

13.48 

39-061-0040 Ohio Hamilton Howard Taft 2008 12.62 

39-061-0040 Ohio Hamilton Howard Taft 2009 12.73 

39-061-0042 Ohio Hamilton W. 8th St. 2007 15.90 

14.67 

39-061-0042 Ohio Hamilton W. 8th St. 2008 14.40 

39-061-0042 Ohio Hamilton W. 8th St. 2009 13.71 

39-061-0043 Ohio Hamilton Kemper Rd. 2007 14.85 

N/A 

39-061-0043 Ohio Hamilton Kemper Rd. 2008 13.32 

39-061-0043 Ohio Hamilton Kemper Rd. 2009 

39-061-7001 Ohio Hamilton Sherman Ave. 2007 15.09 

13.93 

39-061-7001 Ohio Hamilton Sherman Ave. 2008 13.74 

39-061-7001 Ohio Hamilton Sherman Ave. 2009 12.97 

39-061-8001 Ohio Hamilton Murray Rd. 2007 16.07 

14.64 

39-061-8001 Ohio Hamilton Murray Rd. 2008 14.40 

39-061-8001 Ohio Hamilton Murray Rd. 2009 13.44 

39-165-0007 Ohio Warren Southeast St. 2007 13.98 

12.53 

39-165-0007 Ohio Warren Southeast St. 2008 11.92 

39-165-0007 Ohio Warren Southeast St. 2009 11.70 

Value Above the Annual PM2.5 Standard 

Graph 3.1 visually demonstrates the 2003 through 2009 design values for the Cincinnati area. 

 
9 

Graph 3.1

Design Values for the Cincinnati Area for Fine Particles, 2003 through 2009 

Note: The AlexandriaPark monitor in Kentucky was discontinued on December 31, 2006. The Wilwood and Winneste Ave. 

monitors in Ohio were discontinued on December 31, 2005. The Hook Field Airport monitor in Ohio was discontinued on 

December 31, 2007. 

Graph 3.2 

Cincinnati Area Annual Fine Particles Trends, 2005 through 2009 

Note: The Alexandria Park monitor in Kentucky was discontinued on December 31, 2006. The Wilwood and Winneste Ave. 

monitors in Ohio were discontinued on December 31, 2005. The Hook Field Airport monitor in Ohio was discontinued on 

December 31, 2007. 

0

5

10

15

20

25

2005 2006 2007 2008 2009

Alexandria Pk. John Hill Rd. Univ. College

Bonita & St. John Nilles Rd. Wilwood

Hook Field Airport Clermont Dr. Grooms Rd.

Seymour & Vine St. Howard Taft Winneste Ave.

W. 8th St Kemper Rd. Sherman Ave.

μg/m3 0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

16.0

18.0

20.0

Alexandria Pk.

John Hill Rd.

Univ. College

Bonita

& St.

...

Nilles Rd.

Wilwood

Hook Field

...

Clermont Dr.

Grooms Rd.

Seymour

&

...

Howard Taft

Winneste Ave.

W. 8th St

Kemper Rd.

Sherman Ave.

Murray Rd.

Southeast St.

03‐05 04‐06 05‐07 06‐08 07‐09

μg/m3
10 

The design values for the Cincinnati area demonstrate that the annual NAAQS for fine particles 

has been attained. Refer to Appendix A for the complete fine particles monitoring data summary 

for the years 2000 to 2009. 

Graph 3.1 shows the trend in design values, while Graph 3.2 shows the trend for annual fine 

particles. A comprehensive list of the fine particles monitoring sites’ design values over this 

period is outlined in Appendix A. The area's design values have recently trended downward, as 

emissions have declined due to programs such as the Acid Rain program and cleaner 

automobiles and fuels both regionally and locally. U.S. EPA’s rule to control nitrogen oxides 

from specific source categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 

and referred to as the “NOx SIP Call”) has significantly reduced emissions from large electric 

generating units (EGUs), industrial boilers, and cement kilns. Indiana's NOx SIP Call Rule was 

adopted into the Indiana Administrative Code on June 6, 2001 at 326 IAC 10-3 and 326 ICA 10-

4. The elevated fine particle values for 2005 are considered an abnormal occurrence. An 

analysis of meteorological conditions and monitoring values is included in Section 7.0 and 

supports the conclusion that attainment of the standard as of 2009 is not the result of unusually 

favorable meteorological conditions. It is expected that this downward trend will continue as the 

above programs continue and the U.S. EPA’s proposed Transport Rule is implemented. 

3.3 Quality Assurance

Kentucky and Ohio have quality assured all data shown in Appendix A in accordance with 40 

CFR 58.10 and recorded the data in the AQS database and, thus, the data is available to the 

public. 

3.4 Continued Monitoring

Ohio and Kentucky commit to continue monitoring concentrations of fine particles at the active 

sites indicated in Table 3.1 and Appendix A. There are no monitors in the Indiana portion of the 

Cincinnati-Hamilton, OH-KY-IN nonattainment area, however, IDEM will consult with U.S. 

EPA Region V staff should changes to the existing Indiana monitoring network become 

necessary in the future. 

4.0 EMISSION INVENTORY 

U.S. EPA Redesignation Guidance and Implementation Rules require the submittal of a 

comprehensive inventory of precursor emissions for fine particles (NOx, SO2, and direct PM2.5) 

representative of the year when the area achieved attainment of the annual NAAQS for fine 

particles (base year). IDEM is using 2008 as the base year. IDEM must also 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 

requirements related to the emissions inventory include: a projection of the emission inventory to 

a year at least ten years following redesignation; a demonstration that the projected level of 

emissions is sufficient to maintain the annual standard for fine particles; and, a commitment to 

provide future updates of the inventory to enable tracking of emission levels during the ten year 
11 

maintenance period. Consistent with the implementation rule for fine particles, IDEM and U.S. 

EPA do not consider volatile organic compounds (VOCs) or ammonia (NH3) to be significant 

contributors to fine particles. The following subsections address each of these requirements. 

4.1 Emission Trends

Point Sources

Graphs 4.1, 4.2 and 4.3 show that the trend in point source emissions of NOx, SO2, and direct 

PM2.5 respectively for Lawrenceburg Township, Dearborn County, Indiana, generally correspond 

to the years of monitored values used in this redesignation petition. The point source data are 

taken from Indiana's emissions reporting program. While an increase in direct PM2.5 point 

source emissions for Lawrenceburg Township in Dearborn County, Indiana is noted, the increase 

in direct PM2.5 emissions from 2005 to 2008 is due to previously unreported emissions from 

companies that did not submit their direct PM2.5 emissions data in 2005, but did submit direct 

PM2.5 data in the 2008 emissions inventory. Graphs 4.4, 4.5 and 4.6 show the trend in point 

source emissions for the entire Cincinnati-Hamilton, OH-KY-IN nonattainment area. The entire 

Cincinnati area had a 14.6% reduction in NOx point source emissions, a 52.1% reduction in SO2 

point source emissions, and a 9.5% reduction in direct PM2.5 point source emissions. Point 

source data for the entire Cincinnati area is the combination of data from Indiana, Kentucky, and 

Ohio’s annual emissions reporting program. Graphs and data tables of emissions for the point 

source category can be found in Appendix B. 

Graph 4.1 

Dearborn County, IN NOx Point Source Emission Trends, 2005 and 2008

9,100

9,200

9,300

9,400

9,500

9,600

9,700

9,800

9,900

10,000

10,100

2005 2008

Tons per Year

NOX Year
12 

Graph 4.2 

Dearborn County, IN SO2 Point Source Emission Trends, 2005 and 2008 

Graph 4.3 

Dearborn County, IN Direct PM2.5 Point Source Emission Trends, 2005 and 2008

‐

2,500

5,000

7,500

10,000

12,500

15,000

17,500

20,000

22,500

25,000

27,500

30,000

32,500

35,000

37,500

40,000

42,500

45,000

47,500

50,000

52,500

2005 2008

Tons per Year

SO2 Year

660

680

700

720

740

760

780

800

820

840

860

880

2005 2008

Tons per Year

Direct PM 2.5 Year
13 

Graph 4.4 

Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area NOx Point Source Emission 

Trends, 2005 and 2008 

Graph 4.5 

Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area SO2 Point Source Emission 

Trends, 2005 and 2008 

50,000

52,000

54,000

56,000

58,000

60,000

62,000

64,000

66,000

68,000

2005 2008

Tons per Year

NOX Year

50,000

70,000

90,000

110,000

130,000

150,000

170,000

190,000

210,000

230,000

250,000

2005 2008

Tons per Year

SO2 Year
14 

Graph 4.6 

Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area Direct PM2.5 Point Source 

Emission Trends, 2005 and 2008 

All Anthropogenic Sources

Periodic inventories, which include emissions from all sectors (mobile, area, nonroad, and point 

source), were prepared for 2005 and 2008. The 2008 data was extrapolated from the 2005 

emission inventory. Graphs 4.7, 4.8, and 4.9 show the trends for total NOx, SO2, and direct 

PM2.5 emissions for all anthropogenic source categories in Lawrenceburg Township in Dearborn 

County, Indiana for 2005 and 2008. While an increase in direct PM2.5 anthropogenic source 

emissions for Lawrenceburg Township in Dearborn County, Indiana is noted, the increase in 

direct PM2.5 emissions from 2005 to 2008 is due to previously unreported emissions from 

companies that did not submit their direct PM2.5 emissions data in 2005, but did submit direct 

PM2.5 data in the 2008 emissions inventory. Graphs 4.10, 4.11, and 4.12 show the trends for 

total NOx, SO2, and direct PM2.5 emissions for all anthropogenic source categories for the entire 

Cincinnati-Hamilton, OH-KY-IN nonattainment area for 2005 and 2008. These emissions trends 

roughly follow the years of monitored trends discussed in Section 3.0. There is a downward 

trend in NOx and SO2 emissions from 2005 to 2008. The decrease in NOx can be largely 

attributed to the impact of the NOx SIP Call. As can be seen by Graph 4.12, overall the direct 

PM2.5 anthropogenic source emissions for the entire Cincinnati-Hamilton, OH-KY-IN 

nonattainment area have substantially decreased. Graphs and data tables of emissions from each 

source category are available in Appendix C. 

2,900

3,000

3,100

3,200

3,300

3,400

3,500

2005 2008

Tons per Year

Direct PM 2.5 Year
15 

Mobile emissions inventories and projections for all counties were prepared by the OhioKentucky-Indiana Regional Council of Governments (OKI) and is explained in further detail in 

Section 5.0. All 2005 data for the entire Cincinnati-Hamilton, OH-KY-IN nonattainment area is 

from the 2005 periodic inventory which has been identified as one of the preferred databases for 

SIP development. For the 2008 attainment year, emissions were extrapolated from the 2005 

Lake Michigan Air Directors Consortium (LADCO) modeling inventory, using LADCO’s 

growth factors, for all sections except point sources (electrical generating units and non-electrical 

generating units). Point source emissions for 2008 were compiled from Indiana, Kentucky, and 

Ohio’s annual emissions inventory databases. 

The emissions inventory development and emissions projection discussion below, with the 

exception of the mobile emissions inventory and projections, identify procedures used by Ohio 

EPA and LADCO regarding emissions from Ohio’s portion of the counties in the CincinnatiHamilton, OH-KY-IN nonattainment area that differ from procedures used by Kentucky and 

Indiana. Indiana and Kentucky emissions data were obtained through the LADCO emission 

inventory and projections which were prepared using similar methodologies. 

For Ohio, the 2005 and 2008 actual PM2.5 emissions data below generally contains filterable 

fraction emissions only and not the condensable fractions, because Ohio EPA did not have a 

consistent reporting requirement in those years. U.S. EPA Integrated Planning Model(IPM) 

modeling was used to generate future year EGU emissions with the Clean Air Interstate Rule 

(CAIR) program. The IPM modeling added additional PM2.5 condensible emissions into future 

years. Therefore, comparing base and attainment year emissions with the future year predictions 

is not accurate in the IPM CAIR modeling. This step leads to a false perception of significant 

PM2.5 emissions increase. Modeling performed by LADCO, without CAIR, did not incorporate 

added condensable fraction emissions. Although Ohio EPA has stated that it is most appropriate 

to evaluate future year emissions that include the CAIR program, because of this flaw, it is more 

accurate and appropriate for the purposes of PM2.5 to evaluate future year emissions without the 

CAIR program. Therefore all numbers for Ohio for PM2.5 in this document are without CAIR, 

while all numbers for Ohio for NOx and SO2 are with CAIR. Both Indiana and Kentucky have 

used numbers for NOx, SO2, and PM2.5 with CAIR. Emissions tables and charts in this document 

are labeled accordingly and can also be found in Appendix C. 
16 

Graph 4.7 

NOx Emission Trends, All Sources in Dearborn County, IN, 2005 and 2008-With CAIR 

Graph 4.8 

SO2 Emission Trends, All Sources in Dearborn County, IN, 2005 and 2008-With CAIR

10,200

10,400

10,600

10,800

11,000

11,200

11,400

11,600

2005 2008

Tons per Year

NOX Year

‐

10,000

20,000

30,000

40,000

50,000

60,000

2005 2008

Tons per Year

Year SO2
17 

Graph 4.9 

Direct PM2.5 Emission Trends, All Sources in Dearborn County, IN, 

2005 and 2008-With CAIR 

Graph 4.10 

NOx Emission Trends, All Sources in Entire Cincinnati-Hamilton, OH-KY-IN 

Nonattainment Area, 2005 and 2008-With CAIR 

740

760

780

800

820

840

860

880

900

920

940

2005 2008

Tons per Year

Direct PM 2.5 Year

135,000

140,000

145,000

150,000

155,000

160,000

165,000

170,000

2005 2008

Tons per Year

Year NOX
18 

Graph 4.11 

SO2 Emission Trends, All Sources in Entire Cincinnati-Hamilton, OH-KY-IN 

Nonattainment Area, 2005 and 2008-With CAIR

Graph 4.12 

Direct PM2.5 Emission Trends, All Sources in Entire Cincinnati-Hamilton, OH-KY-IN 

Nonattainment Area, 2005 and 2008-Without CAIR 

‐

50,000

100,000

150,000

200,000

250,000

300,000

2005 2008

Tons per Year

Year SO2

8,600

8,700

8,800

8,900

9,000

9,100

9,200

9,300

9,400

9,500

2005 2008

Tons per Year

Direct PM Year 2.5
19 

EGU Sources

Both NOx and SO2 emissions are decreasing substantially in response to national programs 

affecting all EGUs such as the Acid Rain program and the NOx SIP Call. Other sectors of the 

inventory also impact the formation of fine particles, but large regional sources such as EGUs 

have a substantial impact on the formation of fine particles. 

The data was taken from U.S. EPA's Clean Air Markets database1

. Data are available sooner for 

these units than other point sources in the inventory because of the NOx SIP Call budget and 

trading requirements. Information from 2003 is significant because some EGUs started 

operation of their NOx SIP Call controls in order to generate Early Reduction Credits for their 

future year NOx budgets. The first season of the NOx SIP Call budget period began May 31, 

2004. 

As part of the NOx SIP Call, the states were required to adopt into their rules a budget for all 

large EGUs. Indiana’s budget is referenced in 326 IAC 10-4. The budget represents a statewide 

cap on NOx emissions. Although each unit is allocated emissions based upon historic heat input, 

utilities can meet this budget by over-controlling certain units or purchasing credits from the 

market to account for overages at other units. To summarize, NOx emissions have dramatically 

decreased over the years represented on these graphs. 

These emissions, capped by the state rule, are expected to remain near these levels throughout 

the maintenance period covered by this request. The state cap for the NOx SIP Call remained in 

place through 2008, at which time the CAIR program superseded it. CAIR, issued in March 

2005, adopted by the Indiana Air Pollution Control Board on November 1, 2006, and 

implemented beginning in 2010, will continue to reduce regional EGU NOx emissions statewide 

by approximately another 17% by 2015 and 57% for EGU SO2 emissions by 2015. The D.C. 

Circuit court’s vacatur of CAIR in July of 2008 and subsequent remand without vacatur in 

December of 2008 directs U.S. EPA to revise the CAIR rule in the future. The proposed Clean 

Air Transport Rule (Transport Rule) (CAIR’s replacement rule) will result in similar or greater 

emission reductions than assumed within the current emission inventories once it is 

implemented. 

There is one EGU located in the Indiana portion (Lawrenceburg Township, Dearborn County, 

Indiana) of the Cincinnati area: American Electric Power (AEP)- Tanner’s Creek. Graphs 4.13 

and 4.15 depict the trends in NOx and SO2 emissions from the EGU in Lawrenceburg Township, 

Dearborn County, Indiana for the years 1999 to 2009. AEP-Tanner’s Creek entered into a 

Consent Decree with U.S. EPA on October 9, 2007. For NOx, the Consent Decree calls for lowNOx burners and overfire air. Further, they installed Selective Non-Catalytic Reduction 

(SNCRs) on Units 1, 2, and 3 in 2008 to meet CAIR requirements. As a general rule, low NOx

burners are around 40% control and SNCRs are an additional 30%. AEP-Tanner’s Creek’s 

permit does not require operation of these units, but they need to operate the controls to meet 

CAIR allowances for now, and the proposed Transport Rule will control when it is effective. For 

SO2, the Consent Decree and the permit state AEP-Tanner’s Creek has to burn coal not 

exceeding 1.2% sulfur. With the Consent Decree in place these controls are, therefore, 

 

1

 http://www.epa.gov/airmarkets 
20 

considered permanent and enforceable and can be associated with the downward trend in NOx 

and SO2 emissions from AEP-Tanner’s Creek. Graphs 4.14 and 4.16 depict the trends in NOx

and SO2 emissions from the entire Cincinnati-Hamilton, OH-KY-IN nonattainment area for the 

years 1999 to 2009. Graphs and data tables of emissions from the EGU source category can be 

found in Appendix D. 

Graph 4.13 

Lawrenceburg Township, Dearborn County, Indiana NOx Emissions from EGUs, 1999 to 

2009 

0.0

5,000.0

10,000.0

15,000.0

20,000.0

25,000.0

30,000.0

35,000.0

40,000.0

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Total NOx Emissions, tons / year
21 

Graph 4.14 

Entire Cincinnati-Hamilton OH-KY-IN Nonattainment Area NOx Emissions from EGUs, 

1999 to 2009 

Graph 4.15 

Lawrenceburg Township, Dearborn County, Indiana SO2 Emissions from EGUs, 1999 to 2009 

0.0

20,000.0

40,000.0

60,000.0

80,000.0

100,000.0

120,000.0

140,000.0

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Total NOx Emissions, tons / year

0.0

10,000.0

20,000.0

30,000.0

40,000.0

50,000.0

60,000.0

70,000.0

80,000.0

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Total SO2 Emissions, tons / year
22 

Graph 4.16 

Entire Cincinnati-Hamilton OH-KY-IN Nonattainment Area SO2 Emissions from EGUs, 1999 

to 2009 

4.2 Base Year Inventory

IDEM prepared a comprehensive inventory for the Cincinnati area, including area, mobile, 

nonroad, and point sources for direct PM2.5 and precursors of fine particles (NOx and SO2) for 

2005 (the year with the most complete emissions inventory available at this time). The 2008 

data was extrapolated from the 2005 emission inventory to represent a base year for maintenance 

purposes. The 2007 implementation rule for the annual fine particles standard states that NOx, 

SO2, and direct PM2.5 are the regulated precursors of fine particles. Ammonia and VOCs are not 

required to be addressed unless the state or U.S. EPA makes a technical demonstration that 

emissions of these pollutants from sources in the state significantly contribute to PM2.5

concentrations in a given nonattainment area. U.S. EPA and Indiana have not determined 

ammonia or VOCs to be significant contributors to fine particles formation in the State of 

Indiana. Indiana’s 2008 base year inventory was determined by the following: 

 Area sources were extrapolated from the Indiana 2005 periodic inventory submitted to 

U.S. EPA. 

 Mobile source emissions were calculated from U.S. EPA’s Motor Vehicle Emissions 

Simulator (MOVES) model-produced emission factors and data extracted from the 

region’s travel-demand model. These emissions were then interpolated as needed to 

determine 2008 base year values. 

0.0

50,000.0

100,000.0

150,000.0

200,000.0

250,000.0

300,000.0

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Total SO2 Emissions, tons / year
23 

 Point source information was compiled from IDEM’s emissions statement database and 

U.S. EPA's Clean Air Markets acid rain database. 

 Biogenic emissions are not included in these summaries. 

 Nonroad emissions were extrapolated from the 2005 National Emissions Inventory 

(NEI). To address concerns about the accuracy of some of the categories in U.S. EPA’s 

nonroad emissions model, LADCO contracted with two companies to review the base 

data and make recommendations. One of the contractors also estimated emissions for 

two nonroad categories not included in U.S. EPA's nonroad model. Emissions were 

estimated for commercial marine vessels and railroads. The recreational motorboat 

population and spatial surrogates (used to assign emissions to each) were significantly 

updated. The populations for the construction equipment category were reviewed and 

updated based upon surveys completed in the Midwest and the temporal allocation for 

agricultural sources was also updated. A new nonroad estimation model was provided by 

U.S. EPA for the 2005 analysis. 

● The emissions data referenced for Kentucky’s portion of the nonattainment area were 

pulled from LADCO’s emissions inventory files. This inventory was prepared using 

similar methodologies. The 2008 data was extrapolated from the 2005 emission 

inventory to represent a base year for maintenance purposes. 

4.3 Emission Projections

In consultation with the U.S. EPA and other stakeholders, IDEM selected the year 2021 as the 

maintenance year for this redesignation request. This document contains projected emission 

inventories for 2015 and 2021. Emission projections were prepared for Dearborn County, 

Indiana, as well as for the entire nonattainment area. IDEM, with assistance from LADCO, 

prepared emission projections for 2015 and 2021 for the entire nonattainment area. 

The detailed 2015 and 2021 emissions inventory for the entire Cincinnati-Hamilton, OH-KY-IN 

nonattainment area can be found in Appendix E. Emission trends are an important gauge for 

continued compliance with the annual standard for fine particles. Therefore, IDEM performed 

an initial comparison of the inventories for the base year (2008-extrapolated from the 2005 

emission inventory), interim year (2015-interpolated from 2009 emissions and 2018 emissions 

estimates) and maintenance year (2021-extrapolated from 2018 emission estimates) for Dearborn 

County, Indiana and the entire Cincinnati-Hamilton OH-KY-IN nonattainment area. 

For the 2008 attainment year, emissions were extrapolated from the 2005 LADCO modeling 

inventory, using LADCO’s growth factors, for all sections except point sources (electrical 

generating units and non-electrical generating units). Point source emissions for 2008 were 

compiled from Indiana, Kentucky, and Ohio’s annual emissions inventory databases. The 2015 

interim year emissions were estimated based on the 2009 and 2018 LADCO modeling inventory, 

using LADCO’s growth factors, for all sectors. The 2021 maintenance year is based on 

emissions estimates from the 2018 LADCO modeling. 
24 

Graphs 4.17, 4.18, 4.19, and 4.20 visually compare 2008 (base year) NOx, SO2, and direct PM2.5 

estimated emissions with the 2015 and 2021 projected emissions for Lawrenceburg Township, 

Dearborn County, Indiana. Graphs 4.21, 4.22, 4.23, and 4.24 visually compare the 2008 (base 

year) NOx, SO2 and direct PM2.5 estimated emissions with the 2015 and 2021 projected emissions 

for the entire Cincinnati-Hamilton, OH-KY-IN nonattainment area. AEP-Tanner’s Creek 

accounts for over 80% of Lawrenceburg Township’s total emissions. However, Lawrenceburg 

Township accounts for a minor portion (14%) of the total nonattainment area emissions. While 

an increase can be seen in the projected emissions for Lawrenceburg Township, Dearborn 

County, Indiana for NOx, SO2 and direct PM2.5, overall emissions in the entire CincinnatiHamilton, OH-KY-IN nonattainment area are decreasing substantially as can be seen in Graphs 

4.21, 4.22, 4.23 and 4.24. Mobile source emission inventories are further described in Section 

5.0. In addition to LADCO’s estimates, point source emissions were projected based upon the 

statewide EGU NOx budgets from the Indiana NOx rule. It should be noted that EGU emission 

estimates for 2015 and 2021 were projected utilizing the Department of Energy Information’s 

Annual Energy Outlook Supplemental tables for the year 2018. These tables were generated for 

the reference case of the Annual Energy Outlook 2007 (AEO 2007) using the National Energy 

Modeling System. Future year actual emissions for Lawrenceburg Township may vary based 

upon the consent decree for AEP which includes Tanner’s Creek. Additionally, the SO2 and 

NOx allocations for AEP-Tanner’s Creek for 2014 and beyond within the proposed Transport 

Rule are less than 2008 actual emissions. Graphs and data tables of emissions from the EGU 

source category can be found in Appendix D. 

Graph 4.17 

Comparison of 2008, 2015 and 2021 Projected NOx Emissions, Lawrenceburg Township, 

Dearborn County, Indiana-With CAIR 

 Refer to Section 4.3 above for explanation of projected increase in emissions. 

‐

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

2008 2015 2021

Tons per Year

Year NOX
25 

Graph 4.18 

Comparison of 2008, 2015 and 2021 Projected SO2 Emissions, Lawrenceburg Township, 

Dearborn County, Indiana-With CAIR 

 Refer to Section 4.3 above for explanation of projected increase in emissions. 

Graph 4.19 

Comparison of 2008, 2015 and 2021 Projected Direct PM2.5 Emissions, Lawrenceburg 

Township, Dearborn County, Indiana-With CAIR 

 Refer to Section 4.3 above for explanation of projected increase in emissions. 

‐

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

2008 2015 2021

Tons per Year

SO2 Year

860

880

900

920

940

960

980

1,000

1,020

2008 2015 2021

Tons per Year

Direct PM 2.5 Year
26 

Graph 4.20 

Comparison of 2008, 2015 and 2021 Projected SO2, NOx and Direct PM2.5 Emissions, 

Lawrenceburg Township, Dearborn County, Indiana-With CAIR 

Graph 4.21 

Comparison of 2008, 2015 and 2021 Projected NOx Emissions for the Entire CincinnatiHamilton, OH-KY-IN Nonattainment Area-With CAIR 

‐

5,000.00

10,000.00

15,000.00

20,000.00

25,000.00

30,000.00

35,000.00

40,000.00

45,000.00

2008 2015 2021

Tons per Year

NOX SO2 Direct PM2.5

‐

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

2008 2015 2021

Tons per Year

Year NOX
27 

Graph 4.22 

Comparison of 2008, 2015 and 2021 Projected SO2 Emissions for the Entire CincinnatiHamilton, OH-KY-IN Nonattainment Area-With CAIR 

Graph 4.23 

Comparison of 2008, 2015 and 2021 Projected Direct PM2.5 Emissions for the Entire 

Cincinnati-Hamilton, OH-KY-IN Nonattainment Area-Without CAIR 

‐

20,000

40,000

60,000

80,000

100,000

120,000

140,000

2008 2015 2021

Tons per Year

Year SO2

7,800

8,000

8,200

8,400

8,600

8,800

9,000

2008 2015 2021

Tons per Year

Direct PM2.5 Year
28 

Graph 4.24 

Comparison of 2008, 2015 and 2021 Projected SO2, NOx and Direct PM2.5 Emissions for the 

Entire Cincinnati-Hamilton, OH-KY-IN Nonattainment Area-(NOx and SO2 With CAIR, 

PM2.5 Without CAIR) 

NOx emissions within the entire Cincinnati-Hamilton, OH-KY-IN nonattainment area are 

projected to decline by 46.9% between 2008 and 2021. Emission reduction benefits from U.S. 

EPA rules covering the NOx SIP Call, Tier 2 Motor Vehicle Emissions Standards and Gasoline 

Sulfur Control Requirements, Highway Heavy-Duty Engine Rule, and Nonroad Diesel Engine 

Rule are factored into the changes. Additionally, due to implementation of the NOx SIP Call 

across the eastern United States, NOx and fine particle levels entering the Cincinnati area will 

also be decreased. SO2 emissions within the Cincinnati area are projected to decline by 24.3% 

between 2008 and 2021. Direct PM2.5 emissions from 2008 to 2021 are also projected to decline 

by 5.6% within the Cincinnati area, see Tables 4.1 and 4.2. 

Table 4.1 

Comparison of 2008 Estimated and 2021 Projected Emission Estimates Lawrenceburg 

Township, Dearborn County, Indiana (Tons Per Year) 

2008 2021 Change % Change 

NOx 10,621.35 13,767.56 3,146.21 29.6% 

SO2 27,164.52 38,261.63 11,097.11 40.9% 

Direct PM2.5 920.29 1,011.29 91.00 9.9% 

‐

20,000.00

40,000.00

60,000.00

80,000.00

100,000.00

120,000.00

140,000.00

160,000.00

2008 2015 2021

Tons per Year

NOX SO2 Direct PM2.5
29 

Table 4.2 

Comparison of 2008 Estimated and 2021 Projected Emission Estimates Entire CincinnatiHamilton, OH-KY-IN Nonattainment Area (Tons Per Year) 

2008 2021 Change % Change 

NOx 148,706.15 78,819.18 -69,886.97 -46.9% 

SO2 116,966.42 88,540.12 -28,426.30 -24.3% 

Direct PM2.5 8,687.22 8,202.63 -484.59 -5.6% 

4.4 Demonstration of Maintenance

Quality assured ambient air quality data from all the monitoring sites indicate that air quality in 

the Cincinnati area met the annual NAAQS for fine particles for the three-year period ending in 

2009. U.S. EPA’s Redesignation Guidance (Page 9) states, “A state may generally demonstrate 

maintenance of the NAAQS by either showing that future emissions of a pollutant or its 

precursors will not exceed the level of the attainment inventory, or by modeling to show that the 

future mix of sources and emissions rates will not cause a violation of the NAAQS.” Emissions 

projections outlined in Section 4.0 of this document clearly illustrate that regional NOx and SO2 

emissions in the area will continue to decline leading to local reductions between 2008 and 2021

(maintenance plan horizon). Section 7.0 further discusses the implications of these emission 

trends and provides an analysis to support these conclusions. 

In Indiana, major point sources in all counties are required to submit air emissions information 

once every three years, or annually, if the NOx or SO2 potential to emit is greater than 2,500 tons 

per year in accordance with the Emission Reporting Rule, 326 IAC 2-6. IDEM prepares a new 

periodic inventory for all precursor emission sectors every three years. These precursor emission 

inventories will be prepared for 2011, 2014, and 2017, as necessary, to comply with the 

inventory reporting requirements established in the CAA. Emissions information will be 

compared to the 2008 base year and the 2021 projected maintenance year inventories to assess 

emission trends, as necessary, to assure continued compliance with the annual standard for fine 

particles.

4.5 Permanent and Enforceable Emission Reductions

Permanent and enforceable reductions of NOx and SO2 have contributed to the attainment of the 

annual standard for fine particles. Some of these reductions were due to the implementation of 

the NOx SIP Call and some were due to the application of tighter federal standards on motor 

vehicles and fuels. 

Section 6.0 identifies the emission control measures specific to Dearborn County, Indiana, as 

well as the implementation status of each measure. 

4.6 Provisions for Future Updates 

 
30 

As required by Section 175A(b) of the CAA, Indiana commits to submit to the Administrator, 

eight years after redesignation, an additional revision of this SIP. The revision will contain 

Indiana's plan for maintaining the national primary fine particles air quality standard for ten years 

beyond the first ten-year period after redesignation. 

5.0 MOBILE SOURCE EMISSION BUDGETS

U.S. EPA requirements outlined in 40 CFR 93.118(e)(4) stipulate that mobile source emissions 

budgets for PM2.5 and NOx be established as part of a SIP. The mobile source emissions budgets 

are necessary to demonstrate conformance of transportation plans and improvement programs 

with the SIP. 

The following is a summary of the detailed mobile input and output calculation files located in 

Appendix F. 

5.1 Onroad Emissions Estimates

The Ohio-Kentucky-Indiana Regional Council of Governments (OKI) is the Metropolitan 

Planning Organization (MPO) for the Cincinnati-Hamilton OH-KY-IN area which includes: 

Dearborn County in Indiana; Butler, Clermont, Hamilton, and Warren counties in Ohio; and, 

Boone, Campbell, and Kenton counties in Kentucky. This organization maintains a travel 

demand forecasting model that is used to simulate the traffic in the area and to predict what 

traffic would be in future years given growth expectations. The model is used mostly to identify 

where travel capacity will be needed and to determine the infrastructure requirements necessary 

to meet that need. It is also used to support the calculation of mobile source emissions. The 

travel demand forecasting model is used to predict the total daily vehicle miles traveled (VMT) 

and the U.S. EPA software program referred to as MOVES is used to produce emission factors to 

calculate the emissions per mile. The product of these two outputs, once combined, is the total 

amount of pollution emitted by onroad vehicles for the particular analyzed area. 

5.2 Overview

Broadly described, MOVES is used to generate “emission factors,” which are the average 

emissions per mile (grams/mile) for direct PM2.5 and PM2.5 precursors, including NOx and SO2. 

There are numerous variables that can affect the emission factors. The vehicle-fleet (vehicles on 

the road) age and the vehicle types have a major affect on the emission factors. The facility-type 

the vehicles are traveling on (MOVES facility-types are Freeway, Arterial, Local, and Ramp) 

and the vehicle speeds also affect the emission factor values. Meteorological factors such as air 

temperature and humidity affect the emission factors, as does fuel type, such as low Reid Vapor 

Pressure (RVP) gasoline. These data are estimated using the best available data to generate 

emission factors for direct PM2.5 and PM2.5 precursors, including NOx and SO2. After emission 

factors are generated, the emission factors must be multiplied by the VMT to determine the 

quantity of vehicle-related emissions. This information derives from the travel demand model 

(TDM). 
31 

It should be noted that each year analyzed will have different emission factors, volumes, speeds, 

and likely some additional links. MOVES input and output files can all be found in Appendix F. 

5.3 Emission Estimates

Table 5.1 outlines the onroad emission estimates for the Ohio and Indiana portions of the 

nonattainment area for the years 2005, 2008 (Attainment Year), 2015 (Interim Year), and 2021 

(Horizon Year). The following emission estimates are based on the actual TDM network runs for 

the years 2005, 2008, 2015, and 2021. 

Table 5.1 

Emission Estimates for Onroad Mobile Sources 

for the Cincinnati-Hamilton OH-KY-IN PM2.5 Nonattainment Area 

Cincinnati-Hamilton OHKY-IN NA Area 2005 2008 2015 2021 

PM2.5 (tons/year) 2,272.50 2,034.23 1,598.67 1,128.35 

NOx (tons/year) 58,423.36 51,357.02 31,064.20 18,911.05 

Lawrenceburg Township 

(Dearborn County Indiana) 

subtotal 

 

PM2.5 (tons/year) 33.98 29.89 25.14 18.11 

NOx (tons/year) 865.46 748.81 482.33 297.95 

Lawrenceburg Township 

subtotal % 

PM2.5 (tons/year) 1.50 1.47 1.57 1.61 

NOx (tons/year) 1.48 1.46 1.55 1.58 

Table 5.2 contains the 2015 and 2021 regional mobile source emissions budgets for the Ohio and 

Indiana portions of the nonattainment area. 

Table 5.2 

Mobile Source Emission Budgets for the Ohio and Indiana Portions 

of the Cincinnati PM2.5 Nonattainment Area 

2015 2021 

PM2.5 (tons/year) 1,678.60 1,241.19 

NOx (tons/year) 35,723.83 21,747.71 

Consistent with the federal implementation rule for fine particles, IDEM does not consider 

mobile SO2 to be a significant contributor to fine particles for this nonattainment area, as SO2 
32 

constitutes less than one percent (<1%) of the area’s total anthropogenic emissions for the years 

2005, 2008, 2015, or 2021. 

This document creates an interim year budget for 2015 and a horizon year budget for 2021 for 

the Ohio and Indiana portions of the nonattainment area. These budgets are based on the 2008 

onroad emission inventory used to support photochemical modeling for the same year, and has 

incorporated an appropriate safety margin as described below. A similar document was created 

for the Kentucky portion of the nonattainment area. 

Initial Base M (2005) Comprehensive Air Quality Model with Extension (CAMx) modeling 

results indicated a worst case future design value in the Cincinnati-Hamilton OH-KY-IN 

nonattainment area of 84 ppb. In an effort to accommodate future variations in TDMs and 

vehicle miles traveled forecast when no change to the network is planned, IDEM consulted with 

the interagency consultation group, including U.S. EPA – Region 5, to determine a reasonable 

approach to address this variation. The interagency consultation group approved a five percent 

(5%) safety margin for PM2.5 mobile source emissions estimates for the year 2015, a ten percent 

(10%) safety margin for PM2.5 mobile source emissions estimates for the year 2021, and a fifteen 

percent (15%) safety margin for NOx mobile source emissions estimates for the years 2015 and 

2021. 

Safety margins are 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 the safety margin allocations detailed above to mobile sources while still 

continuing to maintain total emissions in the Cincinnati-Hamilton OH-KY-IN area well below 

the 2008 attainment level of emissions. These safety margins were calculated by adding a 

straight-line percentage to the mobile source emission estimates for the years 2015 and 2021. 

Safety margin, as defined by the conformity rule, looks at the total emissions from all sources in 

the nonattainment area. The resulting 2015 and 2021 budgets for PM2.5 and NOx emissions 

remain well below the 2005 base year emissions referenced in Table 5.1. 

In summary, for all three states combined, the mobile budget safety margin allocation translates 

into: 

 An allocation of 98.49 tons/year for PM2.5 and 5,709.06 tons/year for NOx for 2015. 

 An allocation of 140.38 tons/year for PM2.5 and 3,799.82 tons/year for NOx for 2021. 

The federal rule at 40 CFR 93.101 defines safety margin as 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. When compared to the overall safety margin as defined by 40 CFR 93.101, it is 

evident this allocation to mobile sources is significantly below the total safety margin for all 

sources in the Cincinnati-Hamilton OH-KY-IN area as detailed in Table 4.2. 

While IDEM believes that this is sufficient to support the requested increase, IDEM and its 

partners will be conducting additional air quality modeling which will include the adjusted on-
33 

road mobile emissions as well as any additional corrections and modifications that may be 

necessary due to the constant review and evaluation of the model inputs. 

All methodologies, latest planning assumptions, and margins of safety were determined 

appropriate through the interagency consultation process. 

6.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures that have been or will be 

implemented in Dearborn County, Indiana, including CAA requirements and additional state or 

local measures implemented beyond CAA requirements. 

6.1 Reasonably Available Control Technology (RACT)

 As required by Section 172 of the CAA, Indiana in the mid-1990s promulgated rules requiring 

RACT for emissions of VOCs. There were no specific rules required by the CAA, such as 

RACT for existing sources, beyond statewide rules. Statewide RACT rules have applied to all 

new sources locating in Indiana since that time. The Indiana rules are found in 326 IAC 8. The 

following is a listing of applicable rules: 

 326 IAC 8-1-6 BACT for Non-Specific Sources 

326 IAC 8-2 Surface Coating Emission Limitations 

326 IAC 8-3 Solvent Degreasing Operations 

326 IAC 8-4 Petroleum Sources 

326 IAC 8-5 Miscellaneous Operation 

326 IAC 8-6 Organic Solvent Emission Limitations 

Since Dearborn County, Indiana, attained the annual NAAQS for fine particles prior to an 

Attainment SIP or RACT SIP being due, and since the Implementation Rule for fine particles 

stipulates that states are only required to draft and implement RACT rules for the precursor 

emission reductions necessary to attain the standard, no further RACT rules are required for this 

area. These Indiana rules are CAA requirements already in the SIP and provide secondary 

benefits for PM2.5. 

6.2 Implementation of Past SIP Revisions

The Cincinnati area was only recently designated nonattainment for the annual standard for fine 

particles and the area has attained the standard well in advance of its attainment deadline of 

2010. As a result, Indiana is no longer required to develop and submit an Attainment SIP or 

RACT SIP for this area under the annual NAAQS for fine particles. 

6.3 Nitrogen Oxides (NOx) Rule
34 

The U.S. EPA NOx SIP Call required twenty-two states to adopt rules that would result in 

significant emission reductions from large EGUs, industrial boilers, and cement kilns in the 

eastern United States. Indiana adopted this rule in 2001. Beginning in 2004, this rule accounted 

for a reduction of approximately thirty-one percent (31%) of all NOx emissions statewide 

compared to previous uncontrolled years. 

Twenty-one other states have also adopted these rules. The result is that significant reductions 

have occurred regionally and within the nonattainment area because of the number of affected 

units within the region. From Graphs 4.13 and 4.14, it can be seen that emissions covered by this 

program have been trending downward since 1999. Table 6.1, compiled from data taken from 

the U.S. EPA Clean Air Markets Web site, quantifies the gradual NOx reductions that have 

occurred in Indiana as a result of Title IV (Acid Rain) of the CAA and the NOx SIP Call Rule. 

The NOx SIP Call cap stayed in place through 2008, at which time the caps in the CAIR 

program superseded it. Since CAIR is a regional cap and trade program, it cannot be predicted at 

this time what effect this will have on EGU units located in the nonattainment area or other 

upwind counties. 

Further, U.S. EPA published Phase II of the NOx SIP Call that establishes a budget for large 

(emissions of greater than 1 ton per day) stationary internal combustion engines. In Indiana, the 

rule decreases emissions statewide from natural gas compressor stations by 4,263 tons during the 

ozone season (May through September). The Indiana Phase II NOx SIP Call Rule became 

effective February 26, 2006 and implementation began in 2007. 

Table 6.1 

Trends in EGU NOx Emissions Statewide in Indiana 

Year NOx Emissions (tons /year) 

1999 347,216.5 

2000 334,522.1 

2001 315,419.7 

2002 281,146.1 

2003 260,980.0 

2004 224,311.3 

2005 207,981.6 

2006 202,728.0 

2007 196,553.1 

2008 196,134.5 

2009 110,968.9 

Budget 2009-2014 108,935 

Budget 2015 and later 90,779 

6.4 Measures Beyond CAA SIP Requirements

Reductions in fine particles precursor emissions have occurred, or are anticipated to occur, as a 

result of local and federal programs. These additional control measures include: 

 Tier 2 Vehicles Standards2

Federal Tier 2 motor vehicle standards require all passenger vehicles in a manufacturer’s 
35 

fleet, including light-duty trucks and sport utility vehicles (SUVs), to meet an average 

standard of 0.07 grams of NOx per mile. Implementation began in 2004 and was 

completed in 2007. The Tier 2 standards also cover passenger vehicles over 8,500 

pounds gross vehicle weight rating (larger pickup trucks and SUVs), which are not 

covered by the current Tier 1 standards. For these vehicles, the standards were phased in 

beginning in 2008, with full compliance in 2009. The new standards require vehicles to 

be 77% to 95% cleaner than those on the road prior to the program. The Tier 2 standards 

also reduced the sulfur content of gasoline to 30 parts per million (ppm) beginning in 

January 2006. Most gasoline sold in Indiana prior to January 2006 had a sulfur content 

of about 500 ppm. Sulfur occurs naturally in gasoline, but interferes with the operation 

of catalytic converters on vehicles resulting in higher NOx emissions. Lower sulfur 

gasoline is necessary to achieve the Tier 2 vehicle emissions standards. 

Heavy-Duty Gasoline and Diesel Highway Vehicle Standards3

New U.S. EPA standards designed to reduce NOx and VOC emissions from heavy-duty 

gasoline and diesel highway vehicles took effect in 2004. A second phase of standards 

and testing procedures that began in 2007, reduced PM2.5 emissions from heavy-duty 

highway engines and also reduced highway diesel fuel sulfur content to 15 ppm since the 

sulfur can damage emissions control devices. The total program is expected to achieve a 

90% reduction in direct PM2.5 emissions and a 95% reduction in NOx emissions for these 

new engines using low sulfur diesel, compared to existing engines using higher sulfur 

content diesel. There will also be SO2 reductions from these rules. The U.S. EPA has 

not quantified the expected reductions. 

 Large Nonroad Diesel Engine Standards4

In May 2004, U.S. EPA promulgated new rules for large nonroad diesel engines, such as 

those used in construction, agricultural and industrial equipment, to be phased in between 

2008 and 2014. The nonroad diesel rules also reduce the allowable sulfur in nonroad 

diesel fuel by over 99%. Nonroad diesel fuel currently averages approximately 3,400 

ppm sulfur. This rule limits nonroad diesel sulfur content to 500 ppm in 2006 and 15 

ppm in 2010. The combined engine and fuel rules will reduce NOx and PM2.5 emissions 

from large nonroad diesel engines by over 90%, compared to current nonroad engines 

using higher sulfur content diesel. 

Nonroad Spark-Ignition Engines and Recreational Engines Standards

This standard, effective in July 2003, regulates NOx, VOCs, and carbon monoxide (CO) 

for groups of previously unregulated nonroad engines. The 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 (forklifts and airport ground service 

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

recreational marine diesel engines. The regulation varies based upon the type of engine 

and vehicle. 

2

 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 3

 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 4

 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm
36 

The large spark-ignition engines contribute to ozone formation and ambient CO and 

PM2.5 levels in urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 

started in 2007. Like the large spark-ignition engines, recreational vehicles contribute to 

ozone and fine particles formation and ambient CO and PM2.5 levels. For model year 

2006 off-highway motorcycles and all-terrain vehicles, at least 50% of a manufacture’s 

fleet was required to meet the new exhaust emissions standard and 100% of the fleet was 

required to meet the standards in 2007. Recreational marine diesel engines over 37 

kilowatts are used in yachts, cruisers and other types of pleasure craft. Recreational 

marine engines contribute to ozone formation and PM2.5 levels, especially surrounding 

marinas. 

When all of the nonroad spark-ignition engines and recreational engine standards are 

fully implemented, an overall 72% reduction in VOCs, 80% reduction in NOx, and 56% 

reduction in CO emissions are expected by 2020. 

Reciprocating Internal Combustion Engine Standards5 

This new standard, effective in May 2010, regulates air toxics emissions from existing 

diesel powered stationary reciprocating internal combustion engines that meet specific 

siting, 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) used at area sources of air toxics 

emissions and constructed or reconstructed before June 12, 2006; (2) used at major 

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

horsepower, and constructed or reconstructed before June 12, 2006; and, (3) used at 

major sources of air toxics for non-emergency purposes, having a site rating of greater 

than 500 horsepower, and constructed or reconstructed before December 19, 2002. 

Operators of existing engines will be required to: (1) install emissions 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 emissions 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. 

When all of the reciprocating internal combustion engine standards are fully implemented 

in 2013, U.S. EPA estimates that emissions from these engines will reduce air toxics by 

approximately 1,000 tons per year (tpy), PM2.5 by 2,800 tpy, carbon monoxide by 14,000 

tpy, and volatile organic compounds by 27,000 tpy. 

 

5

 http://www.epa.gov/ttn/atw/rice/fr03mr10.pdf
37 

Category 3 Marine Diesel Engine Standards6

This new standard, effective in June 2010, promulgates more stringent exhaust emission 

standards for new large marine diesel engines with per-cylinder displacement at or above 

30 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 will apply beginning in 2011; long-term standards 

requiring an eighty percent (80%) reduction in NOX emissions 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 PM 

emissions in the U.S. will be reduced by approximately 1.2 million tpy and 143,000 tpy, 

respectively. 

Clean Air Interstate Rule (CAIR)

On May 12, 2005, the U.S. EPA promulgated the “Rule to Reduce Interstate Transport of 

Fine Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to Acid Rain 

Program; Revisions to the NOx SIP Call”; Final Rule. (40 CFR Parts 51, 72, 75 and 96) 

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 to 

meet federal requirements. The purpose of CAIR is to reduce interstate transport of 

precursors to fine particles and ozone. 

CAIR applies to: (1) any stationary fossil-fuel-fired boiler or stationary fossil-fuel-fired 

combustion turbine, a generator with nameplate capacity of more than 25 megawatt 

electrical (MWe) producing electricity for sale; and, (2) a unit that qualifies as a 

cogeneration unit during the 12-month period starting on the date that the unit first 

produces electricity and continues to qualify as a cogeneration unit, a cogeneration unit 

serving at any time a generator with a nameplate capacity of more than 25 MWe and 

supplying in any calendar year more than one-third of the unit’s potential electric output 

capacity or 219,000 MWh (megawatt hours), whichever is greater to any utility power 

distribution system for sale. 

6

 http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ae43a6
38 

This rule provides annual state caps for NOx and SO2 in two phases, with the Phase I caps 

for NOx and SO2 starting in 2009 and 2010, respectively. Phase II caps become effective 

in 2015. The U.S. EPA is allowing the caps to be met through a cap and trade program if 

a state chooses to participate in the program. 

In response to U.S. EPA’s rulemaking, IDEM adopted a state rule in 2006 based on the 

model federal rule. IDEM’s rule includes an annual and seasonal NOx trading program 

and an annual SO2 trading program. This rule requires compliance effective January 1, 

2009. 

On March 10, 2005, the U.S. EPA finalized CAIR. SO2 emissions from power plants in 

the 28 eastern states and the District of Columbia covered by CAIR will be cut by 4.3 

million tons by 2009 and reduced by an additional 5.4 million tons in 2015. NOx

emissions will be cut by 1.7 million tons by 2009 and reduced by an additional 1.3 

million tons in 2015. The D.C. Circuit court’s vacatur of CAIR in July of 2008 and 

subsequent remand without vacatur of CAIR in December of 2008 directs U.S. EPA to 

revise/replace CAIR in order to properly address the deficiencies outlined by the court. 

Since the court’s opinion made it clear that CAIR is deficient and must be 

revised/replaced, the program cannot be defined as permanent and enforceable for SIP 

purposes. On July 6, 2010, U.S. EPA proposed the Clean Air Transport Rule to replace 

CAIR. The Transport Rule will result in even further benefits above and beyond CAIR 

than what is assumed within the emission inventories and modeling. 

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

precursors. The modeling analyses discussed in Section 7.0 include these rules and show the 

reductions in annual fine particle concentrations expected to result from the implementation of 

these rules. 

6.5 Controls to Remain in Effect

Indiana commits to maintain the control measures listed above after redesignation, or submit to 

U.S. EPA, as a SIP revision, any changes to its rules or emission limits applicable to NOx, SO2,

or direct PM2.5 sources as required for maintenance of the annual standard for fine particles in 

Dearborn County, Indiana. 

Indiana, through IDEM’s Office of Air Quality and its Compliance and Enforcement Branch, 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 fine particles and fine particle precursors in Dearborn County, Indiana. 

6.6 New Source Review Provisions

Indiana has a long standing and fully implemented New Source Review (NSR) program that is 

outlined at 326 IAC 2. The rule includes provisions for the Prevention of Significant 

Deterioration (PSD) permitting program in 326 IAC 2-2. Indiana's PSD program was 
39 

conditionally approved on March 3, 2003 (68 FR 9892) and received final approval on May 20, 

2004 (69 FR 29071) by U.S. EPA as part of the SIP. 

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

shutdown or curtailment was taken in demonstrating attainment, will not be allowed to construct, 

reopen, modify, or reconstruct without meeting all applicable permit rule requirements. The 

review process will be identical to that used for new sources. Once the area is redesignated, 

OAQ will implement NSR through the PSD program, which requires an air quality analysis to 

evaluate whether the new source will threaten the NAAQS. 

7.0 MODELING AND METEOROLOGY 

Although U.S. EPA Redesignation Guidance does not require modeling for nonattainment areas 

seeking redesignation, extensive modeling has been performed covering the Cincinnati, Ohio 

region to determine the effect of national emission control strategies on fine particle levels. 

These modeling analyses determined that the Cincinnati area, including Dearborn County in 

southeastern Indiana is significantly impacted by regional transport of fine particles and its 

precursors, and that regional SO2 and NOx reductions are an effective way to attain the annual 

standard for fine particles in this area. Future year modeled annual fine particle concentrations 

are expected to be reduced by 0.6 to 1.3 μg/m3. Examples of these modeling analyses are 

described below. 

7.1 Summary of Modeling Results to Support Rulemakings

U.S. EPA Modeling for Transport Rule, 2010

U.S. EPA performed modeling to support the emission reductions associated with the Transport 

Rule. U.S. EPA used Comprehensive Air Quality Model with Extension (CAMx, Version 5), 

applied to the 2005 meteorology, as processed by the Mesoscale Model (MM5), Version 3.7.4. 

Emissions input into CAMx included SO2, NOx, volatile organic compounds (VOC), ammonia, 

and direct PM2.5 for 2005. The modeling was based on the annual fine particles design values 

calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year 

modeling was conducted, which included the Cincinnati area, and the future year design values 

for 2012 and 2014 were evaluated for attainment of the annual NAAQS for fine particles of 15 

μg/m3

, as shown in Table 7.1. Fine particle concentrations are accounted for by modeling both 

the base future year emissions and then the emissions reductions associated with the Transport 

Rule. U.S. EPA found model performance met suggested benchmark performance goals within 

or close to the ranges found in other comparable modeling applications (Technical Support 

Document for the Transport Rule – Air Quality Modeling). 

7 http://www.epa.gov/airquality/transport/pdfs/TR_AQModeling_TSD.pdf 
40 

Table 7.1 

Transport Rule Modeling Results from U.S. EPA – 2010 

County Monitor ID 

Design Value 

 2003-2007 

Future Design 

Value 

2012 Base 

Future Design 

Value 

2014 Base 

 (μg/m3

) (μg/m3) (μg/m3) 

Butler County 39-017-0016 15.74 15.25 14.76 

Butler County 39-017-0017 15.36 14.93 14.48 

Butler County 39-017-1004 14.90 14.51 14.06 

Hamilton County 39-061-0006 14.84 14.36 13.88 

Hamilton County 39-061-0014 17.29 16.69 16.14 

Hamilton County 39-061-0040 15.50 15.03 14.51 

Hamilton County 39-061-0042 16.85 16.33 15.80 

Hamilton County 39-061-0043 15.55 15.05 14.56 

Hamilton County 39-061-7001 16.17 15.65 15.12 

Hamilton County 39-061-8001 17.54 16.93 16.38 

Campbell County 21-037-0003 13.67 13.30 12.81 

Kenton County 21-117-0007 14.36 13.98 13.50 

Modeling results show that the base future year modeling with emission reductions from the 

Transport Rule accounts for approximately 0.4 to 0.6 μg/m3 decreases in concentrations for 2012 

and approximately 0.8 to1.2 μg/m3

 decreases in concentrations for 2014 in the Cincinnati area. 

While results of U.S. EPA’s Transport Rule modeling show modeled concentrations above the 

standard using base case emissions at several PM2.5 monitoring sites in Hamilton County, Ohio, 

it should be noted that base year design value used by U.S. EPA was taken from 2003 through 

2007 and considered higher than current 2005 through 2009 design values in the area. Graph 7.1 

shows the downward trend of the design values from 1999 through 2009 for the PM2.5 monitors 

in the Cincinnati area. The resulting decreases of the 2003 through 2007 design values to the 

2005 through 2009 design value at the Murray Road PM2.5 monitor is 1.75 μg/m3, the decrease at 

the Seymour and Vine Street monitor is 1.27 μg/m3 and 1.39 μg/m3 at the West 8th Street 

monitor. The results decrease from all the area monitors ranged from 1.05 μg/m3

 to 1.75 μg/m3. 

Therefore, U.S. EPA’s Transport Rule modeling, using current 2005 through 2009 design values, 

would show lower modeled concentrations approaching the annual fine particle standard of 15.0 

μg/m3. 
41 

Graph 7.1 

PM2.5 Design Value Trends for Cincinnati Area: 1999 - 2009

Results of the U.S. EPA Transport Rule modeling show that the Cincinnati area will approach 

the annual fine particles NAAQS in 2012 with modeled impacts reduced by 3% to 4%. The 

2014 projected design values will decrease by 6% to 7% from the 2003 through 2007 design 

values. If using current design values, U.S. EPA’s CAIR modeling would show the Cincinnati 

area would approach the current annual fine particles standard. 

LADCO Modeling for CAIR

LADCO conducted modeling to determine the impact of CAIR in the Midwest. LADCO’s 

modeling used the CAMx model applied to the year 2005 meteorology, as processed by the 

MM5. Emissions input into CAMx included SO2, NOx, VOC, ammonia, and direct PM2.5 for 

2005. The modeling was based on 2003 through 2007 design values. Future year modeling for 

2009, 2012, and 2018 was conducted and the future year design values were determined without 

the emission reductions associated with CAIR (Round 6), as shown in Table 7.2. 
42 

Table 7.2 

LADCO’s Round 6 Modeling Results for the Cincinnati Area 

Monitor ID 

Monitor 

Name County 

Design Value 

2003-2007 

Base-case 

2012 

Base-case 

2018 

 (μg/m3) (μg/m3) (μg/m3) 

390170003 Bonita & St. John Butler 16.0 15.0 14.7 

390170016 Nilles Rd Butler 15.7 14.9 14.7 

390170017 3300 Wilwood Butler 16.1 15.1 14.9 

390171004 Hook Field Airport Butler 14.9 14.0 13.7 

390250022 400 Clermont Dr Clermont 14.7 13.8 13.6 

390610006 Grooms Rd Hamilton 15.4 14.5 14.3 

390610014 Seymour & Vine St Hamilton 17.3 16.3 16.1 

390610040 Howard Taft Hamilton 15.5 14.6 14.4 

390610041 5300 Winneste Ave Hamilton 15.4 14.7 14.5 

390610042 101 W. 8th St Hamilton 16.9 15.9 15.7 

390610043 254 Kemper Rd Hamilton 15.5 14.6 14.5 

390617001 Sherman Ave Hamilton 16.2 15.2 15.0 

390618001 Murray Rd Hamilton 17.5 16.5 16.3 

210370003 Alexandria Park Campbell 13.3 13.2 13.0 

211170007 University College Kenton 14.4 13.5 13.4 

Results of the LADCO Round 6 modeling show that all but five of the fifteen monitors in the 

Cincinnati area continue to attain the annual NAAQS for fine particles of 15 μg/m3 in 2012. 

Modeled concentrations at the five fine particle monitors, Murray Road, Seymour & Vine Street, 

Wilwood, Sherman Avenue and West 8th Street were above the fine particles standard. Table 7.2 

shows future year modeled annual fine particle results without CAIR emission reductions. 

Concentrations for 2009 will be 5% to 6% lower than baseline annual fine particles design 

values, 6% to 8% lower in 2018. A graphical representation of the modeling results is shown in 

Graph 7.2. Modeled results for the Cincinnati area would approach the current annual fine 

particle standard would be lower if the current 2005 through 2009 design values, as shown in 

Graph 7.1, were used. 
43 

Graph 7.2 

Modeling Results (without CAIR) for the Cincinnati Area PM2.5 Monitors 

7.2 LADCO’s Round 5 Particulate Source Apportionment Results

Particulate Source Apportionment (PSAT) modeling was conducted by LADCO. The results of 

the PSAT Round 5 modeling shows the regional contributions by emission sectors on each 

monitor that was modeled. Chart 7.1 shows the PSAT modeling results for the Murray Road fine 

particles monitor in Hamilton County in southwest Ohio. Ohio was the biggest regional 

contributor to the Murray Road fine particles monitor with Indiana, Kentucky, the Visibility 

Improvement State and Tribal Association of the Southeast (VISTAS) Regional Planning 

Organization (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South 

Carolina, Tennessee, Virginia and West Virginia and the Eastern Band of the Cherokee Indians), 

the Central Regional Air Planning Association (CENRAP) Regional Planning Organization 

(Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkansas, and Louisiana), the 

Western Regional Air Partnership (WRAP) Regional Planning Organization (Arizona, 

California, Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, Wyoming) and Pennsylvania 

also contributing. 

The sector emissions are described as EGU, non-EGU, NH3 – ammonium emission sources, 

offroad emission sources including marine, air travel and railroad emission sources, onroad 

mobile emission sources, area, and boundary conditions. 

The PSAT modeling results show the majority of Indiana’s emission sector contributions come 

from EGUs, ammonium, onroad, offroad (including marine, aircraft and railroad), non-EGU, and 

area sources. Other contributions resulted mainly from EGU, non-EGU, and ammonium 

emissions from other regional areas. 

12

13

14

15

16

17

18

2003-2007 D.V. 2009 2012 2018

Concentratins (ug/m3)

Future Year 

Bonita & St. John Nilles Rd 3300 Wilwood

Hook Field Airport 400 Clermont Dr Grooms Rd

Seymour & Vine St Howard Taft 5300 Winneste Ave

101 W. 8th St 254 Kemper Rd Sherman Ave

Murray Rd Alexandria Park University College
44 

Chart 7.1 

Regional/Emission Sector PSAT Results at Murray Road in Hamilton County 

The following pie charts depict the species contributions to fine particle concentrations at the 

Cincinnati area monitors. The pie charts include both the observed 2005 contributions and future 

year 2009 modeled contributions for each monitor. Since the monitors are in close proximity of 

each other, results are fairly similar in the distribution of species concentrations among the 

monitors. Charts 7.2 through 7.5 cover the three fine particle monitors in southwestern Ohio and 

one fine particles monitor in northern Kentucky with the highest concentrations used to 

determine compliance with the annual fine particles NAAQS of 15 μg/m3

. 

The speciation listed in the pie charts include SO4 – sulfate mass, NO3 – nitrate mass, OC – 

organic carbon mass, EC – elemental carbon mass, Soil – crustal material mass, NH4 – 

ammonium mass, PBW – particles bound water mass, BLAN – passively collected mass. 
45 

Chart 7.2 

Species Modeled Contributions to Murray Road PM2.5 Monitor 

 

Chart 7.3 

Species Modeled Contributions to Seymour & Vine St. PM2.5 Monitor 

 

Chart 7.4

Species Modeled Contributions to 101 West 8th Street PM2.5 Monitor 

 

Observed 2005 Contributions at Murray Road PM2.5 Monitor

so4

33%

no3

8%

oc

26%

ec

4%

soil

2%

nh4

13%

pbw

11%

blan

3%

so4

no3

oc

ec

soil

nh4

pbw

blan

2009 Modeled Contributions at Murray Road PM2.5 Monitor

so4

37%

no3

oc 7%

22%

ec

3%

soil

2%

nh4

14%

pbw

13%

blan

2%

so4

no3

oc

ec

soil

nh4

pbw

blan

Observed 2005 Contributions at Seymour & Vine St. PM2.5 Monitor

so4

34%

no3

8%

oc

25%

ec

4%

soil

2%

nh4

13%

pbw

11%

blan

3%

so4

no3

oc

ec

soil

nh4

pbw

blan

2009 Modeled Contributions at Seymour & Vine St. PM2.5 Monitor

so4

37%

no3

oc 7%

22%

ec

3%

soil

2%

nh4

14%

pbw

13%

blan

2%

so4

no3

oc

ec

soil

nh4

pbw

blan

Observed 2005 Contributions at 101 West 8th St. PM2.5 Monitor

so4

34%

no3

8%

oc

25%

ec

4%

soil

2%

nh4

13%

pbw

11%

blan

3%

so4

no3

oc

ec

soil

nh4

pbw

blan

2009 Modeled Contributions at the 101 West 8th St. PM2.5 Monitor

so4

39%

no3

oc 6%

21%

ec

3%

soil

2%

nh4

14%

pbw

13%

blan

2%

so4

no3

oc

ec

soil

nh4

pbw

blan
46 

Chart 7.5

Species Modeled Contributions to University College PM2.5 Monitor 

 

Results of the Round 5 PSAT modeling for the Cincinnati area fine particle monitors show the 

highest pollutant contributors to base case and future year fine particle concentrations are sulfate, 

organic carbon, ammonium and nitrate. Future year modeling shows decreases in organic 

carbon, nitrates and elemental carbon. The future year modeling did show increases in sulfates, 

particles bound water and ammonium from the base-case modeled concentrations. 

7.3 Summary of Existing Modeling Results

U.S. EPA and LADCO modeling for future year design values have consistently shown that 

existing national emission control measures will help the Cincinnati area approach attainment of 

the annual NAAQS for fine particles standard of 15 μg/m3. Emission control measures to be 

implemented in the next several years will help air quality meet the standard in the future. U.S. 

EPA future year modeling of national emission control strategies, based on current design 

values, showed the Cincinnati area will approach the annual NAAQS for fine particles. Future 

national and local emission control strategies will ensure that the Cincinnati fine particles

nonattainment area will maintain the lower fine particle concentrations. 

7.4 Meteorological Analysis for Southeastern Indiana

Meteorological conditions are one of the most important factors that influence development and 

transport of fine particles. Stagnant surface conditions and upper air ridging during any time of 

the year provides conducive conditions for development and transport of fine particles. 

Ultimately, passage of surface cold fronts with a clean air mass change will lower fine particle 

readings in the Cincinnati area. 

7.4.1 Surface Air Conditions Present during High Fine Particles Concentrations Days

Higher annual concentrations of fine particles tend to correlate with warmer temperatures and 

lighter wind speeds, although high fine particle episodes can occur in the summer fall, winter or 

spring. It should be noted that higher annual fine particle concentrations are driven by individual 

days with higher fine particle concentrations throughout the monitored year. Therefore, it is 

difficult to attribute higher fine particle concentrations to annualized meteorological rankings. 

Review of several of the higher fine particles concentration episodes (days with concentrations 

Observed 2005 Contributions at University College PM2.5 Monitor

so4

34%

no3

8%

oc

23%

ec

4%

soil

3%

nh4

13%

pbw

11%

blan

4%

so4

no3

oc

ec

soil

nh4

pbw

blan

2009 Modeled Contributions at University College PM2.5 Monitor

so4

39%

no3

6% oc

20%

ec

3%

soil

2%

nh4

14%

pbw

13%

blan

3%

so4

no3

oc

ec

soil

nh4

pbw

blan
47 

over 35 μg/m3

) over the past few years shows conditions were hot in the summer with 

temperatures in the middle 80o

 Fahrenheit or higher and average wind speeds were fairly light. 

Fall and winter high fine particles concentration days had near normal temperatures but very 

light wind speeds with higher humidity. Surface conditions present for higher fine particle days 

had a high pressure system east of the Cincinnati area with a front located either north or west of 

the area. 

Analysis of the Murray Road PM2.5 monitor data on the higher concentration days showed over 

60% occurred with maximum temperatures above 80o

 F and only 5% of the high concentration 

days occurred at maximum temperatures below 40o

 F. The location of this monitor is considered 

downwind of the urban center of Cincinnati so the urban emissions are transported to the 

monitor. However, surface meteorological conditions would also play a large role in increased 

fine particle readings at the monitor. 

7.4.2 Upper Air Conditions Present during High Fine Particles Concentrations Days

Upper air ridges and more stagnant surface wind conditions predominately affect development 

and build up of fine particles. Slow moving upper air ridges can effectively suppress mixing 

within the many levels of the atmosphere and cause pollutants to build up over time. Inversions 

or increases in temperature with a rise in altitude will prevent mixing with air from the upper 

atmosphere. These conditions can occur at any time of the year and are evident in elevated fine 

particle episodes in spring, summer, fall and winter months. Review of upper air features present 

during higher concentration days in the Cincinnati area during the summer showed generally a 

ridge over the area with fairly light winds in the upper atmosphere and warm air advection. The 

upper air features present during higher concentration days in the fall and winter were upper air 

troughs with extremely light winds and moderate temperatures. 

Review of surface and upper air features of higher fine particles concentration days showed 

stagnant surface conditions and upper air ridges existed on those days. These conditions help in 

the buildup of fine particle concentrations in the Cincinnati area. 

7.4.3 Analyses of Atmospheric Conditions for Fine Particles Build-Up

Analyses have been conducted to determine the atmospheric conditions that are most prevalent 

during higher fine particles concentration days in Indiana. LADCO applied a Classification and 

Regression Tree (CART) analysis to data from Indiana that correlated different levels of fine 

particle concentrations to meteorological conditions from 1999 through 2004. (Donna Kenski, 

2005). This type of analysis looks at the meteorological conditions, such as temperature, 

pressure, wind speed, wind direction, relative humidity and dew point temperatures at the 

surface, as well as lower morning and evening mixing heights in the upper atmosphere which 

were present when higher concentrations of fine particles were monitored. Results of this CART 

analysis indicated factors that played a larger role in fine particle concentrations in the southern 

portion of the Midwest were warm-weather conditions with high dew points, southwest winds 

and low evening mixing heights as well as the previous day’s concentrations of fine particles. 
48 

Fine particles are made up of several constituents, including direct PM2.5, sulfates, nitrates, 

ammonium, organic carbon and elemental carbon. Depending on the time of the year, 

concentrations of particulate constituents vary, with nitrates being more prevalent in the winter 

and sulfates more prevalent in the summer. Sulfates and nitrate emission reductions have the 

biggest impact on lower future year fine particle concentrations. 

7.5 Summary of Air Quality Index Days in Southeastern Indiana

An analysis was conducted to review the daily fine particle concentrations over a year to 

determine the Air Quality Index (AQI) trends. Chart 7.6 shows by year (2000 through 2009), the 

percentage number of days during which fine particle concentrations reached the AQI ranges for 

“Good” (0 to 15.3 μg/m3), “Moderate” (15.4 μg/m3 to 40.4 μg/m3) and “Unhealthy for Sensitive 

Groups (USG)” (40.5 μg/m3 to 65.4 μg/m3) at the Murray Road PM2.5 monitor in Hamilton 

County in Ohio. There were no days which the fine particle levels reached the “Unhealthy” level 

of 65.5 μg/m3 to 150.4 μg/m3 or above. 

Chart 7.6 

Distribution of PM2.5 Concentration Days on the AQI Levels of Health Concern

Table 7.3 shows the rankings, by year, for the three AQI ranges. The year 2009 had the most 

“Good” concentration days during the 10-year period analyzed (2000 through 2009) at 61%. 

The year 2005 had the most “Moderate” concentrations days at 60% and “Unhealthy for 

Sensitive Group” concentration days at 8%. As can be seen, weather plays a large role in fine 

particle concentrations development and transport as 2000, 2001, 2004 and 2005 were conducive 

to PM2.5 development which translated to moderate and unhealthy for sensitive group levels of 

air quality over 50% of the time. 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

USG

Moderate

Good
49 

Table 7.3 

Ranking and Percentage of Highest Number of Days 

at AQI Levels of Health Concern 

Ranking Good Moderate 

Unhealthy for 

Sensitive Group 

1st 2009 – 61% 2005 – 60% 2005 – 8% 

2nd 2008 – 60% 2000 – 58% 2000 – 7% 

3rd 2006 – 58% 2004 – 52% 2008 – 6% 

4th 2007 – 56% 2001 – 49% 2001 – 5% 

5th 2002 – 51% 2003 – 46% 2003 – 3% 

6th 2003 – 51% 2002 – 45% 2002 – 3% 

7th 2001 – 46% 2007 – 41% 2007 – 3% 

8th 2004 – 46% 2006 – 39% 2006 – 3% 

9th 2000 – 35% 2009 – 39% 2004 – 2%

10th 2005 – 32% 2008 – 35% 2009 – 0% 

7.6 Summary of Meteorological Analysis for Southeastern Indiana

Annual fine particle concentrations in the Cincinnati area are driven by higher fine particles 

concentration days that can occur during any time of the year. Conditions that are most 

prevalent during higher fine particle concentration days are lighter winds, higher relative 

humidity and above average maximum temperatures in the summer and lighter winds, higher 

relative humidity and normal temperatures in the fall, winter or spring. Upper air weather 

patterns generally include ridging over the area with stagnant conditions at the surface caused by 

lower mixing heights and stable conditions for summer episodes and ridging or troughs over the 

area in the fall, winter or spring episodes. Surface winds from any direction can transport 

pollutants from surrounding areas into the Cincinnati area. Nitrates are bigger contributors to 

fine particle concentrations in the winter and sulfates are bigger contributors to fine particle 

concentrations in the summer. 

8.0 CORRECTIVE ACTIONS 

8.1 Commitment to Revise Plan

As noted in Section 4.6 above, Indiana commits to review and revise as appropriate its 

Maintenance Plan eight years after redesignation, as required by Section 175A of the CAA. 

8.2 Commitment for Contingency Measures

IDEM will monitor fine particle concentrations to determine whether trends indicate higher 

values or whether emissions appear to be increasing. If it is determined that fine particle levels 

and emissions are increasing and action is necessary to reverse that trend, IDEM will take action 

to reverse the noted trend, prior to a violation of the standard occurring. 
50 

Indiana commits to adopt and expeditiously implement necessary corrective action in the 

following circumstance: 

Action Level Response

An Action Level Response shall be prompted whenever a violation of the standard (three 

year average annual arithmetic mean value of 15.1 μg/m3

 or greater) occurs. In the event 

that the Action Level is triggered and is not found to be due to an atypical unfavorable 

meteorological condition, exceptional event, malfunction or noncompliance with a permit 

condition or rule requirement, IDEM will determine additional control measures needed 

to assure future attainment of the annual NAAQS for fine particles. In this case, 

measures that can be implemented in a short time will be selected in order to be in place 

within eighteen months from the close of the fine particles season that prompted the 

Action Level. 

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative 

and legal processes. This process will include publication of notices, an opportunity for 

public hearing and other measures required by Indiana law for rulemaking by state 

environmental boards. 

If a new measure or control is already promulgated and scheduled to be implemented at the 

federal or state level, and that measure or control is determined to be sufficient to address the 

upward trend in air quality, additional local measures may be unnecessary. Furthermore, IDEM 

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

the area to attainment. 

8.3 Contingency Measures

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. Listed below are example 

measures that may be considered. The selection of measures will be based upon costeffectiveness, emission reduction potential, economic and social considerations, or other factors 

that IDEM deems appropriate. IDEM will solicit input from interested and affected persons in 

the maintenance area prior to selecting appropriate contingency measures. All of the listed 

contingency measures are potentially effective or proven methods of obtaining significant 

reductions of fine particles precursor emissions. Because it is not possible at this time to 

determine what control measure will be appropriate at an unspecified time in the future, the list 

of contingency measures outlined below is not comprehensive. IDEM anticipates that if 

contingency measures should ever be necessary, it is unlikely that a significant number (i.e., all 

those listed below) will be required. 

1) Vehicle inspection and maintenance program. 

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

3) Require NOx or SO2 emission offsets for new and modified major sources. 
51 

4) Require NOx or SO2 emission offsets for new and modified minor sources. 

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

6) Require NOx or SO2 controls on new minor sources (less than 100 tons). 

7) Wood stove change-out program. 

8) Require increased recovery efficiency at sulfur recovery plants. 

9) Various emissions reduction measures or dust suppressant for unpaved roads and/or parking 

lots. 

10) Idling Restrictions. 

11) Broader geographic applicability of existing measures. 

12) One or more transportation control measures sufficient to achieve at least a half a percent 

(0.5%) reduction in actual area-wide precursor 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) Transit improvements. 

c) Traffic flow improvements. 

d) Other new or innovative transportation measures not yet in widespread use that affect 

state and local governments deemed appropriate. 

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. 

9.0 PUBLIC PARTICIPATION

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

concerning the draft Redesignation Petition and Maintenance Plan in the Dearborn County 

Register on November 18, 2010. 

A public hearing to receive comments concerning the redesignation request was conducted on 

January 5, 2011 at the Lawrenceburg Public Library in Lawrenceburg, Indiana. During the 

public comment period IDEM received minor technical updates from the Ohio Environmental 

Protection Agency (Ohio EPA) that included an updated Mobile Source Emissions Inventory. 

No other comments were received during the comment period. The public comment period 

closed on January 7, 2011. Appendix J includes a copy of the public notice, certifications of 

publication, the transcript from the public hearing, and a summary of the minor technical updates 

received from Ohio EPA. 

10.0 CONCLUSIONS 

Lawrenceburg Township, Dearborn County, Indiana, has attained the annual NAAQS for fine 

particles and does not significantly contribute to violations outside its portion of the Cincinnati-
52 

Hamilton OH-KY-IN nonattainment area. This petition demonstrates that Lawrenceburg 

Township, Dearborn County, Indiana, has complied with the applicable provisions of the CAA 

regarding redesignation of nonattainment areas for fine particles. IDEM has prepared a State 

Implementation and Maintenance Plan that meets the requirement of Section 110(a)(1) of the 

CAA. 

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

and enforceable measures and that additional significant regional NOx and SO2 reductions 

following implementation of Phase II NOx SIP Call and CAIR and/or its replacement rule or 

program will ensure continued compliance (maintenance) with the standard. Furthermore, 

emission projections indicate that NOx and SO2 emissions will continue to decline, thus ensuring 

that the area continues to maintain compliance with the standard and provide for an increasing 

margin of safety. Based on this presentation, Lawrenceburg Township, Dearborn County, 

Indiana, meets the requirements for redesignation under the CAA (Section 107(d)(3)) and U.S. 

EPA guidance for fine particles. 

Consistent with the authority granted to the U.S. EPA, the State of Indiana requests that 

Lawrenceburg Township, Dearborn County, Indiana, be redesignated to attainment for the 

annual fine particles standard simultaneously with U.S. EPA approval of this Indiana State 

Implementation and Maintenance Plan provisions contained herein.