# ! !!!2

Protect i on Agency



### JUN 16 

### l016

Robert A. Kaplan John R. Kasich, Governor

Mary Taylor

, Lt

. Gov e rno r
Craig W. Butler

, Dir e ctor

Acting Regional Admin i strator

Attn .: R-19J

U

. S. EPA

, Region 5

77West Jackson Blvd. Chicago

, Illinois 60604-3507

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

Columbus

, OH Area for the 2008 Eight-Hour Ozone Standard

Dear Acting Administrator Kaplan :

I am writing to formally request a redesignation to attainment of the Columbus, Ohio area (Delaware

, Fairfield

, Franklin, Knox, Licking and Madison) with respect to the 2008 eighthour o z one standard. The enclosed submittal combines the redesignation request and the required maintenance plan for this area

.

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

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

2012

- 2014 and 2013-2015 air quality data. Emissions projections indicate that current

controls

, existing State rules

, existing federal rules

, and Ohio ' s PSD program will be more than sufficient to maintain the NAAQS indefinitely into the future

. These programs will

, therefore, constitute the attainment and maintenance plan for the Columbus

, Ohio area

.

The enclosed information

, compiled by the Ohio Env i ronmental Protection Agency (EPA),

Ohio Department of Transportation

, the Mid-Ohio Regional Plann i ng Commission

, and the Licking County Area Transportation

, shows significant emission reductions in point and

mobile sources since ambient violations have occurred

. A significant portion of the improved

air quality can be attributed to federal programs for the mobile source sector

, and the regional reductions associated with the transport programs.

The public hearing for this package was held on June 2

, 2016, in Columbus, Ohio and public

comments were accepted through June 2, 2016 as well. The comments received and Ohio

EPA ' s response to those comments is included in this package

.

I am also requesting that this redesignation request be processed by U

. S

. EPA as expeditiously as possible due to the upcoming nonattainment designations for the 2015 ozone NAAQS. These designations are scheduled to occur in October 2017 and the Columbus

, Ohio

area will potentially be designated nonattainment for the 2015 ozone NAAQS

. It is vital to Ohio

50 West Town Street • Suite 700 • P

. O

. B ox 1049 • Co l umbu s, OH 4 32 16 -10 49

epa.o hi o.go v • ( 614) 644

- 3020 • (614) 644 -3 184 (fax)and the Columbus area to reach attainment for the 2008 ozone NAAQS before this time to

avo i d trigging any implications under the Clean Air Act for areas designated nonattainmen t for

a newer standard but have not been designated back to attainment for a standard that has

been revoked

.

This submittal consists of one (1) hard copy of the required documenta t ion

. An exact duplicate

electronic version of the submittal in PDF format i s available at http :// www

. epa.state

. oh

. us / dapc / SIP / 2008

. asp x under the heading " Clean Data Requests

, Redesignations and Maintenance Plans ".

If you have any quest i ons

, please contact Jennifer Van Vlerah in our Division of Air Pollution

Control at (614) 644-3696.

Sincerely

,

enclosures

cc : Robert Hodanbosi

, DAPC

Jennifer Van Vlerah

, DAPC

# REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

THE COLUMBUS, OHIO

8- HOUR OZONE

NONATTAINMENT AREA

Delaware, Fairfield, Franklin, Knox, Licking, and

Madison Counties, Ohio

Prepared b y: Ohio Environmental Protection Agency

Division of Air Pollution Control

June 2016Th is page left intentionally blanki 

### 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 monitori ng

................................ ................................ .......................................................... 10

Ozone NAAQS

................................ ................................ .............................................................. 10 Ambient data quality assured

................................ ................................ ........................................ 11 Three complete years of data

................................ ................................ ....................................... 11 Commitment to continue monitoring

................................ ............................................................. 14

Chapter Four

Emission i nventory

................................ ................................ ........................................................ 15

Base y ear i nventory

................................ ................................ ...................................................... 16

Emission p rojections

................................ ................................ ..................................................... 17

Demonstration of m aintenance

................................ ................................ ..................................... 17

Permanent and e nforceable e missions r eductions

................................ ...................................... 27

Provisions for f uture u pdates

................................ ................................ ........................................ 31

Chapter Five

Con trol measures and regulations

................................ ................................ ................................ 33

Em ission inventories/statements

................................ ................................ .................................. 33 Implementation of p ast SIP r evisions

................................ ........................................................... 33

New s ource r eview p ro v isions

................................ ................................ ..................................... 42

As surance of continued controls

................................ ................................ .................................. 43

Chapter Six

Con tingency measu res

................................ ................................ ................................................. 44 Commitment to revise plan

................................ ................................ ........................................... 44

Commitm ent for contingency measures

................................ ....................................................... 44

P otential contingency measures

................................ ................................ ................................... 46

List of VOC and NO
x sources

................................ ................................ ....................................... 47

Chapter Seven Modeling Analysis

................................ ................................ ......................................................... 49 Summary of Modeling Results for National Emission C ont rol Strategies in Final Rulemaking

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

...................... 49 LADCO Modeling for Eight

- Hour Ozone Sta ndard

................................ ....................................... 52 Summary of Existing Modeling Results

................................ ........................................................ 53ii Chapter Eight Public participation

................................ ................................ ........................................................ 54

C hapter Nine

Conclusions

................................ ................................ ................................ ................................... 55iii FIGURES

Figure 1 Map of the C olumbus , OH N onattainment A rea and M onitor L ocations ................11 Figur e 2 Max imum 8- Hour Concentrations versus High Temperate Days

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

.................. 30 Figure 4 Average Maximum 4 th High versus Relative Humidity

..................................... 31

TABLES

Table 1 Monitoring Data for C olumbus 2012
– 2014 and 2013

- 2015

............................... 13

Table 2 Emission Estimations for On -r oad Mobile Sources for Delaware Co ., Ohio

........ 18

Table 3 Emission Estimations for O n- road Mobile Sources for Fairfield Co ., Ohio

.......... 18

Table 4 Emission Estimations for On

- road Mobile Sources for Franklin Co ., Ohio

.......... 18

Table 5 Emission Estimations for On

- road Mobile Sources for Knox Co. , Ohio

............... 18

Table 6 Em ission Estimations for On

- road Mobile Sources for Licking Co. , Ohio

............ 18

Table 7 Emission Estimations for On

- road Mobile Sources for Madison Co

. , Ohio

......... 18

Table 8 Emission Estimation s for On

- road Total C olumbus Sources

............................... 19

Table 9 Mobile Vehicle Emission Budge t for Columbus, Ohio

.......................................... 19

Table 10 NOx Emission Inventory Delaware Co , Ohio

. ....................................................... 21

Table 1 1 NOx Emission Inventory Fairfield Co., Ohio

. ........................................................ 21

Table 1 2 NOx Emiss ion Inventory Franklin Co., Ohio

. ........................................................ 22

Table 1 3 NOx E mission Inventory Knox Co., Ohio

. ............................................................. 22

Table 14 NOx Emi s sion Inventory Licking Co ., Ohio

. .......................................................... 22

Table 15 NOx Emis sion Inventory Madison Co

., Ohio

. ....................................................... 22

Table 16 NOx Emission Inventory C olumbus

, Total

............................................................ 23

Table 17 V OC Emission Inventory Delaware Co, Ohio.

...................................................... 23

Table 18 VOC Emission Inventory Fairfield Co., Ohio.

....................................................... 23

Tab le 19 VOC Emission Inventory Franklin Co., Ohio.

....................................................... 24

Table 2 0 VOC Emission Inventory Knox Co., Ohi o.

............................................................ 24

Table 21 VOC Emissio n Inventory Licking Co., Ohio.

......................................................... 24

Table 22 VOC Emission Inve ntory Madison Co

., Ohio

. ....................................................... 24

Table 23 VOC Emission Inventory C olumbus

, Ohi o Total

................................................... 25

Table 24 Projected E mission E stimates 2014

- 20 30 C olumbus, Ohio

................................ 25

Table 25 Combined C omparison of 2011 an d 2014 On

- road and EGU Totals

.................. 27

Table 26 U.S. EPA “Good Neighbor” Provision Modeling Results Average Design Values. 51

Table 27 U.S. EPA “G ood Neighbor” Current Design Values

.................................. ....5 2

Table 28 LADCO’s Modeling Results for the C olumbus Area

. ............................................ 53iv APPENDICES

A 2012

- 2014 Air Quality System (AQS) Data and SLAMS Certification

B 2013

- 2015 Air Quality System (AQS) Data and SLAMS Certifi cation

C Mobile Source Emissions Inventory

D Public Participation Documentationv This page left intentionally blank1 REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE COLUMBUS, OH

OZONE NONATTAINMENT AREA

Delaware, Fairfield, Franklin, Knox, Licking, and Madison Counties,

Ohio



### CHAPTER ONE

I ntroduction 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. O n March 12,

2008 , the United States Environmental Protection Agency ( U.S. EPA ) revised the air quality standard for ozone replacing the 1997 eight

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

.

On March 21, 2012 (77 FR 30088)

, U.S. EPA designated nonattainment areas

for the 2008 eight

- hour ozone standard. Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas to be redesignated to attainment provided certain criteria are met. The following are the criteria that must be met in order for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has attained the eight

- hour

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

u nder 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 ot her federal requirements. iv) A fully approved maintenance plan under Section 17 5(A). v) A determination that all Section 110 and Part D requirements

have been met.

Background

The current C olumbus, OH nonattainment area includes the following Counties: Delaware, Fairfield, Franklin, Knox, Licking, and Madison.

As part of the 1997 e ight

- hour ozone standard designations

, the following

C ounties within the Columbus, OH area were designated as basic nonattainment pursuant to Subpart 1 of the CAA and

, therefore

, were subject to nonattainment area rulemakings: Delaware, Fairfield, Franklin, Knox, Licking, and Madison. The Columbus area was redesignated to attainment on2 September 15, 2009 ( 74 FR 47404 ) and a revision to the approved motor vehicle emissions budgets was approved on March 19, 2013 (78 FR 16785)

. A maintenance plan was approved at th at time.

As a result of th e 2012 ozone designations for the 2008 eight

- hour ozone

standard

, U.S. EPA designated the Columbus, OH area marginal

nonattainment , pursuant to Subpart 2 of the CAA

, and the Ohio Environmental Protection Agency ( Ohio EPA ) was required to submit certain nonattainment plan elements by July 20, 2014

. Ohio EPA submitted those elements on July 18, 2014 and U.S. EPA published a proposal and direct final action approving that submittal on March 10, 2016 ( 81 FR 12626 and 81 F R 12591). The approval became effective May 9, 2016

.

T his document is intended to support Ohio’s request that the Columbus, OH

area be redesignated from nonattainment to attainment for the eight

- hour

ozone s tandard

. The Columbus, OH area has recorded thr ee (3) years of complete quality

- assured ambient air quality monitoring data for the years

2012 through 2014 dem onstrating attainment of the eight

- hour ozone

standard. In addition, concentrations from 2013 through 2015 are also shown.

This newer 2015 data was certified on April 29, 2016.

Geographical Description

The Columbus, OH eight

- hour ozone nonattainment area is located in the center of Ohio and includes the following Counties: Delaware, Fairfield, Franklin, Knox, Licking, Madison. T his area is shown in Figure 1 under Chapter Three

.

Status of Air Quality Ozone monitoring data for the m ost recent three (3) years, 2012 through 2014

, demonstrate that the air quality has met the NAAQS for ozone in this marginal nonattainment area. The NAAQS attainment, accompanied by decreases in

emission lev els discussed in Chapter F our, supports a redesignation to

attainment for the Columbus, OH area based on the requirements in Section 107(d)(3)(E) of the CAA

.3 

### C HAPTER TWO

Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (R edesignation

G uidance ), issued September 4, 1992, to Regional Air Directors. T h e redesignation request and maintenance p lan are based on the R edesignation

G uidance, supplemented with additional guidance received from staff of U.S.

EPA Region V.

Below is a s ummary of each redesignation criterion as it applies to the Columbus, OH area.

i.) Attainment of the standard
- CAA Secti on107 (d)(3)(E)(i) There are two components involved in making this

demonstration . The first component relies on ambient air quality

data. The data that are used to demonstrate attainment should be the product of ambient monitoring that is representativ e of the area of highest concentration. The data should be collected and quality

- assured in accordance with 40 CFR 58 and recorded in

the Air Quality System (AQS) in order for it to be available to the public for review. Chapter Three discusses this requirement in

more detail

The second component relies upon supplemental U.S. EPA approved air quality modeling. The supplemental modeling is not required for ozone nonattainmen t areas seeking redesignation ; h owever, Ohio EPA has incorporated photochemical modeling information in Chapter Seven to further support our request that the nonattainment area be redesignated

to attainment

.

ii.) SIP approval
- CAA Section 107 (d)(3)(E)(ii) The SIP for the area must be f ully approved under Section 110(k) and must satis fy all the requirements that apply to the area. Ohio’s SIP was approved on May 4 , 1994 (59 FR 23799)

, and March 23, 1995 (60 FR 15235 ) and includes the Columbus,

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

SIP revision for this area and U.S. EPA published a proposal and direct final action approving that submittal on March 10, 2016 (81 FR 12626 and 81 FR 12591). The approval became effective May 9, 2016

. Chapter F ive discusses this requirement

in more detail

.

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

Section107 (d)(3)(E)(iii)4 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

achi eved from federal measures as well as control measures that have been adopted and implemented by the state.

On March 6, 2015, U.S. EPA finalized the “ Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Re quirements; Final Rule” (herein referred to as “Implementation Rule”). (80 FR 12264) In the Implementation Rule, U.S. EPA states “Under CAA section 182(a), Marginal areas have up to 3 years from the effective date of designation to attain the NAAQS, and are not required to submit an attainment demonstration SIP.” ( 80 FR 12268) Further, U.S. EPA identifies “ An attainment demonstration consists of: (1) Technical analyses, such as base year and

future year modeling of emissions which identifies sources and

q uantifies emissions from those sources that are contributing to nonattainment; (2) analyses of future year emissions reductions and air quality improvement resulting from existing ( i.e., already adopted or ‘‘on the books’’) national, regional and local

pro grams, and pot ential new local measures needed for attainment, including RACM and RACT for the area; (3) a list of adopted measures (including RACT) with schedules for implementation and other means and techniques necessary and appropriate for demonstratin g attainment as expeditiously as practicable but no later than the outside attainment date for the

area’s classification; and (4) a R ACM analysis to determine whether any additional RACM measures could advance attainment by 1 y ear.” (80 FR 12268) Therefore , these requirements, and specifically, the requirement to adopt specific state measures beyond federal measures, are not applicable to marginal areas, such as the C olumbus , OH nonattainment area.

Regardless, Ohio has adopted and i mplemented control

meas ures for these c ounties in th e area beyond the federal

measures in order to comply with the 1997 eight

- hour ozone

standard and Ohio also adopted the initial 1979/1981 s tatewide

rules. These measures and rules remain in effect and have

assisted the C olumbus

, OH area in reach ing attainment for the 2008 eight

- hour ozone standard. Below is a list of several previously adopted Ohio rules that have contributed to reducing

ozone in this area :5 • Portable Fuel Containers requirements

• Architectural and Industria l Maintenance (AIM) Coatings

rules

• Consumer Products rules

• Clean Air Interstate Rule (CAIR)

• NO
x Sip Call rules

C hapters F our and F ive discuss this requirement in more detail.

iv.) Section 110 and Part D requirements
- CAA Section 107 ( d)(3)(E)( v) For purposes of redesignation, a s tate must meet all requirements of Section 110 and P art D that were applicable prior to submittal of the complete redesignation request.

i.) Section 110(a) requirements Section 110(a) of Title I of the CAA contains the g eneral requirements for a S IP. Section 110(a)(1) generally directs states to submit a S IP that provides for implementation, maintenance, and enforcement of the air quality standards to the U.S. EPA after reasonable notice and public hearing. Section 110(a)(2) provides that the infrastructure SIP submitted by a state must have been adopted by the state after reasonable public notice and hearing, and that, among other things, it must include

enforceable emission limitations and ot her control

measures [3 ]

, m eans or techniques necessary to meet the requirements of the CAA; provide for establishment and operation of appropriate devices, methods, systems and procedures necessary to monitor ambient air quality; provide for implementation of a source permit progra m to regulate the modification and c onstruction of any stationary source within the areas covered by the plan; include provisions for the implementation of P art C,

p revention of s ignificant d eterioration (PSD) and P art D, NSR permit programs; include criteria for stationary

source emission control measures, monitoring, and reporting; include provisions for air quality modeling; and provides for public and l ocal agency participation in planning and emission control rule development. In

Ohio’s December 27 , 20 12 infrastructure SIP submission,

Ohio verified that the S tate fulfills the requirements of Section 110(a)(2) of the Act.

[3] Other than nonattainment emission limitations and measures which are a part of nonattainment area plans and subject to the timing requirements of Section 172 of the CAA.6 Subpart 1 of Part D, found in Sections 172

- 176 of the CAA, sets forth the basic nonattainment requirements applicable to all areas which are designated nonattainment based on a violation of the NAAQS. Subpart 2 of Part D, which includes Section 182 of the CAA, establishes more specific requirements depending

on the area’s ozone nonattainment classification.

The C olumbus , OH area was designated under Subpart 2 of Part D as a marginal nonattainment area for ozone as part of U. S. EPA “Air Quality Designations for the 2008 Ozone NAAQS .” (77 FR 30088) Therefore, the C olumbus , OH area must meet the applicable requirements of both Subpart 1 and Subpart 2 of Part D. The applicable Subpart 1 requirements are contained in Section 172(c)(1)

- (9) and i n Section 176. T he applicable Subpart 2 r equirements are contained in Section 182(a) (marginal nonattainment area requirements).

ii.) Subpart 1 of Part D
- Section 172(c) requirements Section 172(c)(1) requires the plans for all nonattainment areas to provide for the implementation of all RACM as expeditiously as practicable and to provide for attainment for the national primary ambient air q uality sta ndards. As

discussed abo ve, U.S. EPA’ s Implementation Rule did not require marginal nonattainment areas to implement RACT/RACM. In addition, because attainment has been

reached in the C olumbus , OH area , no addi tional measures are needed to provide for attainment.

The reasonable further progress ( RFP ) requirement under section 172(c)(2) is defined as progress that must

be made toward attainment. This requirement is not relevant for purposes of redesignation because the

C olumbus , OH area is moni toring attainment of the 2008 eight

- hour ozone standard

. In addition, because the

C olumbus , OH area has attained the ozone standard

and is no l onger subject to an RFP requirement, the section 172(c)(9) contingency measures are not applicable for purposes of redesignation.

Section 172(c)(3) requires submission and approval of a comprehensive, accurate and current inventory of actual

emissions. This requirement was superseded by the inventory requirement in S ection 182(a)(1) discussed

below.7 Sect ion 172(c)(4) requires the identification and quantification of allowable emissions for major new and modified stationary sources in an ar ea, and S ection 172(c)(5) requires source permits for the construction and operation of new and modified major station ary sources anywhere in the nonattainment area. Ohio has a fully approved new source review program which is discussed in more detail under Chapter Five.

Section 172(c)(6) requires the SIP to contain control measures necessary to provide for attainment of the

standard. Because attainment has been r eached, no additional measures are needed t o provide for

attainment.

Section 172(c)(7) requires the SIP to meet the applicable provisions of S ection 110(a)(2). The Ohio SIP meets the requirements of S ectio n 110(a)(2) for purposes of redesignation, as discussed above.

ii i.) Subpart 1 of Part D
- Section 176(c) requirements Section 176(c) of the CAA requires states to establish criteria and procedures to ensure that Federally

supported or funded activities, including highway projects, conform to the air quality planning goals in the applicable

SIPs. The requirement to determine conformity applies to transportation plans, programs and projects developed, funded or approved under T itle 23 of the U.S. Code and the Federal Transit Act (transportation conformity) as well as to all other Federally

- supported or funded projects (general conformity). State conformity revisions must be consistent with Federal conformity regulations relating to consultation, enforcement, and enforceability, which U.S. EPA promulgated pursuant to CAA requirements.

Ohio EPA established two SIPs for conformity. The rules in Ohio Administrative Code (OAC) C hapter 3745

- 101 contained Ohio’s SIP approved rules for transportation conformity, and OAC C hapter 3745

- 102 contained Ohio’s SIP approved rules for general conformity.

Ohio EPA’s transportation conformity rules in OAC Chapter 3745

- 101 were approved as a part of Ohio’s SIP on July 31, 2000 ( 65 FR 34395) and April 27, 2007 (728 FR 20945 ). However, Ohio’s transportation conformity rules in OAC Chapter 3745

- 101 were completely removed from Ohio’s SIP on M arch 2, 2015 ( 80 FR 11134) when the rules were replaced by a s eries of memorandums of understanding (MOUs) between Ohio EPA, U .S.E PA, and the various state and local agencies involved in the transportation conformity process. The currently effective MOUs are available on O hio EPA’s

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

.

Ohio EPA’s general conformity rules in OAC C hapter

3745

- 102 were approved as part of Ohio’s SIP on March 11, 1996 ( 61 FR 9644 ). In April, 2010, U .S

. EPA promulgated changes to 40 CFR 51.851. The language in paragraph (a) of the section was c hanged from “must” to “may”, thereby eliminat ing the requirement for states to

maintain a g eneral c onformity SIP. For this reason, Ohio EPA requested, and U .S

. EPA granted rescission of Ohio’s general conformity SIP. The rules in OAC Ch apter

3745

- 102 were removed from the state SIP on May 26, 2015 (80 FR 29968)

. The state SIP was replaced by the federal rules in 40 CFR Part 93, subpart B.

iv.) Subpart 2 of Part D
- Section 182(a) requirements Section 182(a)(1) requires the submission of a comprehensive emissions inventory. This requirement is addressed under Chapter Four

.

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

corrections to VOC RACT rules, inspection and

maintenance programs and permitting programs. These

corrections were addressed for t he C olumbus , OH area

under the one

- hour ozone standard and do not need to be addressed again under the 2008 eight

- hour standard.

Section 182(a)(3)(B) requires the submission of an emission statement SIP. This requirement is addressed under Chapter Five

.

v.) Maintenance plans
- CAA Section 107 (d)(3)(E)( i v) Section 107(d)(3)(E) stipulates that for an ar ea to be redesignated, U.S. EPA must fully approve a maintenance plan

that meets the requirements of Section 175(A). T he maintenance plan must constitute a SIP revision and m ust provide for maintenance of the relevant NAAQS in the area for9 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 mai ntenance.

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.) a ttainment inventory ; b.) m aintenance demonstration ; c.) m onitoring network ; d.) v erification of continued attainment; and e.) c ontingency plan

.
Chapter S ix discusses this requirement in more detail.10 

### CHAPTER THREE

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

Requirement 1 of 4 A demonstration that the NAAQS for ozone, as published in 40 CFR 50. 15,

has been attained.

Background

There are seven monitor s measuri ng ozone concentrations in

this no nattainm ent area. The monitors are o perated by Ohio

EPA Division of Air Pollution Control Central District Of fice

. A listing of the design values based on the three

- year average of the annual fourth highest daily maximum eight

- hour average

ozone concentration s from 2012 through 2014 certified air quality data is shown in Table 1

. In addition, concentrations

fro m 2013 through 2015 are also shown. This newer 2015 data

was certified on April 29 , 2016. The locations of the monitoring

sites for this nonattainment area are shown on Figure 1

.11 D emonstration

Figure 1 - Map of the C olumbus , OH nonattainment area and

monitor locations

Requirement 2 of 4 Ambient monitoring data quality assured in accordance with 40 CFR 58.10,

recorded in the U.S. EPA air quality system (AQS) data base, and available for public view.

Demonstration

The Ohio EPA has quality assured all 2012 through 2014 data shown in Appendix A in accordance with 40 CFR 58.10 and the Ohio Quality Assurance Manual. Ohio EPA has recorded the data
in the AQS database and

, therefore , the data are available to the public. All 2015 dat a included in Appendix B was quality assured

on April 29 , 2016.

R equirement 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, are12 below 75 par ts per billion (ppb). ( This showing must rely on three complete, consecutive calendar years of quality assured data. )

Background The following information is taken from Appendix P

,

“ Interpretation of the Primary and Secondary NAAQS for O 3 ” of

40 CFR Part 58.

Three complete years of ozone monitoring data are required to demonstrate attainment at a monitoring site. The eight

- hour primary and secondary ozone ambient air quality standards are met at an ambient air quality monitoring site when the three

- yea r average of the annual fourth

- highest daily maximum eight

- hour average ozone concentration s is less than or equal to 0.075 ppm. W hen this occurs, the site is said to be in attainment. Three significant digits must be carried in the computations.

Becaus e the third decimal digit, in ppm, is truncated, 0.075666* ppm is the largest concentration that is less than or equal to 0.075 ppm. Therefore, for the purposes of this request, values

below 0.0757 ppm meet the standard. These data handling procedures are applied on an individual basis at each monitor in the area. An area is in compliance with the eight

- hour ozone NAAQS if, and only if, every monitoring site in the area meets
the NAAQS. A n individual site's three

- year average of the annual fourth highest daily maximum eight

- hour average ozone concentration s is also c alled the site's design value.

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

- 2015 that were retrieved from the U.S. EPA AQS. The air quality design value for the area is the highest design value among all sites in the area. Please note that the standard is measured in ppm while the commonly used unit is ppb. For the remainder of this document, ppb will be used.13 D emonstration

Table 1 – Certified Monitoring Data for the C olumbus

, OH a rea for 2012 – 2014 and 2013 – 2015

Data source: U. S. EPA Air Quality System (AQS) http://www.epa.gov/aqs

SITE ID COUNTY YEAR %OBS 1 st 2 nd 3 rd 4 th 2012

- 2014 2013

- 2015

8

- HR 8

- HR 8

- HR 8

- HR AVE R. AV ER

. 39

- 0 41

-

0002 Delaware 2012 99 99 81 78 77

71 68 39

- 0 41

-

000 2 Delaware 2013 98 74 73 71 70

39

- 0 41

-

000 2 Delaware 2014 100 72 71 67 66

39

- 0 41

-

000 2 Delaware 2015 100 73 70 69 68

39

- 0 49

-

00 29 Franklin 2012 99 106 86 84 82

75 71 39

- 0 49

-

00 29 Franklin 2013 100 77 76 73 73

39

- 0 49

-

00 29 Franklin 2014 100 75 73 71 70

39

- 0 49

-

00 29 Franklin 2015 100 74 74 73 71

39

- 0 49

-

0037 Franklin 2012 98 102 85 82 81

73 67 39

- 0 49

-

0037 Franklin 2013 100 80 72 71 70

39

- 0 49

-

0037 Franklin 2014 100 75 75 70 69

39

- 0 49

-

0037 Franklin 2015 98 70 69 67 64

39

- 0 49

-

00 81 Franklin 2012 100 93 90 82 76

69 65 39

- 0 49

-

00 81 Franklin 2013 100 80 72 71 70

39

- 0 49

-

00 81 Franklin 2014 100 75 75 70 69

39

- 0 49

-

00 81 Franklin 2015 99 72 67 65 63

39

- 0 83

-

0 002 Knox 2012 100 98 75 74 74

69 68 39

- 0 83

-

0 002 Knox 2013 100 73 71 70 67

39

- 0 83

-

0 002 Knox 2014 100 69 68 67 66

39

- 0 83

-

0 002 Knox 2015 98 76 75 72 7114 SITE ID COUNTY YEAR %OBS 1 st 2 nd 3 rd 4 th 2012

- 2014 2013

- 2015

8

- HR 8

- HR 8

- HR 8

- HR AVE R. AVER

. 39

- 0 89

-

000 5 Licking 2012 99 105 90 83 77

69 66 39

- 0 89

-

000 5 Licking 2013 100 72 67 66 65

39

- 0 89

-

000 5 Licking 2014 100 70 68 66 66

39

- 0 89

-

000 5 Licking 2015 99 73 71 70 68

39

- 0 97

-

00 07 Madison 2012 100 95 81 81 78

71 68 39

- 0 97

-

00 07 Madison 2013 99 69 69 68 66

39

- 0 97

-

00 07 Madison 2014 95 73 73 71 69

39

- 0 97

-

00 07 Madison 2015 100 73 70 69 69

The area's design value s ha ve tr ended downward as emissions have

declined due to such factors as cleaner automobiles and fuels

, along

with co ntrols for electric generating units ( EGUs ), both regionally and locally.

Requirement 4 of 4

A commitmen t that once redesignated, the state will continue to operate an appropriate monitoring network to verify the maintenance of the attainment

status.

Demonstration

Ohio EPA commit s to continue monitoring ozone levels at the

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

EPA Region V prior to making changes to the existing monitoring network, should changes become necessary in the

fu ture. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of 40 CF R 58 and al l other federal requirements. Connection to a c entral station and updates to the Ohio EPA w eb site 4 will provide real time availability of the data and knowledge of any exceedances. Ohio

EPA will enter all data into AQS on a timely basis in accordance with federal guidelines.15 

### CHAPTER FOUR

EMISSION INVENTORY

CAA Section 107 (d)(3)(E)(iii) , & 1 07 (d)(3)(E)( v)

U.S. EPA ’s R edesignation G uidance r equires the submittal of a comprehensive inventory of ozone precursor emissions (VOC and NO
x ) 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 be tween the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions

. Other emission inventory related requirements include a pr ojection of the

emission invent ory to a year at least 10 years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain the ozone standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the 10

- year maintenance period.

The emissions inventory development and emissions projection discussion

below , with the exception of the mobile (on

- road) emissions inventory and projections, identifies procedures used Ohio EPA regarding emissions from

the counties in the C olumbus , OH area. Area, non

- road, on

- road and point source emissions were compiled as follows:

• Area, non

- road, and point source emissions (EGUs, non

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

on U.S. EPA’s Emissions M odeling Clearinghouse website 1

. 4 Using Ozone NAAQS Emissions Modeling platform (2011v6.1) data were collected together for the 2011 National Emissions Inventory (NEI) year

and the 2018 and 2025 U .S. EPA

- projected inventories. Therefore, 2011 point emissi ons are actual reported emissions from the 2011 NEI.

• Because the 2014 NEI is not available at this time, Ohio EPA derived 2014 actual point emissions (for EGUs and non

- EGUs) from state inventory databases (e.g., Ohio’s EIS database which serves as the

basi s for the 2014 NEI).

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

the Ozone NAAQS Emissions Modeling platform (2011v6.1) are annual totals, tons per summer day were derived according to the U.S. EPA guidance document Temporal Allocation of Annual Emissions Using EMCH Temporal Profiles , dated April 29, 2002 5

, using the temporal allocation references accompanying the 2011v6.1 modeling inventory

files. These files provide SCC specific profiles that allow annual emission totals to be distributed across various temporal periods, as described in the guidance document referenced here.

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

5 https://www3.epa.gov/ttn/chief/emch/temporal/index.html16 • Using the above datasets:

o 2014 emissions for area, non

- road and AIR point were derived by interpolat ing between 2011 and 2018 . Note that Ohio EPA

does not require airport related emissions to be reported and therefore actual 2014 airport emissions will not be available until the 2014 NEI is available. If those emissions differ appreciably from the emissions projected using this methodology, Ohio EPA

will co mmit to submitting a revised redesignation request and maintenance plan.

o 2020 emissions for area, non

- road and point (EGU, non

- EGU and AIR) were derived by interpolating between 2018 and 2025

.

o 2030 emissions for area, non

- road and point (EGU, non

- EGU

and A IR) were derived using the TREND function in Microsoft Excel. If the TREND function resulted in a negative value, the emissions were assumed to not change.

o Mobile source emissions for all years were developed in conjunction with the Ohio EPA

, Ohio Department of Transportation (O hio DOT) , the Mid

- Ohio Regional Planning Commission (MORPC) and t he Licking County Area Transportation (LCAT)and were calculated from emission factors produced by U.S. EPA’s 201 0 Motor Vehicle Emission Simulator (MOVES) software p rogram and data extracted from the region’s

travel

- demand model. A ppendix C contains detailed methodology and data for mobile source emissions for all years.

o Biogenic emissions are not included in these summaries.

Requirement 1 of 5 A comprehensive emission inventory of the precursors of ozone completed for the base year.

Background The point source data are taken from Ohio's annua l emissions reporting program.

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

- ro ad, and point sources
- are prepared every three years.

Demonstration

The 2011 inventory is used as the nonattainment base year for the purpose of this submittal 3

. The 2014 inventory is used as the

3 On July 18, 2014, Ohio EPA submitted its 2008 base year inventory as required under CAA Section 182(a)(1). Ohio EPA is not requesting that inventory be replaced with the17 attainment year inventory for the purposes of comparison. These inventories represent a comprehensive, accurate, and current inventory of actual emissions from all sources of the relevant pollutants in the C olumbus , OH area. Emissions of VOC and

NOx for 2011 and 2014 are identified under Requirement Three

of th is Chapter.

Requirement 2 of 5 A projection of the emission inventory to a year at least 10 years following redesignation.

Background As discussed above, Ohio EPA prepare d a projected emissions inventory for the C olumbus , OH area including area, non

- ro ad, mobile, AIR

, and point sources for precursors of ozone ( VOCs

and NO
x ) for the nonattainment area.

Demonstration In consultation with U.S. EPA and other stakeholders, Ohio EPA selected the year 2030 as the maintenance year for this redesignation req uest. The request also contains projected

emission inventories for 2020.

On

- Road Mobile Emission Estimations

Table s 2 through 8 contain the results of the emissions anal ysis for the appropriate years. A ll emissions estimations are expressed in tons pe r summer day (TSD).

2011 inventory in this submittal in Ohio’s SIP.18 Table 2 - Delaware County

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 7.14 5.00 3.44 3.26
NOx (TSD) 16.26 11.76 7.79 7.15
VMT (miles/day) 5,319,374 5,572,557 6,397,392 7,406,913

Table 3 - Fairfield County

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 4.82 3.12 2.13 1.84 NOx (TSD) 9.54 7.19 4.73 4.08
VMT (miles/day) 3,605,152 3,823,424 4,241,491 4,817,409

Table 4 - Franklin County

, Ohio Emi ssion Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 70.65 50.81 32.30 27.90 NOx (TSD) 134.04 98.88 60.59 50.99
VMT (miles/day) 32,736,416 34,012,659 36,352,326 38,800,608

Table 5 - Knox County

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 1.36 1.02 0.71 0.64
NOx (TSD) 2.90 2.18 1.46 1.33
VMT (miles/day) 1,211,135 1,228,842 1,246,184 1,282,084

Table 6 – Licking County

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30
VOC (TSD) 8.03 6.00 4.02 3.56

NOx (TSD) 17.45 13.33 8.57 7.41

VMT (miles/day) 5,332,810 5,704,951 6,303,093 7,014,436

Table 7 – Madison County , Ohio Emission Estimations for On

Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 2.83 2. 11 1.45 1.33 NOx (TSD) 7.09 5.31 3.42 3.07

VMT (miles/day) 3,109,996 3,274,563 3,552,950 4,034,00319 Table 8 - Emission Estimation Totals for On

- Road Mobile

Sources for the C olumbus

- OH A rea

20 11 20 14 20 20 20 30 VOC (TSD) 94. 83 68.06 44.05 38.53
NOx (TSD) 187.28 138.65 86.56 74.03
VMT (miles/day) 51,314,883 53,616,996 58,093,436 63,355,453

Motor Vehicle Emission Budget

Table 9 contain s the motor vehicle emissions budget s for the

C olumbus , OH area

.

Table 9 - Mobile Vehicl e Emission s Budget for Columbus, OH

2020

Estimated

Emissions 20 20

Mobile Safety Margin

Allocation* 2020

Total

Mobile Budget 2030

Estimated

Emissions 20 30

Mobile Safety Margin

Allocation* 2030

Total

Mobile Budget

VOC (TSD) 44.05 6.61 50.66 38.53 5.78 44.31

NOx (TSD) 86.56 12.98 99.54 74.03 11.10 85.13

VMT (miles/day) 58,093,436
- - 63,355,453
- - *The 15 per cent margin of safety was calculated by taking 15 percent of the mobile source emission estimates.

Th e above budget s for the Columbus, OH area i nclude the

emission estimates calculated for 2020 and 20 30 (from Table 8)

with an additional 15 percent margin of safety allocated to those

estimates

.

In an effort to accommodate future variations in travel demand

models and VMT forecast when no change to the network is planned, Ohio EPA consulted with U .S

. EPA to determine a reasonable approach to address this variation. Based on this discussion, a 15 percent margin of safety allocation was agreed

upon and has been added t o the emissions estimates for the Columbus, OH nonattainment area.

The emission estimates are derived from the travel demand

model and MOVES2010 as described above

. All methodologies, the latest planning assumptions

, and the safety margins allocations were determined through the inte ragency consultation process described in the Transportation Conformity Memorandum of Understanding (MOU) among MORPC,

LCATS , Ohio DOT, and Ohio EPA.20 A 15 percent margin of safety is appropriate because : 1) there is an acknowledged potential variation in VMT forecast and potential estimated mobile source emissions due to expected modifications to TDM and mobile emissions models; and 2) t he

total decrease in emissions from all sources is sufficient to

accommodate this 15 percent allocation of safety margin to mobile sources while still continuing to maintain the total

emissions in the C olumbus

, OH area well below the 20 14

attainment level of emissions.

The 15 percent margin of safety was calculated by taking 15 percent of the mobile source emission esti mates. S afety margin, as defined by the conformity rule, looks at the total

emissions from all sources in the nonattainment area. T he

actual allocation is less than 15 percent of the total emission

reduction from all sources as can be seen from Table 24

.

In summary, f or all three s tates combined, t he mobile budget safety margin allocation translates into :

- An a llocation of 6.61 TSD for VOC and 12.98 TSD for

NOx for 20 20 ; and

-A n allocation of 5.78 TSD for VOC and 11.10 TSD for

NOx for 20 30

.

When comp ared to the overall safety margin, as defined in 40

CFR 93.101 4

, discussed under “Requirement 3 of 5” below, it is evident this allocation is significantly below the total safety margin for this area (see Table 24)

.

The current eight

- hour budgets will no longer be appl icable either after the effective date of the approved redesignation or after the effective date of any U.S. EPA action approving a finding that the new eight

- hour conformity budget included in this submittal is adequate for transportation co nformity purposes

, whichever date comes first.

4 "safety margin" means the amount by which the total projected emissions from all sources of a given pollutant are less than the total emissions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance.21 Requirement 3 of 5 A demonstration that the projected level of emissions is sufficient to maintain

the ozone standard.

Background

Maintenance is demonstrated when the future

- year (2030) projected emiss ion totals are below the 2014 attainment year

totals.

Sectors included in the following tables are: Electrical Generating Unit (EGU) ; Non

- Electrical Generating Unit (Non

- EGU) ; Airport ( AIR ); Non

- road Mobile (Non

- road) ; Other

- Area ( Area ); and On

- road Mo bile (On

- road).

Demonstration

NO x

Table 10 – Delaware County , Ohio NO x Emission Inventory Totals ( TSD )

Sector 2011

Base 2014

Attainment 2020

Interim 2030

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.08 0.07 0.08 0.07

AIR 0.01 0 .01 0.01 0.01

Non

- road 4.39 3.45 2.16 0.97

Area 2.82 2.67 2.35 1.79

On

- road 16.26 11.76 7.79 7.15

TOTAL 23.56 17.96 12.39 9.99 7.97

Table 11 – Fairfield County, Ohio NO x Emission Inventory Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 30

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 4.52 3.99 4.39 5.64

A IR 0.00 0.00 0.00 0.00

Non

- road 2.79 2.20 1.38 0.60

Area 0.75 0.76 0.76 0.76

On

- road 9.54 7.19 4.73 4.08

TOTAL 17.60 14.14 11.26 11.08 3.0622 T able 1 2 – Franklin County, Ohio NOx Emission Inventory Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 30

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 2.65 1.36 2.44 2.27

A IR 1.48 1.59 1.85 2.36

Non

- road 16.12 12.49 7.7 3 3.96

Area 8.76 8.58 8.20 7.50

On

- road 134.04 98.88 60.59 50.99

TOTAL 163.05 122.90 80.81 67.08 55.82

T able 13 - Knox County, Ohio NO x Emission Inventory Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.08 0.12 0.08 0.09

A IR 0.00 0.00 0.00 0.00

Non

- road 1.36 1.11 0.73 0.33

Area 0.50 0.51 0.52 0.53

On

- road 2.90 2.18 1.46 1.33

TOTAL 4.84 3.92 2.79 2.28 1.64

Table 14 - Licking County, Ohio NO x Emission Inventory Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 1.30 0.93 1.31 1.33

A IR 0.00 0.00 0.00 0.00

Non

- road 2.57 2.05 1.31 0.62

Area 0.98 1.00 1.02 1.04

On

- road 1 7.45 13.33 8.57 7.41

TOTAL 22.30 17.31 12.21 10.40 6.91

Table 15 - Madison County , Ohio NO x Emission Inventory ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.01 0.01 0.01 0.0 1

A IR 0.00 0.00 0.00 0.00

Non

- road 1.66 1.38 0.94 0.41

Area 0.62 0.60 0.56 0.47

On

- road 7.09 5.31 3.42 3.07

TOTAL 9.38 7.30 4.93 3.96 3.3423 T able 16 – C olumbus, OH A rea NO x Emission Inventory Totals ( TSD )

NOx 20 11 Base 20 14

Attainment 20 20

I nterim 20 3 0

Maintenance Safety Margin

Delaware 23.56 17.96 12.39 9.99

Fairfield 17.60 14.14 11.26 11.08

Franklin 163.05 122.90 80.81 67.08

Knox 4.84 3.92 2.79 2.28
Licking 22.30 17.31 12.21 10.40

Madison 9.38 7.30 4.93 3.96

COMBINED NOx

TOTAL 240.73 183.53 124.39 104.79 78 .74

VOC

Table 17 - Delaware County , Ohio VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.34 0.36 0.32 0.32

A IR 0.01 0.01 0.01 0.01

Non

- road 3.31 2.86 2.33 2.09

Area 4.37 4.27 4.14 4.07

On

- road 7.14 5.00 3.44 3.26

TOTAL 15.17 12.50 10.24 9.75 2.75

Table 18 – Fairfield County , Ohio VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainm ent 20 20

Interim 20 3 0

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.49 0.42 0.48 0.55

A IR 0.01 0.01 0.01 0.01

Non

- road 1.25 1.08 0.93 0.94

Area 4.71 4.65 4.52 4.29

On

- road 4.82 3.12 2.13 1.84

TOTAL 11.28 9.28 8.07 7.63 1.6524 Table 19 - Franklin County, Ohio VOC Emission Inventory Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20 Interim 20 3 0

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 3.06 2.22 1.97 1.94

A IR 0.35 0.37 0.41 0.51

Non

- road 11.76 10. 28 8.97 9.53

Area 28.36 27.81 27.07 26.39

On

- road 70.65 50.81 32.30 27.90

TOTAL 114.18 91.49 70.72 66.27 25.22

Table 20 - Knox County, Ohio VOC Emission Inventory Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safet y Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.20 0.19 0.20 0.20

A IR 0.01 0.01 0.01 0.01

Non

- road 0.97 0.82 0.63 0.50

Area 3.42 3.39 3.34 3.23

On

- road 1.36 1.02 0.71 0.64

TOTAL 5.96 5.43 4.89 4.58 0.85

Table 21 – Licking County , Ohio VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.45 0.69 0.40 0.39

A IR 0.01 0.01 0.01 0.01

Non

- road 2.17 1.85 1.47 1.29

Area 6.65 6.57 6.39 6.05

On

- road 8.03 6.00 4.02 3.56

TOTAL 17.31 15.12 12.29 11.30 3.82

Table 22 - Madison County , Ohio VOC Emission Inventory Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.06 0.14 0.06 0.06

A IR 0.01 0.01 0.01 0.01

Non

- road 0.82 0.71 0.59 0.54

Area 2.50 2.46 2.38 2.24

On

- road 2.83 2.11 1.45 1.33

TOTAL 6.22 5.43 4.49 4.18 1.2525 Table 23 – C olumbus, OH Area VOC Emission Inventory Totals ( TSD )

VOC 20 11

Base 20 14

At tainment 20 20

Interim 20 3 0

Maintenance Safety Margin

Delaware 15.17 12.50 10.24 9.75

Fairfield 11.28 9.28 8.07 7.63

Franklin 114.18 91.49 70.72 66.27

Knox 5.96 5.43 4.89 4.58

Licking 17.31 15.12 12.29 11.30

Madison 6.22 5.43 4.49 4.18

CO MBINED VOC

TOTAL 170.12 139.25 110.70 103.71 35.54

VOC and NOx

Table 24 – C olumbus, OH A rea Comparison of 2014 attainment

year and projected emission estimates ( TSD )

2014 2020 2020 Projected

Decrease 20 30 20 3 0

Projected

Decrease

VOC 139.25 110 .70 28.55 103.71 35.54

NO x 183.53 124.39 59.14 104.79 78.74

As shown in the table above, VOC emissions in the

nonattainment area a r e projected to decrease by 28.55 TSD in

2020 and 35.54 TSD in 20 30

. In general, emissions for all sectors are projected to decline or remain stable

. Non

- EGU emissions for all counties are predicted to remain stable or slightly increase. Because Non

- EGU emissions in 2030 are based upon projecting 2011 emissions and in reality 2014 non

EGU emissions in most counties dropped more dramatically than expected, the projected decreases are not as apparent. Area emissions for Fairfield, Knox and Li cking County show slight increases, as do A IR emissions for Franklin County.

These increase s do not affect the overall reduction in VO C

emissions for the area and are likely contributed to slight changes in population projections

. C leaner vehicles and fuels are expected to be in place in 2018 and will cause an overall drop in VOC emissions.

NO
x emissions in the nonattainment area are p rojected to

d ecrease by 59.14 TSD in 20 20 and 78.74 TSD in 20 30

. In general, emissions for all sectors are projected to decline or

remain stable. There are slight emission increases in Fairfield

C ounty for non

- EGU, Franklin County for AIR and Licking

C oun ty for area emissions. However, the small increases in26 these categories do not affect the overall attainment of the Columbus area and the emission totals from all categories in the

nonattainment area show a decrease. Decreases from U.S.

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

Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 5 , Highway Heavy

- Duty Engine Rule 6

, and

the Non

- Road Diesel Engine Rule 7 are factored into the changes.

As identified in Table 9 above , an additional mobile budget margin of safety allocation is being requested for mobile emissions. The mobile budget margin of safety allocation

translates into an additional 6.61 TSD for VOC and 12.98 TSD for NOx in the year 20 20 and 5.78 TSD for VOC and 11.10 TSD

for NOx in the year 20 3 0. U.S. EPA’s conformity regulations

allow for allocation, through a revision to the SIP, of all or some portion of the overall area’s safety margin (emission reductions

from 2014 to 20 30) to the mobile emissions budgets for future conformity :

- In 20 20 : 6.61 TSD of the 28.55 TSD safety margin for

VOC and 12.98 TSD of the 59 .14 TSD safety margin for NOx as a mobile emissions budget safety margin.

- In 20 3 0: 5.78 TSD of the 35.54 TSD safety margin for

VOC and 11.10 TSD of the 78.74 TSD safety margin for NOx as a mobile emissions budget safety margin.

Requirement 4 of 5 A demonstration that improvement in air quality between the year violations

occurred and the year attainment was achieved is based on permanent and

enforcea ble 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 2012 through 2014

. U.S.

EPA ’s R edesignation G uidance (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

5 http://www.epa.gov/fedrg str/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.htm27 to show that the future mix of sources and emissions rates will
not cause a violation of the NAAQS.”

Demonstration

Permanent and enforceable reductions of VOC and N Ox

emissions have contributed to the attainment of the eight

- hour

ozone standard. S ome of these reduction s were due to the application of tighter federal standards on new vehicles and non

road diesel engines

.

With respect to EGUs, changes at a single facilit y have resulted

in reductions in NOx emissions potentially impacting the

nonattainment area

. The Picway Power Plant in Pickaway County officially and permanently shutdown in May of 2015. The

coal

- fired boiler did not operate in 2014. W hile not located in the nonattainment area, the Picway Power Plant is located approximately 1.25 kilometers from the sou thern border of Franklin County. Prior to the shutdown, NOx emissions had dropped from 0.57 TSD to 0.45 TSD (2011 to 201 3 ).

Reductions achieved are discussed in greater detail under Chapter Five.

Table 25 - C olumbus

, OH A rea Combined Comparison of 20 11 base year and 2014 attainment year non

- road, and on

road reductions

2011 2014

Non

- road NOx 28.89 22.68

Non

- road VOC 20.28 17.60

On

- road VOC 94.83 68.06

On

- road NO x 187.28 138.65

To further support Ohio’s demonstration that the improvement in air quality between the year violations occurred and the year attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology , a n analysis was performed b y Ohio EPA in order to demonstrate the improvement in air quality is not based on unusually favorable meteorology.28 Ohio EPA analyzed the maximum fourth

- high eight

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

2015. The values were analyzed against average monthly temperatures, the number of days with a temperature exceeding 80° F, and the average relative humidity. While the formation of tropospheric ozone is dependent on a l arge number of atmospheric variables, ozone formati on is strongly and positively correlated with elevated temperatures and humidity. The utilization of an extended period of record (2000

- 2015) should eliminate or dampen the influence of other meteorological variables affecting ozone formation, such as wind direction and wind speed.

Meteorological data for the Columbus, OH area was compiled from monthly local climatological data obtained from the National Oceanic and A tmospheric Administration’s National Climatic Data Center (NCDC). T he data was recorded at the meteorological station located at the Port Columbus International Airport, WBAN 14821. Ohio EPA has previously determined that data from this meteorological station is representative of meteorological conditions across the nonattainment area, and

u tilizes this same data for New Source Review and Prevention of Significant Deterioration air quality permit modeling applications. Monitor data was compiled from the U.S. EPA’s AQS database for the same period.

The first analysis compared the maximum eigh t- hour ozone concentration at each monitor in the Columbus, OH area to the number of days where the maximum temperature was g reater than or equal to 80° F. The results of this analysis are shown in Figure 2.29 Figure 2 – Maximum eight

- hour ozone con centrations versus number of days greater than or equal to 80° F for

Columbus Monitors

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

correlation between the numbers of days in which temperatures

were at or ex ceeded 80° F, this correlation is not 1 to 1. While there is clearly some degree of correlation when comparing one year to the next, the same is not observed when examining the monitor values and temperature data over the period of study. Secondly, a cle ar trend in decreasing ozone concentrations at all monitors is apparent, while no such trend is observed in the temperature data. Las tly, there is a c lear similarity in the recorded ozone values, which is consistent with the regional nature of ground

- leve l ozone formation.

To further examine the relationship between meteorological factors and oz one concentrations, Ohio EPA examined the relationship between average summer temperatures for each year of the 2000 to 2015 period and the 4 th maximum eight

- hour ozone concentration. Given the similarity of ozone concentrations observed at each monitor (see Figure 2) and the regional nature of ozone formation, Ohio EPA conducted this analysis using the average 4 th maximum eight

- hour ozone

concentration from all mo nitors in the Columbus, OH area. The results of this analysis are shown in Figure 3.30 Figure 3 – Average maximum 4 th high eight

- hour ozone concentrations versus average summer
temperatures

The data shown in Figure 3 indicates that while there is some correlation between average summer temperatures and ozone concentrations, this correlation does not exist over the study period. T he linear regression lines for each data set demonstrate that average summer temperatures have i ncreased over the 2000 t o 2015 per iod, while average ozone

concentrations have decreased. The correlation between temperature and ozone formation is well established; these data serve as strong evidence to suggest that reductions in precursors are responsible for the significant reductions in elevated ozone concentrations in the Columbus, OH area and not due to unusual or favorable summer temperatures.

Lastly, Ohio EPA analyzed the relationship between average summertime relative humidity and average 4 th maximum eight

hour ozone concentrations in the Columbus, OH area. As with the data shown in Figure 3, Ohio EPA considered the overall trend in ozone monitors by analyzing the average of 4 th

maximum eight

- hour concentrations across all monitors in the

ar ea. These data are shown in Figure 4.31 Figure 4 – Average maximum 4 th high eight

- hour ozone concentrations versus average summer relative humidity

The data presented in Figure 4 do not indicate a correlation between relative humidity and ozone concentrations, and the period of study represents a s ignificant spread of average summertime relative humidity.

The analyses of meteorological variables associated with ozone formation above further support Ohio’s demonstration t hat the improvement in air quality between the year violations occurred

and the year attainment was achieved is based on permanent

and enforceable emission reductions and not on unusually favorable meteorology. T he extended study period should dampen the effects of minor variations in wind directions and wind speeds, and provides a sufficient basis to examine long

term trends in both the meteorological variables and the regional ozone concentrations in the Columbus, OH area.

Requirement 5 of 5

Provi sions for future annual updates of the inventory to enable tracking of the

emission levels

, including an annual emission statement from major sources.

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

submit air emissions informat ion annually, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR).32 Ohio EPA prepares a new periodic inventory for all ozone precursor emission sectors every three years. These ozone precursor inventories will be pr epared for future years as necessary to comply with the inventory reporting req uirements

established in the CFR

. Emissions information will be compared

to the 2011 base year and the 20 30 projected maintenance year inventories to assess emission trends, as necessary, and t o assure continued compliance with the ozone standard.33 

### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4 Section 182(a)(3)(B) requires states to submit emissions statements.

Background Section 182(a)(3)(B) requires states to submit emissions statements within two years of the enactment of the Clean Air Act Amendments and then every three years thereafter.

Demonstration

Ohio EPA submitted its emissions statement SIP on March 18, 1994 which was approved by U.S. EPA on October 13, 1995 (59 FR 51863). In addition, on July 18, 2014, Ohio EPA submitted a

SIP revision for this area and U.S. EPA published a proposal and direct final action approving that submittal on March 10,

2016 ( 81 FR 12626 and 81 F R 12591). The approval was effective May 9, 2016

. As discussed in Chapter Four ( Requirement 4), Ohio EPA submits, and commits to submit, emission inventories (statements) every three years.

Requirement 2 of 4 Evidence that control measures required in past ozone SIP revisions have been fully implemented.

Background

O n October 27, 1998, U.S. EPA promulgated the NO
x S IP Call requiring 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and

cement kilns in the eastern United States. Ohio promulgated this

rule in 2001. NOx SIP Call requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff. Compliance is tracked through the Clean Air Markets data monitoring program. Be ginning in 2004, this

rule account s for a reduction of approx imately 31 percent of all

NO
x emissions state wide compared to previous uncontrolled

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

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

the NOx SIP Call with CAIR and CSAPR. CSAPR continue s to34 be implemented and amounts to even further reductions than

that realized under the NOx SIP Call.

D emonstration

NOx SIP Call

Controls for EGUs under the NOx SIP Call formally commenced May 31, 2004. E missions covered by this program have been generally trending downward since 1998 with larger reductions occurring in 2002 and 2003. D ata taken from the U.S. EPA

Clean Air Markets w eb site, quantif y the gradual NO
x reductions

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

CAA Amendments and the beginnin g of the NO
x SIP Call Rule. Ohio developed the NO
x Budget Trading Program rules in OAC Chapter 3745

- 14 8 in response to the SIP Call. OAC Chapter

3745

- 14 regulates EGUs and certain non

- EGUs under a cap and trade program based on an 85 per cent reduction of NOx emissions from EGUs and a 60 per cent reduction of NO
x emissions from non

- EGUs, compared to historical levels. This cap stayed in place through 2008, at which time the CAIR program supersede d it as discussed above

.

On April 21, 2004, U.S. EPA publis hed Phase II of the NO x SIP Call that establishes a budget for large (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio

EPA’s OAC rule 3745

- 14

- 12 addresses stationary internal combustion engines, all used in natural gas pip eline transmissions. U.S. EPA approved this revision to the SIP on April 4, 2008. An 82 percent NO x reduction from 1995 levels is anticipated. Completion of the compliance plan occurred by May 1, 2006

, and the compliance demonstration began May 1, 2007.

Th e 2007 controlled NO x emissions are 599 tons statewide for

the ozone season

.

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

commenced and em issions covered by this program have

continued trending downward. While there are no EGUs in this

nonat tainment area, reductions elsewhere in Ohio and i n neighboring states contribute to declining ozone levels in this

area . CAIR’s cap and trade program stayed in place through 2014, at which time the CSAPR program superseded it.

8 http://www.epa.state.oh.us/dapc/regs/3745

- 14/3745_14.html35 VOC RACT

The C olumbus a rea was required to adopt RACT for the following source categories under Section 182(b)(2) for the one

hour standard : (a) all VOC sources covered by Control Technique Guidelines (C TGs) issued between November 15,

1990 and the date the C olumbus area attained the one

- hour ozone standard; (b) all VOC sources covered by a CTG issued prior to November 15, 1990; and (c) all other major non

- CTG stationary sources in the C olumbus area.

U.S. EPA approved Ohio EPA’s V OC RACT rules on September 7, 1994 (59 FR 46182 ) , October 23, 1995 (60 FR 54308), April 25, 1996 (61 FR 18255), and June 21, 2005 (70 FR 35946 )

.

RACT rules have been applied to all new sources locating in Ohio since that time. RACT requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff. The Ohio RACT rules are found in OAC Chapter 3745

- 21 9

.

Gasoline Vapor Recovery S ystems

Section 182(b)(3) requires states to submit Stage II vapor recovery rules no later than November 15, 1992. The U.S. EPA partially approved and partially disapproved Ohio's SIP revision for implementation of Stage II on O ctober, 20, 1994 ( 59 FR

5291 1). As stated in that rulemaking action, with the exception of paragraph 3745

- 21

- 09 (DDD)(5), U.S. EPA considers Ohio's Stage II program to fully satisfy the criteria set forth in the September 17, 1993, U.S. EPA guidance document for such programs entitled "Enforcement Guidance for Stage II Vehicle Refueling Control Programs." Furthermore, the September 17, 1993, guidance memorandum states that once onboard vapor recovery regulations are promulgated, the Stage II regulations are no l onger applicable for mo derate ozone nonattainment areas. The U.S. EPA promulgated onboard vapor recovery rules in February 1994. Therefore, pursuant to Section 202(a)(6) of the CAA, Stage II would no longer be required. However, some areas, including Ohio, retained Stage II re quirements to provide a control method to comply with rate

- of

- progress emission reduction targets. Congress recognized that onboard refueling

9 http://www.epa.state.oh.us/dapc/regs/3745

- 21/3745_21.html36 vapor recovery and S tage II would eventually become

redundant , and actually increase emissions, and provided the

U .S. EPA authority to allow states to remove Stage II from their SIPs after U.S. EPA finds that onboard refueling vapor recovery is in widespread use. On May 16, 2012, the U.S. EPA determined that onboard refueling vapor recovery technology is in widespread use throughout the motor vehicle fleet for purposes of controlling motor vehicle refueling emissions. This action (77 FR 28772) also provided notice of an upcoming guidance document for states to use to prepare a SIP revision to remove or phase

- out Stage II controls. U.S. EPA published this guidance on August 7, 2012 ( EPA

- 457/B

- 12

- 001). The guidance noted that since Section 182(b)(3) requirements no longer applied, the only requirements for Stage II controls are

state SIPs (which includes Ohio, as noted above ) , Section 184(b)(2) for areas in the ozone transport region (does not apply to Ohio)

, and section 193 for any area that adopted Stage II controls prior to November 15, 1990 (does not apply to Ohio). In order to remove Stage II control requirements from the SIP, CAA Section 110(l) is required to be addressed. Ohio EPA

conducted this demonstration a nd submitted the SIP revision request to U.S. EPA on July 15, 2015

. This demonstration included a new requirement for the use of low permeation hoses

wh ich will provide even greater VOC emissions reductions in the

future.

Tier II Emission Standards for Vehicles and G asoline Sulfur

Standards

In February 2000

, U.S. EPA finalized a f ederal rule to significantly reduce emissions from cars and l ight trucks, including sport utility vehicles (SUVs). U nder 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. T he federal rules w ere phase d in

b etween 2004 and 2009. U.S. EPA has estimated that NO
x emission reductions were approxima tely 77 per cent for

passenge r cars, 86 percent for smaller SUVs, light truc ks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans,

and heavier trucks. VOC emission reductions were

ap proximately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and min ivans, and 15 per cent for larger SUVs, vans, and heavier trucks.37 Tier III Emission Standards for Vehicles and Gasoline Sulfur

Standards

In March 2014, U.S. EPA finalized a f ederal rule to further strengthen Tier II vehicle emission and fuel standards. This rule will require automakers to produce cleaner vehicles and

refineries to make cleaner, lower sulfur gasoline. This rule wi ll be phased in between 2017 and 2025. Tier III requires all passenger vehicles to meet an av erage standard of 0.03 gram/mile of NOx. Compared to Tier II, the Tier III tailpipe standards for light

- duty vehicles are expected to reduce NOx

and VOC emissions by approximately 80%. Tier III vehicle

standards also include evaporative standards using onboard diagnostics that will result in a 50% reduction in VOC emissions compared to Tier II reductions. The rule reduces the sulfur content of gasoline to 10 ppm, beginning in January 2017.

Heavy

- Duty Diesel Engines

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

- sulfur diesel fuel standards, which was phased in from 2004 through 2007. This rule applies to hea vy

- duty gasoline and diesel trucks and buses.

This rule resulted in a 40 percent reduction in NO
x from diesel trucks and bus es, a l arge sector of the mobile sources NO
x 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 m ining. I t also contains a cleaner fuel standard similar to the highway diesel program. The

new standards cut emissions from non

- road di esel engines by more than 90 percent . Non

- road diesel equipment, as described in this rule, accounted for 47 percent of diesel particulate matter (PM) and 25 percent of NO
x from mobile sources nationwide.

Sulfur levels were reduced in non

- road diesel fue l by 99 percent

from previous levels, from appr oximately 3,000 parts per million (ppm ) to 15 ppm in 2009. New engine standards took effect, based on engine horsepower, starting in 2008.38 Non

- road Spark

- Ignition Engines and R ecreational Engine

Standards

Effective in January 2003, this standard regulates NOx, VOCs, and carbon monoxide (CO) for groups of previously unregulated

non

- road engines. This standard applies to all new engines sold in the United States and imported after the standards went into

eff ect. The standard applies to large spark

- ignition engines (forklifts and ai rport ground service equipment), recreational vehicles (off

- highway motorcycles and all

- terrain vehicles), and recreational marine diesel engines. When all of the non

- road spark

- ign ition engines and recreational engine standards are fully implemented, an ov erall 80% reduction in NOx, 72% reduction in VOC, and 56% reduction in CO emissions are expected by 2020.

Reciprocating Internal Combustion Engine Standards

This new standard, ef fective in May 2010, regulates emissions of air toxics from existing diesel powered stationary reciprocating internal combustion engines that meet specific site rating, age, and size criteria. These engines are typically used at industrial facilities (e.g. power, chemical, and m anufacturing plants) to generate electricity for compressors and pumps and to produce electricity to pump water for flood and f ire control during emergencies.

The standard applies to stationary diesel engines: (1) that are located at a major source of air toxics emissions and that were installed prior to June 12, 2006; (2) used at major sources of air toxics, having a s ite rating of less than or equal to 500 horsepower and were constructed or reconstructed before June 12, 2006; and ( 3) used at major sources of air toxics for nonemergency purposes, having a site rating of greater than 500 horsepower and were constructed or reconstructed before December 19, 2002.

Operators of existing engines were required to: (1) install emission control equipment that would limit air toxics up to 70% for stationary non

- emergency engines with a site rating greater than 300 horsepower; (2) perform emission tests to demonstrate engine performance and compliance with rule requirements; and (3) burn ultra

- low sulfur fuel in stationary non

- emergency engines with a site rating greater than 300 horsepower.39 The engine standards took effect in 2013. According to U.S. EPA estimates, this rule has resulted in emission reductions from existing diesel

- powered stationary reciprocating internal combustion engines of approximately 1,000, 2,800, and 27,000 tpy of air toxics, fine particles (PM2.5), and CO, respectively.

Category 3 Marine Diesel Engine Standards

This new standard, effective in June 2010, promulgated m ore stringent exhaust emission standards for new large marine diesel engines with per

- cylinder displacement at or above 30 liters (commonly referred to as Category 3 compression

- ignition marine engines) as part of a coordinated strategy to address

emission s from all ships that affect U.S. air quality. These emission standards are equivalent to those adopted in the

amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL Annex VI). The emission standards apply in two stages: near

- term standards, for newly built engines, which took effect in 2011 and l ong

- term standards requiring an 80% reduction in NOx emissions that will begin in 2016.

U.S. EPA is adopting changes to the diesel fuel program to allow for the p roduction and sale of diesel fuel with up to 1,000 ppm sulfur for use in Category 3 m arine vessels. The regulations generally forbid production and s ale of fuels with more than 1,000 ppm sulfur for use in most U.S. waters unless operators achieve equivalent emission reductions in other ways.

U.S. EPA is also adopting provisions to apply some emission and fuel standards to foreign flagged and in

- use vessels that are covered by MARPOL Annex VI. When this strategy is fully implemented in 2030, U.S. EPA estimates that NOx and PM2.5 emissions in the U.S. will be r educed by approximately 1.2 million tpy and 143,000 tpy, respectively.

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

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

“Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (CAIR); Revisions to Acid Rain Program; Revisions to the NOx SIP Call; Final Rule.” This rule established the requirement for states to adopt rules limiting the emissions of

NOx and SO2 and provided a model rule for the states to use in40 developing their rules in order to meet federal requirements. The purpose of CAIR was to reduce interstate transport of PM2.5, SO2, and ozone precursors (NOx).

CAIR applied to any stationary, fos sil fuel

- fired boiler or stationary, fossil fuel

- fired combustion turbine, or a generator with a nameplate capacity of more than 25 megawatt electrical (MWe) producing electricity for sale. This rule provided annual state caps for NOx and SO2 in two phases , with Phase I caps for NOx and SO2 taking effect in 2009 and 2010, respectively.

Phase II caps were to become effective in 2015. U.S. EPA allowed limits to be met through a cap and trade program if a state chose to participate in the program. SO2 emission s from power plants in the 28 eastern states, as well as Washington D.C subject to CAIR were to be cut by 4.3 million tons from 2003 levels by 2010 and 5.4 million tons from 2003 levels by 2015.

NOx emissions were to be cut by 1.7 million tons by 2009 and reduced by an additional 1.3 million tons by 2015. In response to U.S. EPA’s rulemaking, Ohio submitted a CAIR SIP which was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised

CAIR SIP wa s approved as a direct final action on September 25, 2009 ( 74 FR 48857). Ohio’ s rule included annual and seasonal NOx trading programs, and an annual SO2 trading program. This rule required compliance effective January 1,

2009.

In July 2008, the D.C. Circuit court vacated CAIR and issued a subsequent remand without vacatur of CAIR in December 2008. The court then directed U.S. EPA to revise or replace CAIR in order to address the deficiencies identified by the court. On July 6, 2011, U.S. EPA finalized CS APR as a replacement for CAIR. On August 21, 2012, the U.S. Court of Appeals for the D.C.

Circuit vacated CSAPR and di rected U.S. EPA to continue administering CAIR “pending the promulgation of a valid replacement.” In a subsequent decision on the merits, the Court vacated CSAPR based on a subset of petitioners’ claims, but on April 29, 2014, the U.S. Supreme Court reversed that decision

and remanded the case to the D.C. Circuit court for further proceedings. Throughout the initial round of D.C. Circuit

pro ceedings and the ensuing U.S. Supreme Court proceedings, the stay remained in place and U .S. EPA has continued to implement CAIR. In order to allow CSAPR to replace CAIR in an equitable and orderly manner while further D.C. Circuit Court proceedings were h eld to resolve petitioner’s remaining claims, U.S. EPA filed a motion asking the D.C. Circuit Court to lift the41 stay. U.S EPA also asked the court to toll all CSAPR compliance deadlines that had not passed as of the date of the stay order by three years. On October 23, 2014, the Court granted the U.S.

EPA’s motion. CSAPR became effective on January 1, 2015, for SO2 and annual NOx, and May 1, 2015 for ozone season NOx. Combined with other final state and U.S. EPA actions, CSAPR will reduce power plant SO2 em issions by 73% and N Ox emissions by 54% from 2005 levels in the CSAPR region

.

Oil and Natural Gas Industry Standards

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

air toxic emissions from hydraulically fractured natural gas wells

and als o includes requirements for several other sources of pollution in the oil and natural gas industry that were previously unregulated in the United States. U.S. EPA estimates that these standards will apply to approximately 11,400 new natural gas wells hydraulically fractured each year and an additional 1,400 existing natural gas wells refractured annually. When these standards are fully implemented in 2015, U.S. EPA estimates that VOC and air toxic emissions in the U.S. will be reduced by approximately 190,000 to 290,000 tpy and 12,000 to 20,000 tpy, respectively.

Mercury and Air Toxic Standards

This new standard, effective in April 2012, regulates emissions of mercury, acid gases, and non

- mercury metallic toxic pollutants from new and existing coal and oil

- fired EGUs. U.S.

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

coal

- fired and 300 oil

- fired EGUs at 600 power plants in the U.S. According to U.S. EPA, most facilities will comply with these standards through a range of strategies, including the use of existing emission controls, upgrades to existing emission controls, installation of new pollution controls, and fuel switching.

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

for reconsideration of various provisions of the rule, including requests to reconsider the work practice standards applicable during startup periods and shutdown periods. U.S. EPA granted reconsideration of the startup and shutdown provisions as no opportunity to comment was provided to the public rega rding the work practice requirements contained in the final rule. On November 30, 2012, U.S. EPA published a pr oposed rule reconsidering certain new source standards and s tartup and shutdown provisions in MATS. U.S. EPA proposed certain minor42 changes to th e startup and shutdown provisions contained in the

2012 final rule based on information obtained in the petitions for reconsideration. On April 24, 2013, U.S. EPA took final action on

the new source standards that were reconsidered and also the

technical c orrections contained in the November 30, 2012, proposed action. U.S. EPA did not take final action on the startup and shutdown provisions and, on June 25, 2013, added new information and analysis to the docket and reopened the public comment period for the proposed revisions. U.S. EPA

took final action on the remaining topics open for reconsideration on November 19, 2014. The compliance date for existing sources was April 16, 2015, while the compliance date for new

sources was April 16, 2012.

On November 2 5, 2014, the U.S. Supreme Court accepted several challenges to the rules brought by the utility industry and a coalition of nearly two dozen states. On June 29, 2015, the

U.S. Supreme Court ruled that U.S. EPA did not properly account for compliance costs when crafting the MATS rule and

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

reconsideration.

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

ozone precursors.

Requirement 3 of 4 Acceptable provisions to provide for new source review.

Background Ohio has a longstanding and f ully implemented New Source Review (NSR) program. T his is addressed in OAC Chapter

3745

- 31 10 . The C hapter includes provisions for the Prevention of Significant Deterioration (PSD) permitting pro gram in OAC

rules 3745

- 31

- 01 to 3745

- 31

- 20. Ohio's PSD program was

conditi onally 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 2008 11 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or

10 http://www.epa.state.oh.us/dapc/regs/3745

- 31/3745_31.html

11 On July 18, 2014, Ohio EPA submitted its 2008 base year inventory as required under CAA Section 182(a)(1).43 reconstruct without meeting all applicable NSR requirement s

. On ce the area is redesignated, Ohio EPA will implement NSR through the PSD program

.

Requirement 4 of 4

Assure that all existing control measures will remain in effect after redesignation unless the State demonstrates through photochemical modeling

that the standard can be maint ained without one (1) or more control measure s.

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

NO
x sources, as required for maintenance of the ozone standard

in the C olumbus area , will be submitted to U.S. EPA for approval

as a SIP revision.

Ohio, through Ohio EPA’s Legal section and the Ohio Attorney General’s Office, has the legal authority and necessary

re sources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in the

C olumbus area.44 

### CHAPTER SIX

CONTINGENCY MEASURES

CAA Sectio n 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 p lan 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 vio lations of the ambient standard occur.

Demons tration Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response:

A warning level r esponse shall be prompted whenever an annual (1

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

ozone season within the maintenance area. A warning level

r esponse will consist of a study to determine whether the ozone value indicates a trend toward higher ozone values or whether emissions appear to be i ncreasing. T he study w ill 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 t iming for implementation as well as economic and s ocial considerations. Implementation of

nece s sary controls in response to a w arning level r esponse trigger will take place as expeditiously as possible, but in no

event later than 12 months from the conclusion of the most recent ozone season ( October 31 ).

Shoul d it be determined through the warn ing l evel study that action is necessary to reverse the noted trend, the procedures for control selection and implementation outlined under “ action

l evel response ” shall be followed.45 Action Level Response :

An a ction l evel r esponse shall be prompted whenever a two

- year average fourth high monitored value of 76 ppb or greater occurs within the maintenance area. A violation of the standard (three

year average fourth high value of 85 ppb or greater) shall also prompt an action level response. In the event that the a ction

l evel is triggered and is not found to be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropolitan planning organization or regional council of governments, will

determine additional control measures needed to assure future

attainment of the NAAQS for ozone. In this case, measures that can be implemented in a short time will be selected in order to be in place within 18 months from the close of the ozone season that prompted the a ction l evel. Ohio EPA will also consider the timing of an a ction l evel t rigger and determine if additional, significant new regulations not currently included as part of the maintenance provisions will be implemented in a timely manner and will constitute our response

.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking.

If a new measure/control is already promulgated and scheduled to be i mplemented at the federal or S tate level, and t hat

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.46 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 bas ed on cost

- effectiveness, emission reduction potential, economic and social considerations or other

factors t hat Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to selecting app ropriate contingency

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

what control measure s will be appropriate at an unspecified time in the future, the list of contingency measures outlined be low is

not exhaustive

.

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

EPA Control Technique Guidelines issued after the 1990

CAA

.

2) Apply VOC RA CT to smaller existing sources.

3) One or more transportation control measures sufficient to

achieve at le ast half a percent reduction in actual area wide VOC emissions. Transportation measures will be selected from the following, based upon the factors listed above after consultation with affected local governments:

a) t rip reduction programs, including, but not limited to, employer

- based transportation management plans, area wide rideshare programs, work

sche dule changes, and telecommuting ;

b) t raffic flow and t ransit improvements; and

c) o ther new or innovative transportation measures not yet in widespread use that affected local governments deem appropriate.

4) Alternative fuel and di esel retrofit programs for fleet vehicle operations.

5) Require VOC or NO
x emission offsets for new and modified major sources.47 6) Increase the ratio of emission offsets required for new

sour ces.

7) Require VOC or NO
x controls on new minor sources (less than 100 tons).

8) Adopt NOx RACT for existing combustion sources.

9) High volume, low pressure coating application requirements

for autobody facilities.

10) Requirements for cold cleaner degreaser operations (low

vapor p ressure solvents).

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 NO
x sources potentially subject to future additional control requirement s.

Demonstration The following is a list of VOC and NO
x sources potentially subject to

future controls.

NO
x RACT

• EGUs

• asphalt batching plants

• industrial/commercial and institutional boilers

• process heaters

• internal combustion engines

• combustion turbines

• other sources greater than 100 tons per year

VOC RACT

• architectural and industrial maintenance coatings

• automobile refinishing shops

• cold cleaner degreasers

• synthetic organic compound manufacturing

• organic compound batch processes

• wood manufacturing48 • industrial wastewater

• aerospace in dustry

• bakeries

• plastic parts coating

• volatile organic liquid storage

• industrial solvent c leaning

• offset lithography

• industrial surface coating

• other sources greater than 50 tons per year49 

### CHAPTER SEVEN

MODELING ANALYSIS

Summary of Modeling Results for National Emission Control Strategies in

Final Rulemakings

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

ozone nonattainment areas seeking redesignation, extensive modeling has been performed covering the C olumbus , OH, area to determine the effect of national emission control strategies on ozone levels. This area inclu des Delaware, Fairfield, Franklin, Knox, Licking, and Madison Counties in Ohio

. These modeling analyses determined that this area was significantly impacted by ozone and ozone precursor transport and regional NOx reductions will help

the area attain the 20 08 eight

- hour ozone standard of 75 ppb in this area.

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

Provision

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

Provision. This analysis was performed in 2014 an d included in the “Air Quality Modeling Technical Support Document for the 2008 Ozone NAAQS Transport Assessment” to assist states in developing “Good Neighbor SIPs,” as required by the CAA to address interstate transport of air pollution that affects

down wind states' ability to attain and m aintain the 2008 eight

- hour ozone

standard

. Some of the major federal emission strategies included in the modeling are: National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Reciprocating Internal Combu stion Engines (RICE) and cement manufacturing plants, the Boiler Maximum Achievable Control Technology (MACT) rule, the Energy Independence and Security Act (EISA)

renewable fuel standard mandate, New Source Performance Standards (NSPS) for VOC controls, t he Mobile Source Air Toxics rule, Tier III Emission Standards for Vehicles and Gasoline Sulfur Standards, Emission Standards for Locomotives and M arine Compression

- Ignition Engines, and t he Nonroad Spark

- Ignition Engines and Recreational Engine Standards.

This modeling was conducted to identify monitoring sites that may have difficulty attaining the 2008 eight

- hour o zone standard in 2018 and i dentify states that were contributing to attainment issues at a given monitoring site. The air quality model used f or this rulemaking was the Comprehensive Air Quality Model with Extensions (CAMx) version 6.10. The modeling domain consisted of a 12 kilometer (km) x 12 km coarse grid covering the continental

United States and portions of Canada and Mexico and 25 vertica l layers from the surface up through the troposphere to a height of 50 millibars of pressure. Base year 2011 emissions were modeled. Meteorology from 2011 was created50 using the Weather Research Forecasting (WRF) Model version 3.4 and was used for the base case and pr ojected year modeling runs. More detailed information on t he CAMx input file and addi tional data used for the photochemical modeling can be found in U.S. EPA’s “Air Quality Modeling Technical Support Document for the 2008 O zone NAAQS Transport

A ssessment,” dated January 2015.

Table 26 shows the results of U.S. EPA’s “Good Neighbor” Provision modeling

for ozone impacts at the ozone monitors in the Columbus area The monitor identification number, county, and the 2009
– 2013 eight

- hour ozone base

p eriod average design values that were used to calculate 2018 projected average design values. Note that the 2009 2 013 average design values were calculated by averaging the three 3

- year design values from 2009
– 2011,

2010
– 2012, and 2011
– 2013. Model r esults are used in a relative rather

than absolute sense. Relative use of the model results calculates the fractional change in maximum concentrations based on t wo different emission scenarios, 2011 NEI emissions and 2018 projected emissions for this exerc ise.

This fractional change, also known as a relative response factor (RRF), can be applied to each monitor’s average base period design value to determine ozone impacts. This approach differs from using the absolute or actual modeled result, which may show under
- or over

- predictions with the actual

monitored values. The 2009
– 2013 average design values were multiplied by the corresponding RRF to determine all 2018 projected average design values.51 T able 26 - Comparison of C olumbus Area Average Design Value s with

U.S. EPA “Good Neighbor” Provision Modeling Results ( ppm )

Monitor ID County Monitored
Average Design

Value 2009

- 2013 U.S. EPA
Projected

Average
Design Value

2018

39

- 041

- 0002 Delaware 0.0730 0.0641

39

- 049

- 0029 Franklin 0.0803 0.0719

39

- 049

- 0037 Franklin 0.0750 0.0663

39

- 049

- 0081 Franklin 0.0710 0.0630

39

- 083

- 0002 Knox 0.0737 0.0646

39

- 089

- 0005 Licking 0.0743 0.0644

39

- 097

- 0007 Madison 0.0743 0.0638

Due to the differences in the base period 2009

– 2013 average design values

and more current average design values for all of the Columbus area ozone monitors, a comparison of these two values, as well as the 2018 projected average design values taken from the “Good Neighbor” Provision was made, and are presented in Table 26

. The current average design values were calculated by averaging the three 3

- year design values from 2010

– 2012,

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

.

Comparison of the 2009

– 2013 average design values with current 3

- year

average design value s for all ozone monitors in the C olumbus area show th at current average design values are below the average eight

- hour ozone design

values for 2009

– 2013

.

Based on the 2009
– 2013 average design values, the 2018 projected average design values modeled well below the 2008 eigh t- hour ozone standard of 75 ppb

. I f the modeling was conducted with the 2010

– 2014 average design values, the 2018 projected average design values would be lower than the

current results, further re

- enforcing maintenance of the standard. Modeling

conduct ed using the 2011

- 2015 average design values would result in 2018 projected design values at all monitors well below the current results, again further reinforcing maintenance of the standard. For the highest monitor in the area (Franklin County monitor 39

- 049

- 0029) , the 2018 pr ojected average design value is 0.0 719 ppm, well below the level of the 2008 eight

- hour ozone standard that demonstrates attainment (0.0757 ppm)

.52 T able 27 - Comparison of C olumbus Area Current Design Values with

U.S. EPA “Good Neigh bor” Design Values ( ppm )

Monitor ID County Monitored

Average
Design Value

2009

- 2013 Monitored

Average

Design

Value 2010

- 2014 Monitored
Average Design

Value 2011

- 2015 U.S. EPA
Projected

Average
Design Value

2018

39

- 041

- 0002 Delaware 0.0730 0.0727 0.0707 0. 0641

39

- 049

- 0029 Franklin 0.0803 0.0790 0.0753 0.0719

39

- 049

- 0037 Franklin 0.0750 0.0750 0.0720 0.0663

39

- 049

- 0081 Franklin 0.0710 0.0707 0.0680 0.0630

39

- 083

- 0002 Knox 0.0737 0.0723 0.0700 0.0646

39

- 089

- 0005 Licking 0.0743 0.0727 0.0693 0.0644

39

- 09 7

- 0007 Madison 0.0743 0.0737 0.0710 0.0638

LADCO Modeling for Eight

- Hour Ozone Standard

The LADCO performed photochemical modeling for ozone, which used the most recent emissions inventories and model updates. This modeling was performed to support attainment demonstrations for the five

- state LADCO region. The photochemical model used by LADCO and Indiana for the eight

hour ozone standard analysis is CAMx version 6.11, developed by Environ. This model has been accepted by U.S. EPA as an approved air qua lity model for regulatory analysis and attainment demonstrations. Requirements of 40 CFR 51.112, as well as the “Guidance on t he Use of Models and O ther Analyses in Attainment Demonstrations for the 8

- hour Ozone NAAQS” (EPA

454/R

- 05

- 002, Oct. 2005), are sa tisfied with the use of CAMx for attainment demonstrations. Meteorology from 2011, as well as 2011 base year emissions (based on legally enforceable emission controls required by consent decrees, state rules, or permit), was used to conduct this modeling. The base period

average design values for attainment purposes were calculated from the periods 2009
– 2011, 2010
– 2012, and 2011
– 2013. The projected year

modeled was 2018.

Table 40 shows that modeled ozone concentrations in the C olumbus area for

2018 will be below the eight

- hour ozone standard of 75 ppb. As shown in

Table 39 above, the 2010
– 2014 and 2011

- 2015 average design values

decreased from the 2009

– 2013 average design values

. At all monitors where the design values have decreased, the projecte d average design values would

be lower than the LADCO modeling results

, using the latest average design

values. For the Franklin County monitor (39

- 049

- 0029) , the projected average design value was well below the 2008 eight

- hour ozone standard at 0.07 2 9

pp m. As with U.S. EPA’s modeling, if the LADCO modeling was performed using the slightly lower 2010
– 2014 average design value s , it is expected that53 the 2018 projected average design value s would be well below the standard

for the for all monitor s in the ar ea

.

Table 28 - LADCO’s Modelin g Results for the Columbus Area ( ppm )

Monitor ID County Monitored
Average Design

Value 2009

- 2013 Monitored
Average Design

Value 2010

- 2014 Monitored
Average Design

Value 2011

- 2015 LADCO
Projected
Average Design

Value 2018

39

- 0 41

- 0002 Delaware 0.0730 0.0727 0.0707 0.0667

39

- 049

- 0029 Franklin 0.0803 0.0790 0.0753 0.0729

39

- 049

- 0037 Franklin 0.0750 0.0750 0.0720 0.0684

39

- 049

- 0081 Franklin 0.0710 0.0707 0.0680 0.0653

39

- 083

- 0002 Knox 0.0737 0.0723 0.0700 0.0660

39

- 089

- 0005 Li cking 0.0743 0.0727 0.0693 0.0663

39

- 097

- 0007 Madison 0.0743 0.0737 0.0710 0.0671

Summary of Existing Modeling Result s

U.S. EPA and LA DCO modeling shows that national emission control measures will bring the C olumbus ar ea into attainment of the 2008 e ight

- hour ozone NAAQS by 2018, if not earlier. Rulemakings to be implemented in the next several years will provide assurance that air quality will continue to meet the standard into the future. U.S. EPA’s modeling support for the Interstate Transport “Good Neighbor” Provision show future year design values for the

Columbus area will attain the ozone standard with 2018 projected average design values below the 2008 eight

- hour ozone standard of 75 ppb . In addition, LADCO’s modeling results continue to show 2 018 projected average design values below the eight

- hour ozone standard . U.S. EPA and LADCO modeling demonstrates that the Columbus, OH ozone nonattainment area will

attain the 2008 eight

- hour ozone standard. Future national and local emission

control stra tegies will ensure that the area’s attainment will be maintained with an increasing margin of safety over time.54 

### CHAPTER EIGHT

PUBLIC PARTICIPATION

Ohio published notification for a publ ic hearing and s olicitation for publi c comment concerning the draft redesignation petition and maintenance p lan in

the widely distributed county pub lications

.

The p ublic hearing to receive comments on the redesignation re quest was held

on June 2, 201 6 at 50 West Town Street, Suite 700, Columbus, Ohio 43215.

T he public comm ent peri od close d on

, June 2, 201 6. No testimony was provided at the public hearing and one set of c omments were received during the public comment period. Appendix D includes a copy of the public notice and transcript from the public hearing and comment period.55 

### CHAPTER NINE

CONCLUSIONS

The C olumbus , OH ozone nonattainment area has attained the 2008 NAAQS

for ozone and complied with the applicable provisions of the 1990

Amendments to the CAA regarding redesignations of ozone nonattainment

areas. D ocumentation to that effect is contained herein. O hio EPA has

prepa red a redesignation request and maintenance plan that meet the requirement s of Section 110 (a)(1) of the 1990 CAA

.

Based on this presentation, the C olumbus , OH ozone nonattainment area

meet s the requirements for redesignation under the CAA and U.S. EPA guidance. Ohio has performed an anal ysis that shows the air quality improvements are due to permanent and enforceable measures. Furthermore, because this area is subject to significant transport of pollutants, significant regional NO
x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of O hio hereby requests that the C olumbus , OH ozone nonattainment area be redesignated to attainment simultaneously with U.S.

EPA approval of the maintenance plan provisions contained herein. In addition, the State of Ohio requests that this maintenance plan satisfy the requirements of CAA Section 175A (b), for subsequent plan revisions req uired for areas redesignated for the eight

- hour ozone standard

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