John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Scott J. Nally, Director 

MAR 15 2013 

Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Blvd. R-19J 

Chicago, Illinois 60604-3507 

Re: Request for Review and Approval of the Revised Steubenville-Weirton Area 

Maintenance Plan Approval for the 1997 Eight-Hour Ozone Standard 

Dear Administrator Hedman: 

I am writing to formally request review and approval of a revision to the maintenance plan for 

the Ohio portion of the Steubenville-Weirton area (Jefferson County) with respect to the 1997 

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

plan for this area on September 22, 2006. U.S. EPA approved this requests May 16, 2007 

(72 FR 27652). 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission 

projections and conformity budgets based on emission rates generated from U.S. EPA's 

latest mobile emissions model, the Motor Vehicle Emission Simulation (MOVES) 2010. In 

December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA's official emission factor 

model. The area is still attaining and maintaining the 1997 8-hour ozone standard and the 

point, area and non-road emissions have not changed significantly and did not need to be 

updated for this submittal. 

The enclosed information was compiled by Ohio EPA, Ohio Department of 

Transportation, and Brooke-Hancock-Jefferson Metropolitan Planning Commission. The 

public hearing for this package was held on March 4, 2013 in Steubenville, Ohio. No 

testimony was provided at the public hearing. Comments were received by West 

Virginia Division of Air Quality. A copy of these comments are provided in Appendix D 

along with our responses. 

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

www.epa.ohio.gov • (614) 644-3020 •(614) 644·3184(fax) 
Administrator Hedman 

RE: Request for Review and Approval of the Revised Steubenville-Weirton Area Maintenance Plan Approval for 

the 1997 Eight-Hour Ozone Standard 

Page 2 of2 

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

electronic version of the submittal in PDF format is available at 

http://epa.ohio.gov/dapc/SIP/1997 .aspx under the heading" Redesignations and Maintenance 

Plans". 

If you have any questions, please contact Jennifer Dines in the Division of Air Pollution 

Control at (614) 644-3696. 

Sincerely, 

~o~ally Director 

enclosures 

cc: Bob Hodanbosi, DAPC 

Jennifer Dines, DAPC 
 

REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR THE OHIO 

PORTION OF THE STEUBENVILLEWEIRTON, OH-WV

EIGHT-HOUR OZONE 

NONATTAINMENT AREA 

Jefferson County, Ohio

(Steubenville-Weirton, OH-WV: Jefferson County) 

Developed By: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control in collaboration with 

West Virginia Department of Environmental 

Protection 

July 2006

Revised March 20131

 

1 Revised- to update the on-road (highway) emission estimates and Jefferson County (OH) Motor Vehicle 

Emission Budgets (MVEBs) using the most recent U.S.EPA approved software, MOVES(2010). 
 

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i 

TABLE OF CONTENTS 

Chapter One 

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

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

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

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

Chapter Two 

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

Chapter Three 

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

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

Three complete years of data ......................................................................................................... 7 

Commitment to continue monitoring ............................................................................................... 9 

Chapter Four 

Emission Inventory ........................................................................................................................ 10

Base Year Inventory ...................................................................................................................... 10

Emission Projections ..................................................................................................................... 11

Demonstration of Maintenance ..................................................................................................... 16

Permanent and Enforceable Emissions Reductions .................................................................... 22

Provisions for Future Updates ...................................................................................................... 23

Chapter Five 

Control measures and regulations ................................................................................................ 24

Implementation of Past SIP Revisions ......................................................................................... 24

New Source Review Provisions ................................................................................................... 26

Assurance of continued controls .................................................................................................. 26

Chapter Six 

Contingency measures ................................................................................................................. 28

Commitment to revise plan ........................................................................................................... 28

Commitment for contingency measures ....................................................................................... 28

Potential contingency measures ................................................................................................... 29

List of VOC and NOx sources ....................................................................................................... 30

Chapter Seven 

Public participation ........................................................................................................................ 32

Chapter Eight 

Conclusions ................................................................................................................................... 33
ii

FIGURES 

Figure 1 Steubenville-Weirton, OH-WV: Jefferson County Basic Nonattainment Area ....... 6 

TABLES 

Table 1 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson Co. 2002 – 2004... 8 

Table 2 Monitoring Data for Wheeling, WV-OH: Jefferson County 2003 - 2005 ............... 8 

Table 3 Emission Estimations for On-road Mobile Sources for Jefferson Co. OH ........... 14

Table 4 Emission Estimations for On-road Mobile Sources for Brooke Co. WV .............. 14

Table 5 Emission Estimations for On-road Mobile Sources for Hancock Co. WV ............ 14

Table 6 Combined Emission Estimations for On-road Mobile Sources ............................ 15

Table 7 Mobile Vehicle Emission Budgets......................................................................... 15

Table 8 VOC Emission Inventory Jefferson Co. OH .......................................................... 17

Table 9 VOC Emission Inventory Combined Hancock and Brooke Co. WV .................... 18 

Table 10 VOC Emission Inventory Steubenville-Weirton, OH-WV: Combined Totals ........ 18

Table 11 NOx Emission Inventory Jefferson Co. Ohio ......................................................... 19

Table 12 NOx Emission Inventory Combined Hancock and Brooke Co. WV ...................... 19

Table 13 NOx Emission Inventory Steubenville-Weirton, OH-WV: Combined Totals ......... 20

Table 14 Projected emission estimates 2004-2018 Jefferson Co. Ohio ............................. 20

Table 15 Projected emission estimates 2004-2018 Combined Hancock/ Brooke Co. WV 21

Table 16 Projected emission estimates 2004-2018 Combined VOC/NOx Totals ............... 21

Table 17 Combined comparison of 2002 and 2004 On-road and EGU Totals ................... 23 

 

APPENDICES 

A Aerometric Information Retrieval System (AIRS) Data 

B Emission Inventories 

C Emissions Analysis Method 

D Public Participation Documentation 
iii

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1 

REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR OZONE ATTAINMENT 

IN THE EIGHT-HOUR OZONE BASIC 

NONATTAINMENT AREA 

Steubenville-Weirton, OH-WV: Jefferson County 

CHAPTER ONE 

Introduction 

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

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

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

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

1979 one-hour standard with an eight-hour ozone standard set at 0.08 parts per million 

(ppm). The standard was challenged legally and upheld by the U.S. Supreme Court in 

February of 2001. 

On April 15, 2004, U.S. EPA designated 134 nonattainment areas for the eight-hour ozone 

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

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

request nonattainment areas be redesignated to attainment providing certain criteria are 

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

from nonattainment to attainment: 

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

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

110(k).

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

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

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

met. 

Background 

Jefferson County, Ohio, Hancock and Brooke Counties in WV form the SteubenvilleWeirton, OH-WV interstate nonattainment area and constitute the Steubenville, OH 

Metropolitan Statistical Area. As part of the 1990 CAA Amendments re-evaluation, 

Steubenville-Weirton, OH-WV: Jefferson County was designated as 

Unclassifiable/Attainment for the one-hour ozone standard pursuant to the CAA and 

therefore, has not previously been subject to nonattainment area rule-makings. As a result 

of the 2004 ozone designations, U.S. EPA designated Steubenville-Weirton, OH-WV: 

Jefferson County basic nonattainment and subject to the eight-hour ozone requirements, 

including development of a plan to reduce volatile organic compounds (VOCs) and oxides 
2 

of nitrogen (NOx) emissions and a demonstration that the area will meet the federal eighthour air quality standard for ozone by June 2009. 

This document is intended to support Ohio’s request that the Steubenville-Weirton, OHWV: Jefferson County area be redesignated from nonattainment to attainment for the 

eight-hour ozone standard. Steubenville-Weirton, OH-WV: Jefferson County has recorded 

three (3) years of complete, quality-assured ambient air quality monitoring data for the 

years 2002 – 2004 demonstrating attainment of the eight-hour ozone standard. 

Geographical Description

 Jefferson County is located in eastern Ohio and contains the city of Steubenville. Jefferson 

County is bordered by Columbiana County to the north, Jefferson to the south, Caroll and 

Harrison to the west and Hancock, Brooke and Ohio Counties in West Virginia to the east. 

This area is shown is shown in Figure 1. 

 Status of Air Quality 

Ozone monitoring data for the most recent three (3) years, 2002 through 2004, 

demonstrates that the air quality has met the NAAQS for ozone in this basic nonattainment 

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

Chapter four, supports a redesignation to attainment for Steubenville-Weirton, OH-WV: 

Jefferson County based on requirements in Section 107(d)(3)(E) of the CAA. 
3 

CHAPTER TWO 

Requirements for Redesignation 

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

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

September 4, 1992, to Regional Air Directors. This request for redesignation and 

maintenance plan is based on the redesignation guidance, supplemented with additional 

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

Below is a summary of each redesignation criterion as it applies to SteubenvilleWeirton, OH-WV: Jefferson County. 

i.) Attainment of the standard: 

 There are two components involved in making this demonstration. The first 

component relies on ambient air quality data. The data that are used to 

demonstrate attainment should be the product of ambient monitoring that is 

representative of the area of highest concentration. The data should be 

collected and quality-assured in accordance with 40 CFR 58 and recorded in 

the Aerometric Information Retrieval System (AIRS) in order for it to be 

available to the public for review. 

 The second component relies upon supplemental U.S. EPA-approved air 

quality modeling. The supplemental modeling is not required for ozone 

nonattainment areas seeking redesignation. Therefore, this ozone 

redesignation request for Steubenville-Weirton, OH-WV: Jefferson County 

does not include modeling data. However, in Appendix C the most recent 

modeling results showing future attainment and maintenance are provided. 

Chapter three discusses this requirement in more detail and provides the 

attainment demonstration. 

ii.) SIP approval: 

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

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

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

Steubenville-Weirton, OH-WV: Jefferson County. Chapter five discusses 

this requirement in more detail and provides the attainment demonstration. 

iii.) Permanent and enforceable improvement in air quality; 

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

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

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

state. 
4 

 Steubenville-Weirton, OH-WV: Jefferson County was not designated 

nonattainment for ozone as part of the 1990 CAA Amendments reevaluation. As a result, Ohio has not adopted or implemented control 

measures beyond the federal measures, the initial 1979 statewide rules and 

those 1994 and 1995 rules which applied to “rural” attainment areas. 

Chapters four and five discuss this requirement in more detail and provide 

the attainment demonstration. 

iv.) Section 110 and Part D requirements: 

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

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

redesignation request. 

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

designated nonattainment based on a violation of the NAAQS. 

 i.) Section 172(c) requirements 

 This section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for 

an emission inventory will be satisfied by the inventory requirements 

of the maintenance plan. 

 ii.) Conformity 

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

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

redesignation request should include conformity procedures, if the 

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

conformity procedures in place at the time that it submits a 

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

conformity regulation upon issuance, as applicable. Chapter five 

discusses this requirement in more detail and provides the attainment 

demonstration. 

v.) Maintenance plans. 

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

must fully approve a maintenance plan which meets the requirements of 

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

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

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

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

ensure such maintenance. 
5 

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

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

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

the nonattainment SIP prior to redesignation. 

States seeking redesignation of a nonattainment area should consider the 

following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 

 Chapter six discusses this requirement in more detail and provides the 

attainment demonstration. 
6 

CHAPTER THREE 

OZONE MONITORING

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

Requirement 1 of 4: 

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

attained. Ozone monitoring data must show that violations of the ambient standard are no 

longer occurring. 

Background: 

 There are two monitors measuring ozone concentrations in this 

nonattainment area. The primary monitor is located in Steubenville, Ohio and 

is operated by Ohio EPA’s Southeast District Office, Division of Air Pollution 

Control. Data from a monitor located in Weirton, West Virginia is also 

included for the eight-hour ozone attainment demonstration. The Weirton 

monitor is operated by the West Virginia Department of Environmental 

Protection (DEP), Division of Air Quality (DAQ), Northern Panhandle 

Regional Office. A listing of the four (4) highest readings from 2002 through 

2004 is shown in Table 1 and readings from 2003-2005 are shown in Table 

2. These readings were retrieved from the U.S. EPA air quality system 

(AQS.) The locations of the monitoring sites for this nonattainment area are 

shown on Figure 1. 

Demonstration: 

Figure 1 Steubenville-Weirton, OH-WV: Jefferson County Basic 

Nonattainment Area 

 
7 

Requirement 2 of 4: 

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

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

Demonstration: 

Ohio EPA and WV DEP have quality assured all data shown in Appendix A 

in accordance with 40 CFR 58.10 and all other federal requirements. Ohio 

EPA and WV DEP have recorded the data in the AQS database and 

therefore data are available to the public. 

Requirement 3 of 4: 

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

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

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

quality assured data. 

Background: 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

fourth highest daily maximum eight-hour average ozone concentration is also 

called the site's design value. Table 1 shows the monitoring data for 2002 –

2004 and Table 2 show the monitoring data for 2003-2005 at the 

nonattainment area sites and was retrieved from the U.S. EPA AQS. The air 

quality design value for the area is the highest design value among all sites 

in the area. 
8 

Demonstration: 

 Table 1 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson 

 County 2002 – 2004

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

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

1

st 2nd 3rd 4th 2002-2004

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

39-081-0016 JEFFERSON 227 NORTH 5TH 2002 100 .099 .099 .093 .093

39-081-0016 JEFFERSON 227 NORTH 5TH 2003 99 .107 .097 .090 .079

39-081-0017 JEFFERSON 618 LOGAN 2004 99 .087 .075 .074 .071

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2002 99 .099 .097 .097 .097

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2003 100 .111 .097 .085 .076

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2004 100 .076 .072 .067 .063

Highest Average .081 ppm

 Table 2 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson 

 County 2003 – 2005

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

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

1

st 2nd 3rd 4th 2003-2005

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

39-081-0016 JEFFERSON 227 NORTH 5TH 2003 99 .107 .097 .090 .079

39-081-0016 JEFFERSON 227 NORTH 5TH 2004 99 .087 .075 .074 .071

39-081-0017 JEFFERSON 618 LOGAN 2005 100 .094 .092 .087 .083

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2003 100 .100 .092 .083 .077

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2004 97 .079 .074 .074 .073

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2005 100 .084 .084 .077 .075

Highest Average 0.77 ppm

A comprehensive list of the site’s design values during the 2002-2004 time 

period is in Appendix A. The area's design value has trended downward as 

emissions have declined due to such factors as 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. Ohio's NOx Budget Trading Program Rule was 

approved on May 25, 2004 Ohio Administrative Code (OAC) Chapter 3745-

14. It is expected that this downward trend will continue as the above 

programs continue and some form of the U.S. EPA Clean Air Interstate Rule 

(CAIR) is implemented. 
9 

Requirement 4 of 4: 

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

monitoring network to verify the maintenance of the attainment status. 

Demonstration: 

 Ohio EPA and WV DEP commit to continue monitoring ozone levels at the 

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

EPA Region 5 and Region 3 prior to making changes to the existing 

monitoring network, should changes become necessary in the future. Ohio 

EPA and WV DEP will continue to quality assure the monitoring data to meet 

the requirements of 40 CFR 58 and all other federal requirements. 

Connection to a central station and updates to the Ohio EPA Web site2 will 

provide real time availability of the data and knowledge of any exceedances. 

Ohio EPA and WV DEP will enter all data into AQS on a timely basis in 

accordance with federal guidelines. 

 

2

www.epa.state.oh.us/dapc/ 
10

CHAPTER FOUR 

EMISSION INVENTORY

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

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

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

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

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

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

Other emissions inventory related requirements include a projection of the emission 

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

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

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

10 year maintenance period. 

Requirement 1 of 5: 

A comprehensive emission inventory of the precursors of ozone completed for the base 

year. 

Background: 

The point source data are taken from Ohio's annual emissions reporting 

program. The 2002 periodic inventory has been identified as the preferred 

data base for SIP development and does coincide with nonattainment air 

quality in Steubenville-Weirton, OH-WV: Jefferson County. 

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

a budget for all large EGUs. Ohio’s budget is adopted at OAC Chapter 

3745-14. The budget represents a statewide cap on NOx emissions. These 

emissions, capped by the state rule, should remain at least this low through 

the maintenance period covered by this request. 

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

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

Demonstration: 

While ozone and its precursors are transported into this region from outside 

areas, this information does provide some indication of the impact from Ohio 

sources near the nonattainment area. The emissions are decreasing 

substantially in response to regional and national programs affecting many 

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

of the inventory also impact ozone formation, but large regional sources such 

as EGUs have a substantial impact on the formation of ozone. 
11

Requirement 2 of 5: 

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

Background: 

Ohio EPA prepared a comprehensive inventory for Steubenville-Weirton, OH-WV: 

Jefferson County, including area, mobile, and point sources for precursors of ozone 

(VOCs and NOx) for base year 2002. The information below describes the 

procedures Ohio EPA used to generate the 2002 base inventories. These 

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

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

analyses. These processed modeling inventories have been identified as the 

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

references to LADCO include the Midwest Regional Planning Organization. 

 Area sources were taken from the Ohio 2002 periodic inventory 

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

Department of Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information. 

 Mobile source emissions were calculated from MOVES2010 produced 

emission factors. 

Point source information was compiled from Ohio EPA’s 2002 annual 

emissions inventory database and the 2002 U.S. EPA Air Markets 

acid rain database3

. 

 Biogenic emissions are not included in these summaries. 

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

Mobile Inventory Model (NMIM) 2002 application. To address 

concerns about the accuracy of some of the categories in U.S. EPA’s 

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

companies to review the base data and make recommendations. 

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

Emissions were estimated for aircraft, commercial marine vessels and 

railroads. Recreational motorboat population and spatial surrogates 

(used to assign emissions to each county) were significantly updated. 

The populations for the construction equipment category were 

reviewed and updated based upon surveys completed in the Midwest 

and the temporal allocation for agricultural sources also was updated. 

 

 

3

http://www.epa.gov/airmarkets/acidrain 
12

Demonstration: 

On-Road Emission Estimations 

In coordination with the Brooke, Hancock, Jefferson Transportation Study 

(BHJTS) and the West Virginia Department of Transportation (WVDOT), the 

Ohio Department of Transportation (ODOT) utilizes a regional travel demand 

forecast model to simulate traffic in the area and to forecast traffic flows for 

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

planning tool to evaluate the transportation system including determination of 

locations where additional travel capacity may be needed and to determine 

the infrastructure requirements necessary to meet that need. It is also used 

as a tool for air quality purposes to estimate the total emissions of pollution 

caused by vehicles in the area. The travel demand forecasting model is 

used to predict the total daily vehicle miles traveled (VMT) and a U.S. EPA 

computer program called MOVES is used to calculate emissions per mile. 

The product of these is the total amount of pollution emitted by the on-road 

vehicles for the particular analyzed area. 

Overview 

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

the average emissions per mile (grams/mile) for ozone precursors, NOx and 

VOC. The MOVES model includes a number of variables that affect the 

emission factors. These variables have national default values, some of 

which require modification to reasonably reflect local conditions. Some of 

these variables are discussed here. The vehicle fleet (vehicles on the road) 

age and the vehicle type have a major effect on the emission factors. The 

source types are traveling on road types (MOVES road types are Rural 

Restricted Access, Rural Unrestricted Access, Urban Restricted Access, and 

Urban Unrestricted Access). The vehicle speeds also affect the emission 

factor values. Meteorological conditions such as air temperature and 

humidity have a significant effect on emission factors. Emission factors 

produced by MOVES can also include the effect of emission reduction 

strategies such as vehicle inspection and maintenance programs, regulation 

of fuels, etc. These MOVES inputs are estimated using the best available 

data. 

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

agencies in a formal interagency consultation process. Emission factors are 

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

emissions. 

The emission factors from MOVES can be used with the travel demand 

model information by combining the disaggregate emission rates with VMT, 
13

and source type population for each road type, source type and hour of day, 

and then sum them up to get the total emissions for the area. 

The BHJTS analysis method, developed by ODOT, is to aggregate the 

emission rates by two source types (cars & trucks), then applying VMT and 

source type population, thereby reducing the intensive processes. In the first 

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

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

hourly link volumes generated from travel demand model are combined with 

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

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

Vehicle-based emissions are obtained by the combination of corresponding 

emission factors and source type population. Intrazonal emissions are 

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

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

emission factors to get intrazonal emissions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions. 

Automated programs, using FORTRAN and CUBE scripting, were developed 

by ODOT to generate total emissions. The process uses data on daily and 

directional traffic distributions as well as more up to date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process also 

handles the newer model network formats and MOVES generated emission 

factors. 

MOVES input and output files are provided in Appendix C. 

Best Available Data 

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

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

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

generating emission factors. Likewise, the most current transportation 

planning data available from BHJTS and most current ODOT count data 

were used by ODOT for the emissions estimates. 

Analysis Years 

Analysis years for this re-designation request include 2002, 2004, 2009, and 

2018 to meet the requirements specified by the CAA and U.S. EPA. The 

travel demand model presents the transportation system conditions for each 

of these years. Model runs for each future analysis year contain the road 

network BHJTS and ODOT expects to exist at the beginning of that year with 

corresponding socioeconomic forecasts for that year. 
14

Local Road VMT 

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

travel demand model. These local roads are represented as fictitious 

roadways called centroid connectors. Local road VMT is included in the 

ODOT post process by including the traffic loaded on centroid connectors. In 

addition, some local road traffic is captured as intra-zonal trips which travel 

demand models usually do not assign to roadway segments. ODOT post 

process includes these trips as local road VMT. 

Emission Estimations 

Tables 3 through 5 contain the results of the emissions analysis for the 

appropriate years. 

Table 3 - Emission Estimations for On-Road Mobile Sources for Jefferson 

County, Ohio

Jefferson County 2002 2004 2009 2018

VMT (miles/day) 1,709,448 1,611,125 1,576,635 1,540,060

VOC (tons/day) 6.61 5.62 4.20 1.86

NOx (tons/day) 7.75 6.69 5.14 2.11

Table 4 - Emission Estimations for On-Road Mobile Sources for Brooke 

County, West Virginia

Brooke County 2002 2004 2009 2018

VMT (miles/day) 606,195 600,702 602,928 600,944

VOC (tons/day) 1.40 1.20 0.83 0.36

NOx (tons/day) 2.21 1.86 1.28 0.48

Table 5 - Emission Estimations for On-Road Mobile Sources for Hancock 

County, West Virginia

Hancock County 2002 2004 2009 2018

VMT (miles/day) 561,349 502,239 497,991 495,327

VOC (tons/day) 1.08 0.88 0.58 0.25

NOx (tons/day) 2.02 1.56 1.05 0.37
15

Table 6 Combined VOC and NOx Emission Estimations for On-Road 

Mobile Sources for Jefferson County, OH, Brooke and 

Hancock County, WV 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

County VOC 2018

Jefferson County, OH VOC 1.86

Brooke County, WV VOC 0.36

Hancock County, WV VOC 0.25

TOTAL VOC 2.47

County NOx

Jefferson County, OH NOx 2.11

Brooke County, WV NOx 0.48

Hancock County, WV NOx 0.37

TOTAL NOx

2.96

Motor Vehicle Emission Budget 

Table 7 contains the motor vehicle emissions budget for Jefferson County, Ohio. 

Table 7 Mobile Vehicle Emissions Budget for Jefferson County, Ohio 

 (Steubenville-Weirton, OH_WV)4

Jefferson County 2004 2009 2018

VOC (tons/day) 5.62 4.83 2.14

NOx (tons/day) 6.69 5.91 2.43

Brooke and Hancock Co. 2009 2018

VOC (tons/day) 2.60 3.40 1.90

NOx (tons/day) 3.60 4.20 3.90

 

4 Ohio’s submittal only requests budgets be set for Ohio counties. Current 2004, 2009 and 2018 budgets 

for West Virginia are identified in Table 7 and subsequent tables. These budgets were set by West 

Virginia to address the transition to MOVES and U.S. EPA approved these budgets on September 15, 

2011 (76 FR 56975). West Virginia does not plan to make any further updates to their ozone budgets).
16

The Jefferson County budget includes the emission estimates calculated for 

2009 and 2018 and an additional margin of safety. The emission estimates 

are derived from the Tranplan travel demand model and MOVES 2010 as 

described above under the expected Brooke, Hancock, and Jefferson 

Transportation Study (BHJTS) 2025 Long Range Plan. The mobile source 

budget includes 4.83 tons/day for VOC in 2009, 2.14 tons/day for VOC in 

2018, 5.91 tons/day for NOx in 2009, and 2.43 tons/day for NOx in 2018. 

These correspond to a 15 percent increase from the on-road emissions for 

both VOC and NOx. Appendix C contains data tables and graphs of these 

emissions. Tables 8 through 13 below include the mobile vehicle emission 

budgets. 

All methodologies, latest planning assumptions and the safety margins were 

determined through the interagency consultation process described in the 

Transportation Conformity Memorandum of Understanding (MOU) for 

BHJTS. 

Requirement 3 of 5: 

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

standard. 

Background: 

In consultation with U.S. EPA, Ohio EPA selected the year 2018 as the 

maintenance year for this redesignation request. This document contains 

projected emissions inventories for 2009 and 2018. 

Ohio DOT performed emission projections for Steubenville-Weirton, OH-WV: 

 Jefferson County using the following approaches. 

 Mobile source emission projections are based on the U.S. EPA 

MOVES 2010model. The analysis is described in more detail in 

Appendix C. All projections were made in accordance with 

“Procedures for Preparing Emissions Projections” U.S. EPA-45/4-91-

019. 

 Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. LADCO 

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

categories. These files were used to develop the future year 

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

inventories used for redesignation are consistent with modeling 

performed in the future. 
17

The detailed inventory information for Jefferson County for 2004, 2009 and 

2018 is in Appendix B. Emission trends are an important gauge for 

continued compliance with the ozone standard. Therefore, Ohio EPA 

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

maintenance years. Mobile source emission inventories are described in 

Appendix C. In addition to the LADCO estimates, point source emissions 

were projected based upon the statewide EGU NOx budgets from the Ohio 

NOx rule. Emission Inventories for Hancock and Brooke Counties in WV 

used for this request were developed by DEP staff with the support of the 

contractors for the Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS), a federally recognized regional planning organization. 

 

The following tables include sectors Electrical Generating Unit (EGU-Point), 

Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), 

Other Area (Other), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road). 

Please note that WV non-road sector includes MAR. 

Demonstration: 

 Table 8 Jefferson County VOC Emission Inventory Totals for Base 

 Year 2002, Estimated 2004 and Projected 2009 and 2018 (tons 

 per day) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Sector 2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

EGU Point 0.88 0.92 1.03 1.02

Non-EGU 0.23 0.23 0.22 0.24

Non-road 0.90 0.88 0.82 0.55

Other 3.12 3.06 2.91 2.91

MAR 0.05 0.05 0.05 0.05

On-road 6.61 5.62 4.83* 2.14*

TOTAL 11.79 10.76 9.86 6.91 3.85

 * includes 15 percent increase to the mobile source budget 
18

 Table 9 Combined Hancock and Brooke County VOC Emission 

 Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Sector 2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

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

Non-EGU 6.70 4.80 4.30 5.30

Non-road (includes MAR) 1.50 1.50 1.20 1.00

Other(Area) 4.50 4.60 4.50 5.20

On-road 2.48 2.60 3.40 1.90

TOTAL 15.18 13.50 13.40 13.40 0.10

 

Table 10 Steubenville-Weirton, OH-WV: Combined VOC Emission 

Inventory Totals for Base Year 2002, Estimated 2004 and Projected 

2009 and 2018 (tons per day) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

Jefferson Co. OH 

Total 11.79 10.76 9.86 6.91

Brooke and Hancock 

Co. WV Total 15.18 13.50 13.40 13.40

COMBINED VOC

TOTAL 26.97 24.26 23.26 20.31 3.95
19

 Table 11 Jefferson County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2004 and Projected 2009 and 2018 (tons per 

 day) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Sector 2002 Base 2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

EGU Point 183.99 148.80 60.77 40.95

Non-EGU 6.05 5.93 5.63 5.43

Non-road 0.77 0.72 0.58 0.33

Other 0.17 0.18 0.21 0.21

MAR 1.60 1.53 1.35 1.25

On-road 7.75 6.69 5.91* 2.43*

TOTAL 200.33 163.85 74.45 50.60 113.25

 * includes 15 percent increase to the mobile source budget

Table 12 Combined Hancock and Brooke County NOx Emission 

 Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) http://www.vistas-sesarm.org/. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Sector 2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

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

Non-EGU 5.90 4.50 5.10 5.60

Non-road (includes MAR) 4.30 5.30 3.80 3.20

Other(Area) 4.60 4.80 4.90 5.20

On-road Hancock 4.23 3.60 4.20 3.90

TOTAL 19.03 18.20 18.00 17.90 0.30

 
20

Table 13 Steubenville-Weirton, OH-WV: Combined NOx Emission 

 Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

Jefferson Co. OH 

Total 200.33 163.85 74.45 50.60

Hancock and Brooke 

Co. WV Total 19.03 18.20 18.00 17.90

COMBINED NOx

TOTAL 219.36 182.05 92.45 68.50 113.55

 Table 14 Jefferson County Comparison of 2004 attainment year and 

 2018 projected emission estimates (tons per day, summer) 

 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected 

Decrease

VOC 10.76 6.91 3.85

NOx 163.85 50.60 113.25
21

Table 15 Combined Hancock and Brooke County Comparison of 2004 

attainment year and 2018 projected emission estimates (tons 

per day, summer) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected 

Decrease

VOC 13.50 13.40 0.10

NOx 18.20 17.90 0.30

Table 16 Steubenville-Weirton, OH-WV Combined Comparison of 2004 

attainment year and 2018 projected emission estimates (tons 

per day, summer) 

 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected 

Decrease

Combined VOC Total 24.26 20.31 3.95

Combined NOx Total 182.05 68.50 113.55

VOC emissions in the non-attainment area are projected to decrease by 3.95

tons. Area source emissions and, to a lesser extent, point sources, show an 

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

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

2018 and result in an overall drop in VOC emissions. 

NOx emissions in the nonattainment area are projected to decrease by 

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

Emissions Standards and Gasoline Sulfur Control Requirements5, Highway 

Heavy-Duty Engine Rule6

 and Non-Road Diesel Engine Rule7 also are 

factored into the changes. Further, due to implementation of the NOx SIP 

 

5

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

6

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

7

http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 
22

Call across the eastern United States, NOx and ozone levels entering this 

area also will be decreased. 

Requirement 4 of 5: 

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

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

not on temporary adverse economic conditions or unusually favorable meteorology. 

Background: 

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

the NAAQS for ozone in 2004. U.S. EPA’s redesignation guidance (p 9) 

states, “A state may generally demonstrate maintenance of the NAAQS by 

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

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

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

NAAQS.” 

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

emissions information once every three (3) years or annually if VOC potential 

to emit is greater than 250 tons or NOx potential to emit is greater than 2500 

tons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule 

(CERR). Ohio U.S. EPA prepares a new periodic inventory for all ozone 

precursor emission sectors every three (3) years. These ozone precursor 

inventories will be prepared for 2005, 2008, and 2011 as necessary to 

comply with the inventory reporting requirements established in the CFR. 

Emissions information will be compared to the 2002 base year and the 2018 

projected maintenance year inventories to assess emission trends, as 

necessary, to assure continued compliance with the ozone standard. 

Demonstration: 

Permanent and enforceable reductions of volatile organic compounds and 

oxides of nitrogen have contributed to the attainment of the eight-hour ozone 

standard. Some of these reductions were due to the application of tighter 

federal standards on new vehicles. Also, Title IV of the CAA and the NOx

SIP Call required the reduction of oxides of nitrogen from utility sources. 
23

Table 17 Steubenville-Weirton, OH-WV Combined Comparison of 2002 

base year and 2004 attainment year on-road and EGU 

reductions 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section

2002 2004

On-road VOC 9.09 8.22

On-road NOx 11.98 10.29

EGU NOx 183.99 148.80

Requirement 5 of 5: 

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

levels including an annual emission statement from major sources. 

Demonstration: 

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

Administrator, eight (8) years after redesignation, an additional revision of 

this SIP. The revision will contain Ohio's plan for maintaining the national 

primary ozone air quality standard for 10 years beyond the first 10 year 

period after redesignation. 
24

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4:

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) as applied in Ohio’s rural counties.

Background: 

As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were no 

specific rules required by the CAA such as RACT for existing sources beyond 

statewide rules. 

Demonstration: 

Statewide RACT rules have been applied to all new sources locating in Ohio 

since that time. The Ohio rules are found in OAC Chapter 3745-21.

Requirement 2 of 4:

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

implemented. 

Background: 

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

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

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

Beginning in 2004, this rule accounts for a reduction of approximately 31 

percent of all NOx emissions state-wide compared to previous uncontrolled 

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

Demonstration: 

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

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

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

covered by this program have been generally trending downward since 1998 

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

Clean Air Markets Web site, quantifies the gradual NOx reductions that have 

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

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

Trading Program rules in OAC Chapter 3745-14 in response to the SIP Call. 

OAC chapter 3745-14 regulated EGUs and certain non-EGUs under a cap 

and trade program based on an 85 percent reduction of NOx emissions from 
25

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

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

which time the CAIR program will supersede it. 

U.S. EPA has recently published Phase II of the NOx SIP Call that 

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

stationary internal combustion engines. Ohio EPA’s proposed rule OAC 

3745-14-12 addresses stationary internal combustion engines, all used in 

natural gas pipeline transmissions. An 82 percent NOx reduction from 1995 

levels is anticipated. Completion of the compliance plan is expected by May 

1, 2006 and the compliance demonstration will begin May 1, 2007. The 

2007 controlled NOx emissions will be 599 tons per day. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards 

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

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

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

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

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

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

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

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

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

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

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

Heavy-Duty Diesel Engines 

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

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

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

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

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

inventory. 

Clean Air Non-road Diesel Rule 

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

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

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

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

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

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

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

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

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

engine standards take effect, based on engine horsepower, starting in 2008. 
26

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

ozone precursors. 

Requirement 3 of 4:

Acceptable provisions to provide for new source review. 

Background: 

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

program. This is addressed in OAC Chapter 3745-31. The chapter includes 

provisions for the Prevention of Significant Deterioration (PSD) permitting 

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

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

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

SIP. 

Demonstration: 

Any facility that is not listed in the 2002 emission inventory, or for the closing 

of which credit was taken in demonstrating attainment, will not be allowed to 

construct, reopen, modify, or reconstruct without meeting all applicable 

permit rule requirement. The review process will be identical to that used for 

new sources. Once the area is redesignated, Ohio EPA will implement NSR 

through the PSD program. 

Requirement 4 of 4:

Assure that existing controls will remain in effect after redesignation unless the State 

demonstrates through photochemical modeling that the standard can be maintained 

without one (1) or more controls. 

Demonstration: 

Ohio commits to maintaining the aforementioned control measures after 

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

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

maintenance of the ozone standard in Steubenville-Weirton, OH-WV: 

Jefferson County, will be submitted to U.S. EPA for approval as a SIP 

revision. 

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

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

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

relate to the emission of ozone precursors in Steubenville-Weirton, OH-WV: 

Jefferson County. 
27

LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment 

LADCO performed modeling to evaluate the effect of the NOx SIP Call and Tier II / 

Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This 

modeling was originally designed to assess the one-hour ozone standard. Further 

analysis was conducted and documented in the LADCO’s White Paper “8-Hour 

Ozone Assessment” dated May 2, 2001. Base year design values used were the 

average of the design values for the three (3) three-year periods (1994-1996, 1995-

1997, and 1996-1998). Base year emissions were taken from 1996 and four (4) 

ozone episodes were evaluated: June 22-28, 1991; July 14-21, 1991; June 13-25, 

1995; and July 7-18, 1995. 

While modeling results were not calculated for Steubenville-Weirton, OH-WV: 

Jefferson County, the average decrease in ozone from the base case modeling run 

with modeling runs that applied emission controls required by the CAA, NOx SIP 

Call and Tier II /low-sulfur requirements was nine (9) ppb. 

 LADCO Modeling for CAIR of 2004

On March 10, 2004, the U.S. EPA promulgated the CAIR. NOx emissions will be cut 

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

tons in 2018 in 28 eastern states and the District of Columbia. 

LADCO performed modeling to support the associated emission reductions for 

CAIR. This modeling was based on 2001 – 2002 design values for SteubenvilleWeirton, OH-WV: Jefferson County. Results of the CAIR modeling show 

Steubenville-Weirton, OH-WV: Jefferson County will continue to attain the eighthour ozone NAAQS well into the future. 
28

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4:

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

Demonstration: 

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

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

Requirement 2 of 4:

A commitment to expeditiously enact and implement additional contingency control 

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

event that future violations of the ambient standards occur. 

Demonstration: 

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

Warning Level Response: 

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

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

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

determine whether the ozone value indicates a trend toward higher ozone 

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

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

measures necessary to reverse the trend taking into consideration ease and 

timing for implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

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

(September 30). 

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

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

and implementation outlined under action level response shall be followed. 

 

 Action Level Response 

An action level response shall be prompted whenever a two (2) year average 

fourth high monitored value of 85 ppb occurs within the maintenance area. In 

the event that the action level is triggered and is not due to an exceptional 

event, malfunction, or noncompliance with a permit condition or rule 
29

requirement, Ohio EPA will determine additional control measures needed to 

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

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

within eighteen (18) months from the close of the ozone 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 process. This process will include publication of 

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

Ohio law for rulemaking by state environmental boards. 

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

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

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

additional local measures may be unnecessary. Furthermore, Ohio will 

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

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration: 

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the 

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

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

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

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

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

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

below is not comprehensive. 

1) Lower Reid vapor pressure gasoline program. 

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

Technique Guidelines issued in response to the 1990 CAA. 

3) Apply RACT to smaller existing sources. 

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

least half a percent reduction in actual area wide VOC emissions. 

Transportation measures will be selected from the following, based 
30

upon the factors listed above after consultation with affected local 

governments: 

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

programs, work schedule changes, and telecommuting: 

b) traffic flow and transit improvements: 

c) other new or innovative transportation measures not yet in 

widespread use that affects state and local governments 

deemed appropriate.

5) Alternative fuel and diesel retrofit programs for fleet vehicle 

operations. 

6) Controls on consumer products consistent with those adopted 

elsewhere in the United States. 

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

sources. 

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

sources. 

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

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

tons). 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

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

be fully evaluated. 

Requirement 4 of 4:

A list of VOC and NOx sources potentially subject to future controls. 

Demonstration: 

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

controls. 

NOx RACT 

 EGUs 

 asphalt batching plants 
31

 industrial/commercial and institutional boilers 

 process heaters 

 internal combustion engines 

 combustion turbines 

 other sources greater than 100 tons per year 

VOC RACT 

 consumer products 

 architectural and industrial maintenance coatings 

 stage I gasoline dispensing facilities (including pressure valves) 

 automobile refinishing shops 

 cold cleaner degreasers 

 portable fuel containers 

 synthetic organic compound manufacturing

 organic compound batch processes 

 wood manufacturing 

 industrial wastewater 

 aerospace industry 

 shipbuilding 

 bakeries 

 plastic parts coating 

 volatile organic liquid storage 

 industrial solvent cleaning 

 offset lithography 

 industrial surface coating 

 other sources greater than 50 tons per year 
32

CHAPTER SEVEN 

PUBLIC PARTICIPATION

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

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

county publications. 

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

March 4, 2013, at the Steubenville Schiappa Branch Library, located at 4141 Mall Drive,

in Steubenville, Ohio. The public comment period closed on March 4, 2013. Appendix 

D will include a copy of the public notice, response to comments, and the transcript 

from the public hearing. 
33

CHAPTER EIGHT 

CONCLUSIONS

The Steubenville-Weirton, OH-WV: Jefferson County basic nonattainment area has 

attained the NAAQS standard and complied with the applicable provisions of the 1990 

Amendments to the CAA regarding redesignations of basic ozone nonattainment areas. 

Documentation to that effect is contained herein. Ohio EPA has prepared a state 

implementation and maintenance plan that meets the requirement of Section 110 (a)(1) of 

the 1990 CAA. 

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

permanent and enforceable measures. In addition, significant regional NOx reductions will 

ensure continued compliance (maintenance) with the standard and that all CAA 

requirements necessary for redesignation have been met. 

Based on this presentation, the Steubenville-Weirton, OH-WV: Jefferson County ozone 

basic nonattainment area meets the requirements for redesignation under the CAA and 

U.S. EPA guidance. Furthermore, because this area is subject to significant transport of 

pollutants, significant regional NOx reductions will ensure continued compliance 

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

The State of Ohio hereby requests that the Steubenville-Weirton, OH-WV: Jefferson 

County ozone basic nonattainment area be redesignated to attainment simultaneously with 

U.S. EPA approval of the Ohio state implementation and maintenance plan provisions 

contained herein. 
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Synopsis of Changes 

Revised Steubenville-Weirton Maintenance Plan under the 1997 Ozone Standard 

The original redesignation request and maintenance plan document was submitted to 

U.S. EPA on July 31, 2006. U.S. EPA approved this requests on May 16, 2007 (72 FR 

27640). 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile 

emission projections and conformity budgets based on emission rates generated from 

U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation 

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

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

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

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

A redline/strike-out version of the original document follows this synopsis and identifies all 

changes that were made to the original approved request. In summary, revisions were 

made to the on-road (mobile) source emission estimates and budgets contained within 

the tables and text below. In addition, the discussion section regarding on-road modeling 

protocols was updated to identify the latest process applicable to the use of the newer 

MOVES model. Other minor changes were made to conform to current terminology, 

grammar, and formatting conventions. 

In addition to this document, additional changes were also made to the Appendices of the 

original submittal, as follows: 

 Appendix C: this appendix contains the detailed modeling protocol used to 

generate on-road mobile source emission estimates. The document contained 

within this revised submittal is an entirely new document compared to the original 

modeling protocol document submitted in 2006. Both the original and revised 

documents are available on Ohio EPA’s website under the “Appendix” link.

 Appendix D: this appendix contains documents relevant to the public comment 

period and the public hearing. This will contain a revised public notice and revised 

hearing transcript. In some cases, if comments are received or testimony 

provided, it will also contain a revised response to comments document. Both the 

original and revised documents are available on Ohio EPA’s website under the 

“Appendix” link.

These draft documents can all be found at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx

in the table under the heading “Redesignations and Maintenance Plans.” The public 

comment period is open until March 4, 2013. Please refer to the Public Notice for how to 

submit comments. 
 

REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR

OZONE ATTAINMENT 

IN THE OHIO 

PORTION OF THE STEUBENVILLEWEIRTON, OH-WV

EIGHT-HOUR OZONE BASIC

NONATTAINMENT AREA 

Jefferson County, Ohio

(Steubenville-Weirton, OH-WV: Jefferson County) 

Developed By: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control in collaboration with 

West Virginia Department of Environmental 

Protection 
 

July 2006

Revised March 20131

 

1 Revised- to update the on-road (highway) emission estimates and Jefferson County (OH) Motor Vehicle 

Emission Budgets (MVEBs) using the most recent U.S.EPA approved software, MOVES(2010). 

Formatted: Font: 20 pt
 

This page left intentionally blank
i 

TABLE OF CONTENTS 

Chapter One 

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

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

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

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

Chapter Two 

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

Chapter Three 

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

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

Three complete years of data ......................................................................................................... 7 

Commitment to continue monitoring ............................................................................................... 9 

Chapter Four 

Emission Inventory ........................................................................................................................ 10

Base Year Inventory ...................................................................................................................... 10

Emission Projections ..................................................................................................................... 11

Demonstration of Maintenance ..................................................................................................... 16

Permanent and Enforceable Emissions Reductions ................................................................ 2122

Provisions for Future Updates .................................................................................................. 2223

Chapter Five 

Control measures and regulations ............................................................................................ 2324

Implementation of Past SIP Revisions ..................................................................................... 2324

New Source Review Provisions ............................................................................................... 2526

Assurance of continued controls .............................................................................................. 2526

Chapter Six 

Contingency measures ............................................................................................................. 2728

Commitment to revise plan ....................................................................................................... 2728

Commitment for contingency measures ................................................................................... 2728

Potential contingency measures ............................................................................................... 2829

List of VOC and NOx sources ................................................................................................... 2930

Chapter Seven 

Public participation .................................................................................................................... 3132

Chapter Eight 

Conclusions ............................................................................................................................... 3133
ii

FIGURES 

Figure 1 Steubenville-Weirton, OH-WV: Jefferson County Basic Nonattainment Area ....... 6 

TABLES 

Table 1 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson Co. 2002 – 2004... 8 

Table 2 Monitoring Data for Wheeling, WV-OH: Jefferson County 2003 - 2005 ............... 8 

Table 3 Emission Estimations for On-road Mobile Sources for Jefferson Co. OH ........... 14

Table 4 Emission Estimations for On-road Mobile Sources for Brooke Co. WV .............. 14

Table 5 Emission Estimations for On-road Mobile Sources for Hancock Co. WV ............ 14

Table 6 Combined Emission Estimations for On-road Mobile Sources ............................ 15

Table 7 Mobile Vehicle Emission Budgets......................................................................... 15

Table 8 VOC Emission Inventory Jefferson Co. OH ...................................................... 1617

Table 9 VOC Emission Inventory Combined Hancock and Brooke Co. WV ................ 1718

Table 10 VOC Emission Inventory Steubenville-Weirton, OH-WV: Jefferson Co. 

TotalCombined Totals........................................................................................... 18

Table 11 NOx Emission Inventory Jefferson Co. Ohio ..................................................... 1819

Table 12 NOx Emission Inventory Combined Hancock and Brooke Co. WV ...................... 19

Table 13 NOx Emission Inventory Steubenville-Weirton, OH-WV: Jefferson CoCombined

Totals 20

Table 14 Projected emission estimates 2004-2018 Jefferson Co. Ohio ............................. 20

Table 15 Projected emission estimates 2004-2018 Combined Hancock/ Brooke Co. WV2021

Table 16 Projected emission estimates 2004-2018 Combined VOC/NOx Totals ............... 21

Table 17 Combined comparison of 2002 and 2004 On-road and EGU Totals ............... 2223

 

APPENDICES 

A Aerometric Information Retrieval System (AIRS) Data 

B Emission Inventories 

C Emissions Analysis Method 

D Public Participation Documentation 
iii

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1 

REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR OZONE ATTAINMENT 

IN THE EIGHT-HOUR OZONE BASIC 

NONATTAINMENT AREA 

Steubenville-Weirton, OH-WV: Jefferson County 

CHAPTER ONE 

Introduction 

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

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

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

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

1979 one-hour standard with an eight-hour ozone standard set at 0.08 parts per million 

(ppm). The standard was challenged legally and upheld by the U.S. Supreme Court in 

February of 2001. 

On April 15, 2004, U.S. EPA designated 134 nonattainment areas for the eight-hour ozone 

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

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

request nonattainment areas be redesignated to attainment providing certain criteria are 

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

from nonattainment to attainment: 

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

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

110(k).

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

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

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

met. 

 

Background 

Jefferson County, Ohio, Hancock and Brooke Counties in WV form the SteubenvilleWeirton, OH-WV interstate nonattainment area and constitute the Steubenville, OH 

Metropolitan Statistical Area. As part of the 1990 CAA Amendments re-evaluation, 

Steubenville-Weirton, OH-WV: Jefferson County was designated as 

Unclassifiable/Attainment for the one-hour ozone standard pursuant to the CAA and 

therefore, has not previously been subject to nonattainment area rule-makings. As a result 

of the 2004 ozone designations, U.S. EPA designated Steubenville-Weirton, OH-WV: 

Jefferson County basic nonattainment and subject to the eight-hour ozone requirements, 

including development of a plan to reduce volatile organic compounds (VOCs) and oxides 
2 

of nitrogen (NOx) emissions and a demonstration that the area will meet the federal eighthour air quality standard for ozone by June 2009. 

This document is intended to support Ohio’s request that the Steubenville-Weirton, OHWV: Jefferson County area be redesignated from nonattainment to attainment for the 

eight-hour ozone standard. Steubenville-Weirton, OH-WV: Jefferson County has recorded 

three (3) years of complete, quality-assured ambient air quality monitoring data for the 

years 2002 – 2004 demonstrating attainment of the eight-hour ozone standard. 

Geographical Description

 Jefferson County is located in eastern Ohio and contains the city of Steubenville. Jefferson 

County is bordered by Columbiana County to the north, Jefferson to the south, Caroll and 

Harrison to the west and Hancock, Brooke and Ohio Counties in West Virginia to the east. 

This area is shown is shown in Figure 1. 

 Status of Air Quality 

Ozone monitoring data for the most recent three (3) years, 2002 through 2004, 

demonstrates that the air quality has met the NAAQS for ozone in this basic nonattainment 

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

Chapter four, supports a redesignation to attainment for Steubenville-Weirton, OH-WV: 

Jefferson County based on requirements in Section 107(d)(3)(E) of the CAA. 
3 

CHAPTER TWO 

Requirements for Redesignation 

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

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

September 4, 1992, to Regional Air Directors. This request for redesignation and 

maintenance plan is based on the redesignation guidance, supplemented with additional 

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

Below is a summary of each redesignation criterion as it applies to SteubenvilleWeirton, OH-WV: Jefferson County. 

i.) Attainment of the standard: 

 There are two components involved in making this demonstration. The first 

component relies on ambient air quality data. The data that are used to 

demonstrate attainment should be the product of ambient monitoring that is 

representative of the area of highest concentration. The data should be 

collected and quality-assured in accordance with 40 CFR 58 and recorded in 

the Aerometric Information Retrieval System (AIRS) in order for it to be 

available to the public for review. 

 The second component relies upon supplemental U.S. EPA-approved air 

quality modeling. The supplemental modeling is not required for ozone 

nonattainment areas seeking redesignation. Therefore, this ozone 

redesignation request for Steubenville-Weirton, OH-WV: Jefferson County 

does not include modeling data. However, in Appendix C the most recent 

modeling results showing future attainment and maintenance are provided. 

Chapter three discusses this requirement in more detail and provides the 

attainment demonstration. 

ii.) SIP approval: 

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

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

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

Steubenville-Weirton, OH-WV: Jefferson County. Chapter five discusses 

this requirement in more detail and provides the attainment demonstration. 

iii.) Permanent and enforceable improvement in air quality; 

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

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

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

state. 
4 

 Steubenville-Weirton, OH-WV: Jefferson County was not designated 

nonattainment for ozone as part of the 1990 CAA Amendments reevaluation. As a result, Ohio has not adopted or implemented control 

measures beyond the federal measures, the initial 1979 statewide rules and 

those 1994 and 1995 rules which applied to “rural” attainment areas. 

Chapters four and five discuss this requirement in more detail and provide 

the attainment demonstration. 

iv.) Section 110 and Part D requirements: 

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

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

redesignation request. 

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

designated nonattainment based on a violation of the NAAQS. 

 i.) Section 172(c) requirements 

 This section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for 

an emission inventory will be satisfied by the inventory requirements 

of the maintenance plan. 

 ii.) Conformity 

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

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

redesignation request should include conformity procedures, if the 

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

conformity procedures in place at the time that it submits a 

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

conformity regulation upon issuance, as applicable. Chapter five 

discusses this requirement in more detail and provides the attainment 

demonstration. 

v.) Maintenance plans. 

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

must fully approve a maintenance plan which meets the requirements of 

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

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

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

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

ensure such maintenance. 
5 

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

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

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

the nonattainment SIP prior to redesignation. 

States seeking redesignation of a nonattainment area should consider the 

following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 

 Chapter six discusses this requirement in more detail and provides the 

attainment demonstration. 
6 

CHAPTER THREE 

OZONE MONITORING

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

Requirement 1 of 4: 

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

attained. Ozone monitoring data must show that violations of the ambient standard are no 

longer occurring. 

Background: 

 There are two monitors measuring ozone concentrations in this 

nonattainment area. The primary monitor is located in Steubenville, Ohio and 

is operated by Ohio EPA’s Southeast District Office, Division of Air Pollution 

Control. Data from a monitor located in Weirton, West Virginia is also 

included for the eight-hour ozone attainment demonstration. The Weirton 

monitor is operated by the West Virginia Department of Environmental 

Protection (DEP), Division of Air Quality (DAQ), Northern Panhandle 

Regional Office. A listing of the four (4) highest readings from 2002 through 

2004 is shown in Table 1 and readings from 2003-2005 are shown in Table 

2. These readings were retrieved from the U.S. EPA air quality system 

(AQS.) The locations of the monitoring sites for this nonattainment area are 

shown on Figure 1. 

Demonstration: 

Figure 1 Steubenville-Weirton, OH-WV: Jefferson County Basic Formatted: Centered
7 

Nonattainment Area

 

Requirement 2 of 4: 

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

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

Demonstration: 

Ohio EPA and WV DEP have quality assured all data shown in Appendix A 

in accordance with 40 CFR 58.10 and all other federal requirements. Ohio 

EPA and WV DEP have recorded the data in the AQS database and 

therefore data are available to the public. 

Requirement 3 of 4: 

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

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

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

quality assured data. 

Background: 

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

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

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

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

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

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

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

or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. 
8 

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

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

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

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

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

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

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

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

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

fourth highest daily maximum eight-hour average ozone concentration is also 

called the site's design value. Table 1 shows the monitoring data for 2002 –

2004 and Table 2 show the monitoring data for 2003-2005 at the 

nonattainment area sites and was retrieved from the U.S. EPA AQS. The air 

quality design value for the area is the highest design value among all sites 

in the area. 

Demonstration: 

 Table 1 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson 

 County 2002 – 2004

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

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

1

st 2nd 3rd 4th 2002-2004

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

39-081-0016 JEFFERSON 227 NORTH 5TH 2002 100 .099 .099 .093 .093 .081

39-081-0016 JEFFERSON 227 NORTH 5TH 2003 99 .107 .097 .090 .079

39-081-0017 JEFFERSON 618 LOGAN 2004 99 .087 .075 .074 .071

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2002 99 .099 .097 .097 .097 .078

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2003 100 .111 .097 .085 .076

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2004 100 .076 .072 .067 .063

Highest Average .081 ppm

 Table 2 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson 

 County 2003 – 2005

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

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

1

st 2nd 3rd 4th 2003-2005

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

39-081-0016 JEFFERSON 227 NORTH 5TH 2003 99 .107 .097 .090 .079 .077

39-081-0016 JEFFERSON 227 NORTH 5TH 2004 99 .087 .075 .074 .071

39-081-0017 JEFFERSON 618 LOGAN 2005 100 .094 .092 .087 .083

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2003 100 .100 .092 .083 .077 .075

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2004 97 .079 .074 .074 .073

54-029-1004 HANCOCK (WV) OAK ST & OWIN 2005 100 .084 .084 .077 .075

Highest Average 0.77 ppm

Formatted Table

Formatted Table
9 

A comprehensive list of the site’s design values during the 2002-2004 time 

period is in Appendix A. The area's design value has trended downward as 

emissions have declined due to such factors as 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. Ohio's NOx Budget Trading Program Rule was 

approved on May 25, 2004 Ohio Administrative Code (OAC) Chapter 3745-

14. It is expected that this downward trend will continue as the above 

programs continue and some form of the U.S. EPA Clean Air Interstate Rule 

(CAIR) is implemented. 

Requirement 4 of 4: 

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

monitoring network to verify the maintenance of the attainment status. 

Demonstration: 

 Ohio EPA and WV DEP commit to continue monitoring ozone levels at the 

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

EPA Region 5 and Region 3 prior to making changes to the existing 

monitoring network, should changes become necessary in the future. Ohio 

EPA and WV DEP will continue to quality assure the monitoring data to meet 

the requirements of 40 CFR 58 and all other federal requirements. 

Connection to a central station and updates to the Ohio EPA Web site2

 will 

provide real time availability of the data and knowledge of any exceedances. 

Ohio EPA and WV DEP will enter all data into AQS on a timely basis in 

accordance with federal guidelines. 

 

2

www.epa.state.oh.us/dapc/ 
10

CHAPTER FOUR 

EMISSION INVENTORY

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

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

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

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

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

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

Other emissions inventory related requirements include a projection of the emission 

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

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

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

10 year maintenance period. 

Requirement 1 of 5: 

A comprehensive emission inventory of the precursors of ozone completed for the base 

year. 

Background: 

The point source data are taken from Ohio's annual emissions reporting 

program. The 2002 periodic inventory has been identified as the preferred 

data base for SIP development and does coincide with nonattainment air 

quality in Steubenville-Weirton, OH-WV: Jefferson County. 
11

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

a budget for all large EGUs. Ohio’s budget is adopted at OAC Chapter 

3745-14. The budget represents a statewide cap on NOx emissions. These 

emissions, capped by the state rule, should remain at least this low through 

the maintenance period covered by this request. 

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

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

Demonstration: 

While ozone and its precursors are transported into this region from outside 

areas, this information does provide some indication of the impact from Ohio 

sources near the nonattainment area. The emissions are decreasing 

substantially in response to regional and national programs affecting many 

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

of the inventory also impact ozone formation, but large regional sources such 

as EGUs have a substantial impact on the formation of ozone. 

Requirement 2 of 5: 

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

Background: 

Ohio EPA prepared a comprehensive inventory for Steubenville-Weirton, OH-WV: 

Jefferson County, including area, mobile, and point sources for precursors of ozone 

(VOCs and NOx) for base year 2002. The information below describes the 

procedures Ohio EPA used to generate the 2002 base inventories. These 

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

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

analyses. These processed modeling inventories have been identified as the 

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

references to LADCO include the Midwest Regional Planning Organization. 

 Area sources were taken from the Ohio 2002 periodic inventory 

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

Department of Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information. 

 Mobile source emissions were calculated from 

MOBILE6.2MOVES2010 produced emission factors. 

 Point source information was compiled from Ohio EPA’s 2002 annual 

emissions inventory database and the 2002 U.S. EPA Air Markets 

acid rain database3. 

 

3

http://www.epa.gov/airmarkets/acidrain 
12

 Biogenic emissions are not included in these summaries. 

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

Mobile Inventory Model (NMIM) 2002 application. To address 

concerns about the accuracy of some of the categories in U.S. EPA’s 

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

companies to review the base data and make recommendations. 

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

Emissions were estimated for aircraft, commercial marine vessels and 

railroads. Recreational motorboat population and spatial surrogates 

(used to assign emissions to each county) were significantly updated. 

The populations for the construction equipment category were 

reviewed and updated based upon surveys completed in the Midwest 

and the temporal allocation for agricultural sources also was updated. 

 

Demonstration: 

On-Road Emission Estimations 

In coordination with the Brooke, Hancock, Jefferson Transportation Study 

(BHJTS) and the West Virginia Department of Transportation (WVDOT), the 

Ohio Department of Transportation (Ohio DOTODOT) utilizes a regional 

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

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

long range planning tool to evaluate the transportation system including 

determination of locations where additional travel capacity may be needed 

and to determine the infrastructure requirements necessary to meet that 

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

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

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

(VMT) and a U.S. EPA computer program called MOBILE6.2MOVES is used 

to calculate emissions per mile. The product of these is the total amount of 

pollution emitted by the on-road vehicles for the particular analyzed area. In 

areas outside the regional travel demand model, traffic counts and statewide 

traffic growth rates are used for the VMT estimates.

Overview 

Broadly described, MOBILE6.2MOVES is used to generate “emission 

factors”, which are the average emissions per mile (grams/mile) for ozone 

Formatted: Normal, Indent: Left: 0", Right: 

0.5"

Formatted: Line spacing: Multiple 1.15 li

Formatted: Line spacing: Multiple 1.15 li
13

precursors, NOx and VOC. The MOBILE6.2MOVES model includes a 

number of variables that affect the emission factors. These variables have 

national default values, some of which require modification to reasonably 

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

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

effect on the emission factors. The vehiclesource types are traveling on 

facilityroad types (MOBILE6.2 facilityMOVES road types are Freeway, 

Arterial, LocalRural Restricted Access, Rural Unrestricted Access, Urban 

Restricted Access, and Ramp) and theUrban Unrestricted Access). The

vehicle speeds also affect the emission factor values. Meteorological 

conditions such as air temperature and humidity hashave a significant 

affecteffect on emission factors. Emission factors produced by 

MOBILE6MOVES can also include the effect of emission reduction strategies 

such as vehicle inspection and maintenance programs, regulation of fuels, 

etc. These MOBILE6MOVES inputs are estimated using the best available 

data. 

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

agencies in a formal interagency consultation process. Emission factors are 

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

emissions. 

There are a number of ways emission factors from MOBILE6.2 can be used 

with the travel demand model information. One of the simplest methods is to 

input extensive vehicle fleet, area-specific speed and facility type information 

MOBILE6.2 to generate a single emission factor that represents the average 

for all vehicles and facility types in the modeled area. This only requires 

multiplying this emission factor by the total VMT of the analyzed area to get 

the total emissions for the area. Another method is to create multidimensional emission factor “look-up” tables that describe the emission 

factors by speed, temperature, and facility type. This requires more 

extensive processing, but the resulting total emissions of this method are 

more sensitive to even minor changes in the roadway system. Tables of 

emission factors are created using MOBILE6.2 for each facility type, 

temperature, and speed given the vehicle fleet on that facility. Then, the 

travel model provides information on each segment of road (or “link”) 

regarding speed and facility type which is then “looked-up” in the appropriate 

emission factor table. It should be noted that speed is estimated as a post 

process to the travel demand model. Speeds are not taken directly from the 

travel demand model. The post process for emissions analysis by Ohio DOT 

is by hour of day. This emission factor is multiplied by the link’s trafficvolume and length or VMT to get the emissions from that link for that hour. 

There are other methods as well, each with its advantages and 

disadvantages. The Steubenville-Weirton, WV-OH: Jefferson County 

analysis uses the latter more complex method, a table of emission factors. 

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It should be noted that each year analyzed will have different emission 

factors, volumes, speeds and roadway networks. 

Some of the assumptions built into MOBILE6.2 are: older vehicles have 

much higherThe emission factors from MOVES can be used with the travel 

demand model information by combining the disaggregate emission rates 

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

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

The BHJTS analysis method, developed by ODOT, is to aggregate the 

emission rates by two source types (cars & trucks), then applying VMT and 

source type population, thereby reducing the intensive processes. In the first 

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

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

hourly link volumes generated from travel demand model are combined with 

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

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

Vehicle-based emissions are obtained by the combination of corresponding 

emission factors and source type population. Intrazonal emissions are 

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

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

emission factors to get intrazonal emissions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions. 

Automated programs, using FORTRAN and CUBE scripting, were developed 

by ODOT to generate total emissions. The process uses data on daily and 

directional traffic distributions as well as more up to date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process also 

handles the newer model network formats and MOVES generated emission 

factors than newer vehicles, diesel vehicles have much higher NOx emission 

factors and lower VOC emission factors than gasoline vehicles, and higher 

average speeds have lower emission factors except for diesel vehicles which 

have higher NOx at higher speeds. MOBILE6.2. 

MOVES input and output files are provided in Appendix C. 

Best Available Data 

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

properties data, source type distribution data, and I/M data provided by 

ODOT’s ATRs and WIMs, NOAA, ODPS, and Ohio EPA waswere used by 

the Ohio DOTODOT for generating emission factors. Likewise, the most 

current transportation planning data available from BHJTS and most current 

Ohio DOTODOT count data waswere used by the Ohio DOTODOT for the 

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emissions estimates. Details about each data set and how it was used is 

documented in Ohio DOT’s “BHJTS 8-Hour Ozone Air Quality Conformity 

Analysis Technical Memo” dated 6/29/2006. 

Analysis Years

Analysis years for this re-designation request include 2002, 2004, 2009, and 

2018 to meet the requirements specified by the CAA and U.S. EPA. The 

travel demand model presents the transportation system conditions for each 

of these years. Model runs for each future analysis year contain the road 

network BHJTS and Ohio DOTODOT expects to exist at the beginning of 

that year with corresponding socioeconomic forecasts for that year. 

Local Road VMT

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

travel demand model. These local roads are represented as fictitious 

roadways called centroid connectors. Local road VMT is included in the 

Ohio DOTODOT post process by including the traffic loaded on centroid 

connectors. In addition, some local road traffic is captured as intra-zonal 

trips which travel demand models usually do not assign to roadway 

segments. Ohio DOTODOT post process includes these trips as local road 

VMT. 

Emission Estimations 

Tables 3 through 5 contain the results of the emissions analysis for the 

appropriate years. 

Table 3 - Emission Estimations for On-Road Mobile Sources for Jefferson 

County, Ohio

Jefferson County 2002 2004 2009 2018

VMT (miles/day) 1,871,330709,44

8

1,871,278611,12

5

1,875,362576,63

5

1,882,256540,06

0

VOC (tons/day) 4.226.61 3.555.62 2.294.20 1.1986

NOx (tons/day) 6.287.75 5.406.69 3.575.14 1.452.11

Table 4 - Emission Estimations for On-Road Mobile Sources for Brooke 

County, West Virginia

Brooke County 2002 2004 2009 2018

VMT (miles/day) 669,015606,19

5

662,880600,70

2

696,616602,92

8

710,506600,94

4

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VOC (tons/day) 1.5940 1.2820 0.8583 0.4536

NOx (tons/day) 2.1621 1.8286 1.2728 0.5348

Table 5 - Emission Estimations for On-Road Mobile Sources for Hancock 

County, West Virginia

Hancock County 2002 2004 2009 2018

VMT (miles/day) 676,843561,34

9

674,274502,23

9

664,931497,99

1

657,671495,32

7

VOC (tons/day) 1.6308 1.340.88 0.8458 0.4325

NOx (tons/day) 2.1302 1.8156 1.8105 0.4937

Table 6 Combined VOC and NOx Emission Estimations for On-Road 

Mobile Sources for Jefferson County, OH, Brooke and 

Hancock County, WV 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

County VOC 2018

Jefferson County, OH VOC 1.1986

Brooke County, WV VOC 0.4536

Hancock County, WV VOC 0.4325

TOTAL VOC 2.0747

County NOx

Jefferson County, OH NOx 1.452.11

Brooke County, WV NOx 0.4548

Hancock County, WV NOx 0.4937

TOTAL NOx

2.3996

Motor Vehicle Emission Budget 

Table 7 contains the motor vehicle emissions budget for Jefferson County, Ohio. 

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Table 7 Mobile Vehicle Emissions Budget for Jefferson County, Ohio 

 (Steubenville-Weirton, OH_WV)4

Jefferson County 2004 2009 2018

VOC (tons/day) 5.62 4.83 2.6314 1.3

7

NOx (tons/day) 4.106.6

9

1.675.91 2.43

Brooke and Hancock Co. 2009 2018

VOC (tons/day) 1.9

6

2.8260 3.40 1.90

NOx (tons/day) 1.003.6

0

1.174.20 3.90

ThisThe Jefferson County budget includes the emission estimates calculated 

for 2009 and 2018 and an additional margin of safety. The emission 

estimates are derived from the Tranplan travel demand model and 

MOBILE6.2MOVES 2010 as described above under the expected Brooke, 

Hancock, and Jefferson Transportation Study (BHJTS) 2025 Long Range 

Plan. The mobile source budget includes 1.374.83 tons/day for VOC and 

1.67in 2009, 2.14 tons/day for VOC in 2018, 5.91 tons/day for NOx. in 2009, 

and 2.43 tons/day for NOx in 2018. These correspond to a 15 percent 

increase from the 2018 on-road emissions for both VOC and NOx. Appendix 

C contains data tables and graphs of these emissions. Tables 10 and8 

through 13 below include the mobile vehicle emission budgets. 

All methodologies, latest planning assumptions and the safety margins were 

determined through the interagency consultation process described in the 

Transportation Conformity Memorandum of Understanding (MOU) for 

BHJTS. 

Requirement 3 of 5: 

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

standard. 

 

4 Ohio’s submittal only requests budgets be set for Ohio counties. Current 2004, 2009 and 2018 budgets 

for West Virginia are identified in Table 7 and subsequent tables. These budgets were set by West 

Virginia to address the transition to MOVES and U.S. EPA approved these budgets on September 15, 

2011 (76 FR 56975). West Virginia does not plan to make any further updates to their ozone budgets).

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Background: 

In consultation with U.S. EPA, Ohio EPA selected the year 2018 as the 

maintenance year for this redesignation request. This document contains 

projected emissions inventories for 2009 and 2018. 

Ohio DOT performed emission projections for Steubenville-Weirton, OH-WV: 

 Jefferson County using the following approaches. 

 Mobile source emission projections are based on the U.S. EPA 

MOBILE6.2 model.MOVES 2010model. The analysis is described in 

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

with “Procedures for Preparing Emissions Projections” U.S. EPA-45/4-

91-019. 

 Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. LADCO 

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

categories. These files were used to develop the future year 

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

inventories used for redesignation are consistent with modeling 

performed in the future. 

The detailed inventory information for Jefferson County for 2004, 2009 and 

2018 is in Appendix B. Emission trends are an important gauge for 

continued compliance with the ozone standard. Therefore, Ohio EPA 

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

maintenance years. Mobile source emission inventories are described in 

Appendix BC. In addition to the LADCO estimates, point source emissions 

were projected based upon the statewide EGU NOx budgets from the Ohio 

NOx rule. Emission Inventories for Hancock and Brooke Counties in WV 

used for this request were developed by DEP staff with the support of the 

contractors for the Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS), a federally recognized regional planning organization. 

 

The following tables include sectors Electrical Generating Unit (EGU-Point), 

Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), 

Other Area (Other), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road). 

Please note that WV non-road sector includes MAR. 

Demonstration: 

 Table 8 Jefferson County VOC Emission Inventory Totals for Base 

 Year 2002, Estimated 2004 and Projected 2009 and 2018 (tons 

 per day) 
19

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Sector 2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

EGU Point 0.88 0.92 1.03 1.02

Non-EGU 0.23 0.23 0.22 0.24

Non-road 0.90 0.88 0.82 0.55

Other 3.12 3.06 2.91 2.91

MAR 0.05 0.05 0.05 0.05

On-road 4.226.61 3.555.62 2.634.83

*

1.372.14*

TOTAL 9.4011.7

9

8.6910.76 7.669.86 6.1491 2.553.8

5

 * includes 15 percent increase to the mobile source budget 

 Table 9 Combined Hancock and Brooke County VOC Emission 

 Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Sector 2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

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

Non-EGU 6.70 4.80 4.30 5.30

Non-road

(includes MAR)

1.50 1.50 1.20 1.00

Other(Area) 4.50 4.60 4.50 5.20

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On-road 3.202.4

8

2.60 2.00*3.40 1.00*90

TOTAL 15.9018 13.50 12.0013.4

0

12.5013.40 1.000.1

0

 * includes 15 percent increase to the mobile source budget 

 

Table 10 Steubenville-Weirton, OH-WV: Jefferson CountyCombined

VOC Emission Inventory Totals for Base Year 2002, Estimated 2004 

and Projected 2009 and 2018 (tons per day) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

Jefferson Co. OH 

Total

9.401

1.79

8.6910.76 7.669.8

6

6.1491

Brooke and Hancock 

Co. WV Total

15.90

18

13.50 12.001

3.40

12.5013.40

COMBINED VOC

TOTAL

25.30

26.97

22.1924.26 19.662

3.26

18.6420.31 3.5595

 Table 11 Jefferson County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2004 and Projected 2009 and 2018 (tons per 

 day) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Sector 2002 Base 2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

EGU Point 183.99 148.80 60.77 40.95

Non-EGU 6.05 5.93 5.63 5.43

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Non-road 0.77 0.72 0.58 0.33

Other 0.17 0.18 0.21 0.21

MAR 1.60 1.53 1.35 1.25

On-road 6.287.75 5.406.69 4.105.91* 1.672.43*

TOTAL 198.86200.3

3

162.56163.8

5

72.6474.4

5

49.8450.60 112.72113.2

5

 * includes 15 percent increase to the mobile source budget

Table 12 Combined Hancock and Brooke County NOx Emission 

 Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) http://www.vistas-sesarm.org/. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

Sector 2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

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

Non-EGU 5.90 4.50 5.10 5.60

Non-road (includes MAR) 4.30 5.30 3.80 3.20

Other(Area) 4.60 4.80 4.90 5.20

On-road Hancock 4.3023 3.60 2.80*4.20 1.20*3.90

TOTAL 19.100

3

18.20 16.6018.0

0

15.2017.90 3.000.3

0

 * includes 15 percent increase to the mobile source budget

 

Table 13 Steubenville-Weirton, OH-WV: Jefferson CountyCombined

NOx Emission Inventory Totals for Base Year 2002, Estimated 

2004 and Projected 2009 and 2018 (tons per day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2002 2004 2009 2018 Safety 

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Base Attainment Interim Maintenance Margin

Jefferson Co. OH 

Total

198.86

200.33

162.56163.

85

72.647

4.45

49.8450.60

Hancock and Brooke 

Co. WV Total

19.100

3

18.20 16.601

8.00

15.2017.90

COMBINED NOx

TOTAL

217.95

219.36

183.79182.

05

88.369

2.45

64.6468.50 119.15

113.55

 Table 14 Jefferson County Comparison of 2004 attainment year and 

 2018 projected emission estimates (tons per day, summer) 

 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected 

Decrease

VOC 8.6910.76 6.1491 2.553.85

NOx 162.56163.85 49.8450.60 112.74113.25

Table 1615 Combined Hancock and Brooke County Comparison of 2004 

attainment year and 2018 projected emission estimates (tons 

per day, summer) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected 

Decrease

VOC 13.50 12.5013.40 0.2610

NOx 19.1018.20 15.2017.90 3.210.30

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Table 1716 Steubenville-Weirton, OH-WV: Jefferson County Combined 

Comparison of 2004 attainment year and 2018 projected 

emission estimates (tons per day, summer) 

 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected 

Decrease

Combined VOC Total 22.1924.26 18.6420.

31

3.5595

Combined NOx Total 181.66182.

05

65.0468.

50

116.62113.55

VOC emissions in the non-attainment area are projected to decrease by 

3.5595 tons. Area source emissions and, to a lesser extent, point sources, 

show an increase due to expectations that the population will grow in this 

area. However, cleaner vehicles and fuels are expected to be in place in 

2009 and 2018 and result in an overall drop in VOC emissions. 

NOx emissions in the nonattainment area are projected to decrease by 

116.62113.55 tons. Decreases from U.S. EPA rules covering Tier 2 Motor 

Vehicle Emissions Standards and Gasoline Sulfur Control Requirements5, 

Highway Heavy-Duty Engine Rule6 and Non-Road Diesel Engine Rule7 also 

are factored into the changes. Further, due to implementation of the NOx

SIP Call across the eastern United States, NOx and ozone levels entering 

this area also will be decreased. 

Requirement 4 of 5: 

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

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

not on temporary adverse economic conditions or unusually favorable meteorology. 

Background: 

 

5

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

6

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

7

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

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

the NAAQS for ozone in 2004. U.S. EPA’s redesignation guidance (p 9) 

states, “A state may generally demonstrate maintenance of the NAAQS by 

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

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

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

NAAQS.” 

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

emissions information once every three (3) years or annually if VOC potential 

to emit is greater than 250 tons or NOx potential to emit is greater than 2500 

tons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule 

(CERR). Ohio U.S. EPA prepares a new periodic inventory for all ozone 

precursor emission sectors every three (3) years. These ozone precursor 

inventories will be prepared for 2005, 2008, and 2011 as necessary to 

comply with the inventory reporting requirements established in the CFR. 

Emissions information will be compared to the 2002 base year and the 2018 

projected maintenance year inventories to assess emission trends, as 

necessary, to assure continued compliance with the ozone standard. 

Demonstration: 

Permanent and enforceable reductions of volatile organic compounds and 

oxides of nitrogen have contributed to the attainment of the eight-hour ozone 

standard. Some of these reductions were due to the application of tighter 

federal standards on new vehicles. Also, Title IV of the CAA and the NOx

SIP Call required the reduction of oxides of nitrogen from utility sources. 

Table 1817 Steubenville-Weirton, OH-WV: Jefferson County Combined 

Comparison of 2002 base year and 2004 attainment year onroad and EGU reductions 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

 http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section
25

2002 2004

On-road VOC 7.459.09 6.188.22

On-road NOx 10.5711.98 9.0310.29

EGU NOx 183.99 148.80

Requirement 5 of 5: 

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

levels including an annual emission statement from major sources. 

Demonstration: 

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

Administrator, eight (8) years after redesignation, an additional revision of 

this SIP. The revision will contain Ohio's plan for maintaining the national 

primary ozone air quality standard for 10 years beyond the first 10 year 

period after redesignation. 

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CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4:

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) as applied in Ohio’s rural counties.

Background: 

As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were no 

specific rules required by the CAA such as RACT for existing sources beyond 

statewide rules. 

Demonstration: 

Statewide RACT rules have been applied to all new sources locating in Ohio 

since that time. The Ohio rules are found in OAC Chapter 3745-21.

 

Requirement 2 of 4:

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

implemented. 

Background: 

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

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

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

Beginning in 2004, this rule accounts for a reduction of approximately 31 

percent of all NOx emissions state-wide compared to previous uncontrolled 

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

Demonstration: 

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

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

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

covered by this program have been generally trending downward since 1998 

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

Clean Air Markets Web site, quantifies the gradual NOx reductions that have 

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

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

Trading Program rules in OAC Chapter 3745-14 in response to the SIP Call. 

OAC chapter 3745-14 regulated EGUs and certain non-EGUs under a cap 

and trade program based on an 85 percent reduction of NOx emissions from 
27

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

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

which time the CAIR program will supersede it. 

U.S. EPA has recently published Phase II of the NOx SIP Call that 

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

stationary internal combustion engines. Ohio EPA’s proposed rule OAC 

3745-14-12 addresses stationary internal combustion engines, all used in 

natural gas pipeline transmissions. An 82 percent NOx reduction from 1995 

levels is anticipated. Completion of the compliance plan is expected by May 

1, 2006 and the compliance demonstration will begin May 1, 2007. The 

2007 controlled NOx emissions will be 599 tons per day. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards 

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

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

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

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

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

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

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

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

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

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

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

Heavy-Duty Diesel Engines 

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

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

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

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

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

inventory. 

Clean Air Non-road Diesel Rule 

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

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

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

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

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

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

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

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

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

engine standards take effect, based on engine horsepower, starting in 2008. 
28

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

ozone precursors. 

Requirement 3 of 4:

Acceptable provisions to provide for new source review. 

Background: 

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

program. This is addressed in OAC Chapter 3745-31. The chapter includes 

provisions for the Prevention of Significant Deterioration (PSD) permitting 

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

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

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

SIP. 

Demonstration: 

Any facility that is not listed in the 2002 emission inventory, or for the closing 

of which credit was taken in demonstrating attainment, will not be allowed to 

construct, reopen, modify, or reconstruct without meeting all applicable 

permit rule requirement. The review process will be identical to that used for 

new sources. Once the area is redesignated, Ohio EPA will implement NSR 

through the PSD program. 

Requirement 4 of 4:

Assure that existing controls will remain in effect after redesignation unless the State 

demonstrates through photochemical modeling that the standard can be maintained 

without one (1) or more controls. 

Demonstration: 

Ohio commits to maintaining the aforementioned control measures after 

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

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

maintenance of the ozone standard in Steubenville-Weirton, OH-WV: 

Jefferson County, will be submitted to U.S. EPA for approval as a SIP 

revision. 

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

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

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

relate to the emission of ozone precursors in Steubenville-Weirton, OH-WV: 

Jefferson County. 
29

LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment 

LADCO performed modeling to evaluate the effect of the NOx SIP Call and Tier II / 

Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This 

modeling was originally designed to assess the one-hour ozone standard. Further 

analysis was conducted and documented in the LADCO’s White Paper “8-Hour 

Ozone Assessment” dated May 2, 2001. Base year design values used were the 

average of the design values for the three (3) three-year periods (1994-1996, 1995-

1997, and 1996-1998). Base year emissions were taken from 1996 and four (4) 

ozone episodes were evaluated: June 22-28, 1991; July 14-21, 1991; June 13-25, 

1995; and July 7-18, 1995. 

While modeling results were not calculated for Steubenville-Weirton, OH-WV: 

Jefferson County, the average decrease in ozone from the base case modeling run 

with modeling runs that applied emission controls required by the CAA, NOx SIP 

Call and Tier II /low-sulfur requirements was nine (9) ppb. 

 LADCO Modeling for CAIR of 2004

On March 10, 2004, the U.S. EPA promulgated the CAIR. NOx emissions will be cut 

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

tons in 2018 in 28 eastern states and the District of Columbia. 

LADCO performed modeling to support the associated emission reductions for 

CAIR. This modeling was based on 2001 – 2002 design values for SteubenvilleWeirton, OH-WV: Jefferson County. Results of the CAIR modeling show 

Steubenville-Weirton, OH-WV: Jefferson County will continue to attain the eighthour ozone NAAQS well into the future. 
30

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4:

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

Demonstration: 

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

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

Requirement 2 of 4:

A commitment to expeditiously enact and implement additional contingency control 

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

event that future violations of the ambient standards occur. 

Demonstration: 

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

Warning Level Response: 

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

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

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

determine whether the ozone value indicates a trend toward higher ozone 

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

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

measures necessary to reverse the trend taking into consideration ease and 

timing for implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

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

(September 30). 

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

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

and implementation outlined under action level response shall be followed. 

 

 Action Level Response 

An action level response shall be prompted whenever a two (2) year average 

fourth high monitored value of 85 ppb occurs within the maintenance area. In 

the event that the action level is triggered and is not due to an exceptional 

event, malfunction, or noncompliance with a permit condition or rule 
31

requirement, Ohio EPA will determine additional control measures needed to 

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

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

within eighteen (18) months from the close of the ozone 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 process. This process will include publication of 

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

Ohio law for rulemaking by state environmental boards. 

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

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

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

additional local measures may be unnecessary. Furthermore, Ohio will 

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

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration: 

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the 

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

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

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

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

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

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

below is not comprehensive. 

1) Lower Reid vapor pressure gasoline program. 

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

Technique Guidelines issued in response to the 1990 CAA. 

3) Apply RACT to smaller existing sources. 

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

least half a percent reduction in actual area wide VOC emissions. 

Transportation measures will be selected from the following, based 
32

upon the factors listed above after consultation with affected local 

governments: 

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

programs, work schedule changes, and telecommuting: 

b) traffic flow and transit improvements: 

c) other new or innovative transportation measures not yet in 

widespread use that affects state and local governments 

deemed appropriate.

5) Alternative fuel and diesel retrofit programs for fleet vehicle 

operations. 

6) Controls on consumer products consistent with those adopted 

elsewhere in the United States. 

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

sources. 

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

sources. 

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

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

tons). 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

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

be fully evaluated. 

Requirement 4 of 4:

A list of VOC and NOx sources potentially subject to future controls. 

Demonstration: 

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

controls. 

NOx RACT 

 EGUs 

 asphalt batching plants 
33

 industrial/commercial and institutional boilers 

 process heaters 

 internal combustion engines 

 combustion turbines 

 other sources greater than 100 tons per year 

VOC RACT 

 consumer products 

 architectural and industrial maintenance coatings 

 stage I gasoline dispensing facilities (including pressure valves) 

 automobile refinishing shops 

 cold cleaner degreasers 

 portable fuel containers 

 synthetic organic compound manufacturing 

 organic compound batch processes 

 wood manufacturing 

 industrial wastewater 

 aerospace industry 

 shipbuilding 

 bakeries 

 plastic parts coating 

 volatile organic liquid storage 

 industrial solvent cleaning 

 offset lithography 

 industrial surface coating 

 other sources greater than 50 tons per year 
34

CHAPTER SEVEN 

PUBLIC PARTICIPATION

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

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

county publications on August 1, 2006. 

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

September 7, 2006March 4, 2013, at the Brooke-Hancock-Jefferson Metropolitan 

Planning CommissionSteubenville Schiappa Branch Library, located at 124 North 

Fourth Street4141 Mall Drive, in Steubenville, Ohio. The public comment period will 

closeclosed on September 8, 2006. Comments received during the public comment 

period will be included with the final package.March 4, 2013. Appendix D will include a 

copy of the public notice, certifications of publicationresponse to comments, and the 

transcript from the public hearing.

Formatted: Font: Calibri, 11 pt, Font color:

Custom Color(RGB(31,73,125))
35

CHAPTER EIGHT 

CONCLUSIONS

The Steubenville-Weirton, OH-WV: Jefferson County basic nonattainment area has 

attained the NAAQS standard and complied with the applicable provisions of the 1990 

Amendments to the CAA regarding redesignations of basic ozone nonattainment areas. 

Documentation to that effect is contained herein. Ohio EPA has prepared a state 

implementation and maintenance plan that meets the requirement of Section 110 (a)(1) of 

the 1990 CAA. 

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

permanent and enforceable measures. In addition, significant regional NOx reductions will 

ensure continued compliance (maintenance) with the standard and that all CAA 

requirements necessary for redesignation have been met. 

Based on this presentation, the Steubenville-Weirton, OH-WV: Jefferson County ozone 

basic nonattainment area meets the requirements for redesignation under the CAA and 

U.S. EPA guidance. Furthermore, because this area is subject to significant transport of 

pollutants, significant regional NOx reductions will ensure continued compliance 

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

The State of Ohio hereby requests that the Steubenville-Weirton, OH-WV: Jefferson 

County ozone basic nonattainment area be redesignated to attainment simultaneously with 

U.S. EPA approval of the Ohio state implementation and maintenance plan provisions 

contained herein. 

Formatted: Font: 14 pt, Bold
This page left intentionally blank
BROOKE-HANCOCK-JEFFERSON

TRANSPORTATION STUDY

Transportation Air Quality Analysis and Technical Documentation 

For the Weirton-Steubenville, WV-OH

State Implementation Plan Inventory Mobile Emission Estimates 

Using the USEPA Motor Vehicle Emissions Simulator Model 

For the U.S. EPA Eight-Hour Ozone National Ambient Air Quality Standard 

Submitted: December 2012 
Production of this Document paid for by funds from the U.S. Federal Highway Administration, Federal 

Transit Administration, Ohio Department of Transportation, West Virginia Department of Transportation 

and dues from BHJ member governments. 

Prepared By: 

Brooke-Hancock-Jefferson Metropolitan Planning Commission 

The Metropolitan Planning Organization for 

Steubenville, Ohio-Weirton, WV Area 

124 North Fourth Street, 2nd Floor 

Steubenville, OH 43952 

740/282-3685

304/797-9666

740/282-1821 FAX 

Email: mikepap@bhjmpc.org Website: www.bhjmpc.org
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page i 

BROOKE-HANCOCK-JEFFERSON TRANSPORTATION STUDY 

Transportation Air Quality Analysis and Technical Documentation 

For the Weirton-Steubenville, WV-OH

State Implementation Plan Inventory Mobile Emission Estimates 

Using the USEPA Motor Vehicle Emissions Simulator Model 

For the U.S. EPA Eight-Hour Ozone National Ambient Air Quality Standard 

TABLE OF CONTENTS 

Introduction ......................................................................................................................................... Page 1 

On Road Mobile Emission Summary ................................................................................................. Page 3 

Latest Planning Assumptions .............................................................................................................. Page 5 

Travel Demand Modeling - Analysis Years ....................................................................................... Page 5 

Social-Economic Demographics ......................................................................................................... Page 5 

Emission Factor Generation ................................................................................................................ Page 8 

Temperature and Relative Humidity ................................................................................................... Page 9 

Ramp Fraction ................................................................................................................................... Page 10 

Source Type Population .................................................................................................................... Page 11 

Vehicle Age Distribution .................................................................................................................. Page 11 

Road Type Distribution..................................................................................................................... Page 20 

Post Processing ................................................................................................................................. Page 21 

Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page ii

LIST OF TABLES

Table 1 BHJ Region On-Road Mobile Emissions by State ..................................................... Page 3 

Table 2 BHJ Region On-Road Mobile Emissions by County ................................................. Page 4 

Table 3 BHJ Region Representative Social-Economic Demographic Variables by

County 2005-2020 ...................................................................................................... Page 6 

Table 4 Moves Inputs ........................................................................................................... Page 8-9 

Table 5 Average Temperature and Relative Humidity Data .................................................. Page 10 

Table 6 Ramp Fractions ......................................................................................................... Page 10 

Table 7 Source Type Population for Year 2005 .................................................................... Page 11 

Table 8 Vehicle Age Distribution for Jefferson County, OH .......................................... Page 12-15 

Table 9 Vehicle Age Distribution for Brooke/Hancock County, WV ............................. Page 16-19 

Table 10 Road Type Distribution for Brooke-Hancock-Jefferson 

Non-Attainment Area................................................................................................ Page 20 

LIST OF FIGURES

Figure 1 BHJ Geographic Area Fine Particulate Matter Non-Attainment Area Boundary 

 ..................................................................................................................................... Page 2 

Figure 2 BHJ Geographic Area Covered by Travel Demand Model and 

 Traffic Analysis Zone Structure .................................................................................. Page 7 

Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page iii

SELECTED ABBREVIATIONS & ACRONYMS 

BHJ – Brooke-Hancock-Jefferson Metropolitan 

Planning Commission 

CFR – Code of Federal Regulations 

FHWA – Federal Highway Administration; 

FTA – Federal Transit Administration; 

HC – Hydrocarbons 

HPMS – Highway Performance Monitoring 

System 

LRTP – Long Range Transportation Plan 

MOBILE6 – Mobile Source Emission Factor 

Model 

MOVES – MOtor Vehicle Emission Simulator 

model required for regional emissions analyses 

for transportation conformity determinations 

MOU – Memorandum of Understanding 

MPO – Metropolitan Planning Organization 

MVEB – Motor Vehicle Emissions Budget 

NAAQS – National Ambient Air Quality 

Standard

NOAA – National Oceanic and Atmospheric 

Administration 

NOX – Nitrogen Oxides 

ODOT – Ohio Department of Transportation 

OEPA – Ohio Environmental Protection 

Agency 

PM – Particulate Matter 

PM2.5 - Particulate Matter with an aerodynamic 

diameter less than 2.5 microns (often referred to 

as Fine Particulate Matter) 

PM10 – Particulate Matter with an aerodynamic 

diameter less than 10 microns 

SIP – State Implementation Plan 

STIP – Statewide Transportation Improvement 

Program 

TAZs – Traffic Analysis Zones 

TCM – Transportation Control Measure 

TDM – Travel Demand Model 

TIP – Transportation Improvement Program in a 

Metropolitan Planning Area 

USEPA – United States Environmental 

Protection Agency 

VHT – Vehicle Hours of Travel 

VMT – Vehicle Miles of Travel 

VOC – Volatile Organic Compounds 

WVDEP – West Virginia Department of 

Environmental Protection 

WVDOT – West Virginia Department of 

Transportation 

REVISION HISTORY

1. Submitted incorrect Table 2 on December 10, 2012 attachment – 12/21/2012 (MJP)

Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 1 

Transportation Air Quality Analysis and Technical Documentation 

For the Weirton-Steubenville, WV-OH

State Implementation Plan Inventory Mobile Emission Estimates 

Using the USEPA Motor Vehicle Emissions Simulator Model 

(MOVES 2010a) 

For the U.S. EPA Eight-Hour Ozone National Ambient Air Quality Standard 

INTRODUCTION

This memorandum documents the air quality analyses and underlying planning assumptions performed 

for the U.S. EPA Eight-Hour National Ambient Air Quality Standard on-road mobile source emission 

inventories for the Weirton-Steubenville, WV-OH Metropolitan area State Implementation Plan (SIP). 

This analysis will update the emissions inventories using Motor Vehicle Emission Simulator (MOVES) 

model based value estimates. The Ohio Department of Transportation (ODOT), Division of 

Transportation System Development-Modeling and Forecasting Section and the Brooke-HancockJefferson Planning Commission (BHJMPC) completed these analyses in coordination with the Ohio 

Environmental Protection Agency (OEPA) and West Virginia Department of Environmental Protection 

(WVDEP). 

The BHJMPC serves as the Metropolitan Planning Organization (MPO). The MPO submitted the 

necessary Travel Demand Model networks along with all land use and social-economic demographics. 

The ODOT Modeling and Forecasting section performed the MOVES runs to generate travel demand 

model based emission factors as well as the complete air quality analyses for the metropolitan area. 

The BHJ Region is comprised of the counties of Brooke and Hancock in the north panhandle of West 

Virginia and Jefferson in east-central Ohio. Both the State of Ohio and the State of West Virginia have 

submitted plans to USEPA that establish motor vehicle emission budgets (MVEB) for Nitrogen Oxides 

(NOx) and Volatile Organic Compounds (VOC), under the Eight-hour ozone standard. Each state has 

established separate budgets (i.e. NOx and VOC budgets for Jefferson County, OH and separate NOx 

and VOC budgets for the collective West Virginia Counties of Brooke & Hancock). On April 3, 2007, 

the USEPA circulated a Notice of Adequacy regarding the Jefferson County, Ohio budgets which 

became effective on April 18, 2007 (40 CFR Parts 52 and 81, Vol. 72 Federal Register 15879-80 April 

18, 2007). In the following month on May 16, 2007, the USEPA issued a determination of attainment, 

(40 CFR 52 and 81, Vol. 72 Federal Register 27640-2 June 15, 2007) essentially re-designating 

Jefferson County as attaining the Eight-hour Ozone Standard in force June 15, 2007. Then, on July 5, 

2007, the agency submitted a correcting amendment to the Jefferson County determination of attainment 

(40 CFR Part 52, Vol. 72 Federal Register 36599-60 Jul5, 2007). The revision modified language 

regarding the 2018 MVEB. On the other hand, USEPA issued an approval for a re-designation request 

from non-attainment to attainment for the Eight-hour Ozone Standard for Brooke and Hancock counties, 

West Virginia May 14, 2007 (40 CFR Part 52, Vol. 72 Federal Register 27060-3 June 13, 2007). The 

re-designation request became effective June 13, 2007 and included maintenance emission budgets for 

NOx and VOC. On September 15, 2011, the US EPA took final action to approve a SIP revision by the 

State of West Virginia (40 CFR 56975) to amend the Eight-hour Ozone Maintenance Plan for the 

Weirton, WV area. The revision amended the plan’s safety margins, increasing the area’s MVEB. This 

action became effective November 14, 2011. 
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 2 

Figure 1 

BHJ GEOGRAPHIC AREA 

EIGHT-HOUR OZONE (1997 STANDARD) 

MAINTENANCE AREA BOUNDARY

£0' 27'JO"N 

LEGE NO 

c::::::J tOt~ATT iti. tlT AREA BOU!lOARY 

!TATE BOUII>AR'f 

COl.tlTY BOUI40AR:Y 

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t.t.IIHCiPALAR:EA 

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HGH'V\AY & POUTlCAL LEGEIIO 

-- US ROUTE 

-- $TATE R:Otrre 

rl'>oo o,..t, .. oo "'"~!'OO ~ ... tti'Oif ,., •• "l:d 

•·'*'""'""-·""'" .. ' "-!:"'""='•,..,.rvt" .. ,,.<'f'l .... ., ~till~ .. ,. l l'li f;r .,;~ 12"Uf ~Y.1mt<11 !'t2TIIh• Gi~!Wo~ 

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f ~.i Bmt~k....t-t:aor.<'lt k...Jfl11fl~ 

J~. :=~~·~~ .. ~.: ·,!: ·:~ · .. ····" 

SR US H R EE K 

~ ·-... - ...... ,_ .. ,_ ,._,.,_,. -···~ 

i 

RO S 

J E 

.,. 

CROSS CREE K 

.,. 
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 3 

ON ROAD MOBILE EMISSION SUMMARY 

The Table 1 and 2 below present a summary of the pollutant emissions including Hydrocarbons (HC) 

and Nitrogen Oxides (NOx) modeled for each county that make up the BHJ Region. The Model Years 

for the demonstration includes the Base Year 2002, Attainment Year 2004, and Budget Year Inventories 

2009 and 2018. 

Table 1 

BHJ REGION ON-ROAD MOBILE EMISSIONS BY STATE 

STATE TOTALS

OHIO

Jefferson County

HC NOX VMT

Year (tons/day) (tons/day) (miles/day)

2002 6.61 7.75 1,709,448

2004 5.62 6.69 1,611,125

2009 4.20 5.14 1,576,635

2018 1.86 2.11 1,540,060

WEST VIRGINIA

Brooke and Hancock Counties

HC NOX VMT

Year (tons/day) (tons/day) (miles/day)

2002 2.48 4.23 1,167,544

2004 2.08 3.41 1,102,941

2009 1.41 2.32 1,100,919

2018 0.61 0.86 1,096,271
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 4 

Table 2 

BHJ REGION ON-ROAD MOBILE EMISSIONS BY COUNTY 

Jefferson County, OH

HC NOX VMT

Year (tons/day) (tons/day) (miles/day)

2002 6.61 7.75 1,709,448

2004 5.62 6.69 1,611,125

2009 4.20 5.14 1,576,635

2018 1.86 2.11 1,540,060

Brooke County, WV

HC NOX VMT

Year (tons/day) (tons/day) (miles/day)

2002 1.40 2.21 606,195

2004 1.20 1.86 600,702

2009 0.83 1.28 602,928

2018 0.36 0.48 600,944

Hancock County, WV

HC NOX VMT

Year (tons/day) (tons/day) (miles/day)

2002 1.08 2.02 561,349

2004 0.88 1.56 502,239

2009 0.58 1.05 497,991

2018 0.25 0.37 495,327
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 5 

LATEST PLANNING ASSUMPTIONS 

This report will present the latest population and land use data available that calibrated the modeling 

process used to calculate the vehicle emissions for the mobile emissions budgets as well as the input 

values for U.S. EPA’s most recent emissions software MOVES2010a for this attainment demonstration. 

TRAVEL DEMAND MODELING - ANALYSIS YEARS 

A Travel Demand Model (TDM) is the traditional forecasting tool used to examine potential changes in 

future travel patterns for a specific study area, in this case the Brooke-Hancock-Jefferson Metropolitan 

Area. The BHJ MPO, with the assistance of ODOT Modeling & Forecasting, maintains a validated 

region-wide TDM that employs a four-step modeling process consisting of trip generation, trip 

distribution, mode choice, and route assignment performed with the Cube Voyager software package. 

The model Outputs generated from the TDM are link-by-link directional 24-hour traffic volumes for 

simulating Base Year and Horizon Year travel patterns generated by the LRTP transportation network. 

The current BHJ TDM Validation Year is 2000. The model uses comparable Average Daily Traffic 

count data, updated social-economic variables for each of the analysis years by either updating existing 

or known land use commitment for 2008, 2009, and 2014, or projected 2014 and 2020 variables based 

on a straight-line extrapolation between 2009 set of variables and the Horizon Year 2030 variables. 

These networks represent all planned federal-aid projects as well as any regionally significant projects 

found in the BHJ TIP and LRTP expected to be open for traffic by the end of each respective analysis 

year. 

Interagency consultation established the following model years for this analysis: 

Analysis Year 2002 – Baseline Emissions 

Analysis Year 2004 – Attainment Year 

Analysis Year 2009 – Budget Year Inventory 

Analysis Year 2018 – Budget Year Inventory 

SOCIAL-ECONOMIC DEMOGRAPHICS 

Identifying projected growth centers and understanding urban and rural population changes are essential 

to determine future transportation needs in a given study area. Critical elements include an 

understanding of the past and anticipated future shifts in the region’s economy, population, land use 

patterns, and other environmental factors over time. In turn, these factors are useful for predicting future 

transportation patterns and justify long-range transportation improvements. 

Travel forecasting procedures require the user delineate the TDM study area into geographic areas called 

Traffic Analysis Zones (TAZs). Typically, TAZs are based on factors such as land use, area types 

(urban, suburban or rural), or political government units such as cities, villages, or townships. TAZs 

represent centers of travel generators or attractors based on a set of demographic variables. The 

BHJMPO collects and reviews the TDM independent variables that characterize current and future 

estimates of the metropolitan area’s social and economic activity that may influence land-use 

development patterns. In all, there are 376 TAZs in the BHJ model represented by 60 TAZs for Brooke 

County, 78 TAZs for Hancock County, and 237 TAZs for Jefferson County. Figure 2 displays the BHJ 
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 6 

MPO geography covered by the Steubenville-Weirton Travel Demand Model (the entire three-county 

area) including the Traffic Analysis Zone structure. The computer-based TDM for the SteubenvilleWeirton Metropolitan Area highway network employs the following land use variables: 

[AREA_TYPE] ≡ Area Type

[AVG_PARK] ≡ Average parking cost

[ENROLL] ≡ School enrollment classified by Private [ENROLL_PRIV], Public 

[ENROLL_PUB] and Post-secondary [ENROLL_UNIV] schools 

[HOTEL_RM] ≡ Hotel Rooms

[MED_HHINC] ≡ Median household income

[POP] ≡ Population

[POP_18] ≡ Population 18 years or less

[POP_GRP] ≡ Population residing in Group Quarters

[TOTEMP] ≡ Total Employment grouped by the North American Industrial Classification 

System (NAICS) 

[TOT_HH] ≡ Occupied housing

[TOT_VEH] ≡ Vehicles available per household

[WORKERS] ≡ Workers per household

Table 3 below is a set of demographic variables developed for this report. 

Table 3 

BHJ REGION 

REPRESENTATIVE SOCIAL-ECONOMIC DEMOGRAPHIC 

VARIABLES BY COUNTY 2005-2020 

Brooke, WV Hancock, WV Jefferson, OH

2002 Population 22,334 24,451 85,996 132,781

2002 Households 9,116 9,689 35,911 54,716

2002 Employment 10,394 5,424 31,651 47,469

2004 Population 25,340 32,931 72,631 130,902

2004 Households 10,245 13,879 29,757 53,881

2004 Employment 8,662 14,122 24,217 47,001

2009 Population 24,571 31,804 69,806 126,181

2009 Households 9,901 13,372 28,501 51,774

2009 Employment 8,459 13,660 23,806 45,925

2018 Population 23,187 29,778 64,736 117,701

2018 Households 9,287 12,459 26,256 48,002

2018 Employment 7,943 12,697 23,090 43,730

Variable by Year County Total
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 7 

Figure 2 

BHJ GEOGRAPHIC AREA 

COVERED BY TRAVEL DEMAND MODEL 

AND TRAFFIC ANALYSIS ZONE STRUCTURE 

! _____ , _______ _ 

LEGEND 

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- STATE BOUti>AR'f 

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- amSER\(1\ 11011 AREA 

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Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 8 

EMISSION FACTOR GENERATION

The MOVES model generated the emission factor files were for base year-2005 and attainment year2008 representing the transportation improvement programs implemented in the BHJ Region. The 

model also generated emission factors for two future year scenarios 2015, 2022, and 2025. 

Table 4 summarizes the settings used in the MOVES run specification file and the MOVES CountyData Manager. The subsequent tables provide the specific inputs that are not using the MOVES default 

values.

Table 4 

MOVES INPUTS 

RunSpec Parameter Settings 

MOVES Version MOVES2010A

Scale Custom Domain 

MOVES Modeling 

Technique 

Emission Factor Method 

Rates per Profile (grams/vehicle)

Rates per Distance (grams/vehicle)

Rates per Vehicle (grams/vehicle)

Time Span Time Aggregation: Hour 

1 Month representing average summer temperatures

All hours of day selected, 16 speed bins, weekdays only 

Geographic Bounds Brooke, Hancock, and Jefferson counties

Vehicles/Equipment All source types, gasoline and diesel 

Road Type All road types including off-network 

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

Organic Compounds, NOX, NO, NO2, Total Energy Consumption

Strategies None 

General Output Units = grams, joules and miles 

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

type and source use type

Advance Performance None 
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December 2012 Page 9 

Table 4 (continued) 

MOVES INPUTS 

County Data Manager Sources 

Source Type Population Combination of local and default data 

Local data (2010) ODOT from motor vehicle registration 

Default data used for source types 51, 52, 53, 61, and 62 

Future year growth rate based on MPO model Household growth 

rate

Vehicle Type VMT Combination of local and default data 

HPMSVTypeYear VMT = daily VMT from travel demand model 

monthVMTFraction = default 

dayVMTFraction=default 

hourVMTFraction=local 

I/M Program None

Fuel Formulation Default

Fuel Supply Default 

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

will consist of monthly high and low temperatures and daily relative 

humidity for 2002

Ramp Fraction Using the Base Year Travel Demand Model for VHT fractions

Future fractions will be assumed constant

Road Type Distribution Use ODOT and WV Division of Highways county summary VMT 

categorized by federal functional classes 

Age Distribution Combination of local and default data

Local data (Ohio and West Virginia) from motor vehicle registration 

Default data used for source types 41, 42, 43, 51, 52, 53, 61, and 62 

The same age distribution will be used for all analysis years 

Average Speed 

Distribution Default 

Alternative Fuel Type Default 

TEMPERATURE AND RELATIVE HUMIDITY 

The single season approach for temperature and relative humidity uses weather data collected by the 

National Oceanic and Atmospheric Administration (NOAA) National Climatic Data Center (NCDC).

The data used in this report, taken from the Pittsburgh International Airport collection center, is

representative of 12 months in 2009. Data entered into a spreadsheet provided by U.S. EPA converted 

the Mobile6 to get the correct data for the MOVES model. Listed in the table below are the average 

annual hourly temperatures and relative humidity distribution profiles for the Weirton-Steubenville, 

WV-OH metropolitan area. 
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December 2012 Page 10

Table 5 

AVERAGE TEMPERATURE AND RELATIVE HUMIDITY DATA 

TIME OF DAY AVG HOURLY 

TEMPERATURE

AVG HOURLY RELATIVE 

HUMIDITY

Midnight 47.20 79.7%

1:00 AM 46.10 67.1%

2:00 AM 45.20 80.7%

3:00 AM 44.60 82.9%

4:00 AM 44.10 83.8%

5:00 AM 43.60 84.1%

6:00 AM 43.10 82.6%

7:00 AM 43.50 79.6%

8:00 AM 45.90 74.8%

9:00 AM 49.60 70.1%

10:00 AM 53.50 65.7%

11:00 AM 56.80 62.0%

NOON 59.70 59.8%

1:00 PM 61.30 58.2%

2:00 PM 61.90 57.4%

3:00 PM 62.00 57.3%

4:00 PM 61.60 58.3%

5:00 PM 60.50 61.2%

6:00 PM 58.60 65.3%

7:00 PM 56.20 69.2%

8:00 PM 53.70 66.1%

9:00 PM 51.60 74.3%

10:00 PM 50.10 75.7%

11:00 PM 48.60 78.1%

RAMP FRACTION 

The Base Year Travel Demand Model used the Vehicles Hour of Travel (VHT) fractions to derive the 

Ramp Fractions shown in Table 6. The future year networks also used the base year fractions. 

Table 6 

RAMP FRACTIONS 

roadTypeID roadDesc rampFraction

2 Rural Restricted Access 0.02

4 Urban Restricted Access 0.09
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State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 11

SOURCE TYPE POPULATION 

A combination of local and MOVES default data is the Source Type Population for vehicle 

classifications. The MOVES default values provided the data for Source Type Population 51, 52, 53, 

61, and 62 while local data from Ohio and West Virginia motor vehicle registrations accounted for all 

other Source Type Population needed to run the MOVES model. Table 7 shows the Source Type 

Population identifications, the corresponding Source Type Name, and the number of vehicles analyzed 

for Jefferson County, OH and Brooke/Hancock County, WV combined. 

Table 7 

SOURCE TYPE POPULATION FOR YEAR 2005

Jefferson 

County, OH

Brooke/Hancock 

County, WV

11 MotorCycle 6,072 1,673

21 Passenger Car 74,051 21,369

31 Passenger Truck 39,994 17,415

32 Light Commercial Truck 3,033 2,573

41 Intercity Bus 38 15

42 Transit Bus 68 8

43 School Bus 144 99

51 Refuse truck 23 12

52 Single Unit Short-haul Truck 958 739

53 Single Unit Long-haul Truck 299 84

54 Motor Home 1,953 63

61 Combination Short-haul Truck 283 130

62 Combination Long-haul Truck 326 145

sourceTypeID sourceTypeName

sourceTypePopulation

VEHICLE AGE DISTRIBUTION 

A grouping of data from Ohio and West Virginia sources along with the MOVES model defaults make 

up the Vehicle Age Distribution. MOVES default values included Vehicle Type ID 41, 42, 51, 52, 53, 

61, and 62. Local data from Ohio and West Virginia motor vehicle registrations accounted for all other 

Vehicle Type ID. Table 8 and Table 9 show the Vehicle Age Distribution for Jefferson County, OH and 

Brooke/Hancock County, WV respectively. 
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State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 12

Table 8 

VEHICLE AGE DISTRIBUTION FOR JEFFERSON COUNTY, OH

yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction

2005 11 0 0.0019 2005 21 9 0.0527 2005 31 18 0.0209

2005 11 1 0.0200 2005 21 10 0.0572 2005 31 19 0.0179

2005 11 2 0.0516 2005 21 11 0.0613 2005 31 20 0.0125

2005 11 3 0.0785 2005 21 12 0.0537 2005 31 21 0.0116

2005 11 4 0.0850 2005 21 13 0.0542 2005 31 22 0.0091

2005 11 5 0.0871 2005 21 14 0.0532 2005 31 23 0.0075

2005 11 6 0.0622 2005 21 15 0.0540 2005 31 24 0.0052

2005 11 7 0.0655 2005 21 16 0.0450 2005 31 25 0.0040

2005 11 8 0.0597 2005 21 17 0.0414 2005 31 26 0.0026

2005 11 9 0.0464 2005 21 18 0.0343 2005 31 27 0.0009

2005 11 10 0.0392 2005 21 19 0.0324 2005 31 28 0.0011

2005 11 11 0.0309 2005 21 20 0.0236 2005 31 29 0.0006

2005 11 12 0.0207 2005 21 21 0.0211 2005 31 30 0.0062

2005 11 13 0.0186 2005 21 22 0.0144 2005 32 0 0.0100

2005 11 14 0.0186 2005 21 23 0.0102 2005 32 1 0.0275

2005 11 15 0.0156 2005 21 24 0.0086 2005 32 2 0.0925

2005 11 16 0.0137 2005 21 25 0.0065 2005 32 3 0.0975

2005 11 17 0.0109 2005 21 26 0.0050 2005 32 4 0.0450

2005 11 18 0.0116 2005 21 27 0.0025 2005 32 5 0.0450

2005 11 19 0.0100 2005 21 28 0.0017 2005 32 6 0.0375

2005 11 20 0.0088 2005 21 29 0.0015 2005 32 7 0.0350

2005 11 21 0.0107 2005 21 30 0.0408 2005 32 8 0.0575

2005 11 22 0.0093 2005 31 0 0.0053 2005 32 9 0.0375

2005 11 23 0.0139 2005 31 1 0.0218 2005 32 10 0.0475

2005 11 24 0.0244 2005 31 2 0.0454 2005 32 11 0.0425

2005 11 25 0.0179 2005 31 3 0.0526 2005 32 12 0.0375

2005 11 26 0.0139 2005 31 4 0.0664 2005 32 13 0.0425

2005 11 27 0.0165 2005 31 5 0.0729 2005 32 14 0.0300

2005 11 28 0.0183 2005 31 6 0.0645 2005 32 15 0.0725

2005 11 29 0.0142 2005 31 7 0.0606 2005 32 16 0.0375

2005 11 30 0.1044 2005 31 8 0.0688 2005 32 17 0.0250

2005 21 0 0.0044 2005 31 9 0.0523 2005 32 18 0.0150

2005 21 1 0.0193 2005 31 10 0.0641 2005 32 19 0.0300

2005 21 2 0.0305 2005 31 11 0.0542 2005 32 20 0.0175

2005 21 3 0.0407 2005 31 12 0.0548 2005 32 21 0.0175

2005 21 4 0.0393 2005 31 13 0.0477 2005 32 22 0.0250

2005 21 5 0.0468 2005 31 14 0.0462 2005 32 23 0.0200

2005 21 6 0.0437 2005 31 15 0.0503 2005 32 24 0.0025

2005 21 7 0.0464 2005 31 16 0.0418 2005 32 25 0.0175

2005 21 8 0.0536 2005 31 17 0.0302 2005 32 26 0.0075
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State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 13

Table 8 (continued) 

VEHICLE AGE DISTRIBUTION FOR JEFFERSON COUNTY, OH 

yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction

2005 32 27 0.0075 2005 42 5 0.1429 2005 43 14 0.0000

2005 32 28 0.0050 2005 42 6 0.1429 2005 43 15 0.0074

2005 32 29 0.0000 2005 42 7 0.0000 2005 43 16 0.0000

2005 32 30 0.0150 2005 42 8 0.0000 2005 43 17 0.0074

2005 41 0 0.0000 2005 42 9 0.0000 2005 43 18 0.0074

2005 41 1 0.0000 2005 42 10 0.0000 2005 43 19 0.0148

2005 41 2 0.0333 2005 42 11 0.0000 2005 43 20 0.0296

2005 41 3 0.1000 2005 42 12 0.0000 2005 43 21 0.0000

2005 41 4 0.0333 2005 42 13 0.0000 2005 43 22 0.0074

2005 41 5 0.0333 2005 42 14 0.0000 2005 43 23 0.0222

2005 41 6 0.1667 2005 42 15 0.0000 2005 43 24 0.0000

2005 41 7 0.0333 2005 42 16 0.0000 2005 43 25 0.0000

2005 41 8 0.0333 2005 42 17 0.0000 2005 43 26 0.0000

2005 41 9 0.0333 2005 42 18 0.0000 2005 43 27 0.0000

2005 41 10 0.1333 2005 42 19 0.1427 2005 43 28 0.0000

2005 41 11 0.1000 2005 42 20 0.0000 2005 43 29 0.0000

2005 41 12 0.0667 2005 42 21 0.0000 2005 43 30 0.0074

2005 41 13 0.0000 2005 42 22 0.0000 2005 51 0 0.0000

2005 41 14 0.1000 2005 42 23 0.0000 2005 51 1 0.0000

2005 41 15 0.0333 2005 42 24 0.0000 2005 51 2 0.0455

2005 41 16 0.0000 2005 42 25 0.0000 2005 51 3 0.0455

2005 41 17 0.0000 2005 42 26 0.0000 2005 51 4 0.2727

2005 41 18 0.0333 2005 42 27 0.0000 2005 51 5 0.0000

2005 41 19 0.0000 2005 42 28 0.0000 2005 51 6 0.0455

2005 41 20 0.0333 2005 42 29 0.0000 2005 51 7 0.0909

2005 41 21 0.0000 2005 42 30 0.0000 2005 51 8 0.1818

2005 41 22 0.0000 2005 43 0 0.0444 2005 51 9 0.0909

2005 41 23 0.0000 2005 43 1 0.1185 2005 51 10 0.0000

2005 41 24 0.0000 2005 43 2 0.0667 2005 51 11 0.0455

2005 41 25 0.0000 2005 43 3 0.0593 2005 51 12 0.0909

2005 41 26 0.0000 2005 43 4 0.0222 2005 51 13 0.0455

2005 41 27 0.0000 2005 43 5 0.0593 2005 51 14 0.0000

2005 41 28 0.0000 2005 43 6 0.0370 2005 51 15 0.0000

2005 41 29 0.0000 2005 43 7 0.0444 2005 51 16 0.0000

2005 41 30 0.0336 2005 43 8 0.0519 2005 51 17 0.0000

2005 42 0 0.0000 2005 43 9 0.0667 2005 51 18 0.0000

2005 42 1 0.1429 2005 43 10 0.0741 2005 51 19 0.0000

2005 42 2 0.2857 2005 43 11 0.0667 2005 51 20 0.0000

2005 42 3 0.0000 2005 43 12 0.0815 2005 51 21 0.0000

2005 42 4 0.1429 2005 43 13 0.1037 2005 51 22 0.0453
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State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 14

Table 8 (continued) 

VEHICLE AGE DISTRIBUTION FOR JEFFERSON COUNTY, OH 

yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction

2005 51 23 0.0000 2005 53 1 0.0000 2005 54 10 0.0287

2005 51 24 0.0000 2005 53 2 0.0455 2005 54 11 0.0417

2005 51 25 0.0000 2005 53 3 0.0455 2005 54 12 0.0355

2005 51 26 0.0000 2005 53 4 0.2727 2005 54 13 0.0307

2005 51 27 0.0000 2005 53 5 0.0000 2005 54 14 0.0294

2005 51 28 0.0000 2005 53 6 0.0455 2005 54 15 0.0219

2005 51 29 0.0000 2005 53 7 0.0909 2005 54 16 0.0301

2005 51 30 0.0000 2005 53 8 0.1818 2005 54 17 0.0225

2005 52 0 0.0000 2005 53 9 0.0909 2005 54 18 0.0219

2005 52 1 0.0000 2005 53 10 0.0000 2005 54 19 0.0178

2005 52 2 0.0455 2005 53 11 0.0455 2005 54 20 0.0273

2005 52 3 0.0455 2005 53 12 0.0909 2005 54 21 0.0225

2005 52 4 0.2727 2005 53 13 0.0455 2005 54 22 0.0355

2005 52 5 0.0000 2005 53 14 0.0000 2005 54 23 0.0314

2005 52 6 0.0455 2005 53 15 0.0000 2005 54 24 0.0225

2005 52 7 0.0909 2005 53 16 0.0000 2005 54 25 0.0191

2005 52 8 0.1818 2005 53 17 0.0000 2005 54 26 0.0362

2005 52 9 0.0909 2005 53 18 0.0000 2005 54 27 0.0150

2005 52 10 0.0000 2005 53 19 0.0000 2005 54 28 0.0130

2005 52 11 0.0455 2005 53 20 0.0000 2005 54 29 0.0109

2005 52 12 0.0909 2005 53 21 0.0000 2005 54 30 0.2309

2005 52 13 0.0455 2005 53 22 0.0453 2005 61 0 0.0023

2005 52 14 0.0000 2005 53 23 0.0000 2005 61 1 0.0102

2005 52 15 0.0000 2005 53 24 0.0000 2005 61 2 0.0228

2005 52 16 0.0000 2005 53 25 0.0000 2005 61 3 0.0255

2005 52 17 0.0000 2005 53 26 0.0000 2005 61 4 0.0383

2005 52 18 0.0000 2005 53 27 0.0000 2005 61 5 0.0409

2005 52 19 0.0000 2005 53 28 0.0000 2005 61 6 0.0427

2005 52 20 0.0000 2005 53 29 0.0000 2005 61 7 0.0412

2005 52 21 0.0000 2005 53 30 0.0000 2005 61 8 0.0401

2005 52 22 0.0453 2005 54 0 0.0034 2005 61 9 0.0418

2005 52 23 0.0000 2005 54 1 0.0096 2005 61 10 0.0557

2005 52 24 0.0000 2005 54 2 0.0239 2005 61 11 0.0529

2005 52 25 0.0000 2005 54 3 0.0280 2005 61 12 0.0454

2005 52 26 0.0000 2005 54 4 0.0335 2005 61 13 0.0488

2005 52 27 0.0000 2005 54 5 0.0260 2005 61 14 0.0379

2005 52 28 0.0000 2005 54 6 0.0485 2005 61 15 0.0458

2005 52 29 0.0000 2005 54 7 0.0362 2005 61 16 0.0527

2005 52 30 0.0000 2005 54 8 0.0225 2005 61 17 0.0396

2005 53 0 0.0000 2005 54 9 0.0239 2005 61 18 0.0353
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State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 15

Table 8 (continued) 

VEHICLE AGE DISTRIBUTION FOR JEFFERSON COUNTY, OH 

yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction

2005 61 19 0.0352 2005 62 3 0.0470 2005 62 18 0.0221

2005 61 20 0.0283 2005 62 4 0.0359 2005 62 19 0.0221

2005 61 21 0.0340 2005 62 5 0.0331 2005 62 20 0.0083

2005 61 22 0.0314 2005 62 6 0.0249 2005 62 21 0.0166

2005 61 23 0.0224 2005 62 7 0.0276 2005 62 22 0.0166

2005 61 24 0.0242 2005 62 8 0.0331 2005 62 23 0.0166

2005 61 25 0.0157 2005 62 9 0.0663 2005 62 24 0.0083

2005 61 26 0.0147 2005 62 10 0.0884 2005 62 25 0.0083

2005 61 27 0.0077 2005 62 11 0.1050 2005 62 26 0.0110

2005 61 28 0.0068 2005 62 12 0.1243 2005 62 27 0.0028

2005 61 29 0.0059 2005 62 13 0.0746 2005 62 28 0.0028

2005 61 30 0.0538 2005 62 14 0.0635 2005 62 29 0.0000

2005 62 0 0.0028 2005 62 15 0.0414 2005 62 30 0.0109

2005 62 1 0.0028 2005 62 16 0.0442

2005 62 2 0.0028 2005 62 17 0.0359
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December 2012 Page 16

Table 9 

VEHICLE AGE DISTRIBUTION FOR BROOKE/HANCOCK COUNTY, WV 

yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction

2005 11 0 0.0291 2005 21 9 0.0639 2005 31 18 0.0136

2005 11 1 0.0472 2005 21 10 0.0654 2005 31 19 0.0112

2005 11 2 0.0678 2005 21 11 0.0596 2005 31 20 0.0101

2005 11 3 0.0872 2005 21 12 0.0515 2005 31 21 0.0103

2005 11 4 0.0993 2005 21 13 0.0437 2005 31 22 0.0087

2005 11 5 0.0690 2005 21 14 0.0352 2005 31 23 0.0064

2005 11 6 0.0460 2005 21 15 0.0315 2005 31 24 0.0063

2005 11 7 0.0617 2005 21 16 0.0255 2005 31 25 0.0035

2005 11 8 0.0654 2005 21 17 0.0208 2005 31 26 0.0033

2005 11 9 0.0575 2005 21 18 0.0165 2005 31 27 0.0017

2005 11 10 0.0412 2005 21 19 0.0121 2005 31 28 0.0013

2005 11 11 0.0339 2005 21 20 0.0101 2005 31 29 0.0013

2005 11 12 0.0212 2005 21 21 0.0100 2005 31 30 0.0207

2005 11 13 0.0194 2005 21 22 0.0055 2005 32 0 0.0346

2005 11 14 0.0224 2005 21 23 0.0044 2005 32 1 0.0287

2005 11 15 0.0163 2005 21 24 0.0037 2005 32 2 0.0606

2005 11 16 0.0121 2005 21 25 0.0039 2005 32 3 0.0740

2005 11 17 0.0121 2005 21 26 0.0034 2005 32 4 0.0807

2005 11 18 0.0139 2005 21 27 0.0010 2005 32 5 0.0843

2005 11 19 0.0042 2005 21 28 0.0011 2005 32 6 0.0909

2005 11 20 0.0073 2005 21 29 0.0009 2005 32 7 0.0701

2005 11 21 0.0079 2005 21 30 0.0401 2005 32 8 0.0524

2005 11 22 0.0163 2005 31 0 0.0318 2005 32 9 0.0528

2005 11 23 0.0091 2005 31 1 0.0322 2005 32 10 0.0555

2005 11 24 0.0115 2005 31 2 0.0523 2005 32 11 0.0488

2005 11 25 0.0085 2005 31 3 0.0590 2005 32 12 0.0232

2005 11 26 0.0067 2005 31 4 0.0650 2005 32 13 0.0319

2005 11 27 0.0109 2005 31 5 0.0751 2005 32 14 0.0303

2005 11 28 0.0103 2005 31 6 0.0719 2005 32 15 0.0382

2005 11 29 0.0103 2005 31 7 0.0644 2005 32 16 0.0335

2005 11 30 0.0743 2005 31 8 0.0639 2005 32 17 0.0205

2005 21 0 0.0247 2005 31 9 0.0576 2005 32 18 0.0083

2005 21 1 0.0387 2005 31 10 0.0620 2005 32 19 0.0114

2005 21 2 0.0534 2005 31 11 0.0545 2005 32 20 0.0134

2005 21 3 0.0668 2005 31 12 0.0494 2005 32 21 0.0110

2005 21 4 0.0592 2005 31 13 0.0437 2005 32 22 0.0130

2005 21 5 0.0619 2005 31 14 0.0366 2005 32 23 0.0091

2005 21 6 0.0563 2005 31 15 0.0334 2005 32 24 0.0079

2005 21 7 0.0639 2005 31 16 0.0308 2005 32 25 0.0020

2005 21 8 0.0653 2005 31 17 0.0180 2005 32 26 0.0039
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State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 17

Table 9 (continued) 

VEHICLE AGE DISTRIBUTION FOR BROOKE/HANCOCK COUNTY, WV

yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction

2005 32 27 0.0024 2005 42 5 0.0576 2005 43 14 0.0464

2005 32 28 0.0031 2005 42 6 0.0504 2005 43 15 0.0374

2005 32 29 0.0028 2005 42 7 0.0461 2005 43 16 0.0144

2005 32 30 0.0007 2005 42 8 0.0492 2005 43 17 0.0111

2005 41 0 0.0843 2005 42 9 0.0759 2005 43 18 0.0136

2005 41 1 0.0672 2005 42 10 0.0609 2005 43 19 0.0138

2005 41 2 0.0576 2005 42 11 0.0506 2005 43 20 0.0118

2005 41 3 0.0506 2005 42 12 0.0489 2005 43 21 0.0104

2005 41 4 0.0693 2005 42 13 0.0434 2005 43 22 0.0107

2005 41 5 0.0562 2005 42 14 0.0394 2005 43 23 0.0073

2005 41 6 0.0488 2005 42 15 0.0320 2005 43 24 0.0092

2005 41 7 0.0379 2005 42 16 0.0321 2005 43 25 0.0000

2005 41 8 0.0453 2005 42 17 0.0181 2005 43 26 0.0000

2005 41 9 0.0535 2005 42 18 0.0082 2005 43 27 0.0000

2005 41 10 0.0560 2005 42 19 0.0231 2005 43 28 0.0000

2005 41 11 0.0550 2005 42 20 0.0071 2005 43 29 0.0000

2005 41 12 0.0597 2005 42 21 0.0032 2005 43 30 0.0000

2005 41 13 0.0528 2005 42 22 0.0007 2005 51 0 0.0498

2005 41 14 0.0487 2005 42 23 0.0013 2005 51 1 0.0398

2005 41 15 0.0400 2005 42 24 0.0009 2005 51 2 0.0340

2005 41 16 0.0167 2005 42 25 0.0006 2005 51 3 0.0767

2005 41 17 0.0147 2005 42 26 0.0002 2005 51 4 0.0926

2005 41 18 0.0133 2005 42 27 0.0004 2005 51 5 0.0604

2005 41 19 0.0180 2005 42 28 0.0003 2005 51 6 0.0544

2005 41 20 0.0112 2005 42 29 0.0001 2005 51 7 0.0243

2005 41 21 0.0090 2005 42 30 0.0002 2005 51 8 0.0696

2005 41 22 0.0099 2005 43 0 0.0794 2005 51 9 0.0625

2005 41 23 0.0038 2005 43 1 0.0660 2005 51 10 0.0514

2005 41 24 0.0048 2005 43 2 0.0647 2005 51 11 0.0730

2005 41 25 0.0048 2005 43 3 0.0594 2005 51 12 0.0610

2005 41 26 0.0040 2005 43 4 0.0798 2005 51 13 0.0796

2005 41 27 0.0036 2005 43 5 0.0406 2005 51 14 0.0442

2005 41 28 0.0026 2005 43 6 0.0511 2005 51 15 0.0479

2005 41 29 0.0007 2005 43 7 0.0435 2005 51 16 0.0145

2005 41 30 0.0000 2005 43 8 0.0585 2005 51 17 0.0169

2005 42 0 0.0624 2005 43 9 0.0696 2005 51 18 0.0156

2005 42 1 0.0771 2005 43 10 0.0419 2005 51 19 0.0040

2005 42 2 0.0742 2005 43 11 0.0526 2005 51 20 0.0043

2005 42 3 0.0727 2005 43 12 0.0556 2005 51 21 0.0043

2005 42 4 0.0627 2005 43 13 0.0512 2005 51 22 0.0000
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 18

Table 9 (continued) 

VEHICLE AGE DISTRIBUTION FOR BROOKE/HANCOCK COUNTY, WV

yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction

2005 51 23 0.0092 2005 53 1 0.1419 2005 54 10 0.0323

2005 51 24 0.0027 2005 53 2 0.1124 2005 54 11 0.0161

2005 51 25 0.0070 2005 53 3 0.0585 2005 54 12 0.0161

2005 51 26 0.0003 2005 53 4 0.0609 2005 54 13 0.0161

2005 51 27 0.0000 2005 53 5 0.1017 2005 54 14 0.0000

2005 51 28 0.0000 2005 53 6 0.0783 2005 54 15 0.0323

2005 51 29 0.0000 2005 53 7 0.0185 2005 54 16 0.0161

2005 51 30 0.0000 2005 53 8 0.0138 2005 54 17 0.0645

2005 52 0 0.0622 2005 53 9 0.0686 2005 54 18 0.0161

2005 52 1 0.0520 2005 53 10 0.0748 2005 54 19 0.0161

2005 52 2 0.0412 2005 53 11 0.0517 2005 54 20 0.0484

2005 52 3 0.0466 2005 53 12 0.0129 2005 54 21 0.0645

2005 52 4 0.0559 2005 53 13 0.0031 2005 54 22 0.0806

2005 52 5 0.0572 2005 53 14 0.0064 2005 54 23 0.0323

2005 52 6 0.0434 2005 53 15 0.0067 2005 54 24 0.0968

2005 52 7 0.0344 2005 53 16 0.0000 2005 54 25 0.0323

2005 52 8 0.0351 2005 53 17 0.0032 2005 54 26 0.0161

2005 52 9 0.0435 2005 53 18 0.0024 2005 54 27 0.0000

2005 52 10 0.0578 2005 53 19 0.0000 2005 54 28 0.0000

2005 52 11 0.0531 2005 53 20 0.0002 2005 54 29 0.0000

2005 52 12 0.0460 2005 53 21 0.0101 2005 54 30 0.1452

2005 52 13 0.0580 2005 53 22 0.0006 2005 61 0 0.0843

2005 52 14 0.0430 2005 53 23 0.0011 2005 61 1 0.0672

2005 52 15 0.0251 2005 53 24 0.0005 2005 61 2 0.0576

2005 52 16 0.0409 2005 53 25 0.0000 2005 61 3 0.0506

2005 52 17 0.0220 2005 53 26 0.0020 2005 61 4 0.0693

2005 52 18 0.0219 2005 53 27 0.0000 2005 61 5 0.0562

2005 52 19 0.0239 2005 53 28 0.0000 2005 61 6 0.0488

2005 52 20 0.0190 2005 53 29 0.0000 2005 61 7 0.0379

2005 52 21 0.0225 2005 53 30 0.0000 2005 61 8 0.0453

2005 52 22 0.0088 2005 54 0 0.0161 2005 61 9 0.0535

2005 52 23 0.0112 2005 54 1 0.0000 2005 61 10 0.0560

2005 52 24 0.0115 2005 54 2 0.0484 2005 61 11 0.0550

2005 52 25 0.0125 2005 54 3 0.0000 2005 61 12 0.0597

2005 52 26 0.0130 2005 54 4 0.0000 2005 61 13 0.0528

2005 52 27 0.0265 2005 54 5 0.0323 2005 61 14 0.0487

2005 52 28 0.0059 2005 54 6 0.0645 2005 61 15 0.0400

2005 52 29 0.0032 2005 54 7 0.0323 2005 61 16 0.0167

2005 52 30 0.0027 2005 54 8 0.0484 2005 61 17 0.0147

2005 53 0 0.1697 2005 54 9 0.0161 2005 61 18 0.0133
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 19

Table 9 (continued) 

VEHICLE AGE DISTRIBUTION FOR BROOKE/HANCOCK COUNTY, WV

yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction

2005 61 19 0.0180 2005 62 3 0.1140 2005 62 18 0.0035

2005 61 20 0.0112 2005 62 4 0.1186 2005 62 19 0.0012

2005 61 21 0.0090 2005 62 5 0.0804 2005 62 20 0.0010

2005 61 22 0.0099 2005 62 6 0.0643 2005 62 21 0.0006

2005 61 23 0.0038 2005 62 7 0.0403 2005 62 22 0.0010

2005 61 24 0.0048 2005 62 8 0.0304 2005 62 23 0.0000

2005 61 25 0.0048 2005 62 9 0.0315 2005 62 24 0.0009

2005 61 26 0.0040 2005 62 10 0.0320 2005 62 25 0.0003

2005 61 27 0.0036 2005 62 11 0.0290 2005 62 26 0.0003

2005 61 28 0.0026 2005 62 12 0.0080 2005 62 27 0.0000

2005 61 29 0.0006 2005 62 13 0.0087 2005 62 28 0.0000

2005 61 30 0.0001 2005 62 14 0.0115 2005 62 29 0.0000

2005 62 0 0.1668 2005 62 15 0.0062 2005 62 30 0.0000

2005 62 1 0.1331 2005 62 16 0.0013

2005 62 2 0.1140 2005 62 17 0.0011
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 20

ROAD TYPE DISTRIBUTION 

The ODOT and WV Division of Highway county summary Vehicle Miles Traveled (VMT) data 

categorized by federal functional class for the three county non-attainment areas is the basis for Road 

Type Distribution Fraction. Table 10 illustrates Road Type Distribution.

Table 10 

ROAD TYPE DISTRIBUTION FOR BROOKE-HANCOCK-JEFFERSON

NON-ATTAINMENT AREA

source

TypeID

road

TypeID roadDesc roadTypeVMTFraction

source

TypeID

road

TypeID roadDesc roadTypeVMTFraction

11 1 Off-Network 0 43 4 Urban Restricted Access 0.25

11 2 Rural Restricted Access 0.11 43 5 Urban Unrestricted Access 0.26

11 3 Rural Unrestricted Access 0.38 51 1 Off-Network 0

11 4 Urban Restricted Access 0.25 51 2 Rural Restricted Access 0.11

11 5 Urban Unrestricted Access 0.26 51 3 Rural Unrestricted Access 0.38

21 1 Off-Network 0 51 4 Urban Restricted Access 0.25

21 2 Rural Restricted Access 0.11 51 5 Urban Unrestricted Access 0.26

21 3 Rural Unrestricted Access 0.38 52 1 Off-Network 0

21 4 Urban Restricted Access 0.25 52 2 Rural Restricted Access 0.11

21 5 Urban Unrestricted Access 0.26 52 3 Rural Unrestricted Access 0.38

31 1 Off-Network 0 52 4 Urban Restricted Access 0.25

31 2 Rural Restricted Access 0.11 52 5 Urban Unrestricted Access 0.26

31 3 Rural Unrestricted Access 0.38 53 1 Off-Network 0

31 4 Urban Restricted Access 0.25 53 2 Rural Restricted Access 0.11

31 5 Urban Unrestricted Access 0.26 53 3 Rural Unrestricted Access 0.38

32 1 Off-Network 0 53 4 Urban Restricted Access 0.25

32 2 Rural Restricted Access 0.11 53 5 Urban Unrestricted Access 0.26

32 3 Rural Unrestricted Access 0.38 54 1 Off-Network 0

32 4 Urban Restricted Access 0.25 54 2 Rural Restricted Access 0.11

32 5 Urban Unrestricted Access 0.26 54 3 Rural Unrestricted Access 0.38

41 1 Off-Network 0 54 4 Urban Restricted Access 0.25

41 2 Rural Restricted Access 0.11 54 5 Urban Unrestricted Access 0.26

41 3 Rural Unrestricted Access 0.38 61 1 Off-Network 0

41 4 Urban Restricted Access 0.25 61 2 Rural Restricted Access 0.11

41 5 Urban Unrestricted Access 0.26 61 3 Rural Unrestricted Access 0.38

42 1 Off-Network 0 61 4 Urban Restricted Access 0.25

42 2 Rural Restricted Access 0.11 61 5 Urban Unrestricted Access 0.26

42 3 Rural Unrestricted Access 0.38 62 1 Off-Network 0

42 4 Urban Restricted Access 0.25 62 2 Rural Restricted Access 0.11

42 5 Urban Unrestricted Access 0.26 62 3 Rural Unrestricted Access 0.38

43 1 Off-Network 0 62 4 Urban Restricted Access 0.25

43 2 Rural Restricted Access 0.11 62 5 Urban Unrestricted Access 0.26

43 3 Rural Unrestricted Access 0.38
Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville, WV-OH

State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard 

December 2012 Page 21

POST PROCESSING 

Several custom programs created by ODOT were computed the total emissions. The process uses data 

on daily and directional traffic distributions as well as more up to date volume/delay functions from the 

2000 Highway Capacity Manual (HCM). This process, described below and illustrated in Figure 4, also 

uses rewritten code able to handle the newer model network formats and MOVES generated emission 

factors. 

The first step in the process involves running postcms.exe to calculate hourly link volumes based on the 

percentage of the daily volume (travel demand model output) determined by a link’s facility and area 

type. The analysis does not use the link speeds from the travel demand model. Using a link’s volumeto-capacity ratio and link group code, a post-process to the model based on HCM methods estimates the 

link speeds. 

The second step (mmoves.exe) uses a combination of the MOVES emission factors and the hourly link 

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

emission factor for the corresponding hour of day, speed bin, and road type; calculate emissions for 

every network link for each hour. The final link on road vehicle emissions for the area is the sum of all 

individual link-hour emissions. 

The third step, (vehcalm.exe), calculates vehicle-based emissions for each source type for each hour of 

the day. A combination of local and default data is the source for the vehicle source type. The final 

vehicle emissions for each county are the sum of all individual hourly emissions for all vehicle types. 

Since the intrazonal trips are not loaded onto the network, the fourth step in the process requires a 

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

program uses intrazonal trips to estimate VMT using the area in square miles and intrazonal trips of each 

zone. The computer program assumes that the zone is circular and uses the radius of the circle as the 

average trip length for these intrazonal trips. By combining MOVES generated emissions with 

estimated intrazonal VMT, the intrazonal emissions are then calculated. The emission rates are the same 

as those used to calculated link based emissions. 

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

analyzed year, and to multiply annual average daily emissions by 365 to produce an annual estimate. 

Public Notice 

Ohio Environmental Protection Agency 

Revision of Redesignation and Maintenance Plan for the Ohio portion of the 

former Steubenville-Weirton WV-OH Ozone Nonattainment Area 

Jefferson County, OH 

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

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

EPA) revise the current maintenance plan for the Ohio portion of the SteubenvilleWeirton WV-OH area (Jefferson County, OH) with respect to the 1997 eight-hour ozone 

national ambient air quality standard (NAAQS). Ohio EPA submitted a redesignation 

request and maintenance plan for this area on July 31, 2006 Subsequently, U.S. EPA 

approved this requests on May 16, 2007 (72 FR 27640). Air quality monitoring data 

collected in the region demonstrated attainment of the NAAQS and there was evidence 

that the improved air quality is due to permanent, enforceable emission reductions. In 

addition, existing requirements are sufficient to maintain the 1997 eight-hour ozone 

standard in this area throughout the maintenance period. 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile 

emission projections and conformity budgets based on emission rates generated from 

U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation 

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

official emission factor model. 

These actions must be noticed to allow public comment and to satisfy U.S. EPA 

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

Ohio EPA’s reliance on the emission projections as evidence of attainment and 

maintenance and the commitment to institute contingency measures if ambient 

exceedances or violations trigger the contingency plan requirements. Written comments 

will be received on or before March 4, 2013 at the following address: 

E-mail: erica.fetty@epa.state.oh.us

Mailing address: Erica Fetty 

Ohio Environmental Protection Agency, DAPC 

Lazarus Government Center 

P.O. Box 1049 

Columbus, Ohio 43216-1049 

Phone: (614) 644-2310 

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

redesignation request will be conducted as follows: March 4, 2013 at 1:15 P.M., 

Steubenville Schiappa Branch Library, 4141 Mall Drive, Steubenville, Ohio. 
All interested persons are entitled to attend or be represented at the hearings and give 

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

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

the close of business on March 4, 2013 will be considered by Ohio EPA prior to final 

action on this redesignation. Written statements submitted after March 4, 2013 may be 

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

the hearing. 

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

page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx. 

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

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

either Erica Fetty, (614)-644-2310, Erica.Fetty@epa.state.oh.us or Jennifer Dines at 

(614) 644-3696, Jennifer.Dines@epa.state.oh.us or mailed to Erica Fetty or Jennifer 

Dines at the above address. 
BEFORE THE OHIO EPA

- - -

IN RE: :

:

Revision of Redesignation and :

Maintenance Plan for the Ohio Portion :

of the Former Steubenville-Weirton :

West Virginia-Ohio Ozone Nonattainment :

Area

- - -

Audiotaped public Hearing before 

Moderator Kristopher Weiss, taken at the 

Steubenville Schiappa Branch Library, 4141 Mall 

Drive, Steubenville, Ohio, at 1:15 p.m. on March 

4, 2013.

- - -

FRALEY, COOPER & ASSOCIATES

222 East Town Street, Second Floor

Columbus, Ohio 43215-4620

(614) 228-0018 - (614) 852-6163

Fax - (614) 224-5724

- - -
P-R-O-C-E-E-D-I-N-G-S

- - -

MODERATOR WEISS: My name is Kristopher 

Weiss. I'm a public involvement coordinator in 

Ohio EPA's Public Interest Center in Columbus. I 

will be presiding over today's public hearing.

Thank you for taking the time to attend 

this hearing before the Ohio Environmental 

Protection Agency. The purpose of the hearing 

today is to obtain comments from any interested 

person regarding Ohio EPA's proposed action.

The State of Ohio is requesting that the 

U.S. EPA revise the current maintenance plan for 

the Steubenville/Weirton Ohio and West Virginia 

area, which includes Jefferson County in Ohio, 

with respect to the 1997 eight-hour ozone 

national ambient air quality standard.

Ohio EPA is now requesting a revision to 

the maintenance plan to update mobile emission 

projections and conformity budgets based on 

emission rates generated from U.S. EPA's latest 

mobile emissions model, the Motor Vehicle 

Emission Simulation 2010. In December 2009 MOVES 

replaced MOBILE6.2 as U.S. EPA's official 

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emission factor model.

All interested persons are entitled to 

attend or be represented and to present oral 

and/or written comments concerning the proposed 

action. All written and oral comments received 

as part of the official record will be considered 

by the Director of Ohio EPA. 

To be included in the official record, 

written comments must be received by Ohio EPA by 

the close of business today, March 4, 2013. 

These comments may be filed with me today or 

e-mailed to erica.fetty@epa.ohio.gov. 

All written comments submitted for the 

record receive the same consideration as oral 

testimony given today. Written statements 

submitted after today may be considered as time 

and circumstances permit but will not be part of 

the official record for the hearing.

If you wish to present oral testimony at 

this hearing today and have not already signed 

the registration sheet, please do so at this 

time. The sheet is available at the registration 

table. People will be called in the order in 

which they have registered.

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There is no cross-examination of 

speakers or of representatives of Ohio EPA in 

public hearings such as this. Ohio EPA hearings 

such as this afford citizens the opportunity to 

provide comments on the official record. 

Therefore, we will not be able to answer 

questions during the hearing. However, members 

of the panel may ask clarifying questions of the 

person testifying to ensure the record is as 

complete and accurate as possible.

I will now read the names of those who 

have registered at this hearing and will give 

each person an opportunity to testify.

Seeing that no one wants to testify, we 

will now go off the record.

(Break taken.)

MODERATOR WEISS: We are now back on the 

record. 

Is there anyone else who wishes to 

testify? (No audible response.)

Seeing no further requests for 

testimony, I'll remind you that the written 

comments can be submitted through 5 p.m. today. 

Thank you for attending.

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The time is now 1:45 p.m., and this 

hearing is adjourned.

(Thereupon, the public hearing was 

adjourned at 1:45 p.m. on Monday, March 4, 2013.)

* * *

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C E R T I F I C A T E

- - -

STATE OF OHIO :

 SS:

COUNTY OF FRANKLIN :

I, Jennifer L. Parish, Registered 

Professional Reporter, do hereby certify that the 

foregoing is a true, correct, and complete 

transcription of the above-mentioned audiotaped 

public hearing before the Ohio EPA to the best of 

my ability.

DATED this 15th day of March, 2013.

_________________________

JENNIFER L. PARISH, RPR

NOTARY PUBLIC-STATE OF OHIO

My Commission Expires: November 23, 2014.

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Division of Air Pollution Control 

Response to Comments 

Revised Redesignation Request and Maintenance Plan 

For the 1997 8-Hour Ozone Standard for the Steubenville-Weirton Area 

Agency Contact for this Package

Division Contact: (Erica Fetty, Division of Air Pollution Control, 614-644-2310, 

Erica.Fetty@epa.state.oh.us) 

Ohio EPA held a public hearing in Columbus, OH on March 4, 2013, regarding the revised 

Maintenance Plan for the former Steubenville-Weirton Ozone Nonattainment Area. This 

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

the associated comment period, which ended on March 4, 2013. Ohio EPA reviewed and 

considered all comments received during the public comment period. 

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

environment and public health. 

The name of the commenter follows the comment in parentheses. 

Comment 1: This 2013 update is based upon a 2006 original document. The 

narrative introduction should explain why the document is being 

updated (e.g., inter alia, to update the on-road (highway) emission 

estimates and Motor Vehicle Emission Budgets (MVEBs) using the 

most recent EPA approved software, MOVES). The narrative could 

benefit from general polishing and refreshing, including discussion 

of fundamental points raised below. (William Durham- West 

Virginia Division of Air Quality) 

Response 1: Ohio EPA will be adding a footnote to the title page explaining the 

purpose of the revision. Ohio EPA included updates to the 

narrative throughout this document to reflect the changes regarding 

the use of the new MOVES model. Where necessary, based on 

comments below, Ohio EPA has incorporated additional 

clarification. 
Comment 2: Any discussions related to the West Virginia MVEB’s and Safety 

Margins should clearly reference the most recent EPA approved 

WV 1997 8-hour ozone budgets [see 76, Federal Register 56975, 

September 15, 2011; Weirton area summarized on page 56978; file 

attached in PDF]. Such discussions should clearly state that 

nothing in the Ohio proposal will change any of the EPA approved 

WV MVEB’s or Safety Margins. (William Durham- West Virginia 

Division of Air Quality) 

Response 2: Ohio EPA has updated Table 7, the MVEBs, using those budgets 

established for the WV portion of this area in the September 15, 

2011 Federal Register. The footnote has also been clarified to 

describe the basis of West Virginia’s MVEBs. Subsequent tables 

and narrative have also been updated to reflect this change. 

Comment 3: For example, though the title of Table 7 refers to Jefferson County 

(OH) MVEBs, the table also displays values for Brooke and 

Hancock (WV), which are incorrect and could mislead readers into 

thinking that the WV MVEBs have been, or are being, changed. 

This is absolutely NOT the case. (William Durham- West Virginia 

Division of Air Quality) 

Response 3: Please see response to comment 2 

Comment 4: The same concern applies to Table 9, which displays WV on-road 

emission estimates, then shows 15% increases as the resulting 

MVEBs (via asterisk-referenced text). Again, while the on-road 

emission estimates may be correct as now calculated using 

MOVES, the 2009 Interim and 2018 Maintenance values that have 

been flagged with asterisks are NOT the EPA approved MVEBs. 

The text should clearly state that the displayed values are shown 

ONLY for informational purposes and the EPA approved MVEBs 

should be shown in the document (this could be done in the 

narrative itself, in a separate table, or as a footnote). (William 

Durham- West Virginia Division of Air Quality) 

Response 4: Please see response to comment 2

Comment 5: Table 10 & Table 12 should then be revised to show the correct WV 

values and resultant total safety margins. 

The EPA approved values for WV total emissions [based upon 

augmented MOBILE6.2 on-road (highway) emission estimates, 
NOT MOVES; see 76 FR at 56978, Table 8 - portion labeled 

Revised Total Emissions in the Revised Maintenance Plan 

(Tons/Day)] are: 

 2004 2009 2018 

VOC: 13.5 13.4 13.4 tons per summer 

day

NOx: 18.2 18.0 17.9 tons per summer 

day (William Durham- West Virginia Division of Air Quality) 

Response 5: Please see response to comment 2 

Comment 6: We suggest that a more comprehensive explanation of “safety 

margin” would help clarify its meaning. 

The Transportation Conformity Rule (40 CFR 93.101) defines 

Safety margin as:

“[t]he 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” (emphasis added). 

To assure maintenance, the 2009 total emission estimates AND the 

2018 total emission estimates, respectively, must be less than the 

2004 maintenance plan base year total emissions (for a given 

pollutant/precursor). Thus, in the context of this maintenance plan, 

there are actually four safety margins: 

2009 NOx; 2009 VOC; 2018 NOx; and 2018 VOC. 

(Arguably, one could say there are a total of eight safety margins 

for the entire former nonattainment area, because the Ohio and 

West Virginia respective SIPs establish separate MVEBs for each 

state, with distinct resulting safety margins). These safety margins 

are calculated by subtracting the 2009 total emissions (for a given 

pollutant) and the 2018 total emissions (for a given pollutant), 

respectively, from the 2004 attainment year total emissions (for a 

given pollutant). We may refer to the results for a given 

pollutant/precursor as the 2009 safety margin and the 2018 safety 

margin, respectively. Portions of the original safety margins may be 

reallocated to the MVEBs as long as adequate margins remain to 

ensure maintenance. 

It is important to consider that transportation planning organizations 

typically develop a twenty year Long Range Transportation Plan 
(LRTP) while the initial air quality maintenance plan only lasts for 

ten years. Under the conformity rule, the last year of the LRTP must 

be tested against the MVEBs established for the last year of the 

maintenance plan. Therefore, future transportation conformity 

determinations will not only be made for the specific years 

contained in the maintenance plans but also for horizon years 

contained in the LRTP, which now may extend to the year 2040. 

That is, the future expected highway emissions, including growth, in 

2040 will be compared against the 2018 MVEBs. Therefore, 

reallocation of appropriate portions of the safety margins into the 

respective MVEBs helps to assure future positive transportation 

conformity determinations while preserving good air quality. 

(William Durham- West Virginia Division of Air Quality) 

Response 6: Ohio EPA has added additional clarification where necessary to 

explain the origin of West Virginia’s safety margin. Beyond that, 

Ohio EPA is not updating additional language in this originally 

approved submittal. The purpose of this submittal is to revise the 

previously approved safety margin.

Comment 7: We concur with Ohio EPA, that there are adequate remaining 

safety margins to assure maintenance for the 1997 8-hour ozone 

standard. (William Durham- West Virginia Division of Air 

Quality) 

Response 7: Thank you.