o Environmental

Protection Agency

Ted Strickland. Governor

Lee Fisher, Lt, Governor

Chris Korieski, Director

Ms. Susan Hedman

Regional Administrator

U.S. EPA Region V

77 W. Jackson Blvd.

Chicago, IL 60604

DEC 0 9 2010

Re: PM2.5 redesignation request for the 1997 PM2.5 Annual Standard for the CincinnatiHamilton Area

Dear Administrator Hedman:

I am writing to formally request a redesignation to attainment of the Ohio portion of the

Cincinnati-Hamilton, OH-IN-KY area (Butler, Clermont, Hamilton, and Warren Counties

in Ohio; Dearborn Township in Indiana; and Boone, Campbell, and Kenton Counties in

Kentucky) with' respect to the 1997 PM2.5 annual standard. The enclosed submittal

combines the redesignation request and the required maintenance plan for this area.

Monitoring of existing air quality indicates that the 1997 National Ambient Air Quality

Standard (NAAQS) for PM2.5 has been attained throughout this area based on 2007-

2009 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 Ohio's portion of the CincinnatiHamilton area.

The enclosed information, compiled by the Ohio Environmental Protection Agency (Ohio

EPA), Ohio Department of Transportation, and the Ohio, Indiana, and Kentucky

Regional Council of Governments (associated planning organization), 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, the regional reductions associated with the NOx

Trading Program, and control strategies implemented by Ohio, such as Low Reid Vapor

Pressure Fuel requirements.

The pUblic hearing for this package was held on November 29, 2010, in Cincinnati, Ohio

and public comments were accepted through November 30,2010.

50 West Town Street, Suite 700

P.O. Box 1049

Columbus,OH 43216·1049

6141 644 3020

614 1644 3184 (fax)

www.epa.ohio.gov
If you have questions, please contact Jennifer Hunter in our Division of Air Pollution

Control at (614) 644-3696.

Sincerely,

Chris Korleski

Director
 

REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR 

THE OHIO PORTION OF THE 

CINCINNATI-HAMILTON, OH-KY-IN 

ANNUAL PM2.5

NONATTAINMENT AREA 

Butler, Clermont, Hamilton, 

and Warren Counties, Ohio 

Prepared by: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control 

December 2010 
 

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 i 

TABLE OF CONTENTS 

Chapter One 

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

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

Status of air quality ....................................................................................................................... 3 

Chapter Two 

Requirements for redesignation .................................................................................................... 4 

Chapter Three 

PM2.5 monitoring ............................................................................................................................ 8 

Annual PM2.5 NAAQS .................................................................................................................... 8 

Ambient data quality assured ........................................................................................................ 9 

Three complete years of data ....................................................................................................... 9 

Commitment to continue monitoring ........................................................................................... 13 

Chapter Four 

Emission inventory ...................................................................................................................... 14 

Base year inventory .................................................................................................................... 14 

Emission projections ................................................................................................................... 15 

Demonstration of maintenance ................................................................................................... 24 

Permanent and enforceable emissions reductions ..................................................................... 39 

Provisions for future updates ...................................................................................................... 40 

Chapter Five 

Control measures and regulations .............................................................................................. 41 

Marginal nonattainment areas to implement RACM and RACT .................................................. 41 

Show Reasonable Further Progress (RFP) ................................................................................ 43 

Emission inventories ................................................................................................................... 43 

Implementation of past SIP revisions .......................................................................................... 44 

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

Assurance of continued controls ................................................................................................. 46 

Chapter Six 

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

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

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

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

List of PM2.5, SO2, and NOx sources ........................................................................................... 50 

Chapter Seven 

Public participation ...................................................................................................................... 51 

Chapter Eight 

Conclusions ................................................................................................................................ 52 
 ii 

FIGURES 

Figure 1 Map of the Cincinnati-Hamilton, OH-KY-IN nonattainment area and monitor 

locations ................................................................................................................ 9 

Figure 2 PM2.5 Annual Mean Trends LADCO States ......................................................... 12 

Figure 3 PM2.5 Annual Mean Trends Midwest States ........................................................ 12 

Figure 4 PM2.5 Annual Mean National Trends .................................................................. 13 

TABLES 

Table 1 Monitoring Data for Cincinnati-Hamilton, OH-KY-IN area for 2007 – 2009 ......... 11 

Table 2 Butler County, Ohio Emission Estimations for On-road Mobile Sources ............. 20 

Table 3 Clermont County, Ohio Emission Estimations for On-road Mobile Sources ........ 20 

Table 4 Hamilton County, Ohio Emission Estimations for On-road Mobile Sources ........ 21 

Table 5 Warren County, Ohio Emission Estimations for On-road Mobile Sources .......... 21 

Table 6 Dearborn County, Indiana Emission Estimations for On-road Mobile Sources ... 21 

Table 7 Summary of Ohio and Indiana Emissions Estimations for On-road Mobile 

 Sources ............................................................................................................... 21 

Table 8 Boone County, Kentucky Emission Estimations for On-road Mobile Sources ..... 21 

Table 9 Campbell County, Kentucky Emission Estimations for On-road Mobile Sources 21 

Table 10 Kenton County, Kentucky Emission Estimations for On-road Mobile Sources .... 22 

Table 11 Summary of Kentucky Emission Estimations for On-Road Mobile Sources ........ 22 

Table 12 Emission Estimations Totals for On-road Mobile Sources for the CincinnatiHamilton Area ...................................................................................................... 22 

Table 13 Mobile Vehicle Emission Budget for Ohio and Indiana ....................................... 22 

Table 14 Mobile Vehicle Emission Budget for Kentucky .................................................... 22 

Table 15 Reductions in SO2 and NOx EGU Emissions Between 2008 and 2009. ............. 26 

Table 16 Reductions in SO2 and NOx EGU Emissions Between the First Half of 2008 

 and 2010.... ......................................................................................................... 27 

Table 17 Butler County, Ohio PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 29 

Table 18 Clermont County, Ohio PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 29 

Table 19 Hamilton County, Ohio PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 29 

Table 20 Warren County, Ohio PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 30 

Table 21 Dearborn County, Indiana PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR ................ 30 

Table 22 Boone County, Kentucky PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 30 

Table 23 Campbell County, Kentucky PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 31 

Table 24 Kenton County, Kentucky PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR ................ 31 

Table 25 Cincinnati-Hamilton Area PM2.5 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 31 

Table 26 Butler County, Ohio NOx Emission Inventory Total for Base Year 2005, Estimated 

2008, and Projected 2015 and 2021 (tpy) – With CAIR ...................................... 32 
 iii 

Table 27 Clermont County, Ohio NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 32 

Table 28 Hamilton County, Ohio NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 32 

Table 29 Warren County, Ohio NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 33 

Table 30 Dearborn County, Indiana NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 33 

Table 31 Boone County, Kentucky NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 33 

Table 32 Campbell County, Kentucky NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 34 

Table 33 Kenton County, Kentucky NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 34 

Table 34 Cincinnati-Hamilton Area NOx Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 34 

Table 35 Butler County, Ohio SO2 Emission Inventory Total for Base Year 2005, 

 Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 35 

Table 36 Clermont County, Ohio SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 35 

Table 37 Hamilton County, Ohio SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 35 

Table 38 Warren County, Ohio SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 36 

Table 39 Dearborn County, Indiana SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 36 

Table 40 Boone County, Kentucky SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 36 

Table 41 Campbell County, Kentucky SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 37 

Table 42 Kenton County, Kentucky SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 37 

Table 43 Cincinnati-Hamilton Area SO2 Emission Inventory Total for Base Year 2005, 

Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 37 

Table 44 Cincinnati-Hamilton Area Comparison of 2008 attainment year and 2015 and 

2021 projected emission estimates (tpy) ............................................................. 38 

Table 45 Miami Fort Station, Hamilton County , Emission Reductions (tpy) as Reported 

 by Clean Air Markets Division.............................................................................. 39 

Table 46 Cincinnati-Hamilton Area Combined Comparison of 2005 base year and 2008 

attainment year on-road and EGU reductions ..................................................... 39 

APPENDICES 

A Air Quality System (AQS) Data 

B Ohio 2005 SIP Base Year Inventory Discussion 

C “Mobile Source Emissions Inventory for the Cincinnati Ozone Nonattainment Area” 

D LADCO Technical Support Document 

E Public Participation Documentation 
 iv 

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REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO 

PORTION OF THE CINCINNATI-HAMILTON, OH-KY-IN 

ANNUAL PM2.5 NONATTAINMENT AREA 

Butler, Clermont, Hamilton, and Warren Counties, Ohio 

CHAPTER ONE 

Introduction

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

Quality Standard (NAAQS) for the annual PM2.5 to develop State Implementation 

Plans (SIP’s) to expeditiously attain and maintain the standard. The United 

States Environmental Protection Agency (U.S. EPA) revised the NAAQS for 

particulate matter in July 1997. It replaced the existing PM10 standard with a 

health based PM2.5 standard and retained the PM10 standard as a “coarse” 

standard protecting welfare. The standards include an annual standard set at 

15.0 micrograms per cubic meter (μg/m3

), based on the 3-year average of 

annual mean PM2.5 concentrations and a 24-hour standard of 65 μg/m3

, based 

on the 3-year average of the 98th percentile of 24-hour concentrations. 

The revised NAAQS were legally challenged in the U.S. Court of Appeals for the 

District of Columbia Circuit (The D.C. Circuit). On May 14, 1999, the D.C. Circuit 

remanded, without vacatur, the standard back to U.S. EPA. The remand did not 

question the level at which U.S. EPA set the standards but rather the 

constitutionality of the CAA provision that authorizes U.S. EPA to set national air 

quality standards. U.S. EPA requested a rehearing which the D.C. Circuit denied. 

Therefore, in December 1999, U.S. EPA appealed the D.C. Circuit decision to 

the U.S. Supreme Court. The U.S. Supreme Court issued a decision on 

February 27, 2001 that unanimously affirmed the constitutionality of the CAA 

provision but did remand several other issues back to the D.C. Circuit, including 

the issue of whether U.S. EPA acted arbitrarily and capriciously in establishing 

the specific levels of the standards. 

The D.C. Circuit heard arguments in this remanded case in December 2001, and 

issued its decision on March 26, 2002. The D.C. Circuit rejected the claims that 

the U.S. EPA had acted arbitrarily and capriciously in setting the levels of the 

standards. 

On December 17, 2004, U.S. EPA promulgated the initial PM2.5 nonattainment 

areas designations for the PM2.5 standards across the country. Modifications to 

those designations were made and an effective date was set at April 5, 2005. 

Unlike Subpart 2 of the CAA Amendments of 1990 which defined five ozone 

nonattainment classifications for the areas that exceed the NAAQS based on the 
 2 

severity of the ozone levels, PM2.5 nonattainment designations are simply 

labeled “nonattainment.” The CAA Amendments require states with PM2.5

nonattainment areas to submit a plan within three years of the effective date of 

the designations (April 5, 2008) detailing how the PM2.5 standards will be 

attained by April 5, 2010. Ohio EPA submitted its attainment demonstration for 

the entire State of Ohio on July 16, 2008. 

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 PM2.5 standard.

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

Section 110(k).

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

permanent and enforceable reductions in emissions resulting from 

implementation of the SIP and other federal requirements.

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

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

been met. 

This document addresses each of these requirements, and provides additional 

information to support continued compliance with the annual PM2.5 standard. 

 

Geographical Description and Background

The current Cincinnati-Hamilton nonattainment area is located in southwest Ohio 

and includes the following counties: Butler, Clermont, Hamilton, and Warren in 

Ohio; Dearborn (partial nonattainment of Lawrenceburg Township only) in 

Indiana; and Boone, Campbell, and Kenton in Kentucky. This area is shown in 

Figure 1 under Chapter Three. 

The Cincinnati-Hamilton area has not previously been subject to nonattainment 

area rulemakings for fine particles. 

As a result of the 2005 PM2.5 designations, U.S. EPA designated the CincinnatiHamilton area nonattainment for the 15.0 μg/m3 annual standard1

, and Ohio EPA 

was required to develop a plan to reduce oxides of nitrogen (NOx), sulfur dioxide 

(SO2) and direct PM2.5 emissions and to demonstrate that the area will meet the 

federal annual air quality standard by April 5, 2010. Ohio’s main PM2.5

components are primary particles (organic carbon, crustal material, and 

elemental carbon), SO2 and NOx, which were included in the attainment 

demonstration analysis. Volatile organic compounds (VOCs) and ammonia 

(NH3) were not included in the analysis since they were not part of Ohio’s 

 

1 There were no monitors in Ohio that violated the 1997 24-hour PM2.5 standard of 65μg/m3. 
 3 

current attainment strategy for PM2.5 (although controls for VOCs have been 

implemented for ozone nonattainment). This is consistent with U.S. EPA’s “Clean 

Air Particle Implementation Rule” [74FR 20856] (hereafter referred to as 

“Implementation Rule”). In the Implementation Rule U.S. EPA presumes NH3 

emissions are not a PM2.5 attainment plan precursor and that States are not 

required to address VOC unless the State or U.S. EPA makes technical 

demonstration that emissions of VOCs significantly contribute to nonattainment. 

This document is intended to support Ohio’s request that the Ohio portions of the 

Cincinnati-Hamilton area be redesignated from nonattainment to attainment for 

the annual PM2.5 standard. In addition, the States of Kentucky and Indiana also 

intend to submit requests for their respective portions of the Cincinnati-Hamilton 

area.

Status of Air Quality

PM2.5 complete quality-assured ambient air quality monitoring data for the most 

recent three (3) years, 2007 through 2009, demonstrate that the air quality has 

met the NAAQS for annual PM2.5 in this nonattainment area. The NAAQS 

attainment, accompanied by decreases in emission levels discussed in Chapter 

Four, supports a redesignation to attainment for the Cincinnati-Hamilton area 

based on the requirements in Section 107(d)(3)(E) of the CAA. 
 4 

CHAPTER TWO 

Requirements for Redesignation

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

Processing Requests to Redesignate Areas to Attainment (redesignation 

guidance), issued September 4, 1992, to Regional Air Directors. The 

redesignation request and maintenance plan are based on the redesignation 

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

EPA Region V. 

Below is a summary of each redesignation criterion as it applies to the 

Cincinnati-Hamilton area. 

i.) Attainment of the standard (CAA Section 107(d)(3)(E)(i)) 

There are two components involved in making this demonstration. 

The first component relies on ambient air quality data. The data 

that are used to demonstrate attainment should be the product of 

ambient monitoring that is representative of the area of highest 

concentration. The data should be collected and quality-assured in 

accordance with 40 CFR 58 and recorded in the Air Quality 

System (AQS)in order for it to be available to the public for review. 

The second component relies upon supplemental U.S. EPAapproved air quality modeling. While no modeling is required for 

redesignating nonattainment areas, the redesignation guidance 

states it is “generally necessary” for particulate matter 

redesignations. Appendix C and Appendix D contains the most 

recent modeling results showing future attainment and 

maintenance are provided. Chapter Three discusses this 

requirement in more detail and provides the attainment 

demonstration. 

ii.) Permanent and enforceable improvement in air quality (CAA 

Section 107(d)(3)(E)(iii))

The state must be able to reasonably attribute the improvement in 

air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures that 

have been adopted and implemented by the state. 

It was not necessary for Ohio to adopt or implement control 

measures for these counties beyond the federal measures. 

Ohio EPA has adopted several rules recently that will have an 

impact Statewide on PM2.5 emissions in the future: 
 5 

• Clean Air Interstate Rule (CAIR) 

• NOx SIP Call Rules 

In addition, since the initial designations were made federally 

enforceable consent decrees have resulted in reductions in 

emissions from utilities across the state, including this area. 

Chapters Four and Five 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 state must meet all requirements 

of Section 110 and Part D that were applicable prior to submittal of 

the complete redesignation request. 

Subpart 1 of Part D consists of general requirements applicable to 

all areas which are designated nonattainment based on a violation 

of the NAAQS. Subpart 4 of Part D consists of more specific 

requirements applicable to particulate matter (specifically to 

address PM10). However, for the purpose of implementing the 

1997 PM2.5 standard, U.S. EPA’s Implementation Rule stated 

Subpart 1, rather than Subpart 4, is appropriate for the purpose of 

implementing PM2.5.[72 FR 20589] 

i.) Section 110(a) requirements

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

requirements for a SIP. Section 110(a)(2) provides that the 

implementation plan submitted by a state must have been 

adopted by the state after reasonable public notice and 

hearing, and that, among other things, it must include 

enforceable emission limitations and other control 

measures, means or techniques necessary to meet the 

requirements of the CAA; provide for establishment and 

operation of appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 

provide for implementation of a source permit program to 

regulate the modification and construction of any stationary 

source within the areas covered by the plan; include 

provisions for the implementation of Part C, prevention of 

significant deterioration (PSD) and Part D, NSR permit 

programs; include criteria for stationary source emission 

control measures, monitoring, and reporting; include 

provisions for air quality modeling; and provides for public 

and local agency participation in planning and emission 

control rule development. In Ohio’s December 5, 2007 and 

September 4, 2009 infrastructure SIP submissions, Ohio 
 6 

verified that the State fulfills the requirements of Section 

110(a)(2) of the Act. 

Section 110(a)(2)(D) also requires State plans to prohibit 

emissions from within the State which contribute 

significantly to nonattainment or maintenance areas in any 

other State, or which interfere with programs under Part C 

to prevent significant deterioration of air quality or to 

achieve reasonable progress toward the national visibility 

goal for Federal class I areas (national parks and 

wilderness areas). In order to assist States in addressing 

their obligations regarding regionally transported pollution, 

U.S. EPA finalized CAIR to reduce SO2 and NOx emissions 

from large electric generating units (EGU). Ohio has met 

the requirements of the federal CAIR to reduce NOx and 

SO2 emissions contributing to downwind states. On 

February 1, 2008, U.S. EPA approved Ohio’s CAIR 

program, which can be found in Ohio Administrative Code 

(OAC) Chapter 3745-1092. On July 6, 2010, U.S. EPA 

proposed a replacement to the CAIR program, the 

Transport Rule. [75 FR 45210] Upon finalization, it will 

further assist States in addressing their obligations 

regarding regionally transported pollution by providing 

reductions in NOx and SO2 emissions in 2012 and 2014. 

ii.) Section 172(c) requirements

 This Section contains general requirements for 

nonattainment plans. The requirements for reasonable 

further progress, identification of certain emissions 

increases, and other measures needed for attainment will 

not apply for redesignations because they only have 

meaning for areas not attaining the standard. The 

requirements for an emission inventory will be satisfied by 

the inventory requirements of the maintenance plan. 

Chapters Four and Five discuss this requirement in more 

detail. 

iii.) Conformity

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

provisions are consistent with the Section 176(c)(4) 

conformity requirements. The redesignation request should 

include conformity procedures, if the state already has 

these procedures in place. If a state does not have 

conformity procedures in place at the time that it submits a 

 

2 http://www.epa.ohio.gov/dapc/regs/regs.aspx#3745-109 
 7 

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

EPA’s conformity regulation upon issuance, as applicable. 

v.) Maintenance plans (CAA Section 107(d)(3)(E)(iv))

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

U.S. EPA must fully approve a maintenance plan that meets the 

requirements of Section 175(A). The maintenance plan will 

constitute a SIP revision and must provide for maintenance of the 

relevant NAAQS in the area for at least 10 years after 

redesignation. Section 175 (A) further states that the plan shall 

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

ensure such maintenance. 

In addition, the maintenance plan shall contain such contingency 

measures as the Administrator deems necessary to ensure prompt 

correction of any violation of the NAAQS. At a minimum, the 

contingency measures must include a requirement that the state 

will implement all measures contained in the nonattainment SIP 

prior to redesignation. 

States seeking redesignation of a nonattainment area should 

consider the following provisions: 

a.) attainment inventory; 

b.) maintenance demonstration; 

c.) monitoring network; 

d.) verification of continued attainment; and 

e.) contingency plan. 

Chapter Six discusses this requirement in more detail. 
 8 

CHAPTER THREE 

PM2.5 MONITORING 

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

Requirement 1 of 4 

A demonstration that the NAAQS for annual PM2.5, as published in 40 CFR 50.7, 

has been attained. 

Background

There are sixteen monitors measuring PM2.5 concentrations in this 

nonattainment area. Twelve of the sixteen monitors are located in 

Ohio3

 and are operated by Ohio EPA Division of Air Pollution 

Control, Southwest District Office and the Hamilton County Division 

of Environmental Services. A listing of the design values based on 

the three-year average of the annual mean concentrations from 

2007 through 2009 is shown in Table 1. The locations of the 

monitoring sites for this nonattainment area are shown on Figure 1. 

 

3 The four remaining PM2.5 monitors are located in Kentucky. 
 9 

Demonstration

 

Figure 1 - Map of the Cincinnati-Hamilton, OH-KY-IN 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) database, and available for 

public view. 

Demonstration

The Ohio EPA has quality assured all data shown in Appendix A in 

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

EPA has recorded the data in the AQS database and, therefore, the data 

are available to the public. 

Requirement 3 of 4 

A showing that the three-year average of the annual mean values, based on 

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

below 15.0 μg/m3

. (This showing must rely on three complete, consecutive 

calendar years of quality assured data.) 

 
 10 

Background

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

Data Handling Conventions for the PM NAAQS," U.S. EPA-454/R99-008, April 1999. 

In accordance with the CAA Amendments, three complete years of 

monitoring data are required to demonstrate attainment at a 

monitoring site. The annual PM2.5 primary and secondary ambient air 

quality standards are met at an ambient air quality monitoring site 

when the three-year average of the annual average is less than 15.0 

μg/m3. While calculating design values, three significant digits must 

be carried in the computations, with final values rounded to the 

nearest 0.1 μg/m3. Decimals 0.05 or greater are rounded up, and 

those less than 0.05 are rounded down, so that 15.049 μg/m3 is the 

largest concentration that is less than, or equal to 15.0 μg/m3

. 

Values at or below 15.0 μg/m3 meet the standard; values equal to or 

greater than 15.1 μg/m3 exceed the standard. An area is in 

compliance with the annual PM2.5 NAAQS only if every monitoring 

site in the area meets the NAAQS. An individual site's 3-year 

average of the annual average concentrations is also called the 

site's design value. The air quality design value for the area is the 

highest design value among all sites in the area. 

Table 1 shows the monitoring data for 2007 – 2009 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. 
 11 

Demonstration

Table 1 - Monitoring Data for the Cincinnati-Hamilton, OH-KY-IN area 

for 2007 – 2009 

Average

2007 2008 2009 2007-2009

39-017-0003 15.4 13.8 12.8 14.0

39-017-0016 14.9 13.8 13.1 13.9

39-017-1004 [a] 14.6

39-025-0022 Clermont, OH 14.0 11.7 11.0 12.2

39-061-0006 14.6 12.5 12.1 13.1

39-061-0014 16.6 15.1 13.4 15.0

39-061-0040 15.1 12.6 12.7 13.5

39-061-0042 15.9 14.4 13.7 14.7

39-061-0043 [b] 14.8 13.3

39-061-7001 15.1 13.7 13.0 13.9

39-061-8001 16.1 14.4 13.4 14.6

39-165-0007 Warren, OH 14.0 11.9 11.7 12.5

21-037-3002 [c] Campbell, KY 14.4 11.8 11.3 12.5

21-117-0007 Kenton, KY 14.2 12.0 11.0 12.4

Less than 75% capture in at least one quarter

[a] This site was terminated at the end of 2007. Based on data from available previous years,

 the site incidcates attainment for the PM2.5 annual standard.

 2004-2006 average: 14.6ug/m3; 2005-2007 average: 15.0 ug/m3

[b] This site was discontinued at the end of 2008. Based on data from available previous

 years, the site indicates attainment for the PM2.5 annual standard 

 2006-2008 average: 14.2ug/m3

[c] This site did not start operating until 8/1/2007. All available data indicates attainment of

 the PM2.5 annual standard.

Year Site County

Hamilton, OH

Butler, OH

Annual Standard

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

The design values calculated for the Cincinnati-Hamilton area 

demonstrates that the annual PM2.5 NAAQS has been attained. The area's 

design values have trended downward as emissions have declined due to 

such factors as cleaner automobiles and fuels, and controls for EGUs, at 

the national, regional and local level. 

National monitoring for PM2.5 began in 1999. With respect to each of the 

Lake Michigan Air Directors Consortium (LADCO) states, there has been a 

clear downward trend in design values: 
 12 

Figure 2 - PM2.5 Annual Mean Trends LADCO States 

Source: LADCO; Recent Ozone and PM2.5 Trends – Aug 26 2010.pptx

The same trend can be seen within the Midwest States as a whole: 

Figure 3 - PM2.5 Annual Mean Trends Midwest States 

Source: LADCO; Recent Ozone and PM25 Trends - Aug 26 2010.pptx 
 13 

Design values have also trended downward nationally: 

Figure 4 - PM2.5 Annual Mean National Trends 

Source: http://www.epa.gov/airtrends/pm.html 

Requirement 4 of 4 

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

appropriate monitoring network to verify the maintenance of the attainment 

status. 

Demonstration

Ohio EPA commits to continue monitoring PM2.5 levels at the Ohio 

sites indicated in Figure 1 and Table 1. Ohio EPA will consult with 

U.S. EPA Region V prior to making changes to the existing 

monitoring network, should changes become necessary in the 

future. Ohio EPA will continue to quality assure the monitoring data 

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

requirements. Connection to a central station and updates to the 

Ohio EPA web site4

 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. 

 

4 www.epa.ohio.gov/dapc 
 14 

CHAPTER FOUR 

EMISSION INVENTORY

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

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

inventory of PM2.5 precursor emissions (primary particles (organic carbon, crustal 

matter, and elemental carbon), SO2 and NOx

5

) representative of the year when 

the area achieves attainment of the annual PM2.5 air quality standard. Ohio also 

must demonstrate that the improvement in air quality between the year that 

violations occurred and the year that attainment was achieved is based on 

permanent and enforceable emission reductions. Other emission inventory 

related requirements include a projection of the emission inventory to a year at 

least 10 years following redesignation; a demonstration that the projected level 

of emissions is sufficient to maintain the annual PM2.5 standard; and a 

commitment to provide future updates of the inventory to enable tracking of 

emission levels during the 10-year maintenance period. 

The emissions inventory development and emissions projection discussion 

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

projections, identifies procedures used by Ohio EPA and the LADCO regarding 

emissions from Ohio’s portion of the counties in the Cincinnati-Hamilton area. 

Specific emissions data are provided for all counties, including those in Ohio, 

Kentucky and Indiana. Indiana and Kentucky emissions data were also obtained 

though the LADCO emissions inventory and projections. All of these inventories 

and emissions projections were prepared using similar methodologies. Ohio 

recognizes that revisions to the emissions data below may be necessary once 

Kentucky and Indiana prepare a redesignation request and maintenance plan for 

their portion of the nonattainment area. Mobile emissions inventories and 

projections for all counties were prepared by the Ohio, Kentucky, Indiana Council 

of Governments (OKI). 

Requirement 1 of 5 

A comprehensive emission inventory of PM2.5, SO2 and NOx completed for the 

base year. 

Background

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

reporting program. The 2005 periodic inventory has been identified 

as one of the preferred databases for SIP development and 

coincides with nonattainment air quality in the Cincinnati-Hamilton 

area. 

 

5 VOC and NH3 are not addressed. 
 15 

Periodic inventories, which include emissions from all sectors - 

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

three years. 

Demonstration

The 2005 inventory is used as the base year for the purpose of this 

submittal and was submitted to U.S. EPA with Ohio’s PM2.5

attainment demonstration SIP submitted on July 18, 2008 and 

revised on June 7, 2010. The detailed emission inventory 

information for the Ohio portion of the Cincinnati-Hamilton area is 

provided in Appendix B. Emissions of PM2.5, SO2 and NOx for 2005 

are identified under Requirement Three of this Chapter. 

Requirement 2 of 5 

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

redesignation. 

Background

Ohio EPA prepared a comprehensive inventory for the Ohio portion of the 

Cincinnati-Hamilton area including area, mobile, and point sources for 

PM2.5, S02 and NOx for base year 2005. The 2005 inventory was submitted 

to U.S. EPA on July 18, 2008 as part of Ohio’s PM2.5 attainment 

demonstration SIP for this area. The information below describes the 

procedures Ohio EPA used to generate the 2005 base year inventory and 

to develop SIP-ready modeling inventories and future year projections 

(Pechan Report6) based on a 2005 base year inventory. The report by 

Pechan generated future year estimates of annual emissions for each 

source sector using accepted growth surrogates. These inventories were 

provided to the LADCO and have been processed to develop average daily 

emissions for use in the air quality analyses. These processed modeling 

inventories have been identified as the correct iteration of the inventory for 

use in the redesignation. In this document, references to LADCO include 

the Midwest Regional Planning Organization. Note, the on-road mobile 

source sector was addressed by specific PM2.5 and NOx modeling as 

discussed below. 

• Area sources were taken from the Ohio 2005 periodic 

inventory submitted to U.S. EPA. These projections were 

made from the U.S. Department of Commerce Bureau of 

Economic Analysis (BEA) growth factors, with some updated 

local information. 

 

6 

http://www.ladco.org/tech/emis/r5/reports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con

trols%20Report_Final.pdf 
 16 

• Mobile source emissions were calculated from MOVES2010 -

produced emission factors. Only PM2.5 and NOx necessitate 

emissions inventory analysis. As documented in Ohio EPA’s 

attainment demonstration SIP, Ohio EPA in consultation with 

U.S. EPA determined mobile sources are insignificant 

contributors for SO2. Consistent with Ohio EPA’s attainment 

demonstration, Ohio EPA continues to consider mobile 

source SO2 to be an insignificant contributor to fine particles 

for this nonattainment area. Based on the demonstration 

below, SO2 constitutes less than one percent (<1%) of the 

area’s total SO2 emissions in 2005, 2008, 2015 and 2021 

(ranging between 0.09% and 0.31%). 

• Point source information was compiled from Ohio EPA’s 

2005 annual emissions inventory database and the 2005 

U.S. EPA Air Markets acid rain database7

. 

• Biogenic emissions are not included in these summaries. 

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

National Mobile Inventory Model (NMIM) 2002 application. 

To address concerns about the accuracy of some of the 

categories in U.S. EPA’s non-road emissions model, LADCO 

contracted with two (2) companies to review the base data 

and make recommendations. One of the contractors also 

estimated emissions for three (3) non-road categories not 

included in U.S. EPA’s non-road model. Emissions were 

estimated for aircraft, commercial marine vessels, and 

railroads. Recreational motorboat population and spatial 

surrogates (used to assign emissions to each county) were 

significantly updated. The populations for the construction 

equipment category were reviewed and updated based upon 

surveys completed in the Midwest, and the temporal 

allocation for agricultural sources also was updated. 

 

Demonstration

On-Road Emission Estimations

In coordination with the Ohio Department of Transportation (Ohio 

DOT), OKI utilizes a regional travel demand forecast model to 

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

growth expectations. The model has been validated to observed 

traffic volumes for the model base year 2005. The model is primarily 

used as a long range planning tool to evaluate the transportation 

system including determination of locations where additional travel 

capacity may be needed and to determine the infrastructure 

requirements necessary to meet that need. It is also used as a tool 

 

7 http://www.epa.gov/airmarkets/acidrain 
 17 

for air quality purposes to estimate the total emissions of pollution 

caused by vehicles in the area. The travel demand forecasting 

model is used to predict traffic volumes vehicle miles traveled 

(VMT), travel speeds, and a U.S. EPA computer program called 

MOVES is used to calculate emissions per mile. The product of 

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

for the area. 

Overview 

U.S.EPA published a Federal Register notice8 of availability on 

March 2, 2010, to approve MOVES2010 (Motor Vehicle Emissions 

Simulator), hereafter referred to as MOVES. Upon publication of the 

Federal Register notice, MOVES became U.S. EPA’s approved 

motor vehicle emission factor model for estimating VOCs, NOx, CO, 

PM10 and PM2.5 and other pollutants and precursors from cars, 

trucks, motorcycles, and buses by state and local agencies. MOVES 

is a computer program designed by the U.S. EPA to estimate air 

pollution emissions from mobile sources. MOVES replaces U.S. 

EPA’s previous emissions model for on-road mobile sources, 

MOBILE6.2. MOVES can be used to estimate exhaust and 

evaporative emissions as well as brake and tire wear emissions 

from all types of on-road vehicles. 

The CAA requires U.S. EPA to regularly update its mobile source 

emission models. U.S. EPA continuously collects data and 

measures vehicle emissions to make sure the Agency has the best 

possible understanding of mobile source emissions. This 

assessment, in turn, informs the development of U.S. EPA’s mobile 

source emission models. MOVES represents the Agency’s most upto-date assessment of on-road mobile source emissions. MOVES 

also incorporates several changes to the U.S. EPA’s approach to 

mobile source emission modeling based upon recommendations 

made to the Agency by the National Academy of Sciences. 

U.S.EPA believes that MOVES should be used in ozone, CO, PM, 

and nitrogen dioxide SIP development as expeditiously as possible. 

The CAA requires that SIP inventories and control measures be 

based on the most current information and applicable models that 

are available when a SIP is developed. 

Regarding transportation conformity, U.S. EPA and U.S. DOT intend 

to establish a two-year grace period before MOVES is required for 

new transportation conformity analyses. 

 

8 http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ab1f98 
 18 

The MOVES more detailed approach (when compared with the 

previous MOBILE model) to modeling allows U.S. EPA to easily 

incorporate large amounts of in-use data from a wide variety of 

sources, such as data from vehicle inspection and maintenance 

(I/M) programs, remote sensing device (RSD) testing, certification 

testing, portable emission measurement systems (PEMS), etc. This 

approach also allows users to incorporate a variety of activity data to 

better estimate emission differences such as those resulting from 

changes to vehicle speed and acceleration patterns. MOVES has a 

graphical user interface which allows users to more easily set up 

and run the model. MOVES database-centered design provides 

users much greater flexibility regarding output choices. Unlike earlier 

models which provided emission factors in grams-per-mile in fixed 

output formats, MOVES output can be expressed as total mass (in 

tons, pounds, kilograms, or grams) or as emission factors (gramsper-mile and in some cases grams-per-vehicle). Output can be 

easily aggregated or disaggregated to examine emissions in a range 

of scales, from national emissions impacts down to the emissions 

impacts of individual transportation projects. The database-centered 

design also allows U.S. EPA to update emissions data incorporated 

in MOVES more easily and will allow users to incorporate a much 

wider array of activity data to improve estimation of local emissions. 

For example, the improvements in MOVES will allow project-level 

PM2.5 emissions to be estimated. 

OKI’s utilized U.S.EPA’s emissions model MOVES to develop 

emissions factors for SO2, NOx and PM2.5. Further details on the use 

of MOVES are found on Appendix C. Transportation system 

performance was estimated using the OKI Travel Demand Model 

Version 7.6. The model uses demographic and land use data and 

capacity and free-flow speed characteristics for each roadway 

segment in the network to produce a “loaded” highway network with 

forecasted traffic volumes with revised speeds based on specified 

speed/capacity relationships. 

Travel analysis zones are the basic geographic unit for estimating 

travel in the OKI model. The OKI region is subdivided into 1608 

traffic analysis zones to permit detail as well as manageability. A 

variety of socioeconomic data items are used in the OKI 

transportation planning process. These data are used primarily to 

forecast future travel patterns by serving as independent variables in 

OKI trip generation equations. The following categories of planning 

data are utilized: 

- Population. 

- Households. 
 19 

- Household vehicles. 

- Employment. 

- Labor force participation. 

- Area type. 

The principal data requirements of the OKI travel demand 

forecasting model are population and employment, from these 

variables other characteristics including household, labor force, and 

personal vehicles may be derived (OKI 2030 Regional 

Transportation Plan 2008 Update provides a complete demographic 

overview of the region). 

OKI utilizes both base year (2005) and future year data (2010, 2020 

and 2030) in the planning process. Planning data are maintained at 

the Traffic Analysis Zone (TAZ) level, and originate in the 2000 

Census of Population and Housing. Base year 2005 and future yare 

data for each variable are developed through various methods. 

OKI’s Travel Demand Model has been validated to observed traffic 

volumes for the model base year 2005. The modeling network 

encompasses the entire PM2.5 nonattainment area. The modeling 

network also includes Greene, Miami and Montgomery counties in 

Ohio and the remainder of Dearborn County, Indiana. The 

differences between estimated vehicle miles traveled (VMT) and 

2005 observed VMT is less than 1%. A highway screenline analysis 

compares the screenline observed and simulated traffic volume 

discrepancies with the Ohio Department of Transportation (ODOT) 

standard of maximum desirable deviation. The comparison shows 

that the model performs at a satisfactory level and all the errors 

were under the ODOT curve (OKI’s 2007 report, “OKI/MVRPC 

Travel Demand Model Methodology/Validation Report”). For the 

calibration, OKI used over 3000 traffic counts collected through 2006 

by the ODOT, the Kentucky Transportation Cabinet, many county 

and local governments, transportation engineering consultants, and 

OKI. These traffic counts cover nearly 50% of the links in the OKI 

portion of the modeling network. The methodology provides 

consistency with past emission inventory and conformity analysis 

work performed by OKI. 

OKI incorporates a variety of sources of local data to both improve 

and confirm the accuracy of VMT, as well as other travel-related 

parameters. Free flow speeds used on the highway and transit 

networks are based on travel time studies performed locally. An 

OKI post-processing program uses the loaded highway network to 

generate VMT by hour, VMT by speed distribution, and VMT by 

facility type. These tables are then included as input into MOVES. 
 20 

The VMT by hour tables utilize hourly traffic distribution and 

directional split factors for different roadway types as developed by 

OKI. The main source of the data was the permanent traffic counting 

stations located throughout the OKI region for the years of 1998-

2002. These data were supplemented with data collected at 

coverage count stations (locations with counts taken on only onetwo days). The stations were classified by area type (urban and 

rural) and functional classification (freeway, arterial and collector). 

Speeds representing various “loaded” conditions (with traffic 

volumes) are estimated using techniques from the 1997 Highway 

Capacity Manual. This permits the estimation of speeds as 

conditions vary from hour to hour on the different facility types 

throughout the region. The post-processing program performs the 

appropriate summation by area and roadway type as well as 

regional totals. OKI has also developed seasonal conversion factors 

to adjust traffic volumes to summer conditions. The factors were 

derived from local data collected at permanent traffic counting 

stations during 1994-1997 utilizing the average daily traffic monthly 

conversion factors for June, July and August. 

On-Road Mobile Emission Estimations

Tables 2 through 12 contain the results of the emissions analysis for the 

appropriate years. All emissions estimations are expressed in tons per year 

(tpy). 

Table 2 - Butler County, Ohio Emissions Estimations for On-Road 

Mobile Sources 

2005 2008 2015 2021 

PM2.5 (tpy) 413.970 377.640 301.16 215.76 

NOx (tpy) 10,910.37 9,803.70 6,064.61 3,757.91 

SO2 (tpy) 30.01 34.25 34.28 37.90 

Annual VMT 2,469,168,490 2,598,061,793 2,792,190,918 2,966,040,396 

Table 3 – Clermont County, Ohio Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2021 

PM2.5 (tpy) 281.790 256.600 204.32 145.39 

NOx (tpy) 7,295.87 6,516.40 3,993.63 2,449.31 

SO2 (tpy) 20.51 23.32 23.34 25.66 

Annual VMT 1,684,261,582 1,765,146,867 1,899,319,930 2,005,373,961 

 

 
 21 

Table 4 – Hamilton County, Ohio Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2021 

PM2.5 (tpy) 1,222.020 1,080.540 826.00 571.48 

NOx (tpy) 31,127.09 27,020.93 15,925.19 9,530.16 

SO2 (tpy) 88.85 98.30 94.43 100.82 

Annual VMT 7,241,536,812 7,421,012,594 7,630,239,650 7,811,745,310 

Table 5 – Warren County, Ohio Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2021 

PM2.5 (tpy) 320.740 289.560 242.05 177.61 

NOx (tpy) 8,224.57 7,267.18 4,598.44 2,875.72 

SO2 (tpy) 23.54 26.57 27.77 31.58 

Annual VMT 1,949,619,088 2,031,755,542 2,285,057,933 2,498,434,852 

Table 6 – Dearborn County, Ohio Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2021 

PM2.5 (tpy) 33.980 29.890 25.14 18.11 

NOx (tpy) 865.46 748.81 482.33 297.95 

SO2 (tpy) 2.45 2.69 2.87 3.19 

Annual VMT 196,738,031 199,778,078 223,644,622 240,321,759 

Table 7 – Summary of Ohio and Indiana Emissions Estimations for 

On-Road Mobile Sources 

 2005 2008 2015 2021 

PM2.5 (tpy) 2,272.50 2,034.23 1,598.67 1,128.35 

NOx (tpy) 58,423.36 51,357.02 31,064.20 18,911.05 

SO2 (tpy) 165.36 185.13 182.69 199.15 

Annual VMT 13,541,324,003 14,015,754,874 14,830,453,053 15,521,916,278 

Table 8 – Boone County, Kentucky Emissions Estimations for OnRoad Mobile Sources 

 2005 2008 2015 2021 

PM2.5 (tpy) 205.210 251.850 151.35 114.05 

NOx (tpy) 5,126.88 5,067.94 2,788.45 1,772.72 

SO2 (tpy) 15.91 16.71 20.67 24.37 

Annual VMT 1,273,226,967 1,350,001,539 1,628,041,282 1,800,571,684 

Table 9 – Campbell County, Kentucky Emissions Estimations for OnRoad Mobile Sources 

 2005 2008 2015 2021 

PM2.5 (tpy) 120.300 146.460 82.36 60.09 

NOx (tpy) 3,041.21 2,988.33 1,570.14 985.28 

SO2 (tpy) 9.30 9.69 11.21 12.77 

Annual VMT 741,790,595 774,762,718 875,774,487 936,445,352 
 22 

Table 10 – Kenton County, Kentucky Emissions Estimations for OnRoad Mobile Sources 

 2005 2008 2015 2021 

PM2.5 (tpy) 212.290 29.890 137.40 101.24 

NOx (tpy) 5,328.44 5,057.93 2,637.63 1,677.96 

SO2 (tpy) 16.24 16.34 18.62 21.48 

Annual VMT 1,274,091,641 1,300,575,248 1,427,569,972 1,549,817,325 

Table 11 – Summary of Kentucky Emissions Estimations for On-Road 

Mobile Sources 

 2005 2008 2015 2021 

PM2.5 (tpy) 537.8 645.62 371.11 275.38

NOx (tpy) 13,496.53 13,114.20 6,996.22 6,421.15

SO2 (tpy) 41.45 42.74 50.50 72.15

Annual VMT 3,289,109,203.00 3,425,339,505.00 3,931,385,741.00 5,452,303,073.00

Table 12 – Emissions Estimations Totals for On-Road Mobile Sources 

for the Cincinnati-Hamilton Area 

 2005 2008 2015 2021 

PM2.5 (tpy) 2,810.30 2,679.85 1,969.78 1,403.73

NOx (tpy) 71,919.89 64,471.22 38,060.42 25,332.20

SO2 (tpy) 206.81 227.87 233.19 271.30

Annual VMT 16,830,433,206.00 17,441,094,379.00 18,761,838,794.00 20,974,219,351.00

Motor Vehicle Emission Budget

Table 13 and Table 14 contain the motor vehicle emissions budgets 

for the Cincinnati-Hamilton area. For planning purposes, budgets are 

established for the combined Ohio and Indiana portions and for the 

separate Kentucky portion. 

Table 13 - Mobile Vehicle Emissions Budget for Ohio and Indiana 

 2015 Estimated 

Emissions 

2015 Mobile 

Safety Margin 

Allocation* 

2015 Total 

Mobile 

Budget 

2021 Estimated 

Emissions 

2021 Mobile 

Safety Margin 

Allocation* 

2021 Total 

Mobile 

Budget 

PM2.5 (tpy) 1598.67 79.93 1678.60 1128.35 112.84 1241.19

NOx (tpy) 31,064.20 4659.63 35,723.83 18,911.05 2836.65 21,747.71

Annual VMT 14,830,453,053 - - 15,521,916,278 - - 

*The 5 to15 percent margin of safety was calculated by taking 5 to15 percent of the mobile source emission estimates 

Table 14 - Mobile Vehicle Emissions Budget for Kentucky 

 2015 

Estimated 

Emissions 

2015 Mobile 

Safety Margin 

Allocation* 

2015 Total 

Mobile 

Budget 

2021 

Estimated 

Emissions 

2021 Mobile 

Safety Margin 

Allocation* 

2021 Total 

Mobile 

Budget 

PM2.5 (tpy) 371.11 18.56 389.67 275.38 27.54 302.92 

NOx (tpy) 6,996.22 1049.43 8,045.65 6,421.15 963.17 7,384.32

Annual VMT 3,931,385,741 5,452,303,073 

*The 5 to15 percent margin of safety was calculated by taking 5 to15 percent of the mobile source emission estimates 
 23 

The above budgets for the Ohio and Indiana portion and for the 

Kentucky portion of the area, agreed upon as part of the interagency 

consultation process, include the emission estimates calculated for 

2015 and 2021 (from Table 7 and Table 11) with an additional 5 

percent margin of safety allocated for PM2.5 in 2015, 10 percent 

margin of safety allocated to PM2.5 in 2021 and 15 percent margin of 

safety allocated to NOx in 2015 and 2021. 

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 5 to15 percent margin of safety allocation was agreed 

upon and has been added to the emissions estimates for the Ohio 

and Indiana portions of this nonattainment area. 

All methodologies, the latest planning assumptions, and the safety 

margins allocations were determined through the interagency 

consultation process described in the Transportation Conformity 

Memorandum of Understanding (MOU) among OKI, Ohio DOT, and 

Ohio EPA. 

A 5 to15 percent margin of safety is appropriate because: 1) there is 

an acknowledged potential variation in VMT forecast and potential 

estimated mobile source emissions due to expected modifications to 

TDM and mobile emissions models; and 2) the total decrease in 

emissions from all sources is sufficient to accommodate this 5 to15 

percent allocation of safety margin (as defined in 40 CFR93.1019

) to 

mobile sources while still continuing to maintain the total emissions 

in the Cincinnati-Hamilton area well below the 2008 attainment level 

of emissions. 

 

The 5 to 15 percent margin of safety was calculated by taking 5 to 

15 percent of the mobile source emission estimates. Safety margin, 

as defined by the conformity rule, looks at the total emissions from 

all sources in the nonattainment area. The actual allocation is less 

than 5 to 15 percent of the total emission reduction from all sources 

as can be seen from Table 44. 

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

margin allocation translates into an additional 98.49 tpy for PM2.5

and 5,709.06 tpy for NOx for 2015 and an additional 140.38 tpy for 

PM2.5 and 3,799.82 tpy for NOx for 2021. 

 

9 "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.
 24 

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

93.101, discussed under “Requirement 3 of 5” below, it is evident 

this allocation is significantly below the total safety margin for this 

area. 

The current PM2.5 and NOx mobile budgets for the fine particle 

NAAQS will no longer be applicable either after the effective date of 

the approved redesignation or after the effective date of any U.S. 

EPA action approving a finding that the PM2.5 and NOx conformity 

budgets included in this submittal are adequate for transportation 

conformity purposes, whichever date comes first. 

Finally, it is important to underline that all motor vehicle emission 

budgets in this Redesignation submittal, which are based on 

MOVES2010, will replace previous motor vehicle emission budgets 

on Attainment Demonstration submittals based on MOBILE6.2. 

Requirement 3 of 5 

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

PM2.5 standard. 

Background

In consultation with U.S. EPA, Ohio EPA selected the year 2021 as 

the maintenance year for this redesignation request. This document 

contains projected emissions inventories for 2015 and 2021. 

Emission projections for the Cincinnati-Hamilton area were 

performed using the following approaches: 

• As performed by OKI, mobile source emission projections are 

based on the U.S. EPA MOVES model. The analysis is 

described in more detail in Appendix C. All projections were 

made in accordance with “Procedures for Preparing Emissions 

Projections” U.S. EPA-45/4-91-019. 

• Emissions inventories are required to be projected to future 

dates to assess the influence growth and future controls will 

have. LADCO has developed growth and control files for point, 

area, and non-road categories. These files were used to develop 

the future-year emissions estimates used in this document. This 

was done so the inventories used for redesignation are 

consistent with modeling performed in the future. Appendix D 
 25 

contains LADCO’s technical support document detailing the 

analysis used to project emissions (Base M10). 

• For the Ohio portion of the Cincinnati-Hamilton area, for the 2008 

attainment year, emissions were grown from the 2005 LADCO 

modeling inventory, using LADCO’s growth factors, for all 

sectors except point sources (electrical generating units and 

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

were compiled from Ohio EPA’s 2008 annual emissions 

inventory database. The 2015 interim year emissions were 

estimated based on the 2009 and 2018 LADCO modeling 

inventory, using LADCO’s growth factors, for all sectors. The 

2021 maintenance year is based on emissions estimates from 

the 2018 LADCO modeling. 

The detailed inventory information for the Ohio portion of the 

Cincinnati-Hamilton area for 2005 is in Appendix B. Emission trends 

are an important gauge for continued compliance with the PM2.5

standard. Therefore, Ohio EPA performed an initial comparison of 

the inventories for the base year and maintenance years. Mobile 

source emission inventories are described in Section 5 of Appendix 

B. 

Sectors included in the following tables are: Electrical Generating 

Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Area (Other); Marine; Aircraft; Rail 

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

Ohio EPA is identifying emissions projections for 2015 and 2021 for 

EGUs with implementation of the CAIR program. U.S. EPA has 

raised concerns regarding the CAIR program and its remand. 

However, as discussed below, with the proposed CAIR replacement, 

the Transport Rule, Ohio EPA believes these are the most 

appropriate and accurate future projections. 

On March 10, 2004, the U.S. EPA promulgated the CAIR. 

Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 

eastern states and the District of Columbia to significantly reduce 

emissions of NOx and SO2. CAIR replaced the NOx SIP Call for 

EGUs. The intent of the CAIR program is for national NOx emissions 

to be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 

2009, and 1.3 million tons in 2018 in 28 states. States were required 

to submit a CAIR SIP as part of this effort. Ohio submitted a CAIR 

SIP which was approved by U.S. EPA on February 1, 2007. 

 

10 http://www.ladco.org/tech/emis/current/index.php 
 26 

Revisions to the CAIR SIP were again submitted on July 15, 2009. 

The revised CAIR SIP was approved as a direct final action on 

September 25, 2009 (74 FR 48857). As a result of CAIR, U.S. EPA 

projects that in 2009 emissions of NOx will decrease from a baseline 

of 264,000 tons per year to 93,000 tons per year while in 2010 

emissions of SO2 will decrease from a baseline of 1,373,000 tons 

per year to 298,000 tons per year, within Ohio. And by 2015 U.S. 

EPA projects emissions of NOx will decrease to 83,000 tons per year 

while emissions of SO2 will decrease to 208,000 tons per year, 

within Ohio11. 

On December 23, 2008, U.S. EPA’s CAIR program was remanded 

without vacatur by the D.C. Circuit Court. As mentioned above, Ohio 

EPA has not incorporated these expected CAIR reductions into this 

redesignation request. It should also be noted that Ohio’s SIPapproved NOx SIP Call program and regulations are still in place. 

Ohio EPA is currently in the process of revising these regulations to 

provide a “back stop” for the reinstatement of the NOx SIP Call 

program in the event the CAIR program, or an equivalent, is no 

longer implemented by U.S. EPA. 

As can be seen in Table 15 below, Ohio has seen a significant 

decline in the 264,000 tons of NOx and 1,373,000 tons of SO2

emitted in 2005. In 2008 and 2009 facilities began preparing for and 

implementing control programs to address CAIR12 and consent 

decrees. 

Table 15 - Reductions in SO2 and NOx EGU Emissions Between 

2008 and 2009 

SO2 NOx

 2008 2009 Change 2008 2009 Change 

Ohio 709,444 601,101 15% 235,018 96,351 59% 

LADCO States 2,019,036 1,620,071 20% 702,384 393,930 44% 

National 7,616,262 5,747,353 25% 2,996,287 1,990,385 34% 

Source: Clean Air Markets Quarterly Emissions Tracking13

Significant reductions also occurred regionally and nationally as can 

be seen from the above. Data is also available for the first two 

quarters of 2010, the year SO2 reductions are to be implemented 

under CAIR: 

 

11 http://www.epa.gov/CAIR/oh.html 

12 Under CAIR, NOx reductions are to occur beginning in 2009 while SO2 reductions are to occur 

beginning in 2010.

13 http://www.epa.gov/airmarkets/quarterlytracking.html
 27 

Table 16 – Reductions in SO2 and NOx EGU Emissions 

Between the First Half of 2008 and 2010 

SO2 NOx

 2008 

(1st half) 

2010 

(1st half) Change 2008 

(1st half) 

2010 

(1st half) Change 

Ohio 373,798 279,854 25% 130,598 53,187 59% 

LADCO States 1,190,497 854,282 28% 419,114 220,907 47% 

National 3,895,472 2,502,965 36% 1,487,179 930,148 37% 

Source: Clean Air Markets Quarterly Emissions Tracking14

The following was reported by U.S. EPA’s Clean Markets Division: 

“Based on emissions monitoring data, EPA has observed substantial 

reductions in SO2 emissions from 2005 to 2009 and in the first two 

quarters of 2010 as companies installed more controls, electric 

demand declined, and low natural gas prices made combined-cycle 

gas-fired units more competitive in several parts of the country. 

Thus, even after CAIR's vacatur and subsequent remand in late 

2008, the controls in place generally have continued to operate, 

helping to drive continued progress in reducing emissions.15” 

On July 6, 2010, U.S. EPA proposed a replacement to the CAIR 

program, the Transport Rule. [75 FR 45210] U.S. EPA intends to 

finalize the Transport Rule in time for reductions to begin in 2012. 

As proposed, the Transport Rule will preserve those initial 

reductions achieved under CAIR and provide more reductions in 

NOx and SO2 emissions in 2012 and 2014, ahead of the 2015 CAIR 

Phase 2. 

Ohio EPA is in agreement with the analysis by U.S.EPA that the 

CAIR program is providing real reductions at this time, Ohio believes 

these reductions have assisted with PM2.5 attainment in this 

nonattainment area and throughout Ohio. It is also Ohio EPA’s 

belief that the Transport Rule, when finalized, will continue to 

provide the necessary reductions, and likely even greater 

reductions, that will be necessary for maintenance of the annual 

PM2.5 standard to occur. As stated by U.S. EPA regarding the 

proposed Transport Rule, “the results of the air quality modeling 

indicate that all but one site16 is projected to be in attainment and 

only one site17 is projected to have a maintenance problem for 

annual PM2.5 in 2014 with the emissions reductions expected from 

this proposal.” [75 FR 45345] Therefore, it is Ohio EPA’s belief it is 

most appropriate to evaluate Ohio EPA’s demonstration that the 

 

14 http://www.epa.gov/airmarkets/quarterlytracking.html

15 http://www.epa.gov/airmarkets/background.htm

16 Allegheny, PA

17 Birmingham, AL
 28 

projected level of emissions is sufficient to maintain the annual PM2.5

standard by assessing future year emissions that include the CAIR 

program. 

Maintenance is demonstrated when the future-year (2021) projected 

emission totals are below the 2008 attainment year totals. 

The Ohio emissions data in the tables below are based on the 

following data sources: 

- All On-Road data source: OKI Transportation Modeling 

Department. 

- 2008 EGU and non-EGU: Ohio EPA’s 2008 annual emissions 

inventory database. 

- All other data source: Lake Michigan Air Directors Consortium 

(LADCO). 

Demonstration

PM2.5

The 2005 and 2008 actual PM2.5 emissions data below generally contains 

particulate fraction emissions only and not the condensable fractions as 

Ohio EPA did not have a consistent reporting requirement at those years. 

U.S. EPA Integrated Planning Model (IPM) modeling was used to generate 

future year EGU emissions with the CAIR program. The IPM modeling 

added additional PM2.5 condensable emissions into future years. Therefore, 

comparing base and attainment year emissions with the future year 

predictions is not accurate in the IPM CAIR modeling. This step leads to a 

false perception of significant PM2.5 emissions growth. Modeling performed 

by LADCO, without CAIR, did not incorporate added condensable fraction 

emissions. Although Ohio EPA has stated that it is most appropriate to 

evaluate future year emissions that include the CAIR program, because of 

this flaw it will be more accurate and appropriate for the purposes of PM2.5 

to evaluate future year emissions without the CAIR program. 

Table 17 - Butler County18, Ohio PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – Without CAIR

 

18 Ohio EPA has revised the Butler County, Ohio PM2.5, NOx and SO2 Emissions Inventory (non-EGU) to 

incorporate the total emissions reduction credits available and used to offset the allowed emissions of a 
 29 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

EGU Point 15.27 16.78 15.86 15.59 1.19 

Non-EGU 944.29 1045.15 1254.70 1337.03 -291.88 

Non-road 185.28 158.41 109.75 66.98 91.43 

Other 173.24 180.43 180.86 182.45 -2.02 

MAR 31.19 27.40 16.01 6.43 20.97 

On-road 413.97 377.64 301.16 215.76 161.88 

TOTAL 1763.24 1805.81 1878.34 1824.24 -18.43 

Table 18 - Clermont County, Ohio PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

EGU Point 648.21 532.61 651.88 711.22 -178.61 

Non-EGU 7.93 3.86 6.42 7.33 -3.47 

Non-road 104.54 89.84 62.51 38.56 51.28 

Other 193.70 196.15 193.49 191.83 4.32 

MAR 6.11 5.64 3.54 1.81 3.83 

On-road 281.79 256.60 204.32 145.39 111.21 

TOTAL 1242.28 1084.70 1122.16 1096.14 -11.44 

 

Table 19 - Hamilton County, Ohio PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – Without CAIR

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

EGU Point 648.64 202.88 554.65 708.74 -505.86 

Non-EGU 161.88 158.14 171.28 179.45 -21.31 

Non-road 355.97 307.30 218.86 141.16 166.14 

Other 303.61 323.94 330.03 338.37 -14.43 

MAR 42.04 37.82 23.54 11.64 26.18 

On-road 1222.02 1080.54 826.00 571.48 509.06 

TOTAL 2734.16 2110.62 2124.36 1950.84 159.78 

 

 

Table 20 - Warren County, Ohio PM2.5 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – Without CAIR 

 major source modified within the maintenance area that will begin operating during the maintenance period. 

The total emissions included in the inventory, and in all the Butler County tables below for this facility in 

2015 and 2021, are 117.81 tpy PM2.5, 479.57 tpy NOx and 1209.92 tpy SO2. The emissions increase does 

not significantly impact the safety margin for this area or prevent the area from maintaining the standard in 

future years. 
 30 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 18.75 19.91 19.01 18.60 1.31 

Non-road 143.72 122.20 79.69 42.68 79.52 

Other 236.92 238.33 233.88 230.65 7.68 

MAR 2.95 2.58 1.53 0.64 1.94 

On-road 320.74 289.56 242.05 177.61 111.95 

TOTAL 723.08 672.58 576.16 470.18 202.40 

Table 21 - Dearborn County, Indiana PM2.5 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim

2021 

Maintenance 

Safety 

Margin 

EGU Point 673.94 804.18 847.16 922.81 -118.63 

Non-EGU 67.38 62.02 60.00 57.32 4.70 

Non-road 23.96 19.91 13.34 9.07 10.84 

Other 4.29 4.29 4.11 3.98 0.31 

MAR 

On-road 33.98 29.89 25.14 18.11 11.78 

TOTAL 803.55 920.29 949.75 1011.29 -91.00 

*MAR emissions are included in Non-road emissions 

Table 22 - Boone County, Kentucky PM2.5 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 19

2015 

Interim

2021 

Maintenance

Safety 

Margin 

EGU Point 76.85 76.70 80.70 83.42 -6.72 

Non-EGU 58.77 68.81 84.35 98.94 -30.13 

Non-road 89.15 82.90 62.42 45.30 37.60 

Other 351.27 353.71 359.57 364.58 -10.87 

MAR 215.61 227.62 206.01 191.23 36.39 

On-road 205.21 251.85 151.35 114.05 137.80 

TOTAL 996.86 1061.59 944.40 897.52 164.07 

Table 23 - Campbell County, Kentucky PM2.5 Emission Inventory Total 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim

2021 

Maintenance

Safety 

Margin 

 

19 Kentucky 2008 data is grown from the 2005 LADCO modeling inventory, using LADCO’s growth 

factors, for all sectors, including EGUs.
 31 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 84.26 89.52 101.84 112.39 -22.87 

Non-road 25.29 22.35 16.18 10.84 11.51 

Other 200.08 201.26 200.05 199.32 1.94 

MAR 55.66 53.74 41.25 31.15 22.59 

On-road 120.30 146.46 82.36 60.09 86.37 

TOTAL 485.59 513.33 441.68 413.79 99.54 

Table 24 - Kenton County, Kentucky PM2.5 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – Without CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim

2021 

Maintenance

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 9.53 11.11 13.50 15.76 -4.65 

Non-road 56.44 50.98 38.18 27.22 23.76 

Other 365.74 366.69 363.77 361.65 5.04 

MAR 62.64 59.63 44.85 32.76 26.87 

On-road 212.29 247.31 137.40 101.24 146.07 

TOTAL 706.64 735.72 597.70 538.63 197.09 

Table 25 – Cincinnati-Hamilton Area PM2.5 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and projected 2015 

and 2021 (tpy) – Without CAIR 

PM2.5

2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

Butler 1763.24 1805.81 1878.34 1824.24 -18.43 

Clermont 1242.28 1084.70 1122.16 1096.14 -11.44 

Hamilton 2734.16 2110.62 2124.36 1950.84 159.78 

Warren 723.08 672.58 576.16 470.18 202.40 

Dearborn 803.55 920.29 949.75 1011.29 -91.00 

Boone 996.86 1061.59 944.40 897.52 164.07 

Campbell 485.59 513.33 441.68 413.79 99.54 

Kenton 706.64 735.72 597.70 538.63 197.09 

COMBINED 

PM2.5 TOTAL 9455.40 8904.64 8634.55 8202.63 702.01 

 

NOx
 32 

Table 26 - Butler County, Ohio NOx Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim 

2021 

Maintenanc

e 

Safety 

Margin 

EGU Point 743.27 856.92 343.95 124.10 732.82 

Non-EGU 4367.15 3940.28 4626.45 4686.11 -745.83 

Non-road 2348.42 1986.81 1228.83 572.69 1414.12 

Other 796.34 807.64 811.94 817.28 -9.64 

MAR 919.91 847.08 545.76 297.37 549.71 

On-road 10910.37 9803.70 6064.61 3757.91 6045.79 

TOTAL 20085.46 18242.43 13621.54 10255.46 7986.97 

Table 27 - Clermont County, Ohio NOx Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim 

2021 

Maintenanc

e 

Safety 

Margin 

EGU Point 28063.56 24233.18 16491.26 10451.28 13781.90 

Non-EGU 67.50 42.71 60.83 68.68 -25.97 

Non-road 1218.23 1039.67 655.01 322.89 716.78 

Other 612.97 619.27 620.94 623.36 -4.09 

MAR 259.07 245.25 159.04 89.20 156.05 

On-road 7295.87 6516.40 3993.63 2449.31 4067.09 

TOTAL 37517.20 32696.48 21980.71 14004.72 18691.76 

 

Table 28 - Hamilton County, Ohio NOx Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim 

2021 

Maintenanc

e 

Safety 

Margin 

EGU Point 15236.04 12372.00 7236.90 5036.15 7335.85 

Non-EGU 2756.21 2652.79 2943.73 3139.37 -486.58 

Non-road 4845.98 4029.63 2464.90 1098.14 2931.49 

Other 1923.27 1955.47 1974.77 1995.51 -40.04 

MAR 1463.80 1372.41 909.89 532.19 840.22 

On-road 31127.09 27020.93 15925.19 9530.16 17490.77 

TOTAL 57352.39 49403.23 31455.38 21331.52 28071.71 

 
 33 

Table 29 - Warren County, Ohio NOx Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 1024.95 1043.27 1035.29 1034.26 9.01 

Non-road 1789.97 1517.53 919.21 403.56 1113.97 

Other 426.57 432.28 434.26 436.82 -4.54 

MAR 96.07 89.92 60.22 35.92 54.00 

On-road 8224.57 7267.18 4598.44 2875.72 4391.46 

TOTAL 11562.13 10350.18 7047.42 4786.28 5563.90 

Table 30 - Dearborn County, Indiana NOx Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

EGU Point 7961.30 7429.20 9862.76 11229.31 -3800.11 

Non-EGU 2024.68 1979.83 1965.19 1943.22 36.61 

Non-road 382.53 318.09 219.83 154.18 163.91 

Other 141.37 145.42 143.39 142.90 2.52 

MAR* 

On-road 865.46 748.81 482.33 297.95 450.86 

TOTAL 11375.34 10621.35 12673.50 13767.56 -3146.21 

*MAR emissions are included in Non-road emissions

Table 31 - Boone County, Kentucky NOx Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim 

2021 

Maintenance

Safety 

Margin 

EGU Point 3926.27 1962.59 1504.39 1308.03 654.56 

Non-EGU 58.03 61.66 66.48 71.21 -9.55 

Non-road 931.11 845.72 582.34 361.41 484.31 

Other 1844.50 1897.28 1985.25 2063.30 -166.02 

MAR 2927.85 2926.70 2310.38 1828.25 1098.45 

On-road 5126.88 5067.94 2788.45 1772.72 3295.22 

TOTAL 14814.64 12761.89 9237.29 7404.92 5356.97 

Table 32 – Campbell County, Kentucky NOx Emission Inventory Total 

for Base Year 2005, Estimated 2008, and Projected 2015 
 34 

and 2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 53.68 49.52 53.81 55.21 -5.69 

Non-road 284.66 261.59 189.27 128.67 132.92 

Other 523.45 536.71 563.83 587.37 -50.66 

MAR 1617.89 1571.87 1156.10 822.91 748.96 

On-road 3041.21 2988.33 1570.14 985.28 2003.05 

TOTAL 5520.89 5408.02 3533.15 2579.44 2828.58 

Table 33 – Kenton County, Kentucky NOx Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 19.50 20.44 21.79 23.09 -2.65 

Non-road 616.67 562.88 395.18 254.61 308.27 

Other 1542.27 1581.60 1654.75 1718.86 -137.26 

MAR 2068.01 1999.72 1453.68 1014.71 985.01 

On-road 5328.44 5057.93 2637.63 1677.96 3379.97 

TOTAL 9574.89 9222.57 6163.03 4689.23 4533.34 

Table 34 - Cincinnati-Hamilton Area NOx Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – With CAIR 

NOx 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

Butler 20085.46 18242.43 13621.54 10255.46 7986.97 

Clermont 37517.20 32696.48 21980.71 14004.72 18691.76 

Hamilton 57352.39 49403.23 31455.38 21331.52 28071.71 

Warren 11562.13 10350.18 7047.42 4786.28 5563.90 

Dearborn 11375.34 10621.35 12673.50 13767.56 -3146.21 

Boone 14814.64 12761.89 9237.29 7404.92 5356.97 

Campbell 5520.89 5408.02 3533.15 2579.44 2828.58 

Kenton 9574.89 9222.57 6163.03 4689.23 4533.34 

COMBINED 

NOx TOTAL 167802.94 148706.15 105712.02 78819.13 69887.02 

SO2
 35 

Table 35 - Butler County, Ohio SO2 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenanc

e 

Safety 

Margin 

EGU Point 1959.10 2181.63 654.49 0.00 2181.63 

Non-EGU 6185.26 5442.54 6847.48 6828.13 -1385.59 

Non-road 260.36 95.29 15.09 0.80 94.49 

Other 224.54 221.09 209.01 198.96 22.13 

MAR 80.84 79.05 62.61 49.44 29.61 

On-road 30.01 34.25 34.28 37.90 -3.65 

TOTAL 8740.11 8053.85 7822.96 7115.23 938.62 

Table 36 - Clermont County, Ohio SO2 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim 

2021 

Maintenanc

e 

Safety 

Margin 

EGU Point 88876.65 42918.28 32590.92 20589.16 22329.12 

Non-EGU 162.19 118.05 148.28 160.98 -42.93 

Non-road 138.93 50.86 8.05 0.43 50.43 

Other 164.72 162.20 151.29 142.32 19.88 

MAR 22.73 15.39 5.26 0.78 14.61 

On-road 20.51 23.32 23.34 25.66 -2.34 

TOTAL 89385.73 43288.10 32927.14 20919.33 22368.77 

Table 37 - Hamilton County, Ohio SO2 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim 

2021 

Maintenanc

e 

Safety 

Margin 

EGU Point 77381.13 24693.00 16390.65 7508.46 17184.54 

Non-EGU 7819.40 6552.65 7739.34 8309.88 -1757.23 

Non-road 474.85 174.16 28.47 1.93 172.23 

Other 163.45 161.80 151.81 143.71 18.09 

MAR 117.60 100.46 64.96 34.20 66.26 

On-road 88.85 98.30 94.43 100.82 -2.52 

TOTAL 86045.28 31780.37 24469.66 16099.00 15681.37 

 

 
 36 

Table 38 - Warren County, Ohio SO2 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 3.39 3.53 3.45 3.42 0.11 

Non-road 23.54 26.57 27.77 31.58 -5.01 

Other 140.25 138.31 131.36 125.59 12.72 

MAR 8.13 7.99 6.34 5.03 2.96 

On-road 208.73 76.29 11.87 1.73 74.56 

TOTAL 384.4 252.69 180.79 167.35 85.34 

Table 39 - Dearborn County, Indiana SO2 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment

2015 

Interim 

2021 

Maintenanc

e 

Safety 

Margin 

EGU Point 46533.70 25729.10 39295.70 36843.66 -11114.56 

Non-EGU 1331.15 1334.33 1335.94 1337.95 -3.62 

Non-road 40.16 17.38 4.73 1.14 16.24 

Other 78.72 81.02 77.64 75.69 5.33 

MAR* 

On-road 2.45 2.69 2.87 3.19 -0.50 

TOTAL 47986.18 27164.52 40716.88 38261.63 -111097.11 

*MAR emissions are included in Non-road emissions

 

Table 40 - Boone County, Kentucky SO2 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance

Safety 

Margin 

EGU Point 3644.98 2812.16 2617.84 2534.56 277.60 

Non-EGU 16.82 17.97 19.50 21.01 -3.04 

Non-road 59.56 26.45 5.98 0.51 25.94 

Other 1054.33 1066.79 1093.47 1116.53 -49.74 

MAR 434.71 409.48 322.39 249.85 159.63 

On-road 15.91 16.71 20.67 24.37 -7.66 

TOTAL 5226.31 4349.56 4079.85 3946.83 402.73 
 37 

Table 41 - Campbell County, Kentucky SO2 Emission Inventory Total 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim

2021 

Maintenance

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 0.97 0.96 1.04 1.09 -0.13 

Non-road 18.01 7.89 1.78 0.17 7.72 

Other 471.77 479.14 491.66 502.75 -23.61 

MAR 221.98 198.32 147.50 103.61 94.71 

On-road 9.30 9.69 11.21 12.77 -3.08 

TOTAL 722.03 696.00 653.19 620.39 75.61 

Table 42 - Kenton County, Kentucky SO2 Emission Inventory Totals 

for Base Year 2005, Estimated 2008, and Projected 2015 

and 2021 (tpy) – With CAIR 

Sector 2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance

Safety 

Margin 

EGU Point 0.00 0.00 0.00 0.00 0.00 

Non-EGU 12.91 13.89 15.16 16.41 -2.52 

Non-road 41.75 18.27 4.01 0.31 17.96 

Other 1196.61 1210.42 1238.92 1263.63 -53.21 

MAR 206.59 172.13 123.08 78.68 93.45 

On-road 16.24 16.34 18.62 21.48 -5.14 

TOTAL 1474.10 1431.05 1399.79 1380.51 50.54 

Table 43 - Cincinnati-Hamilton Area SO2 Emission Inventory Totals for 

Base Year 2005, Estimated 2008, and Projected 2015 and 

2021 (tpy) – With CAIR 

SO2

2005 

Base 

2008 

Attainment 

2015 

Interim 

2021 

Maintenance 

Safety 

Margin 

Butler 8740.11 8053.85 7822.96 7115.23 938.62 

Clermont 89385.73 43288.10 32927.14 20919.33 22368.77 

Hamilton 86045.28 31780.37 24469.66 16099.00 15681.37 

Warren 384.04 252.69 180.79 167.35 85.34 

Dearborn 47986.18 27164.52 40716.88 38261.63 -11097.11 

Boone 5226.31 4349.56 4079.85 3946.83 402.73 

Campbell 722.03 696.00 653.19 620.39 75.61 

Kenton 1474.10 1431.05 1399.79 1380.51 50.54 

COMBINED 

SO2 TOTAL 239963.78 117016.14 112250.26 88510.27 28505.87 
 38 

PM2.5, NOx, and SO2

Table 44 - Cincinnati-Hamilton Area Comparison of 2008 attainment 

year and 2015 and 2021 projected emission estimates 

(tpy) 

 

2008 Base 2015 

Interim 

2015 

Projected 

Decrease 

2021 

Maintenance

2021 

Projected 

Decrease 

PM2.5 8,904.64 8,634.55 270.09 8,202.63 702.01 

NOx 148,706.15 105,712.02 42,994.13 78,819.13 69,887.02 

SO2 117,016.14 112,250.26 4,765.88 88,510.27 28,505.87 

 

As shown in the table above (Table 44), PM2.5 emissions in the 

nonattainment area are projected to decrease by 270.09 tpy in 2015 

and 702.01 tpy in 2021. NOx emissions in the nonattainment area 

are projected to decrease by 42,994.13 tpy in 2015 and 69,887.02 

tpy in 2021. SO2 emissions in the nonattainment area are projected 

to decline by 4,765.88 tpy in 2015 and 28,505.87 in 2021. 

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

an increase due to expectations that the population will grow in this 

area; however, cleaner vehicles and fuels are expected to be in 

place in 2009 and 2018, and the Transport Rule will be implemented 

in 2012 and 2014 and these programs should cause an overall drop 

in all three pollutants emissions. Decreases from U.S. EPA rules 

covering Tier 2 Motor Vehicle Emissions Standards and Gasoline 

Sulfur Control Requirements20, Highway Heavy-Duty Engine Rule21, 

and the Non-Road Diesel Engine Rule22 are factored into the 

changes. 

In addition to the above, the Miami Fort Station in Hamilton County 

implemented important changes in 2007. Two units, B005 (# 5-1) 

and B006 (# 5-2) permanently shut down effective December 31, 

2007. Each were 50 megawatt coal fired boilers. In addition, units 

B015 (# 7) and B017 (# 8) were issued a new source review permitto-install scrubbers, accepting a restricted SO2 allowable emissions 

rate that will not cause or contribute to a violation of a National 

Ambient Air Quality Standard (NAAQS) and/or Prevention of 

Significant Deterioration (PSD) increment violation based upon air 

dispersion modeling. These scrubbers began operating in April 2007 

and December 2007.23 The following summarizes Miami Fort’s 

 

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

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

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

23 The lower rates will be incorporated into the facility’s Title V operating permit at renewal. 
 39 

emissions changes from the base year (2005), to the attainment 

year (2008), and for 2009: 

Table 45 - Miami Fort Station, Hamilton County, Emission Reductions 

(tpy) as Reported by Clean Air Markets Division 

SO2 NOx 

2005 77,583 12,264 

2008 24,693 12,371 

2009 25,340 4,338 

Requirement 4 of 5

A demonstration that improvement in air quality between the year violations 

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

enforceable emission reductions and not on temporary adverse economic 

conditions or unusually favorable meteorology. 

Background

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

the NAAQS for PM2.5 in 2007-2009. U.S. EPA’s redesignation guidance (p 

9) states: “A state may generally demonstrate maintenance of the NAAQS 

by either showing that future emissions of a pollutant or its precursors will 

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

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

of the NAAQS.” 

Demonstration

Permanent and enforceable reductions of PM2.5, NOx, and SO2 emissions 

have contributed to the attainment of the annual PM2.5 standard. Some of 

these reductions were due to the application of tighter federal standards on 

new vehicles. Also Title IV of the CAA, the NOx SIP Call, CAIR, and federal 

consent decrees required the reductions of SO2 and NOx emissions from 

utility sources. Reductions achieved are discussed in greater detail under 

Chapter Five. 

Table 46 - Cincinnati-Hamilton Area Combined Comparison of 2005 

base year and 2008 attainment year on-road and EGU 

reductions 

2005 2008 

On-road PM2.5 2810.30 2679.85 

On-road NOx 71919.89 64471.22 

On-road SO2 392.00 277.59 

EGU PM2.5 2062.91 1633.15 

EGU NOx 55930.44 46853.89 

EGU SO2 218395.56 98334.17 
 40 

Requirement 5 of 5 

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

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

Demonstration

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

emissions information annually, in accordance with U.S. EPA’s 

Consolidated Emissions Reporting Rule (CERR). Ohio EPA 

prepares a new periodic inventory for all PM2.5 precursor emission 

sectors every three years. These PM2.5 precursor inventories will be 

prepared for future years as necessary to comply with the inventory 

reporting requirements established in the CFR. Emissions 

information will be compared to the 2005 base year and the 2021 

projected maintenance year inventories to assess emission trends, 

as necessary, and to assure continued compliance with the annual 

PM2.5 standard. 
 41 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 6

Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with 

nonattainment areas to implement RACM and RACT. 

Background

Section 172(c)(1) of the 1990 Clean Air Act Amendments requires 

states with nonattainment areas to submit a SIP providing for 

implementation of all reasonably available control measures and 

expeditiously as practicable (including such reductions in emissions 

from existing sources in the area as may be obtained through the 

adoption, at a minimum, of reasonable available control technology). 

U.S. EPA’s Implementation Rule interprets this requirement in great 

detail. Under U.S. EPA’s approach, RACT is determined as part of 

the broader RACM analysis and identification of all measures (for 

stationary, mobile, and area sources) that are technically and 

economically feasible, and that would collectively contribute to 

advancing the attainment date (i.e. by one year or more). States are 

required to use a combined approach to RACT and RACM, that (1) 

identifies potential measures that are reasonable, (2) uses modeling 

to identify the attainment date that is as expeditious as practicable, 

and (3) selects the appropriate RACT and RACM. 

The Implementation Rule also provides for a presumption that in 

States that fulfill their CAIR emission reduction requirements, EGU 

compliance with CAIR is equivalent to RACM/RACT. 

Demonstration

In 1972, 1980, and 1991, Ohio promulgated rules requiring 

reasonably available controls measures for particulate emissions 

from stationary sources. 

Statewide 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 

3745-1724. 

 

24 http://www.epa.ohio.gov/dapc/regs/3745_17.aspx 
 42 

In addition, Ohio EPA promulgated NOx SIP Call rules (OAC 

Chapter 3745-1425), CAIR (OAC Chapter 3745-10926), and NOx

Reasonably Available Control Technology rules (OAC Chapter 

3745-11027) over the past five years. Emissions from EGUs make up 

a significant contribution to Ohio’s inventory. Beginning in 2009, 

Ohio implemented CAIR which has, and will, provide for significant 

reductions in NOx, PM2.5, and SO2 until such time it is replaced by 

U.S. EPA’s proposed Transport Rule. Then the Transport Rule will 

provide for even greater reductions. 

As part of a larger initiative, LADCO, in consultation with two 

contractors, performed a series of studies exploring control 

measures for reducing both ozone precursors and PM2.5 precursors 

in Ohio, Illinois, Indiana, Michigan, and Wisconsin area. The first 

consultant, MACTEC, prepared a series of white papers28

researching different stationary source categories. The results were 

compiled into two reports29. The second consultant, Environ, 

investigated control options for mobile sources. The results were 

compiled into two reports30. The stationary and mobile source 

sectors (and associated control measures) were selected by the 

LADCO States based on several factors presented in the report 

(See Chapter 2). 

Photochemical modeling was then conducted (as part of LADCO 

Round 4 modeling) to assess the air quality benefit of the candidate 

control measures and a modeling report was developed31. Based on 

the results, the LADCO project team felt it would not be possible to 

advance the attainment date for PM2.5. Ohio EPA, in its attainment 

demonstration submitted on July 18, 2008, demonstrated (using a 

weight of evidence approach) that attainment would be achieved in 

this area by 2009. Because of a projected 2009 attainment date, it 

would not have been reasonably possible or practicable for Ohio to 

 

25 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 

26 http://www.epa.ohio.gov/dapc/regs/3745_109.aspx 

27 http://www.epa.ohio.gov/dapc/regs/3745_110.aspx

28 http://www.ladco.org/reports/control/white_papers 

29 

http://www.ladco.org/reports/control/final_reports/identification_and_evaluation_of_candidate_control_measures_i_

april_2005.pdf; 

http://www.ladco.org/reports/control/final_reports/identification_and_evaluation_of_candidate_control_measures_ii_

june_2006.pdf 

30

http://www.ladco.org/reports/control/final_reports/final_report_evaluation_of_candidate_mobile_source_control_me

asures_february_2006.pdf; 

http://www.ladco.org/reports/control/final_reports/final_report_evaluation_of_candidate_mobile_source_control_me

asures_for_ladco_states_in_2009_and_2012_march_2007.pdf

31 http://www.ladco.org/reports/control/modeling/round4_modeling.pdf
 43 

develop RACT/RACM requirements, promulgate regulations and 

implement a control program prior to the projected attainment date. 

Requirement 2 of 6

Section 172(c)(2) of the 1990 CAA Amendments requires attainment 

demonstration SIPs for nonattainment areas to show reasonable further 

progress (RFP). 

Background

U.S. EPA’s Implementation Rule requires RFP only for any area 

which a State projects an attainment date beyond 2010. The RFP 

would provide emission reductions showing linear progress between 

2002 and 2009. If a State demonstrates attainment will occur by 

2010 or earlier, U.S. EPA considers the attainment demonstration to 

demonstrate achievement of RFP. 

Demonstration

In Ohio’s attainment demonstration submitted on July 18, 2008, 

Ohio demonstrated (using a weight of evidence approach) that 

attainment would be achieved in this area by 2009; and therefore, it 

was not necessary to submit a separate RFP plan. 

Requirement 3 of 6

Section 172(c)(3) requires states to submit a comprehensive inventory of actual 

emissions. 

Background

Section 172(c)(3) requires states to submit a comprehensive 

inventory of actual emissions in the area, including the requirement 

for periodic revisions as determined necessary. 40 CFR 51.1008 

requires such inventory to be submitted within three years of 

designation and requires a baseline emission inventory for calendar 

year 2002 or other suitable year to be used for attainment planning. 

Demonstration

The 2005 comprehensive inventory was submitted to U.S. EPA with 

Ohio’s PM2.5 attainment demonstration SIP submitted on July 18, 

2008. It was then subsequently revised and resubmitted on June 7, 

2010. 

Ohio also updates its inventory in accordance with U.S. EPA’s 

CERR rule (i.e. emissions statements). 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). As discussed in 

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

submit, emission inventories (statements) every three years. 
 44 

Requirement 4 of 6

Evidence that control measures required in past PM2.5 SIP revisions have been 

fully implemented. 

Background

In addition to the historic RACT requirements for PM, the U.S. EPA 

NOx SIP Call required 22 states to pass rules that would result in 

significant emission reductions from large EGUs, industrial boilers, 

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

in 2001. NOx SIP Call requirements are incorporated into permits 

along with monitoring, recordkeeping, and reporting necessary to 

ensure ongoing compliance. Ohio EPA also has an active 

enforcement program to address violations discovered by field office 

staff. Compliance is tracked through the Clean Air Markets data 

monitoring program. Beginning in 2004, this rule accounts for a 

reduction of approximately 31 percent of all NOx emissions 

statewide compared to previous uncontrolled years. The other 21 

states also have adopted these rules. 

On March 10, 2004, the U.S. EPA promulgated the CAIR. 

Beginning in 2009, U.S. EPA’s CAIR rule requires EGUs in 28 

eastern states and the District of Columbia to significantly reduce 

emissions of NOx and SO2. CAIR replaced the NOx SIP Call for 

EGUs. National NOx emissions will be cut from 4.5 million tons in 

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

2018 in 28 states. States were required to submit a CAIR SIP as 

part of this effort. Ohio submitted a CAIR SIP which was approved 

by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were 

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

approved as a direct final action on September 25, 2009 (74 FR 

48857). 

Demonstration

Controls for EGUs under the NOx SIP Call formally commenced May 

31, 2004. Emissions covered by this program have been generally 

trending downward since 1998 with larger reductions occurring in 

2002 and 2003. Data taken from the U.S. EPA Clean Air Markets 

web site, quantify the gradual NOx reductions that have occurred in 

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

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

Trading Program rules in OAC Chapter 3745-1432 in response to the 

SIP Call. OAC Chapter 3745-14 regulates EGUs and certain nonEGUs under a cap and trade program based on an 85 percent 

 

32 http://www.epa.ohio.gov/dapc/regs/3745_14.aspx 
 45 

reduction of NOx emissions from EGUs and a 60 percent reduction 

of NOx emissions from non-EGUs, compared to historical levels. 

This cap was in place through 2008, at which time the CAIR 

program superseded it as discussed above. Requirement 3 of 5 

under Chapter 4 above discussed the reductions Ohio has seen as 

a result of CAIR. 

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

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

emissions) stationary internal combustion engines. Ohio EPA’s OAC 

rule 3745-14-12 addresses stationary internal combustion engines, 

all used in natural gas pipeline transmissions. U.S. EPA approved 

this revision to the SIP on April 4, 2008. An 82 percent NOx 

reduction from 1995 levels is anticipated. Completion of the 

compliance plan occurred by May 1, 2006, and the compliance 

demonstration began May 1, 2007. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur 

Standards

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

reduce emissions from cars and light trucks, including sport utility 

vehicles (SUVs). Under this proposal, automakers will be required 

to sell cleaner cars, and refineries will be required to make cleaner, 

lower sulfur gasoline. This rule will apply nationwide. The federal 

rules will phase in between 2004 and 2009. U.S. EPA has 

estimated that NOx emission reductions will be approximately 77 

percent for passenger cars, 86 percent for smaller SUVs, light 

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

SUVs, vans, and heavier trucks. The sulfur content of gasoline is 

estimated to be reduced by up to 90 percent. VOC emission 

reductions will be approximately 12 percent for passenger cars, 18 

percent for smaller SUVs, light trucks, and minivans, and 15 percent 

for larger SUVs, vans, and heavier trucks. 

Heavy-Duty Diesel Engines

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

Engines, a program which includes low-sulfur diesel fuel standards, 

which will be phased in from 2004 through 2007. This rule applies to 

heavy-duty gasoline and diesel trucks and buses. This rule will 

result in a 40 percent reduction in NOx from diesel trucks and buses, 

a large sector of the mobile sources NOx inventory. It also estimated 

the level of sulfur in highway diesel fuel will be reduced by 97 

percent by mid-2006. 
 46 

Clean Air Non-road Diesel Rule

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

This rule applies to diesel engines used in industries such as 

construction, agriculture, and mining. It also contains a cleaner fuel 

standard similar to the highway diesel program. The new standards 

will cut emissions from non-road diesel engines by more than 90 

percent. Non-road diesel equipment, as described in this rule, 

currently accounts for 47 percent of diesel particulate matter (PM) 

and 25 percent of NOx from mobile sources nationwide. Sulfur 

levels will be reduced in non-road diesel fuel by 99 percent from 

current levels, from approximately 3,000 parts per million (ppm) now 

to 15 ppm in 2009. New engine standards take effect, based on 

engine horsepower, starting in 2008. Together, these rules will 

substantially reduce local and regional sources of PM2.5 precursors. 

Requirement 5 of 6

Acceptable provisions to provide for new source review. 

Background

Ohio has a longstanding and fully implemented New Source Review 

(NSR) program. This is addressed in OAC Chapter 3745-3133. The 

Chapter includes provisions for the Prevention of Significant 

Deterioration (PSD) permitting program in OAC rules 3745-31-01 to 

3745-31-20. Ohio's PSD program was conditionally approved on 

October 10, 2001 (66 FR 51570) and received final approval on 

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

Demonstration

Any facility that is not listed in the 2005 emission inventory, or for the 

closing of which credit was taken in demonstrating attainment, will 

not be allowed to construct, reopen, modify, or reconstruct without 

meeting all applicable NSR requirements. Once the area is 

redesignated, Ohio EPA will implement NSR through the PSD 

program. 

Requirement 6 of 6

Assure that all existing control measures will remain in effect after redesignation 

unless the State demonstrates through modeling that the standard can be 

maintained without one or more control measures. 

Demonstration

Ohio commits to maintaining the aforementioned control measures 

after redesignation. Ohio hereby commits that any changes to its 

 

33 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx 
 47 

rules or emission limits applicable to PM2.5, SO2, and NOx as 

required for maintenance of the annual PM2.5 standard in the 

Cincinnati-Hamilton area, will be submitted to U.S. EPA for approval 

as a SIP revision. 

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

necessary resources to actively enforce any violations of its rules or 

permit provisions. After redesignation, it intends to continue 

enforcing all rules that relate to the emission of PM2.5 precursors in 

the Cincinnati-Hamilton area. 
 48 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4

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

Demonstration

Ohio hereby commits to review its maintenance plan eight years 

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

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

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

Demonstration

Ohio hereby commits to adopt and expeditiously implement 

necessary corrective actions in the following circumstances: 

Warning Level Response:

A warning level response shall be prompted whenever the PM2.5

average of the weighted annual mean of 15.5 μg/m3 occurs in a 

single calendar year within the maintenance area. A warning level 

response will consist of a study to determine whether the PM2.5

value indicates a trend toward higher PM2.5 values or whether 

emissions appear to be increasing. The study will evaluate whether 

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

necessary to reverse the trend taking into consideration ease and 

timing for implementation as well as economic and social 

considerations. Implementation of necessary controls in response to 

a warning level response trigger will take place as expeditiously as 

possible, but in no event later than 12 months from the conclusion of 

the most recent calendar year. 

Should it be determined through the warning level study that action 

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

selection and implementation outlined under “action level response” 

shall be followed. 

Action Level Response: 

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

average of the weighted annual means of 15.0 μg/m3 or greater 

occurs within the maintenance area. A violation of the standard 
 49 

(three-year average of the weighted annual means of 15.0 μg/m3 or 

greater) shall also prompt an action level response. In the event 

that the action level is triggered and is not found to be due to an 

exceptional event, malfunction, or noncompliance with a permit 

condition or rule requirement, Ohio EPA in conjunction with the 

metropolitan planning organization or regional council of 

governments, will determine additional control measures needed to 

assure future attainment of the NAAQS for annual PM2.5. 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 calendar year that prompted the action level. Ohio EPA will also 

consider the timing of an action level trigger and determine if 

additional, significant new regulations not currently included as part 

of the maintenance provisions will be implemented in a timely 

manner and will constitute our response. 

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the 

necessary administrative and legal process. This process will 

include publication of notices, an opportunity for public hearing, and 

other measures required by Ohio law for rulemaking. 

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

be implemented at the federal or State level, and that 

measure/control is determined to be sufficient to address the upward 

trend in air quality, additional local measures may be unnecessary. 

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

demonstrate the proposed measures are adequate to return the 

area to attainment. 

Requirement 3 of 4

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

event. 

Demonstration

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at 

the time the selection is made. The selection of measures will be 

based on cost-effectiveness, emission reduction potential, economic 

and social considerations or other factors that Ohio EPA deems 

appropriate. Ohio EPA will solicit input from all interested and 

affected persons in the maintenance area prior to selecting 

appropriate contingency measures. Because it is not possible at 

this time to determine what control measures will be appropriate at 

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

outlined below is not exhaustive. 
 50 

1) Diesel reduction emission strategies. 

2) Alternative fuel (e.g., liquid propane and compressed natural 

gas) and diesel retrofit programs for fleet vehicle operations. 

3) Tighter PM2.5, SO2, and NOx emissions offsets for new and 

modified major sources. 

4) Impact crushers located at recycle scrap yards – upgrade wet 

suppression. 

5) Concrete manufacturing – upgrade wet suppression. 

6) Additional NOx RACT statewide. 

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 PM2.5, SO2, and NOx sources potentially subject to future additional 

control requirements. 

Demonstration

The following is a list of PM2.5, SO2, and NOx sources potentially subject to 

future controls. 

• ICI Boilers - SO2 and NOx controls; 

• EGUs; 

• process heaters; 

• internal combustion engines; 

• combustion turbines; 

• other sources greater than 100 tons per year; 

• Fleet vehicles; 

• Concrete manufacturers; 

• Aggregate processing plants; 
 51 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in the 

widely distributed county publications on October 28, 2010. 

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

on November 29, 2010 at 2:30 P.M. at the Hamilton County Department of 

Environmental Services, Cincinnati, Ohio. The public comment period closed on 

November 30, 2010. No testimony was provided at the public hearing. 

Comments were received during the public comment period. Appendix E 

includes a copy of the public notice, the transcript from the public hearing, and 

the response to comments. 
 52 

CHAPTER EIGHT 

CONCLUSIONS

The Cincinnati-Hamilton annual PM2.5 nonattainment area has attained the 1997 

annual NAAQS for PM2.5 and complied with the applicable provisions of the 1990 

Amendments to the CAA regarding redesignations of PM2.5 nonattainment areas. 

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

redesignation request and maintenance plan that meet the requirements of 

Section 110 (a)(1) of the 1990 CAA. 

Based on this presentation, the Cincinnati-Hamilton annual PM2.5 nonattainment 

area meets the requirements for redesignation under the CAA and U.S. EPA 

guidance. Ohio has performed an analysis that shows the air quality 

improvements are due to permanent and enforceable measures. Furthermore, 

because this area is subject to significant transport of pollutants, significant 

regional SO2 and NOx reductions will ensure continued compliance 

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

The State of Ohio hereby requests that the Cincinnati-Hamilton annual PM2.5

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

approval of the maintenance plan provisions contained herein. 
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