# 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: PM 2

. 5 redesignation request for the 1997 PM 2

. 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 PM 2

. 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 PM 2 .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 1 644 3184 (fax) www.epa.ohio.govIf 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 PM 2.5 

# NONATTAINMENT AREA

Butler, Clermont, Hamilton, and Warren Counties, Ohio

Prepared by: Ohio Environmental Protection Agency Division of Air Pollution Control

December 2010This page left intentionally blanki 

### TABLE OF CONTENTS

Chapter One Introduction .................................................................................................................. ................. 1 Geographical description ...................................................................................................... ........ 2 Status of air quality ......................................................................................................... .............. 3

Chapter Two Requirements for redesignation ................................................................................................ .... 4

Chapter Three PM 2.5 monitoring ................................................................................................................... ......... 8 Annual PM 2.5 NAAQS .................................................................................................................... 8 Ambient data quality assured ........................................................................................................ 9 Three complete years of data .................................................................................................. ..... 9 Commitment to continue monitoring ........................................................................................... 1 3

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 PM 2.5 , SO 2 , and NO x sources ........................................................................................... 50

Chapter Seven Public participation .......................................................................................................... ............ 51

Chapter Eight Conclusions ................................................................................................................... ............. 52ii FIGURES

Figure 1 Map of the Cincinnati-Hamilton, OH-KY-IN nonattainment area and monitor locations ................................................................................................................ 9 Figure 2 PM 2.5 Annual Mean Trends LADCO States ......................................................... 12 Figure 3 PM 2.5 Annual Mean Trends Midwest States ........................................................ 12 Figure 4 PM 2.5 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 ........ 22Table 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 SO 2 and NO x EGU Emissions Between 2008 and 2009. ............. 26 Table 16 Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010.... ......................................................................................................... 27 Table 17 Butler County, Ohio PM 2.5 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 29 Table 18 Clermont County, Ohio PM 2.5 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 29 Table 19 Hamilton County, Ohio PM 2.5 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 29 Table 20 Warren County, Ohio PM 2.5 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 30 Table 21 Dearborn County, Indiana PM 2.5 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR ................ 30 Table 22 Boone County, Kentucky PM 2.5 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 30 Table 23 Campbell County, Kentucky PM 2.5 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 31 Table 24 Kenton County, Kentucky PM 2.5 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR ................ 31 Table 25 Cincinnati-Hamilton Area PM 2.5 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR. ............... 31 Table 26 Butler County, Ohio NO x Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ...................................... 32iii Table 27 Clermont County, Ohio NO x Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 32 Table 28 Hamilton County, Ohio NO x Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 32 Table 29 Warren County, Ohio NO x Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 33 Table 30 Dearborn County, Indiana NO x Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 33 Table 31 Boone County, Kentucky NO x Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 33 Table 32 Campbell County, Kentucky NO x Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 34 Table 33 Kenton County, Kentucky NO x Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 34 Table 34 Cincinnati-Hamilton Area NO x Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 34 Table 35 Butler County, Ohio SO 2 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 35 Table 36 Clermont County, Ohio SO 2 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 35 Table 37 Hamilton County, Ohio SO 2 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 35 Table 38 Warren County, Ohio SO 2 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 36 Table 39 Dearborn County, Indiana SO 2 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 36 Table 40 Boone County, Kentucky SO 2 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR. .................... 36 Table 41 Campbell County, Kentucky SO 2 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 37 Table 42 Kenton County, Kentucky SO 2 Emission Inventory Total for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR ..................... 37 Table 43 Cincinnati-Hamilton Area SO 2 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 Documentationiv This page left intentionally blankREDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE OHIO PORTION OF THE CINCINNAT I-HAMILTON, OH-KY-IN ANNUAL PM 2.5 NONATTAINMENT AREA

Butler, Clermont, Hamilton, and Warren Counties, Ohio



### CHAPTER ONE

Introduction The Clean Air Act (CAA) requires areas fa iling to meet the National Ambient Air Quality Standard (NAAQS) for the annual PM 2.5 to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standard. The United States Environmental Pr otection Agency (U.S. EPA) revised the NAAQS for particulate matter in July 1997. It replaced the existing PM 10 standard with a health based PM 2.5 standard and retained the PM 10 standard as a “coarse” standard protecting welfare. The standards include an annual standard set at 15.0 micrograms per cubic meter (μg/m 3 ), based on the 3- year average of annual mean PM 2.5 concentrations and a 24- hour standard of 65 μg/m 3 , based on the 3-year average of the 98 th 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. Cir cuit). On May 14, 1999, the D.C. Circuit remanded, without vacatur, the standard ba ck to U.S. EPA. The remand did not question the level at wh ich U.S. EPA set the st andards but rather the constitutionality of the CAA provision that authorizes U.S. EPA to set national air quality standards. U.S. EPA requested a rehear ing 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 affirm ed the constitutionality of the CAA provision but did remand several other iss ues back to the D.C. Circuit, including the issue of whether U.S. EPA acted arbitrarily and capric iously 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 arbitr arily and capriciously in setting the levels of the standards.

On December 17, 2004, U.S. EPA promulgated the initial PM 2.5 nonattainment areas designations for the PM 2.5 standards across the country. Modifications to those designations were made and an effect ive date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendment s of 1990 which defined five ozone nonattainment classifications for the ar eas that exceed the NAAQS based on the2 severity of the ozone levels, PM 2.5 nonattainment designations are simply labeled “nonattainment.” The CAA Amendments require states with PM 2.5 nonattainment areas to submit a plan within three years of the effective date of the designations (April 5, 2008) detailing how the PM 2.5 standards will be attained by April 5, 2010. Ohio EPA subm itted its attainment demonstration for the entire State of Ohio on July 16, 2008.

Section 107(d)(3)(E) of the CAA allows st ates to request nonattainment areas to be redesignated to attainment provided cert ain criteria are met. The following are the criteria that must be met in or der for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has attained the PM 2.5 standard. ii) An approved State Implementati on Plan (SIP) for the area under Section 110(k). iii) A determination that the improv ement 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 Secti on 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 PM 2.5 standard.

Geographical Description and Background The current Cincinnati-Hamilton nonattainment area is located in southwest Ohio and includes the following counties: Butl er, Clermont, Hamilton, and Warren in Ohio; Dearborn (partial nonattainm ent 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 PM 2.5 designations, U.S. EPA designated the CincinnatiHamilton area nonattainment for the 15.0 μg/m 3 annual standard 1 , and Ohio EPA was required to develop a plan to reduce oxides of nitrogen (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and to demonstrate that the area will meet the federal annual air quality standard by April 5, 2010. Ohio’s main PM 2.5 components are primary particles (or ganic carbon, crustal material, and elemental carbon), SO2 and NO x , which were included in the attainment demonstration analysis. Volatile or ganic compounds (VOCs) and ammonia (NH3) were not included in the analysis si nce they were not part of Ohio’s

1 There were no monitors in Ohio that violated the 1997 24-hour PM 2.5 standard of 65μg/m 3

.3 current attainment strategy for PM 2.5 (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 Implem entation Rule U.S. EPA presumes NH3 emissions are not a PM 2.5 attainment plan precurso r and that States are not required to address VOC unless the State or U.S. EPA makes technical demonstration that emissions of VOCs si gnificantly contribut e to nonattainment.

This document is intended to support Ohio’s request that the Ohio portions of the Cincinnati-Hamilton area be r edesignated from nonattainment to attainment for the annual PM 2.5 standard. In addition, the Stat es of Kentucky and Indiana also intend to submit requests for their respec tive portions of the Cincinnati-Hamilton

area.

Status of Air Quality PM 2.5 complete quality-assured ambient ai r quality monitoring data for the most recent three (3) years, 2007 through 2009, demonstrate that the air quality has met the NAAQS for annual PM 2.5 in this nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter Four, supports a redesignation to atta inment for the Cincinnati-Hamilton area based on the requirements in Sect ion 107(d)(3)(E) of the CAA.4 

### CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed gui dance 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 pl an are based on the redesignation guidance, supplemented with additional guidanc e received from staff of U.S. EPA Region V.

Below is a summary of each redesignat ion 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 ambi ent air quality data. The data that are used to demonstrate atta inment should be the product of ambient monitoring that is repr esentative of t he area of highest concentration. The data should be collected and quality-assured in accordance with 40 CFR 58 and re corded in the Air Quality System (AQS) in order for it to be avail able 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 ar eas, the redesignation guidance states it is “generally necessary” for particulate matter redesignations. Appendix C and A ppendix D contains the most recent modeling results sho wing future attainment and maintenance are provided. C hapter Three discusses this requirement in more detail and provides the attainment demonstration.

ii.) Permanent and enforceable impr ovement in air quality (CAA Section 107(d)(3)(E)(iii)) The state must be able to reasonabl y attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should es timate the percent reduction achieved from federal m easures as well as control measures that have been adopted and implement ed 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 rule s recently that will have an impact Statewide on PM 2.5 emissions in the future:5 • Clean Air Interstate Rule (CAIR)

• NOx SIP Call Rules

In addition, since the initial des ignations were made federally enforceable consent decrees hav e resulted in reductions in emissions from utilities across t he 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 st ate 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 nonat tainment based on a violation of the NAAQS. Subpart 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 ). However, for the pur pose of implementing the 1997 PM 2.5 standard, U.S. EPA’s Implem entation Rule stated Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 .[72 FR 20589]

i.) Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Secti on 110(a)(2) provides that the implementation plan submitt ed 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 limitat ions and other control measures, means or techniques necessary to meet the requirements of the CAA; pr ovide for establishment and operation of appropriate dev ices, methods, systems and procedures necessary to m onitor ambient air quality; provide for implementation of a source permit program to regulate the modification and cons truction of any stationary source within the areas cove red by the plan; include provisions for the implementati on of Part C, prevention of significant deterioration (PSD) and Part D, NSR permit programs; include criteria fo r stationary source emission control measures, monito ring, and reporting; include provisions for air quality mode ling; 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, Ohio6 verified that the State fulfills the requirements of Section 110(a)(2) of the Act.

Section 110(a)(2)(D) also requi res State plans to prohibit emissions from within t he State which contribute significantly to nonattainment or maintenance areas in any other State, or which interf ere with programs under Part C to prevent significant deterio ration of air quality or to achieve reasonable progress towa rd the national visibility goal for Federal class I areas (national parks and wilderness areas). In order to assist States in addressing their obligations regarding r egionally transported pollution, U.S. EPA finalized CAIR to reduce SO 2 and NO x emissions from large electric generating units (EGU). Ohio has met the requirements of the f ederal CAIR to reduce NO x and SO 2 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 3745-109 2 . 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 transport ed pollution by providing reductions in NO x and SO 2 emissions in 2012 and 2014.

ii.) Section 172(c) requirements This Section contains general requirements for nonattainment plans. The r equirements for reasonable further progress, identificat ion of certain emissions increases, and other measur es needed for attainment will not apply for redesignations because they only have meaning for areas not atta ining the standard. The requirements for an emission in ventory 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#3745-1097 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 ma intenance 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) furt her 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 d eems necessary to ensure prompt correction of any violation of t he NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all meas ures 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

PM 2.5 MONITORING CAA Section 107(d)(3)(E)(i)

Requirement 1 of 4 A demonstration that the NAAQS for annual PM 2.5 , as published in 40 CFR 50.7, has been attained.

Background There are sixteen monitors measuring PM 2.5 concentrations in this nonattainment area. Twelve of t he sixteen monitors are located in Ohio 3 and are operated by Ohio EPA Division of Air Pollution Control, Southwest District Office and the Hamilton County Division of Environmental Services. A lis ting 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 nonattainm ent area are shown on Figure 1.

3 The four remaining PM 2.5 monitors are located in Kentucky.9 Demonstration

Figure 1 - Map of the Cincinnati-H amilton, OH-KY-IN nonattainment area and monitor locations

Requirement 2 of 4 Ambient monitoring data quality assur ed in accordance with 40 CFR 58.10, recorded in the U.S. EPA air quality syst em (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 ot her federal requirements. Ohio EPA has recorded the data in the AQ S database and, ther efore, the data are available to the public.

Requirement 3 of 4 A showing that the three-year av erage of the annual mean values, based on data from all monitoring sites in the ar ea or its affected downwind environs, are below 15.0 μg/m 3 . (This showing must rely on three complete, consecutive calendar years of quality assured data.)10 Background The following information is tak en 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 Amendment s, three complete years of monitoring data are required to demonstrate attainment at a monitoring site. The annual PM 2.5 primary and secondary ambient air quality standards are met at an ambi ent air quality monitoring site when the three-year average of t he annual average is less than 15.0 μg/m 3 . While calculating design values , three significant digits must be carried in the computations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or gr eater are rounded up, and those less than 0.05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than, or equal to 15.0 μg/m 3

. Values at or below 15.0 μg/m 3 meet the standard; values equal to or greater than 15.1 μg/m 3 exceed the standard. An area is in compliance with the annual PM 2.5 NAAQS only if every monitoring site in the area meets the NAAQS. An individual site's 3-year average of the annual average concent rations is also called the site's design value. The air qualit y 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 quarte r [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 fo r the Cincinnati-Hamilton area demonstrates t hat the annual PM 2.5 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 PM 2.5 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 - PM 2.5 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 - PM 2.5 Annual Mean Trends Midwest States

Source: LADCO; Recent Ozone and PM25 Trends - Aug 26 2010.pptx13 Design values have also trended downward nationally:

Figure 4 - PM 2.5 Annual Mean National Trends

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

Requirement 4 of 4 A commitment that once redesignated, the state will cont inue to operate an appropriate monitoring network to verify the maintenance of the attainment status.

Demonstration Ohio EPA commits to continue monitoring PM 2.5 levels at the Ohio sites indicated in Figure 1 and T able 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 qua lity assure the monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. Connection to a c entral station and updates to the Ohio EPA web site 4 will provide real time av ailability 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/dapc14 

### CHAPTER FOUR

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

U.S. EPA’s redesignation guidance require s the submittal of a comprehensive inventory of PM 2.5 precursor emissions (primary par ticles (organic carbon, crustal matter, and elemental carbon), SO 2 and NO x 5 ) representative of the year when the area achieves attainment of the annual PM 2.5 air quality standard. Ohio also must demonstrate that the improvement in air qualit y between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable em ission reductions. Other emission inventory related requirements include a projection of the emission invent ory to a year at least 10 years following redesignation; a demonstration that t he projected level of emissions is sufficient to maintain the annual PM 2.5 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 mob ile (on-road) emi ssions inventory and projections, identifies procedures us ed by Ohio EPA and the LADCO regarding emissions from Ohio’s portion of the c ounties in the Cincinnat i-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 pr ojections. All of these inventories and emissions projections were prepar ed using similar methodologies. Ohio recognizes that revisions to the emi ssions data below may be necessary once Kentucky and Indiana prepare a redesignat ion request and maintenance plan for their portion of the nonatta inment area. Mobile em issions inventories and projections for all counties were prepar ed by the Ohio, Kent ucky, Indiana Council of Governments (OKI).

Requirement 1 of 5 A comprehensive emission inventory of PM 2.5 , SO 2 and NO x completed for the base year.

Background The point source data are tak en from Ohio's annual emissions reporting program. The 2005 periodi c inventory has been identified as one of the preferred databas es for SIP development and coincides with nonattainment air quality in the Cin cinnati-Hamilton

area.

5 VOC and NH 3 are not addressed.15 Periodic inventories, which incl ude emissions from all sectors - mobile, area, non-road, and point sources - are prepared every three years.

Demonstration The 2005 inventory is used as the bas e year for the purpose of this submittal and was submitted to U.S. EPA with Ohio’s PM 2.5 attainment demonstration SIP s ubmitted on July 18, 2008 and revised on June 7, 2010. The det ailed emission inventory information for the Ohio portion of the Cincinnati-Hamilton area is provided in Appendix B. Emissions of PM 2.5, SO 2 and NO x 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 invent ory for the Ohio portion of the Cincinnati-Hamilton area including area, mobile, and point sources for PM 2.5 , S0 2 and NO x for base year 2005. The 2005 inventory was submitted to U.S. EPA on July 18, 2008 as part of Ohio’s PM 2.5 attainment demonstration SIP for this area. T he information below describes the procedures Ohio EPA used to generat e the 2005 base year inventory and to develop SIP-ready modeling invent ories and future year projections (Pechan Report 6 ) based on a 2005 base year inventory. The report by Pechan generated future year estima tes of annual emissions for each source sector using accepted growth surrogates. These inventories were provided to the LADCO and have been proc essed to develop average daily emissions for use in the air quality analyses. These processed modeling inventories have been identified as the co rrect iteration of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organiza tion. Note, the on-road mobile source sector was addr essed by specific PM 2.5 and NO x 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. Departm ent of Commerce Bureau of Economic Analysis (BEA) growth factors, with some updated local information.

6 http://www.ladco.org/tech/emis/r5/r eports/LADCO%202005%20Base%20Yr%20Growth%20and%20Con trols%20Report_Final.pdf16 • Mobile source emissions we re calculated from MOVES2010 - produced emission factors. Only PM 2.5 and NO x necessitate emissions inventory analysis. As documented in Ohio EPA’s attainment demonstration SIP, Ohio EPA in consultation with U.S. EPA determined mobile s ources are insignificant contributors for SO 2 . Consistent with Ohio EPA’s attainment demonstration, Ohio EPA conti nues to consider mobile source SO 2 to be an insignificant cont ributor to fine particles for this nonattainment area. Based on the demonstration below, SO 2 constitutes less than one percent (<1%) of the area’s total SO 2 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 inv entory database and the 2005 U.S. EPA Air Markets acid rain database 7

.

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generated using U.S. EPA’s National Mobile Inventory M odel (NMIM) 2002 application. To address concerns about the accuracy of some of the categories in U.S. EPA’s non-r oad emissions model, LADCO contracted with two (2) compani es 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-r oad model. Emissions were estimated for aircraft, co mmercial marine vessels, and railroads. Recreational moto rboat population and spatial surrogates (used to assign emi ssions to each county) were significantly updated. The populat ions for the construction equipment category were re viewed 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 D epartment of Transportation (Ohio DOT), OKI utilizes a regional tr avel 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 lo cations 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/acidrain17 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 traffi c volumes vehicle miles traveled (VMT), travel speeds, and a U.S. EPA computer program called MOVES is used to calculate emi ssions 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 notice 8 of availability on March 2, 2010, to approve MOVES 2010 (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, NO x , CO, PM 10 and PM 2.5 and other pollutants and pr ecursors 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 regul arly update its mobile source emission models. U.S. EPA c ontinuously collects data and measures vehicle emissions to ma ke 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 r epresents the Agency’s most upto-date assessment of on-road m obile source emissions. MOVES also incorporates several changes to the U.S. EPA’s approach to mobile source emission mode ling based upon recommendations made to the Agency by the National Academy of Sciences.

U.S.EPA believes that MOVES shoul d be used in ozone, CO, PM, and nitrogen dioxide SIP development as expeditiously as possible. The CAA requires that SIP invent ories and control measures be based on the most current info rmation 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.r egulations.gov/search/Regs/hom e.html#document Detail?R=0900006480ab1f9818 The MOVES more detailed appr oach (when compared with the previous MOBILE model) to mode ling allows U.S. EPA to easily incorporate large amount s of in-use data from a wide variety of sources, such as data from v ehicle inspection and maintenance (I/M) programs, remote sensing dev ice (RSD) testing, certification testing, portable emission measur ement systems (PEM S), etc. This approach also allows users to incorpor ate a variety of activity data to better estimate emission differences such as those resulting from changes to vehicle speed and acce leration 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 regar ding output choices. Unlike earlier models which provided emission fact ors 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 gram s-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 transportati on 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 emissi ons model MOVES to develop emissions factors for SO 2 , NO x and PM 2.5 . 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 char acteristics for each roadway segment in the network to produc e a “loaded” highway network with forecasted traffic volumes with revised speeds based on specified speed/capacity relationships.

Travel analysis zones are the bas ic geographic unit for estimating travel in the OKI model. The OK I 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. T hese 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 requirement s of the OKI travel demand forecasting model are populati on and employment, from these variables other characteristics in cluding 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) le vel, 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 y ear 2005. The modeling network encompasses the entire PM 2.5 nonattainment area. The modeling network also includes Greene, Mi ami and Montgomery counties in Ohio and the remainder of D earborn County, Indiana. The differences between estimated v ehicle 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 Departm ent of Transportation (ODOT) standard of maximum desirable devia tion. The comparison shows that the model performs at a sati sfactory level and all the errors were under the ODOT curve (O KI’s 2007 report, “OKI/MVRPC Travel Demand Model Methodology/V alidation Report”). For the calibration, OKI used over 3000 tr affic counts collected through 2006 by the ODOT, the Kentucky Trans portation Cabinet, many county and local governments, transportati on engineering consultants, and OKI. These traffic counts cover near ly 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 sour ces 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 s peed 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 differ ent 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 suppl emented with data collected at coverage count stations (locat ions 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 “l oaded” 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 summe r 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 result s of the emissions analysis for the appropriate years. All emissions estimati ons are expressed in tons per year (tpy).

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

2005 2008 2015 2021 PM 2.5 (tpy) 413.970 377.640 301.16 215.76 NO x (tpy) 10,910.37 9,803.70 6,064.61 3,757.91 SO 2 (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

PM 2.5 (tpy) 281.790 256.600 204.32 145.39 NO x (tpy) 7,295.87 6,516.40 3,993.63 2,449.31 SO 2 (tpy) 20.51 23.32 23.34 25.66 Annual VMT 1,684,261,582 1,765,146,867 1,899,319,930 2,005,373,96121 Table 4 – Hamilton County, Ohio Em issions Estimations for On-Road Mobile Sources

2005 2008 2015 2021

PM 2.5 (tpy) 1,222.020 1,080.540 826.00 571.48 NO x (tpy) 31,127.09 27,020.93 15,925.19 9,530.16 SO 2 (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 Em issions Estimations for On-Road Mobile Sources

2005 2008 2015 2021

PM 2.5 (tpy) 320.740 289.560 242.05 177.61 NO x (tpy) 8,224.57 7,267.18 4,598.44 2,875.72 SO 2 (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 Em issions Estimations for On-Road Mobile Sources

2005 2008 2015 2021

PM 2.5 (tpy) 33.980 29.890 25.14 18.11 NO x (tpy) 865.46 748.81 482.33 297.95 SO 2 (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 I ndiana Emissions Estimations for On-Road Mobile Sources

2005 2008 2015 2021

PM 2.5 (tpy) 2,272.50 2,034.23 1,598.67 1,128.35 NO x (tpy) 58,423.36 51,357.02 31,064.20 18,911.05 SO 2 (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

PM 2.5 (tpy) 205.210 251.850 151.35 114.05 NO x (tpy) 5,126.88 5,067.94 2,788.45 1,772.72 SO 2 (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

PM 2.5 (tpy) 120.300 146.460 82.36 60.09 NO x (tpy) 3,041.21 2,988.33 1,570.14 985.28 SO 2 (tpy) 9.30 9.69 11.21 12.77 Annual VMT 741,790,595 774,762,718 875,774,487 936,445,35222 Table 10 – Kenton County, Kentucky Emissions Estimations for OnRoad Mobile Sources

2005 2008 2015 2021

PM 2.5 (tpy) 212.290 29.890 137.40 101.24 NO x (tpy) 5,328.44 5,057.93 2,637.63 1,677.96 SO 2 (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 Em issions Estimations for On-Road Mobile Sources

2005 2008 2015 2021

PM 2.5 (tpy) 537.8 645.62 371.11 275.38 NO x (tpy) 13,496.53 13,114.20 6,996.22 6,421.15 SO 2 (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

PM 2.5 (tpy) 2,810.30 2,679.85 1,969.78 1,403.73 NO x (tpy) 71,919.89 64,471.22 38,060.42 25,332.20 SO 2 (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-Ham ilton 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 taki ng 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 taki ng 5 to15 percent of the mobile source emission estimates23 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 PM 2.5 in 2015, 10 percent margin of safety allocated to PM 2.5 in 2021 and 15 percent margin of safety allocated to NO x 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 pl anning assumptions, and the safety margins allocations were determined through the interagency consultation process described in the Transportation Conformity Memorandum of Understanding (MO U) among OKI, Ohio DOT, and Ohio EPA.

A 5 to15 percent margin of safety is appropriate becaus e: 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 su fficient to accommodate this 5 to15 percent allocation of safety ma rgin (as defined in 40 CFR93.101 9 ) 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 safe ty was calculated by taking 5 to 15 percent of the mobile source em ission 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 in to an additional 98.49 tpy for PM 2.5 and 5,709.06 tpy for NO x for 2015 and an additional 140.38 tpy for PM 2.5 and 3,799.82 tpy for NO x for 2021.

9 "Safety margin" means t he amount by which the total projected em issions from all sources of a given pollutant are less than the total em issions 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 PM 2.5 and NO x 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 PM 2.5 and NO x conformity budgets included in this submitta l 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 s ubmittals based on MOBILE6.2.

Requirement 3 of 5 A demonstration that the projec ted level of emissions is sufficient to maintain the PM 2.5 standard.

Background In consultation with U.S. EPA, Oh io 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 s ource emission projections are based on the U.S. EPA MOVES model. The analysis is described in more detail in A ppendix C. All projections were made in accordance with “Proc edures for Preparing Emissions Projections” U.S. EPA-45/4-91-019.

• Emissions inventories are requi red 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 categor ies. These files were used to develop the future-year emissions estima tes used in this document. This was done so the inventories used for redesignation are consistent with modeling perfo rmed in the future. Appendix D25 contains LADCO’s technical support document detailing the analysis used to project emissions (Base M 10 ).

• For the Ohio portion of the Cincinnati-Hamilton area, for the 2008 attainment year, emissions we re 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 in terim year emissions were estimated based on the 2009 and 2018 LADCO modeling inventory, using LADCO’s growth fa ctors, 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 cont inued compliance with the PM 2.5 standard. Therefore, Ohio EPA per formed 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 tabl es are: Electrical Generating Unit (EGU-Point); Non-Electrical Generating Unit (Non-EGU); Nonroad Mobile (Non-road); Other Ar ea (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 t he CAIR program. U.S. EPA has raised concerns regarding the CAIR program and its remand. However, as discussed below, wit h the proposed CAIR replacement, the Transport Rule, Ohio EPA be lieves 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 NO x and SO 2 . CAIR replaced t he NOx SIP Call for EGUs. The intent of the CAIR program is for national NO x 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/i ndex.php26 Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approv ed 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 NO x will decrease from a baseline of 264,000 tons per year to 93,000 tons per year while in 2010 emissions of SO 2 will decrease from a bas eline of 1,373,000 tons per year to 298,000 tons per year, within Ohio. And by 2015 U.S. EPA projects emissions of NO x will decrease to 83,000 tons per year while emissions of SO 2 will decrease to 208,000 tons per year, within Ohio 11

.
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 al so be noted that Ohio’s SIPapproved NOx SIP Call progr am and regulations are still in place. Ohio EPA is currently in the proce ss of revising these regulations to provide a “back stop” for the re instatement 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 NO x and 1,373,000 tons of SO 2 emitted in 2005. In 2008 and 2009 fa cilities began preparing for and implementing control pr ograms to address CAIR 12 and consent decrees.

Table 15 - Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2009 SO 2 NO x 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 Tracking 13

Significant reductions also occurr ed regionally and nationally as can be seen from the above. Data is also available for the first two quarters of 2010, the year SO 2 reductions are to be implemented under CAIR:

11 http://www. epa.gov/CAIR/oh.html 12 Under CAIR, NOx reductions are to occur begi nning in 2009 while SO2 reductions are to occur beginning in 2010. 13 http://www. epa.gov/airmarkets/quarterlytracking.html27 Table 16 – Reductions in SO 2 and NO x EGU Emissions Between the First Half of 2008 and 2010 SO 2 NO x 2008 (1 st half) 2010 (1 st half) Change 2008 (1 st half) 2010 (1 st 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 Tracking 14

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

“Based on emissions monitoring dat a, EPA has observed substantial reductions in SO 2 emissions from 2005 to 2009 and in the first two quarters of 2010 as companies inst alled 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 vacatu r and subsequent remand in late 2008, the controls in place gener ally 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 NO x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2.

Ohio EPA is in agreement with t he analysis by U.S.EPA that the CAIR program is providing real reduc tions at this time, Ohio believes these reductions have assisted with PM 2.5 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 reduc tions, and likely even greater reductions, that will be necessary for maintenance of the annual PM 2.5 standard to occur. As stat ed by U.S. EPA regarding the proposed Transport Rule, “the result s of the air quality modeling indicate that all but one site 16 is projected to be in attainment and only one site 17 is projected to have a maintenance problem for annual PM2.5 in 2014 with the emissi ons reductions expected from this proposal.” [75 FR 45345] Therefor e, it is Ohio EPA’s belief it is most appropriate to evaluate Oh io EPA’s demonstrat ion that the

14 http://www. epa.gov/airmarkets/quarterlytracking.html 15 http://www. epa.gov/airmarkets/background.htm 16 Allegheny, PA 17 Birmingham, AL28 projected level of emissions is su fficient to maintain the annual PM 2.5 standard by assessing future year em issions 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 t he 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 Mich igan Air Directors Consortium (LADCO).

Demonstration

PM 2.5

The 2005 and 2008 actual PM 2.5 emissions data below generally contains particulate fraction emissions only and not the condensable fractions as Ohio EPA did not have a consistent r eporting requirement at those years. U.S. EPA Integrated Planning Model (IP M) modeling was used to generate future year EGU emissions with t he CAIR program. The IPM modeling added additional PM 2.5 condensable emissions into future years. Therefore, comparing base and attainment year emissions with the future year predictions is not accurate in the IP M CAIR modeling. This step leads to a false perception of significant PM 2.5 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 PM 2.5 to evaluate future year emissions without the CAIR program.

Table 17 - Butler County 18 , Ohio PM 2.5 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 reduc tion credits available and used to o ffset the allowed emissions of a29 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 PM 2.5 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 PM 2.5 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 PM 2.5 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – Without CAIR

major source modified within the maintenance area t hat will begin operating duri ng 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 ar ea 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 PM 2.5 Emission Inventory Totals for Base Year 2005, Estima ted 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 PM 2.5 Emission Inventory Totals for Base Year 2005, Estima ted 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 PM 2.5 Emission Inventory Total for Base Year 2005, Estimate d 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 fr om the 2005 LADCO modeling invent ory, 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 PM 2.5 Emission Inventory Totals for Base Year 2005, Estima ted 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 PM 2.5 Emission Inventory Totals for Base Year 2005, Estima ted 2008, and projected 2015 and 2021 (tpy) – Without CAIR

PM 2.5 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 PM 2.5 TOTAL 9455.40 8904.64 8634.55 8202.63 702.01

NO x32 Table 26 - Butler County, Ohio NO x 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 NO x 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 NO x 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 28071.7133 Table 29 - Warren County, Ohio NO x 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 NO x Emission Inventory Totals for Base Year 2005, Estimate d 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 NO x 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 NO x Emission Inventory Total for Base Year 2005, Estimate d 2008, and Projected 201534 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 NO x Emission Inventory Totals for Base Year 2005, Estimate d 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 NO x Emission Inventory Totals for Base Year 2005, Estimate d 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

SO 235 Table 35 - Butler County, Ohio SO 2 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 SO 2 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 SO 2 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 15681.3736 Table 38 - Warren County, Ohio SO 2 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 SO 2 Emission Inventory Totals for Base Year 2005, Estimate d 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 SO 2 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 3946.83 402.7337 Table 41 - Campbell County, Kentucky SO 2 Emission Inventory Total for Base Year 2005, Estima ted 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 SO 2 Emission Inventory Totals for Base Year 2005, Estima ted 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 SO 2 Emission Inventory Totals for Base Year 2005, Estimated 2008, and Projected 2015 and 2021 (tpy) – With CAIR

SO 2 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 SO 2 TOTAL 239963.78 117016.14 112250.26 88510.27 28505.8738 PM 2.5 , NO x , and SO 2

Table 44 - Cincinnati-Hamilton Ar ea Comparison of 2008 attainment year and 2015 and 2021 proj ected emission estimates (tpy)

2008 Base 2015 Interim 2015 Projected Decrease 2021 Maintenance 2021 Projected Decrease PM 2.5 8,904.64 8,634.55 270.09 8,202.63 702.01 NO x 148,706.15 105,712.02 42,994.13 78,819.13 69,887.02 SO 2 117,016.14 112,250.26 4,765.88 88,510.27 28,505.87

As shown in the table above (Table 44), PM 2.5 emissions in the nonattainment area are projected to decrease by 270.09 tpy in 2015 and 702.01 tpy in 2021. NO x emissions in the nonattainment area are projected to decrease by 42,994.13 tpy in 2015 and 69,887.02 tpy in 2021. SO 2 emissions in the nonattain ment area are projected to decline by 4,765.88 tpy in 2015 and 28,505.87 in 2021.

Area source emissions and, to a le sser 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 Tr ansport 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 Requirements 20 , Highway Heavy-Duty Engine Rule 21

, and the Non-Road Diesel Engine Rule 22 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 fi red boilers. In addition, unitsB015 (# 7) and B017 (# 8) were issued a new source review permitto-install scrubbers, accepting a re stricted SO2 allowable emissions rate that will not cause or contri bute to a violation of a National Ambient Air Quality Standard (N AAQS) 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 y ear (2005), to the attainment year (2008), and for 2009:

Table 45 - Miami Fort Station, Ha milton 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 bet ween 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 monitori ng sites indicate that air quality met the NAAQS for PM 2.5 in 2007-2009. U.S. EPA’s r edesignation guidance (p 9) states: “A state may generally dem onstrate 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 em issions rates will not cause a violation of the NAAQS.”

Demonstration Permanent and enforceable reductions of PM 2.5 , NO x , and SO 2 emissions have contributed to the attainment of the annual PM 2.5 standard. Some of these reductions were due to the applicat ion of tighter federal standards on new vehicles. Also Title IV of the CAA, the NO x SIP Call, CAIR, and federal consent decrees requir ed the reductions of SO 2 and NO x emissions from utility sources. Reductions achieved are discussed in gr eater detail under Chapter Five.

Table 46 - Cincinnati-Hamilton Ar ea Combined Comparison of 2005 base year and 2008 attainment year on-road and EGU reductions 2005 2008 On-road PM 2.5 2810.30 2679.85 On-road NO x 71919.89 64471.22 On-road SO 2 392.00 277.59

EGU PM 2.5 2062.91 1633.15 EGU NO x 55930.44 46853.89 EGU SO 2 218395.56 98334.1740 Requirement 5 of 5 Provisions for future annual updates of t he inventory to enable tracking of the emission levels, including an annual emissi on 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 PM 2.5 precursor emission sectors every three years. These PM 2.5 precursor inventories will be prepared for future years as necessa ry to comply with the inventory reporting requirements establis hed in the CFR. Emissions information will be compared to the 2005 base year and the 2021 projected maintenance year invent ories to assess emission trends, as necessary, and to assure c ontinued compliance with the annual PM 2.5 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 Cl ean 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 (incl uding such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonabl e available control technology).

U.S. EPA’s Implementation Rule interp rets 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 source s) that are technically and economically feasible, and that w ould collectively contribute to advancing the attainment date (i.e. by one year or more). States are required to use a combined approac h 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 prov ides for a presumption that in States that fulfill t heir 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 meas ures 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 compli ance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff. The Ohio RA CT rules are found in OAC Chapter 3745-17 24

.

24 http://www. epa.ohio.gov/dapc/regs/3745_17.aspx42 In addition, Ohio EPA promulgated NO x SIP Call rules (OAC Chapter 3745-14 25 ), CAIR (OAC Chapter 3745-109 26 ), and NO x Reasonably Available Control Technology rules (OAC Chapter 3745-110 27 ) 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 NO x , PM 2.5 , and SO 2 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 bot h ozone precursors and PM 2.5 precursors in Ohio, Illinois, Indiana, Michigan, and Wisconsin area. The first consultant, MACTEC, prepared a series of white papers 28 researching different stationary sour ce categories. The results were compiled into two reports 29 . The second consultant, Environ, investigated control options for m obile sources. The results were compiled into two reports 30 . The stationary and mobile source sectors (and associated control m easures) were selected by the LADCO States based on several fa ctors presented in the report (See Chapter 2).

Photochemical modeling was t hen conducted (as part of LADCO Round 4 modeling) to assess the ai r quality benefit of the candidate control measures and a modeling report was developed 31 . Based on the results, the LADCO project team felt it would not be possible to advance the attainment date for PM 2.5 . Ohio EPA, in its attainment demonstration submitted on July 18, 2008, demonstrated (using a weight of evidence appr oach) that attainment would be achieved in this area by 2009. Because of a pr ojected 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/r eports/control/white_papers 29 http://www.ladco.org/r eports/control/final_reports/identification_and_evaluation_of_candidate_control_measures_i_ april_2005.pdf; http://www.ladco.org/r eports/control/final_reports/identification_and_evaluation_of_candidate_control_measures_ii_ june_2006.pdf 30 http://www.ladco.org/r eports/control/final_reports/final_report_eval uation_of_candidate_mobile_source_control_me asures_february_2006.pdf; http://www.ladco.org/r eports/control/final_reports/final_report_eval uation_of_candidate_mobile_source_control_me asures_for_ladco_states_in_2009_and_2012_march_2007.pdf 31 http://www.ladco.org/r eports/control/modeling/round4_modeling.pdf43 develop RACT/RACM requirements, promulgate regulations and implement a control progr am prior to the projec ted 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 atta inment 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 demonstrat ion submitted on July 18, 2008, Ohio demonstrated (using a weight of evidence approach) that attainment would be achieved in th is 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 subm it 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 det ermined necessary. 40 CFR 51.1008 requires such inventory to be s ubmitted within three years of designation and requires a baseline em ission inventory for calendar year 2002 or other suitable year to be used for attainment planning.

Demonstration The 2005 comprehensive inventory wa s submitted to U.S. EPA with Ohio’s PM 2.5 attainment demonstration SIP submitted on July 18, 2008. It was then subsequently revi sed and resubmitted on June 7, 2010.

Ohio also updates its inventor y in accordance with U.S. EPA’s CERR rule (i.e. emissions stat ements). Ohio EPA submitted its emissions statement SIP on Marc h 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 (sta tements) every three years.44 Requirement 4 of 6 Evidence that control meas ures required in past PM 2.5 SIP revisions have been fully implemented.

Background In addition to the historic RACT requirements for PM, the U.S. EPA NO x SIP Call required 22 st ates to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern Unit ed States. Ohio passed this rule in 2001. NOx SIP Call requirement s are incorporated into permits along with monitoring, recordkeepi ng, and reporting necessary to ensure ongoing compliance. Oh io EPA also has an active enforcement program to address violat ions 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 approximatel y 31 percent of all NO x 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 NO x and SO 2 . CAIR replaced the NOx SIP Call for EGUs. National NO x 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 r equired to submit a CAIR SIP as part of this effort. Ohio submi tted a CAIR SIP which was approved by U.S. EPA on February 1, 2007. Re visions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final acti on on September 25, 2009 (74 FR 48857).

Demonstration Controls for EGUs under the NO x SIP Call formally commenced May 31, 2004. Emissions covered by this program have been generally trending downward since 1998 with la rger reductions occurring in 2002 and 2003. Data taken from t he U.S. EPA Clean Air Markets web site, quantify the gradual NO x reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 32 in response to the SIP Call. OAC Chapter 3745-14 r egulates EGUs and certain nonEGUs under a cap and trade pr ogram based on an 85 percent

32 http://www. epa.ohio.gov/dapc/r egs/3745_14.aspx45 reduction of NOx emissions from EGUs and a 60 percent reduction of NO x emissions from non-EGUs, com pared to historical levels. This cap was in place through 2008, at which time the CAIR program superseded it as discuss ed 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 NO x SIP Call that establishes a budget for lar ge (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 pipeli ne transmissions. U.S. EPA approved this revision to the SIP on Ap ril 4, 2008. An 82 percent NO x reduction from 1995 levels is ant icipated. Completion of the compliance plan occurred by Ma y 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 li ght trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refinerie s 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 NO x 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 tr ucks, 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 lo w-sulfur diesel fuel standards, which will be phased in from 2004 thr ough 2007. This rule applies to heavy-duty gasoline and diesel tr ucks and buses. This rule will result in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x 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 engi nes used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highway di esel program. The new standards will cut emissions from non-road diesel engines by more than 90 percent. Non-road diesel equipmen t, as described in this rule, currently accounts for 47 percent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwide. Sulfur levels will be reduced in non-road dies el fuel by 99 percent from current levels, from approximatel y 3,000 parts per million (ppm) now to 15 ppm in 2009. New engine st andards take effect, based on engine horsepower, starting in 2008. Together, these rules will substantially reduce local and regional sources of PM 2.5 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 3745-31 33 . The Chapter includes provisions for the Prevention of Significant Deterioration (PSD) permitting progr am 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 t he 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 require ments. Once the area is redesignated, Ohio EPA will impl ement 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 t he aforementioned control measures after redesignation. Ohio hereby commits that any changes to its

33 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx47 rules or emission limits applicable to PM 2.5 , SO 2 , and NO x as required for maintenance of the annual PM 2.5 standard in the Cincinnati-Hamilton area, will be subm itted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal secti on, has the legal authority and necessary resources to actively enfor ce any violations of its rules or permit provisions. After redesignat ion, it intends to continue enforcing all rules that rela te to the emission of PM 2.5 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 pl an 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 ex ceeding specified predetermined levels (triggers) or in the event that future vi olations 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 sha ll be prompted whenever the PM 2.5 average of the weighted annual mean of 15.5 μg/m 3 occurs in a single calendar year within the ma intenance area. A warning level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to conti nue and, if so, the control measures necessary to reverse the trend ta king 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 wa rning level study that action is necessary to reverse the noted trend, the procedures for control selection and implementation outli ned 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/m 3 or greater occurs within the maintenance ar ea. A violation of the standard49 (three-year average of the wei ghted annual means of 15.0 μg/m 3 or greater) shall also prompt an acti on level response. In the event that the action level is trigger ed 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 organizati on or regional council of governments, will determine additional control measures needed to assure future attainment of the NAAQS for annual PM 2.5 . In this case, measures that can be impl emented in a short time will be selected in order to be in place wit hin 18 months from the close of the calendar year that prompted the action level. Ohio EPA will also consider the timing of an acti on level trigger and determine if additional, significant new regulati ons not currently included as part of the maintenance provisions will be implemented in a timely manner and will constitute our response.

Control Measure Select ion 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 al ready promulgated and scheduled to be implemented at t he federal or Stat e level, and that measure/control is determined to be sufficient to address the upward trend in air quality, additional lo cal 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 contingen cy measures that would be implemented in such an event.

Demonstration Contingency measures to be c onsidered 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 ot her factors that Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the maint enance area prior to selecting appropriate contingency measures. Because it is not possible at this time to determine what cont rol 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., li quid propane and compressed natural gas) and diesel retrofit programs for fleet vehicle operations. 3) Tighter PM 2.5 , SO 2 , and NO x 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 NO x RACT statewide.

No contingency measure shall be im plemented without providing the opportunity for full public participati on 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 PM 2.5 , SO 2 , and NO x sources potentially subject to future additional control requirements.

Demonstration The following is a list of PM 2.5 , SO 2 , and NO x sources potentially subject to future controls.

• ICI Boilers - SO 2 and NO x 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 redesignat ion petition and maintenance plan in the widely distributed county publicat ions on October 28, 2010.

The public hearing to receive comment s on the redesignation request was held on November 29, 2010 at 2: 30 P.M. at the Hamilt on County Department of Environmental Services, Cincinnati, Ohio . The public comment period closed on November 30, 2010. No testimony wa s provided at the public hearing. Comments were received during the public comment period. Appendix E includes a copy of the public notice, t he transcript from t he public hearing, and the response to comments.52 

### CHAPTER EIGHT

CONCLUSIONS

The Cincinnati-Hamilton annual PM 2.5 nonattainment area has attained the 1997 annual NAAQS for PM 2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of PM 2.5 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 PM 2.5 nonattainment area meets the requirements for r edesignation under t he CAA and U.S. EPA guidance. Ohio has performed an anal ysis that shows the air quality improvements are due to permanent and enf orceable measures. Furthermore, because this area is subject to signific ant transport of pollu tants, significant regional SO 2 and NO x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of Ohio hereby requests that the Cincinnat i-Hamilton annual PM 2.5 nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenance plan provisions contained herein.This page left intentionally blank