John R. Kasith, Governor
Mary Taylor, Lt. Governor

Scott J. Nally, Director



## APR 1 8 2013

Susan Hedman Regional Administrator
U.S. EPA, Region 5

77 West Jackson Blvd. R-19J Chicago, Illinois 60604-3507

Re: Request for Review and Approval of the Revised Toledo Area Maintenance Plan Approval for the 1997 Eight-Hour Ozone Standard

Dear Administrator Hedman:

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

the Toledo area ( Lucas and Wood Counties) with respect to the 1997 eight-hour ozone standard. Ohio EPA submitted a redesignation request and maintenance plan for this area on December 22, 2006. U.S. EPA approved this requests on August 9, 2007 (72 FR 44784).

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budgets based on emission rates generated from U.S. EPA's

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

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

model. The area is still attaining and maintaining the 1997 8-hour ozone standard and the point, area and non-road emissions have not changed significantly and did not need to be updated for this submittal.

The enclosed information was compiled by Ohio EPA, Ohio Department of Transportation, and Toledo Metropolitan Area Council of Governments. The public hearing for this package was held on April 9, 2013 in Toledo, Ohio. No testimony was provided, nor were any comments received.

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

electronic version of the submittal in PDF format is available at http://epa.ohio.gov/dapc/SIP/1997.aspx under the heading" Redesignations and Maintenance

Plans".

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049
www.epa.ohio.gov • (614) 644-3020 • (614) 644·3184 (fax)Administrator Hedman

RE: Request for Review and Approval of the Revised Toledo Area Maintenance Plan Approval for the 1997 EightHour Ozone Standard

Page 2 of 2



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

Control at (614) 644-3696.

Sincerely,

# ~ Director

enclosures

cc: Bob Hodanbosi, DAPC

Jennifer Dines, DAPC

# REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR THE TOLEDO, OH

NONATTAINMENT AREA

Toledo

, OH:

Lucas and Wood County



# Developed By:

Ohio Environmental Protection Agency

Division of Air Pollution Control

December

, 2006

Revised April 201 3

### Thi s page left intentionally blanki 

### TABLE OF CONTENTS

Chapter One

Introduction

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

................................ ................................ ................................ ................................ ..... 1 Geographical d escription

................................ ................................ ................................ ................ 2 Status of air q uality

................................ ................................ ................................ .......................... 2

Chapter Two Requirements for redesignation

................................ ................................ ................................ ...... 3

Chapter Three

O zone m onitoring

................................ ................................ ................................ ............................ 6 Ambient data quality assured

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

................................ ................................ ................................ ......... 7
Com mitment to continue monitoring

................................ ................................ ............................... 8

Chapter Four

E mission I nventory

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

B ase Year Inventory

................................ ................................ ................................ ...................... 10 Emission Projections

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

Demonstration of Maintenance

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

Permanent and Enf orceable Em issions Reductions

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

P rovisions for Future Up dat es

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

Chapter Five Control measures and regulations

................................ ................................ ................................ 23 Implementation of Past SIP Revisions

................................ ................................ ......................... 23
New Source Review Provisions

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

Assurance of con tinued controls

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

Chapter Six

C ontingency measures

................................ ................................ ................................ ................. 27 Commitment to revise plan

................................ ................................ ................................ ........... 27
Com mit ment for continge ncy measures

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

P otential contingency measures

................................ ................................ ................................ ... 28
List of VOC and NO

x 

### sources

................................ ................................ ................................ ....... 29

Chapter Seven Public participation

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

Chapter Eight

Conclusions

................................ ................................ ................................ ................................ ... 32ii 

### FIGURES

Figure 1 Toledo, OH area Basic Nonattainment Area

................................ .......................... 6

TABLES

Table 1 Monitoring Data for the Toledo, OH area 2004

– 2006

................................ .......... 8

Table 2 Emission Estimations for On

- ro ad Mobile Sources for Lucas County

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

Table 3 Emission Estimations for On

- road Mobile Sources for Wood County

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

Table 4 Combined Emission Estimatio ns for On

- road Mobile Sources

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

T able 5 Mobile Vehicle Emission Budget

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

Table 6 V OC Emission Inventory Lucas County

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

Table 7 VOC Emission Inventory Wood County

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

Table 8 VOC Emission Inventory Toledo, OH area Totals

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

Table 9 NO

x 

### Emission Inventory Lucas Count y

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

Table 10 NO

x 

### Emission Inventory Wood County

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

Table 11 NO

x 

### Emission Inv entory Toledo, OH area Totals

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

Table 12 Projected emission estimates 2004

- 2018 Lucas County

................................ ..... 20

Table 13 Projected emission estimates 2004

- 2018 Wood County

................................ ..... 20

Table 14 Projected emission esti mates 2004

- 2018 Combined VOC/NOx Totals

............... 20

Table 15 Combined comparison of 2002 an d 2004 On

- road and EGU Totals

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

APPENDICES

A Air Quality System (AQS)

B Emission Inventories
C Emissions Analysis Method

D Public Participation Documentationiii 

### This page left intentionally blank1 

### REQUEST FOR REDESIGNATION AND

MAINTENANCE PLAN FOR OZONE ATTAINMENT

IN THE EIGHT

- HOUR OZONE BASIC

NONATTAINMENT AREA

TOLEDO

, OH:

Lucas and Wood Counties



## CHAPTER ONE

I ntroduction The Clean Air Act (CAA) requires areas faili ng to meet the National Ambient Air Quality Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standard. In 1997, the United States Enviro nmental Protection Agency ( U.S. EPA ) revised the air q uality standards for ozone replacing the

1979 one

- hour standard with an eight

- hour ozone standard set at 0.08 parts per million ( ppm

. ) The standard was challenged legally and upheld by the U.S. Supr eme Court in February of 2001.

On April 30 , 2004, U.S. E PA designated 134 nonattainment areas for the eight

- hour ozone

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

areas to the next lower classification. Section 107(d)(3)(E) of the CAA allows states to
request no nattainment areas be redesignated to attainment providing certain criteria are met. The following are the criteria that must be met in order for an area to be redesignated

from nonattainment to attainment:

i) A determination that the area has attained the e ight

- hour ozone standard. ii) An appr oved SIP for the area under Sectio n 110(k ). iii) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirem ents. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirements have been

met.

Background As part of the 1990 CAA Amendments re

- evaluation, the Tol edo, OH area was designated

Moderate Nonattainm ent for the one

- hour ozone standard p ursuant t o the CAA and therefore, has been subject to nonattainment area rule

- makings. The Toledo, OH area was redesignated to attainment with respect to the one

- hour ozone standard on August 1,

1995 (60FR39115 ). A ma intenance plan was approved at that time as well. As a result of

th e 2004 ozone designations, U.S. EPA designated the Toledo, OH area b asic

nonatt ainment and subject to the eight

- hour ozone requirements, including development of a plan to reduce volatile organic compounds (VOCs) and oxides of nitrogen (NO

x 

### )2



### emissions and a demonstration that the area will meet the federal eight

- hour air quality standard for ozone by June 2009.

This document is intended to support Ohio ’s request that the Toledo, OH area be redesignated from nona ttainment to attainment for the eight

- hour ozone s tandard. The Toledo, OH area has recorded three (3) years of complete, quality

- assured ambient air quality mo nitoring data for the years 2004

– 2006 dem onstrating attainment of the e ight

hour ozone standard.

Geographical Description The Toledo, OH nonattainment area includes Lucas and Wood Counties which are located

in n orthwest Ohio . Lucas County contains the C ity of Toledo and Wood County contains the City of Bowling Green. Lucas County is bordered by Lake Erie to the n orth and east,

Wood to the s outh and Fulton and Henry to the west. The Toledo, OH nonattainment area is shown in Figure 1.

Status of Air Quality Ozone monitoring data for the m ost recent three (3) years, 2004 through 2006

, demonstrates that the air quality has m et the NAAQS for ozone in this b as ic nonattainment area. The NAAQS attainment, accompanied by decreases in emission lev els discussed in Chapter f our, supports a redesignation to attainment for Toled o, OH area based on requirements in Section 107(d)(3)(E) of the CAA

.3



## C HAPTER TWO

Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation g uidance ), issued September 4, 1992 , to Regional Air Directors. This request for redesignation and maintenance p lan is based on the redesignation g uidance, supplemented with additional guidance re ceived from staff of U.S. EPA Region V.

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

area. i.) Attainment of the standard : There are two components involved in making this demonstration. The first component relies on ambient air quality data. T he data that are used to demonstrate attainment should be the product of ambient monitoring that is representative of the area of highest concentration. The data should be collected and quality

- assured in accordance with 40 CFR 58 and re corded in

the Air Quality System (AQS) in order for it to be available to the public for

review.

The second component relies upon supplemental U.S. EPA

- approved air quality modeling. The supplemental modeling is not required for ozone nonattainment areas seeking redesign ation. However, in Appendix C the most recent modeling results showing future attainment and maintenance

are provided. C hapter t hr ee discusses this requirement in more detail and provides the attainment demonstration.

ii.) SIP approval : The SIP for the are a must be fully approved under S ection 110(k) and must satisfy all requirements that apply to the area. Ohio’s SIP was appr oved on May 9, 1994 (59FR23799), March 23, 1995 (60FR15235) and August 1, 1995 (60FR39115) and includes the Toledo, OH area

. C h apter f ive discusses this requirement in more detail and provides the attainment

demonstration.

iii.) Permanent and enforce able improvement in air quality: The state must be able to reasonably attribute the improvement in air quality

to emission reductio ns which are permanent and enforceable. The state should estimate the percent reduction achieved from federal measures as well as control measures that have been adopted and implemented by the

state.

The Toledo, OH area was designated Moderate N onattain ment for ozone as part of the 1990 CAA Amendments re

- evaluation. As a result, Ohio has adopted or implemented control measure s beyond the federal measures, the4



### initial 1979 statewide rules and those 1994 and 1995 rules which applied to

“rural” attainment areas. Chapter s f our and f ive discuss this require ment in more detail and provide the attainment demonstration.

iv.) Section 110 and Part D requirements : For purposes of redesignation, a state must meet all requirements of S ection 110 and part D that we re applicable prior to submittal of the complete redesignation request.

Part D consists of general requirements applicable to all areas which are designated nonattainment based on a violation of the NAAQS.

i.) Section 172(c) requirements

This section contains general requirements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for

attainment will not apply for redesignations because they only have

mean ing for areas not attaining the standard. The requirements for an emission inventory will be satisfied by the inventory requirements

of the mainte nance plan. Chapter four discusses this requirement in

more detail.

ii.) Conformity

The state must work with U.S. EPA to show that its SIP provisions are consistent with section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedures in place. If a state does not have

conf ormity procedures in place at the time that it submits a redesignation request, the state must commit to follow U.S. EPA ’s conformity regulation upon issuance, as applicable.

v.) Maintenance plans

. Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan whic h meets the requirements of

S ection 175(A). The maintenance plan will constitute a SIP revision and must provide for maintenance of the relevant NA AQS in the area for at least

10 years afte r redesignation. Section 175 (A) further states that the plan shall contain such additional measures, if any, as may be necessary to

ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures

as the Administrator d eems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.5



### States seeki ng redesignation of a nonattainment area should consider the following provisions:

a.) a ttainment inventory ; b.) m aintenance demonstration ;

c. ) m onitoring network ; d.) v erification of continued attainment ; and e.) c ontingency plan

.

Chapter s ix disc usses this requirement in more detail and provides the

attainment demonstration.6



## CHAPTER THREE

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

Requirement 1 of 4 : A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, have been

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

Background : There are five monitor s measuri ng ozone concentrations in this

no nattainm ent area. The monitor located in Wood County is currently operated by the Ohio Environmental Protection Agency (Ohio EPA) Northwest District Office, Division of Air Pollution Control and the monitors located in Lucas County are operated by the Toledo Division of

Environmental Services

. The location s of the monitoring site s for this

nonattainment area are shown on Figure 1

.

Demonstration :

Figure 1 Map of Toledo, OH area7



### Requirement 2 of 4 : Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in the U.S. EPA air qua lity system (AQS) data base, and available for public view.

Demonstration : Ohio EPA has quality assu re d all data shown in Appendix A in accordance

with 40 CFR 58.10 and the Ohio Quality Assurance Manual. Ohio EPA has
recorded the data in the AQS database an d therefore data are available to the public.

Requirement 3 of 4 : A showing that the three

- year average of the fourth highest values, based on data from all monitoring sites in the area or its affected downwind environs, are below 85 parts per billion (ppb ). This showing must rely on three (3) complete, consecutive calendar years of quality assured data.

Background : The following information is taken from U.S. EPA 's "Guideline on Data Handling Conventions for the eight

- hour Ozone National Ambient Air Qu ality Standard (NAAQS)," U.S. EPA

- 454/R

- 98

- 017, December 1998.

Three (3) complete years of ozone monitoring data are required to demonstrate attainment at a monitoring site. The eight

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

- year average of the annual fourth

highest daily maximum eight

- hour average ozone concentration is less than or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. Three (3) significant digits must be carried in the computations. Because the third decimal digit, in ppm, is rounded, 0.084 ppm is the largest concent ration that is less than or equal to 0.08 ppm. Therefore, for the purposes of this request, the eight

- hour standa rd is considered to be 0.085 ppm. Values

below 0.085 ppm meet the standard, values equal to or greater than 0.085 ppm exceed the standard. These data handling procedures are applied on an individual basis at each monitor in the area. An area is in compl iance with

the eight

- hour ozone NAAQS if, and only if, every monitoring site in the area meets the NAAQS. An individual site's three (3) year average of the annual fourth highest daily maximum eight

- hour average ozone concentration is also

c alled the site 's design value.

Table 1 shows the monitoring data for t he thre e most recent years, 2004

- 2006

, in the nonattainment area and was retrieved from the U.S. EPA AQS. Please note that the standard is measured in ppm while the commonly used unit is ppb. For the remainder of this document, ppb will be used.8



### Demonstration :

Table 1 : Monitoring Data for Toledo, OH area 2004

– 2006

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

.

http://www.ep a.gov/ttn/airs/airsaqs/index.htm

1 st 2 nd 3 rd 4 th 2004

- 2006

SITE ID COUNTY ADDRESS YEAR %OBS 8

- HR 8

- HR 8

- HR 8

- HR AVERAGE

39

- 095

- 0024 Lucas Erie 2004 99 72 72 72 67

74 39

- 095

- 0024 Lucas Erie 2005 100 92 91 84 80

39

- 095

- 0024 Lucas Erie 2006 99 81 79 76 75

39

- 095

- 0027 Lucas Waterville 2004 100 76 76 76 74

75 39

- 095

- 0027 Lucas Waterville 2005 100 89 88 87 84

39

- 095

- 0027 Lucas Waterville 2006 100 79 77 72 69

39

- 095

- 0034 Lucas Low Serve 2004 100 90 79 79 78

79 39

- 095

- 0034 Lucas Low Serve 2005 99 108 92 89 87

39

- 095

- 0034 Lucas Low Serve 2006 100 79 77 74 74

39

- 095

- 0081 Lucas Friendship 2004 99 86 79 78 78

79 39

- 095

- 0081 Lucas Friendship 2005 100 101 94 90 87

39

- 095

- 0081 Lucas Friendship 2006 98 80 80 75 74

39

- 173

- 0003 Wood Bowling Gr 20 04 100 79 78 77 76

77 39

- 173

- 0003 Wood Bowling Gr 2005 100 92 86 85 84

39

- 173

- 0003 Wood Bowling Gr 2006 100 81 80 75 73
Highest Average 79 pp b



### A compr ehensive list of the site ’s design values during the 2004

- 2006 time period is in Appendix A . The a rea's design value has tr ended downward as

emissions have declined due to such factors as cleaner automobiles and fuels both regionally and locally.

Requirement 4 of 4 : A commitmen t that once redesignated, the s tate will continue to operate an appropri ate monitoring network to verify the maintenance of the attainment status.

Demonstration : Ohio commits to continue moni toring ozone levels at the site indicated in Figure 1

. Ohio EPA will consult with U.S. EPA Region V staff prior to making changes to t he existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58. Connection to a central station and updates to the Ohio EPA W eb site 1 

### will provide real time availability of the data and knowledge of any exceedances. Ohio EPA will

1
www .epa.state.oh.us/dapc/9



### enter all data into AQS on a timely basis in accordance with federal guidelines.10



## CHAPTER FOUR

EMISSION INVENTORY

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

U.S. EPA ’s redes ignation g uidance requires the submittal of a comprehensive inventory of ozone precursor emissions (VOC and NO

x 

### ) representative of the year when the area

achieves attainment of the ozone air quality standard. Ohio also must demonstrate that the improvemen t in air quality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions

. Other emissions inventory related requirements include a projection of the emission

inven tory to a year at least 10 years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain the ozone standard; and a commitment to provide future updates of the inventory to enable tracking of emi ssion levels during the ten( 10 ) year maintenance period.

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

year.

Background : The point source data are taken from Ohio's annua l emissions reporting program. The 2002 pe riodic inventory has been identified as the preferred

data base for SIP deve lopment and does coincide with nonattainment air quality in the Toledo, OH area

.

Periodic inventories, which include emissions from all sectors

- mobile, area,

non

- road, and point sources

- are prepared every three (3) years.

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

areas, information from current and previous SIP modeling efforts do es provide some indication of the impact from Ohio sources near the nonattainment area. The emissions are decreasing substantially in response

to regional and national programs affecting many EGUs such as the Acid Rain program and the NO

x 

### SIP Call.

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

Background : Ohio EPA prepared a comprehensive inventory for the Toledo, OH area

, including area, mobile, and point sources for precursors of ozone (volatile organic compounds and nitrogen oxi des) for base year 2002

. The information below describes the procedures Ohio EPA used to generate the11



### 2002 base inventories and to develop SIP ready modeling inventories and future year projections . These inventories were provided to the Lake Michigan Ai r Directors' Conso rtium (LADCO) and have been processed to develop summer day emissions for use in the air quality analyses. These processed modeling inventories have been identified as the correct iteration of the inventory for use in the redesignation. In this document, references to

LADCO include the Midwest Regional Planning Organization.

Area sources were taken from the Ohio 2002 periodic inventory

submitted to U.S. EPA . These projections were made from the U.S. Department of Commerce Bureau of Eco nomic Analysis (BEA) growth factors, with some updated local information.

Mobile source emissions were calculated using emissions factors produced with MOVES2010

. P oint source information was compiled from Ohio EPA’s 2002 annual emissions inventory databas e and the 2002 U.S. EPA Air Markets

acid rain database 2



### . Biogenic emissions are not included in these summaries.

Non

- road emissions were generated using U.S. EPA’s National Mobile Inventory Model (NMIM) 2002 application . To address

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

non

- road emissions model, LADCO contracted with two (2 ) companies to review the base data and make recommendations.

One of the contractors als o estimated emissions for three (3 ) non

road categories not included in U.S. EPA ’s non

- road mod el.

Emissions were estimated for aircraft, commercial marine vessels and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations f or the construction equipment category were reviewed and updated based upon surveys completed in t he Midwest and the temporal allocati on for agricultural sources also was updated.

The report by Pechan generated future year estimates of annual emissions for each source sector using accepted growth surrogates. The on

- road mobile source sector however was addressed by specific modeling as addressed below.

Demonstration :

On

- Road Emission Estimations In coordination with the Ohio Dep artment of Transport ation (O DOT) the Toledo Metropolitan Area Council of Governments (TMACOG) utilizes a regional travel

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

2 http://www.epa.gov/airmarkets/acidrain12



### given growth expectations. The model is primarily used as a long r ange planning tool to evaluate the transportation system including determination of locations where additional travel capacity may be needed and to determine the infrastructure requirements necessary to meet that need. It is also used as a tool for air qu ality purposes to estimate the total emissions of pollution caused by vehicles in the area. The travel demand forecasting model is used to predict the total daily vehicle miles traveled (VMT) and an U.S EPA computer program called MOVES 2010 is used to

cal culate emissions per mile. The product of these is the total amount of pollution emitted by the on

- road vehicles for the particular analyzed area.

Overview Broadly described, MOVES 2010 is used to gen erate “emission factors”, which are the average emissi ons per mile (grams/mile) for ozone precursors, NO

x 

### and VOC.

The MOVES 2010 model includes a number of variables that affect the emission factors. These variables have national default values, some of which require modification to reasonably reflect local conditions. Some of these variables are discussed here. The vehicle fleet (vehicles on the road) age and the vehicle type have a major effect on the emission factors. The source types are traveling on road types (MOVES 2010 road types are Rural Restric ted Access, Rural Unrestricted Access, Urban Restricted Access, and Urban Unrestricted Access). The vehicle speeds also affect the emission factor values. Meteorological conditions such as air temperature and humidity have a significant effect on emission factors. Emission factors produced by MOVES 2010 can also include the effect of emission reduction strategies such as vehicle inspection and maintenance programs, regulation of fuels, etc. These MOVES 2010 inputs are estimated using the best available dat a.

These inputs are reviewed and agreed to by U.S. EPA and transportation agencies in a formal interagency consultation process. Emission factors are multiplied by

VMT from the travel demand model to estimate the total vehicle emissions.

The emission fa ctors from MOVES 2010 can be used with the travel demand model information by combining the disaggregate emission rates with VMT, and source type population for each road type, source type and hour of day, and then sum them up to get the total emissions for the area.

The TMACOG ana lysis method, developed by O DOT, is to aggregate the emission rates by two source types (cars & trucks), then applying VMT and source type population, thereby reducing the intensive processes. In the first step emission

factors ar e broadly classified into total vehicles, cars and trucks by pollutant, by average speed, road type and hour of day. Then the hourly link volumes generated

from travel demand model are combined with emission factors for each network link

for each hour. The on

- road vehicle emissions for the area is the sum of all individual

link

- hour emissions. Vehicle

- based emissions are obtained by the combination of corresponding emission factors and source type population. Intrazonal emissions are computed using a separa te method to account for those trips that use local13



### roads to travel within a zone. Intrazonal VMT is combined with corresponding emission factors to get intrazonal emissions. Total emissions are sum of on

- road vehicle emissions, vehicle

- based emissions and intrazonal emissions.

Automated programs, using FORTRAN and CUBE scripting, were developed by ODOT to generate total emissions. The process uses data on daily and directional traffic distributions as well as more up to date volume/delay functions from t he 2000 Highway Capacity Manual (HCM). This process also handles the newer model

network formats and MOVES 2010 generated emission factors. MOVES2010 input and output files are provided in Appendix C.

Best Available Data Most current vehicle age distribu tion data, temperature data, fuel properties data, source type distribution data, and I/M data provided by ODOT’s ATRs and WIMs, NOAA, ODPS, and Ohio EPA were used by the O DOT for generating emission factors. Likewise, the most current transportation plan ning data available from TMACOG and most current ODOT count data were used by O DOT for the

emissions estimates.

Analysis Years Analysis years for this request include 2002, 2004, 2009, and 2018 to meet the requirements specified by the CAA and U.S. EPA. T he travel demand model

re presents the transportation system conditions for each of these years. Model runs for each future analysis year contain t he road network TMACOG and O DOT expects to exist at the beginning of that year with corresponding socioeconom ic forecasts for that year.

Local Road VMT Most local roads such as subdivision streets are not explicitly modeled in a travel demand model. These local roads are represented as fictitious roadways called

centroid connectors . Local road VMT is include d in the O DOT post process by including the traffic loaded on centroid connectors. In addition, some local road traffic is captured as intra

- zonal trips which travel demand models usually do not assign to roadway segments. The ODOT post process includes these trips as local

road VMT.

Model area VMT For TMACOG, the travel demand model covers the entire MPO and portions of Sandusky County, and also Michigan. VMT for the portion of model which extends beyond Lucas and Wood Counties is removed before total e missions are

calculated.14



### Emission Estimations

Table 2 contains the results of the emissions analysis for the appropriate

years.

Table 2 Emission Estimations for On

- Road Mobile Sources for Lucas

County , Ohio

Data source: On

- road only, TMACOG Travel Demand Model.



### Lucas County 2002 2004 2009 2018
VMT (miles/day) 10,302,083 10,245,650 10,320,228 9,654,159

VOC (tons/day) 20.51 17.86 12.49 5.20

NO

x 

### (tons/day) 40.26 35.58 26.41 9.63

Table 3 Emission Estimations for On

- Road Mobile Sources for Wood

C ounty, Ohio

Data source: On

- road only, TMACOG Travel Demand Model.



### Wood County 2002 2004 2009 2018
VMT (miles/day) 5,162,330 5,738,286 5,895,270 5,792,238

VOC (tons/day) 9.23 9.00 6.30 2.94

NO

x 

### (tons/day) 19.33 19.54 14.27 5.71

Table 4 Combined V OC and NO
x 

### Emission Estimations for On

- Road

Mobile Sources f or the Toledo, OH area

.

Data source: On

- road only, TMACOG Travel Demand Model.



### County VOC 2018 Lucas County, OH VOC 5.20 Wood County, OH VOC 2.94

TOTAL VOC 8.14

County NO
x 

### Lucas County, OH NO

x 

### 9.63 Wood County, OH NO

x 

### 5.71

TOTAL NO
x 

### 15.3415



### Motor Vehicle Emission Budget

Table 5 contains the motor vehicle emissions budget for the Toledo, OH area

.

Table 5 Mobile Vehicle Emission Budget for Toledo, OH: Lucas a nd

Wood County

Data source: On

- road only, TMACOG Travel Demand Model.



### 20 09 2018 VOC (tons/day ) 21.61 * 9.36 *

NO

x 

### (tons/day) 46.78 * 17.64 * *includes 15 percent

This budget includes the emission estimates calculated for 2009 and 20 18

. The emission estimates are derived from the Tranplan travel demand model

and MOVES2010 as described above under the expected TMACOG 2035 Long Range Plan

. The mobile source budget for 2009 include s 21.61 tons

per summer day (tp d) for VOC and 46.78 tpd for NO x. The mobile source budget for 2018 includes 9.36 tpd for VOC and 17.64 tpd for NO

x 

### . These correspond to a 15 percent increase from the 20 18 on

- road emissions for

both VOC and NO

x 

### . Appendix C contains data tables and graphs of these

emissions.

All meth odologies, latest planning assumptions and the safety margins were determined through the interagency consultation process described in the Transportation Conformity Memorandum of Understanding (MOU) for

TMACOG

.

The current 1

- hour budget s will no longer be applicable either after the effective date of the approved redesignation or after the effective date of any

U.S. EP A action approving a finding that the eight

- hour conformity budget

inclu ded in this submittal adequate for transportation conformity purp oses whichever date comes first

.

Requirement 3 of 5 : A demonstration that the projected level of emissions is sufficient to maintain the ozone

standard.

Background : In consultation with U.S. EPA , Ohio EPA selected the year 2018 as the maintenance year f or this redesignation request. This document contains projected emissions inventories for 2009 and 2018.

TMACOG performed emission projections for Toledo, OH area using the following approaches.16 

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

MOVES2010 model. The analysis is describ e d in more detail in Appendix C . All projections were made in accordance with

“Procedures for P reparing Emissions Projections” U.S. EPA

- 45/4

- 91

- 019.

Emissions inventories are required to be projected to futur e dates to assess the influence growth and future controls will have. LADCO developed growth and control files for point, area, and non

- road categories. These files were used to develop the future year

emissions estimates used in this d ocument. This was done so the inventories used for redesignation are consistent with modeling performed in the future.

The detailed inventory information for the Toledo, OH area for 2002, 2004

, 2009 and 2018 is in Appendix B . Emission trends are an important gauge for

con tinued compliance with the ozone standard. Therefore, Ohio EPA performed an initial comparison of the inventories for the base year and maintenance years for Lucas and Wood c ounties . M obile source emission

inventories are described in Appendix B

. In add ition to the LADCO estimates, point source emissions were projected based upon the state wide

EGU NO

x 

### budgets from the Ohio NO

x 

### rule.

The following tables include sectors Electrical Generating Unit (EGU

- Point),

Non

- Electrical Generating Unit (Non

- EGU)

, Non

- road Mobile (Non

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

- road Mobile (On

- road). Maintenance is demonstrated when the future year projected emission totals (2018 total) are below the 2004 attainment year total.17



### Demonstrati on :

Table 6 Lucas County VOC Emission Inventory Totals for Base Year

2002

, Estimated 2004 and Projected 2009 and 2018 (tons per

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.



### Sector 2002

Base 2004

Attainment 2009

Interim 2018

Ma intenance Safety

Margin

EGU Point 0.15 0.15 0.17 0.15

Non

- EGU 7.50 7.29 6.75 7.52

Non

- road 8.17 7.35 5.32 n \ a
Other 22.71 22.78 22.97 25.06

MAR 0.32 0.31 0.30 0.30

On

- road 20.51 17.86 12.49 5.20

TOTAL 59.36 55.74 48.00 38.23 17.51

Table 7 Wood County VOC Emission Inventory Totals for Base Year

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

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.



### Sector 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Sa fety

Margin

EGU

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

Non

- EGU 0.49 0.43 0.29 0.32

Non

- road 2.58 2.38 1.90 n/a

Other 7.91 7.77 7.43 7.54

MAR 0.28 0.27 0.26 0.27

On

- road 9.23 9.00 6.30 2.94

TOTAL 20.49 19.85 16.18 11.07 8.7818



### Table 8 Toledo, OH area VOC Emis sion Inventory Totals for Base Year

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

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.



### 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

Luca s County 59.36 55.74 48.00 38.23 Wood County 20.49 19.85 16.18 11.07

COMBINED

VOC TOTAL 79.85 75.59 64.18 49.30 26.29

Table 9 Lucas County NO
x 

### Emission Inventory Totals for Base Year

2002

, Estimated 2004 and Projected 2009 and 2018 (tons per

summe r day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Rep orts.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.



### Sector 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Point 24.91 22.57 16.73 3.83

Non

- EGU 13.97 12.97 10.47 9.03

Non

- road 8.54 7.96 6.51 n/a

Other 0.97 1.03 1.17 1.18

MAR 8.26 7.72 6.37 6.05

On

- road 40.26 35.58 26.41 9.63

TOTAL 96.91 87.83 67.66 29.72 58.1119



### Table 10 Wood County NO
x 

### Emission Inventory Totals for Base Year

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

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.



### Sector 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Point n/a n/a 0.02 0.04

Non

- EGU n/a n/a n/a n/a

Non

- road 3.87 3.63 3.05 n/a

Other 0.64 0.67 0.74 0.79

MAR 6.19 5.51 3.83 3.60

On

- road 19.33 19.54 14.27 5.71

TOTAL 30.03 29.35 21.91 10.14 19.21

Table 11 Toledo, OH area NO
x 

### Emission Inventory Totals for Base Year

2002

, Estimated 2004 and Projected 2009 and 2018 (tons per

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data sou rce: O n

- road only, TMACOG Travel Demand Model.



### 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin Lucas County 96.91 87.83 67.66 29.72 Wood County 30.03 29.35 21.91 10.14

COMBINED

NO
x 

### TOTAL 126.94 117.18 89.57 39.86 77.3220



### Table 12 Lucas County Comparison of 2004 attainment year and

2018 projected emission estimates (tons per day, summer)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.



### 2004 2018 Projected

Decrease

VOC 55.74 38.23 17.51

NO
x 

### 87.83 29 .72 58.11

Table 13 Wood County Comparison of 2004 attainment year and

2018 projected emission estimates (tons per day, summer)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.



### 2004 2018 Projected

Decrease

VOC 19.85 11.07 8.78

NO
x 

### 29.35 10.14 19.21

Table 14 Toledo, OH area Combined Compar ison of 2004 attainment

year and 2018 projected emission estimates (tons per day,

summer )

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

Directors Consorti um (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.



### 2004 2018 Projected Change

VOC 75.59 49.30 26.29

NO
x 

### 117.18 39.86 77.3221



### VOC emissions in the non

- attainment ar ea are projected to decrease 26.29 tons per day (tpd) . Area source emissions and, to a lesser extent, point sources, show an increase due to expectations that the population will g row in this area. However, cleaner vehicles and fuels are expected to be in place in 2009 and 2018 and result in an overall drop in VO C emissions.

NO

x 

### emissions in the nonattainment area a re projected to decrease by 77.32 tpd . Decreases from U.S. EPA ru les covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 3 

### , Highway Heavy

- Duty Engine Rule 4 

### and Non

- Road Diesel Engine Rule 5 

### also factored into the changes. Further, due to implementation of the NO

x 

### SIP Call across

the eastern United States, NO

x 

### and ozone levels entering this area also will

be decreased.

Requirement 4 of 5 : A demonstration that improvement in air quality between the year violations occurred and attainment was achieved is based on permanent and enfor ceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background : A mbient air quality data from the monitoring site indicate s that air quality met the NAAQS for ozone in 2005

. U.S. EPA ’s redesigna tion g uidance (p 9) states, “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the

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

N AAQS.”

In Ohio, major point sources in all counties are required to submit air emissions information once every three (3) years or annually if VOC potential to emit is greater than 250 tons or NO

x 

### potential to emit is greater than 2500

t ons, in accordance with U.S. EPA ’s Consolidated Emissions Reporting Rule (CERR)

. Ohio EPA prepares a new periodic inventory for all ozone precursor emission sectors every three (3) years. These ozone pr ecursor inventories will be prepared for 2005, 2008, and 2011 as necessary to comply with the inventory reporting requirements established in the CFR

. Emissions information will be compared to the 2002 base year and the 2018 projected maintenance year inv entories to assess emission trends, as necessary, to assure continued compliance with the ozone standard.

3 http://www.epa.gov/fedrgstr/EPA

- AIR/2000/February/Day

- 10/a19a.htm

4 http://www.epa.gov/fedrg str/EPA

- AIR/1997/October/Day

- 21/a27494.htm

5 http://www.epa.gov/fedrgstr/EPA

- AIR/1998/October/Day

- 23/a24836.htm22



### Demonstration : Permanent and enforceable reductions of volatile organic compounds and oxides of nitrogen have contributed to the attainment of the e ight

- hour ozone
stan dard. Some of these reductions were due to the application of tighter

federal standards on new vehicles. Also , Title IV of the CAA and the NO

x 

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

While no EGU r eductions occurred within Toledo, OH area , statewide NO

x 

### reductions from EGUs were over 85 percent due to this program.

Table 1 5 Toledo, OH area Comparison of 2002 base year and 2004

attainment year on

- road and EGU reductions (tons per day, summer)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.



### 2002 2004

On

- road VOC 29.74 26.86

On

- road NO

x 

### 59.59 55.12

EGU NO

x 

### 24.91 22.57

Requirement 5 of 5 : Provisions for future annual updates of the inventory to enable tracking of the emissio n levels including an annual emission statement from major sources.

Demonstration : As required by Section 175A(b) of the CAA , Ohio commits to submit to the Administrator, eight (8) years after redesignation, an additional revision of

this SIP. The revisio n will contain Ohio's plan for maintaining the national primary ozone a ir quality standard for 10 years beyond the first 10 year period after redesignation.23



## CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4 : U.S. EPA approved SIP control strategy that includes RACT requirements for existing stationary sources covered by Control Technology Guidelines (CTG) as applied in Ohio’s

rural counties.

Background : As required by Section 1 72 of the 1990 CAA Amendments, in the mid

- 1990’s Ohio promulgated rule requ iring RACT for emissions of VOC s. There were

no s pecific rules required by the CAA such as RACT for existing sources beyond statewide rules.

Demonstration : Statewide RACT rules h ave been applied to all new sources locating in Ohio since that time. The Ohio rules are found in OAC Chapter 3745

- 21.

Requirement 2 of 4 : Evidence that control measures required in pas t ozone SIP revisions have been f ully implemented.

Background : The U.S. EPA NO

x 

### SI P Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. Ohio passed this rule in 2001.

Be ginning in 2004, this rule acc ount ed for a reduction of approximately 31 percent of all NO

x 

### emissions state wide compared to previous uncontrolled

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

The Toledo, OH area also implemented rules as part of the 15 percent rate of prog ress demonstrati on. These measures included Non

- CTG RACT,

NESHAP and enforcement cases. These rules were also assumed to be in place as part of the maintenance plan following the one

- hour redesignation.

Demonstration : U.S. EPA and Ohio EPA performed mod eling that indicated this area would

attain the eight

- hour ozone standard with the implementation of the NO

x 

### SIP Call. Controls for EGUs formally commenced May 31, 2004. E missions covered by this program have been generally trending downward since 1998

w ith larger reductions occurring in 2002 and 2003. D ata taken from U.S. EPA

Clean Air Markets W eb site, quantifies the gradual NO

x 

### reductions that have24



### 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 in response to the SIP Call. OAC chapter 3745

- 14 regulated EGUs and certain non

- EGUs under a cap and trade program based on an 85 percent reduction of NO

x 

### emissions from

EGU s and a 60 percent reduction of NO

x 

### emissions from non

- EGUs, compared to historical levels. This cap will stay in place through 2008, at which time the CAIR program will supersede it.

U.S. EPA has recently published Phase II of the NO

x 

### SIP Call that

es tablishes a budget for large (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio EPA’s proposed rule OAC

3745

- 14

- 12 addresses stationary internal combustion engines, all used in natural ga s pipeline transmissions. An 82 p ercent NO

x 

### reduction from 1995 levels is anticipated. Completion of the compliance plan is expected by May 1, 2006 and the compliance demonstration will begin May 1, 2007. The

2007 controlled NO

x 

### emissions will be 599 tons per day.

Tier II Emission Sta ndards for Vehicles and Gasoline Sulfur Standards

In February 2000

, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required t o sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and

2009. U.S. EPA has estimated that NO

x 

### emission reductions will be approxima te ly 77 percent for passenge r cars, 86 percent for smaller SUVs,

l ight truc ks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. VOC emission reductions will be ap proximately 12 percent for passen ger cars, 18 percent f or smaller SUVs, light trucks, and

min ivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy

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

- sulfur diesel fuel s tandards, which will be phased in from 2004 through 2007. This rule applies to heavy

- duty gasoline

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

NO

x 

### from diesel trucks and buses, a large sector of the mobile sources NO

x 

### i nventory.

Clean Air Non

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

- road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard simi lar to the highway diesel program. The new standards will cut emissions from non

- road diesel engi nes by more than 90 percent . Non

- road diesel equipment, as described25



### in this rule, currently accounts for 47 percent of diesel particulate matter and 25 perc ent of NO

x 

### from mobile sources nationwide. Sulfur levels will be

reduced in non

- road diesel fuel by 99 percent from current levels, from approximately 3,000 ppm now to 15 ppm in 2009.

Together, these rules will substantially reduce local and regiona l so urces of

ozone precursors.

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

Background : Ohio has a long standing and fully implemented New Source Review (NSR) program. Thi s is a ddressed in OAC Chapter 3745

- 31. The chapter in cludes provisions for the Prevention of Significant Deterioration (PSD) permitting

program in OAC 3745

- 31

- 01 to 3745

- 31

- 20

. Ohio's PSD program was

conditi onally approved on October 10, 2001 (66 FR 51570 ) and received final appro val on January 22, 2003 (68 FR 2909 ) by U.S. EPA as part of the

SIP

.

Demonstration : Any facility that is not listed in the 2002 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconst ruct without meeting all applicable permit rule requirement. The review process will be identical to that used for

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

.

Requirement 4 of 4 : Assure that existing controls will remain in effect after redesignation unless the State demonstrates through photochemical modeling that the standard can be maintained without one (1) or more controls.

Demonstration : Ohio commits to maintaining the aforementioned control mea sures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicable to VOC and/or NO

x 

### sources, as required for

maintenance of the ozone standard in the Toledo, OH area , will be submitted

to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal section, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that

relate to th e emission of ozone precursors in the Toledo, OH area

.26



### LADCO Modeling Analysis for 8

- Hour Ozone Standard Assessment

LADCO performed modeling to evaluate the effect of the NO

x 

### SIP Call and

Tier II / Low Sulfur rule for future year 2007 ozone in the Lake M ichigan area. This modeling was originally designed to assess the one

- hour ozone standard. Further analysis was conducted and documented in the LADCO’s White Paper “8

- Hour Ozone Assessment” dated May 2, 2001. Base year design values used were the average of the design values for the three (3)

three

- year periods (1994

- 1996, 1995

- 1997, and 1996

- 1998). Base year emissions were taken from 1996 and four (4) ozone episodes were

evaluated: June 22

- 28, 1991; July 14

- 21, 1991

While modeling results were not calc ulated for the Toledo, OH area

, the average decrease in ozone from the base case modeling run with modeling runs that applied emission contro ls required by the CAA

, NO

x 

### SIP Call and

Tier II /low

- sulfur requirements was 15 ppb (2009 Future design v alue of

7 3.3ppb*.) [* LADCO Base K 2009 Future Base case with on

- the

- books” including CAIR].

LADCO Modeling for CAIR of 2004

On March 10, 2004

, U.S. EPA promulgated CAIR . 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 eastern states and the District of Columbia.

LADCO performed modeling to support the associated emission reductions for CAIR. This modeling was based on 2001

– 2002 design values for Toledo, OH area

. Results of the CAIR modeling show that the Toledo, OH

area will continue to attain the eight

- hour ozone NAAQS well into the future.27



## CHAPTER SIX

CONTINGENCY MEASURES

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

Requirement 1 of 4: A commitment to submit a revised plan eight (8) ye ars after redesignation.

Demonstration : Ohio hereby commits to review its maintenance p lan eight (8) years after redesignation, as required by Section 175(A) of the CAA

.

Requirement 2 of 4: A commitment to expeditiously enact and implement additional con tingency control measures in response to exceeding specified predetermined levels (triggers) or in the

event that future violations of the ambient standards occur.

Demonstration : Ohio hereby commits to adopt and expeditiously implement necessary

correctiv e actions in the following circumstances:

Warning Level Response: A warning level r esponse shall be prompted whenever an annual (1

- year) fourth high monitored value of 85 ppb occurs in a single ozone season within the maintenance area. A warning level r es ponse will consist of a study to determine whether the ozone value indicates a trend toward higher ozone values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and timing for implementation as well as economic and social considerations. Implementation of necessary controls in respons e to a warning level

r esponse trigger will take place as expe ditiously as possible, but in no event

later than 12 months from the conclusion of the most recent ozone season (September 30).

Shoul d it be determined through the warning l evel study that action is necessary to reverse the noted trend, the procedures for control selection

and implementation outlined under “ action l evel response ” shall be followed.

Action Level Response :

An Action Level Response shall be prompted whenever a two

- year average fourth high monitored value of 85 parts per billion (ppb) or greater occurs within the maintenance area. A violation of the standard (three

- year average fourth high value of 85 ppb or greater) shall also prompt an action level28



### response. In the event that the Action Level is triggered and is not found to

be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropolitan planning organization or regional council of governments, will determine

additional control measures needed to as sure future attainment of NAAQS for ozone. In this case, measures that can be implemented in a short time will be selected in order to be in place within 18 months from the close of the ozone season that prompted the Action Level. Ohio EPA will also cons ider the timing of an Action Level Trigger and determine if additional, significant new regulations not currently included as part of the maintenance provisions (e.g., AIM and Consumer Products) will be implemented in a timely manner

and will constitute ou r Response.

Control Measure Selection and Implementation :

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

If a new measure/control is already promulgated and scheduled to be implemented at the federal or state level, and that measure/control is

determined to be sufficient to add ress the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Ohio will

submit to U.S. EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

Requirement 3 of 4:

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

Demonstration : Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the

time the selection is made. The select ion of measures will be based on cost

effectiveness, emission reduction potential, economic and social

considerations or other factors t hat Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the main tenance area prior to selecting appropriate contingency measures. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined

below is not co mprehensive.29



### Lower Reid vapor pressure gasoline program.

1) Tighten RACT on existing sources covered by U.S. EPA Control Technique Guidelines issued in response to the 1990 CAA

.

2) Apply RA CT to smaller existing sources.

3) One or more transportation control m easures sufficient to achieve at least half a percent reduction in actual area wide VOC emissions. Transportation measures will be selected from the following, based upon the factors listed above after consultation with affected local governments:

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

based transportation management plans, area wide rideshare programs, work sche dule changes, and telecommuting;

b) traffic flow and t ransit improvements; and

c) other new or innovative transportation me asures not yet in widespread use that affect s state and local governments deemed appropriate.

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

5) Controls on consumer products consistent with those adopted

elsewhere in the United States.

6) Require VOC or NO

x 

### emission offsets for new and modified major

sources.

7) Require VOC or NO

x 

### emission offsets for new and modified minor

sources.

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

9) Require VOC or NO

x 

### controls on new minor sources (less than 100 tons).

No contingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated.30



### Requirement 4 of 4:

A list of VOC and NO

x 

### sources potentially subject to future controls.

Demonstration : The following is a list of VOC and NO

x 

### sources potentially subject to future

controls.

NO

x 

### RACT

EGUs asphalt batching plan ts

industrial/commercial and institutional boilers process heaters internal combustion engines

combustion turbines other sources greater than 100 tons per year

VOC RACT consumer products architectural and industrial maintenance coatings stage I gasoline d ispensing facilities (including pressure valves) automobile refinishing shops cold cleaner degreasers synthetic organic compound manufacturing organic compound batch processes wood manufacturing

industrial wastewater aerospace industry shipbuilding

bakerie s plastic parts coating volatile organic liquid storage industrial solvent cleaning offset lithography industrial surface coating other sources greater than 50 tons per year31



## CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesignation peti tion and maintenance plan in a widely distributed county publications.

The p ublic hearing to receive comments on the redesignation request was held on April 9

, 2013 at the Toledo Public Library

- South Branch

, 1736 Broadway Street

, Toledo

, Ohio

. The public commen t period close on April 9

, 2013

. No comments were received during the public comment period and no testimony was provided at the hearing. Appendix E include s

a co py of the public n otice and the hearing transcript

.32



## CHAPTER EIGHT

CONCLUSIONS

The Toledo, OH area basic nonattainment area has attained the NAAQS standard and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesig nations of basic ozone nonattainment areas. Documentation to that effect is

contained herein. Ohio EPA has prepared a state implementation and maintenance p lan that meets the requirement of Section 110 (a)(1) of the 1990 CAA

.

Ohio has performed an ana lysis that shows the air quality improvements are due to permanent and enforceable measures. In addition, significant regional NO

x 

### reductions will ensure continued compliance (maintenance) with the standard and that all CAA requirements necessary for rede signation have been met.

Based on this presentation, the Toledo, OH area ozone basic nonattainment area meets the requirements for redesignation under the CAA and U.S. EPA guidance. Furthermore, because this area is subject to significant transport of po llutants, significant regional NO

x 

### reductions will ensure continued compliance (maintenance) with the standards with an increasing margin of safety.

The State of Ohio hereby requests that the Toledo, OH area ozone basic nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio state implementation and m ai ntenance p lan provisions contained herein. In addition, the State of Ohio requests that this maintenance plan satisfy the requirements of CAA Section 175A (b), for subsequent plan revisions required for areas redesignated for the one

- hour ozone standard, as was the case with the Toledo, OH nonattainment area.33 

### This page left intentionally blank

### Synopsis of Changes

Revised Toledo Maintenance Plan under the 1997 Ozone Standard

The original redesignation request and maintenance plan document was submitted to U.S. EPA on December 22, 2006. U.S. EPA approved this requests on August 9, 2007 (72 FR 4 4784 ).

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budgets based on emission rates generated from U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation (MOV ES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s official emission factor model. The area is still attaining and maintaining the 1997 8

- hour ozone standard and the point, area and non

- road emissions have not changed significantly and did not need to be updated for this submittal.

A redline/strike

- out version of the original document follows this synopsis and identifies all changes that were made to the original approved request. In summary, revisions were

made to the on

- road (mobile) source emission estimates and budgets contained within the tables and text below. In addition, the discussion section regarding on

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

MOVES model. Other min or changes were made to conform to current terminology, grammar, and formatting conventions.

In addition to this document, additional changes were also made to the Appendices of the original submittal, as follows:

Appendix C: this appendix contains the d etailed modeling protocol used to generate on

- road mobile source emission estimates. The document contained within this revised submittal is an entirely new document compared to the original modeling protocol document submitted in 2006. Both the original and revised documents are available on Ohio EPA’s website under the “Appendix” link. Appendix E : this appendix contains documents relevant to the public comment period and the public hearing. This will contain a revised public notice and revised hearing transcript. In some cases, if comments are received or testimony provided, it will also contain a revised response to comments document. Both the original and revised documents are available on Ohio EPA’s website under the “Appendix” link.

These draft doc uments can all be found at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx in the table under the heading “Redesignations and Maintenance Plans.” The public comment period closed on April 9 , 2013.

# REQUEST FOR REDESIGNATION

REQUEST AND

MAINTENANCE PLAN FOR

OZONE ATTAINMENT

IN THE EIGHT

- HOUR OZONE

BASIC TOLEDO, OH

NONATTAINMENT AREA

Toledo

, OH:

Lucas and Wood County



# Developed By:

Ohio Environmental Protection Agency

Division of Air Pollut ion Control

December

, 2006

Revised April 201 3 Formatted: Subtitle, Left, Tab stops: Not at 0"

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Chapter One

Introduction

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

................................ ................................ ................................ ................................ ..... 1 Geographical d escription

................................ ................................ ................................ ................ 2 Status of air q uality

................................ ................................ ................................ .......................... 2

Chapter Two Requirements for redesignation

................................ ................................ ................................ ...... 3

Chapter T hree
O zone m onitoring

................................ ................................ ................................ ............................ 6 Ambient data quality assured

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

................................ ................................ ................................ ......... 7
Com mitment to continue monitoring

................................ ................................ ............................... 8

Chapter Four

E mission I nventory

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

B ase Year Inventory

................................ ................................ ................................ ...................... 10 Emission Projections

................................ ................................ ................................ ................. 11 10

Demonstration of Maintenance

................................ ................................ ................................ . 16 15

Permanent and E nf orceable Em issions Reductions

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

P rovisions for Future Updat es

................................ ................................ ................................ .. 21 22

Chapter Five Control measures and regulations

................................ ................................ ................................ 23 Implementation of Past SIP Revisions

................................ ................................ ......................... 23
New Source Review Provisions

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

Assurance of con tinued controls

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

Chapter Six

C ontingency mea sures

................................ ................................ ................................ ................. 27 Commitment to revise plan

................................ ................................ ................................ ........... 27
Com mit ment for contingency measures

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

P otential contingency measures

................................ ................................ ................................ ... 28
List of VOC and NO

x sources

................................ ................................ ................................ ....... 29

Chapter Seven Public participation

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

Chapter Eight

Conclusions

................................ ................................ ................................ ............................... 31 32ii FIGURES

Figure 1 Toledo, OH area Basic No nattainment Area

................................ .......................... 6

TABLES

Table 1 Monitoring Data for the Toledo, OH area 2004

– 2006

................................ .......... 8

Table 2 Emission Estimations for On

- ro ad Mobile Sources for Lucas County

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

Table 3 Emission Estimations for On

- road Mobile Sources for Wood County

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

Table 4 Combined Emission Estimatio ns for On

- road Mobile Sources

........................ 15 14

Table 5 Mobile Vehicle Emission Budget

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

Table 6 V OC Emission Inventory Lucas County

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

Table 7 VOC Emission Inventory Wood County

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

Table 8 VOC Emission Inventory Toledo, OH area To tals

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

Table 9 NO

x Emission Inventory Lucas Count y

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

Table 10 NO

x Emission Inventory Wood County

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

Table 11 NO

x Emission Inv entory Toledo, OH area Totals

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

Table 12 Projected emission estimates 2004

- 2018 Lucas County

................................ ..... 20

Table 13 Projected emission es timates 2004

- 2018 Wood County

................................ ..... 20

Table 14 Projected emission estimates 2004

- 2018 Combined VOC/NOx Totals

............... 20

Table 15 Combined comparison of 2002 an d 2004 On

- road and EGU Totals

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

APPENDICES

A Air Quality System (AQS)

B Emission Inventories
C Emiss ions Analysis Method

D Public Participation Documentationiii This page left intentionally blank1 REQUEST FOR REDESIGNATION AND

MAINTENANCE PLAN FOR OZONE ATTAINMENT

IN THE EIGHT

- HOUR OZONE BASIC

NONATTAINMENT AREA

TOLEDO

, OH:

Lucas and Wood Counties



### CHAPT ER ONE

I ntroduction The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air Quality Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standard. In 1997, the United St ates Enviro nmental Protection Agency ( U.S. EPA ) revised the air quality standards for ozone replacing the

1979 one

- hour standard with an eight

- hour ozone standard set at 0.08 parts per million ( ppm

. ) The standard was challenged legally and upheld by the U .S. Supr eme Court in February of 2001.

On April 30 , 2004, U.S. EPA designated 134 nonattainment areas for the eight

- hour ozone

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

areas to the next lower classificat ion. Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas be redesignated to attainment providing certain criteria are met. The following are the criteria that must be met in order for an area to be redesignated

from nonattainment to attainment:

i) A determination that the area has attained the eight

- hour ozone standard. ii) An appr oved SIP for the area under Sectio n 110(k ). iii) A determination that the improvement in air quality is due to permanent

and enforceable reductions in emissions re sulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirements have been

met.

Background As part of the 1990 CAA Amendments re

- e valuation, the Tol edo, OH area was designated

Moderate Nonattainment for the one

- hour ozone standard p ursuant t o the CAA and therefore, has been subject to nonattainment area rule

- makings. The Toledo, OH area was redesignated to attainment with respect to the one

- hour ozone standard on August 1,

1995 (60FR39115 ). A maintenance plan was approved at that time as well. As a result of

th e 2004 ozone designations, U.S. EPA designated the Toledo, OH area b asic

nonatt ainment and subject to the eight

- hour ozone requirements, including development of a plan to reduce volatile organic compounds (VOCs) and oxides of nitrogen (NO

x )2

emissions and a demonstration that the area will meet the federal eight

- hour air quality standard for ozone by June 2009.

This document is intended to support Ohio ’s request that the Toledo, OH area be redesignated from nona ttainment to attainment for the eight

- hour ozone s tandard. The Toledo, OH area has recorded three (3) years of complete, quality

- assured ambient air quality mo nitoring data for the years 2004

– 2006 dem onstrating attainment of the eight

hour ozone standard.

Geographical Description The Toledo, OH nonattainment area includes Lucas and Wood Counties which are located

in n orthwest Ohio . Lucas County contains the C it y of Toledo and Wood County contains the City of Bowling Green. Lucas County is bordered by Lake Erie to the n orth and east,

Wood to the s outh and Fulton and Henry to the west. The Toledo, OH nonattainment area is shown in Figure 1.

Status of Air Qua lity Ozone monitoring data for the m ost recent three (3) years, 2004 through 2006

, demonstrates that the air quality has m et the NAAQS for ozone in this b as ic nonattainment area. The NAAQS attainment, accompanied by decreases in emission lev els discussed in Chapter f our, supports a redesignation to attainment for Toledo, OH area based on requirements in Section 107(d)(3)(E) of the CAA

.

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### C HAPTER TWO

Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation g uidance ), issued September 4, 1992 , to Regional Air Directors. This request for redesignation and maintenance p lan is based on the redesignation g uidance, supp lemented with additional guidance re ceived from staff of U.S. EPA Region V.

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

area. i.) Attainment of the standard : There are two components involved in making this demonstr ation. The first component relies on ambient air quality data. The data that are used to demonstrate attainment should be the product of ambient monitoring that is representative of the area of highest concentration. The data should be collected and qua lity

- assured in accordance with 40 CFR 58 and re corded in the Air Quality System (AQS) in order for it to be available to the public for

review.

The second component relies upon supplemental U.S. EPA

- approved air quality modeling. The supplemental model ing is not required for ozone nonattainment areas seeking redesignation. However, in Appendix C the most recent modeling results showing future attainment and maintenance

are provided. C hapter t hr ee discusses this requirement in more detail and provides the attainment demonstration.

ii.) SIP approval : The SIP for the are a must be fully approved under S ection 110(k) and must satisfy all requirements that apply to the area. Ohio’s SIP was appr oved on May 9, 1994 (59FR23799), March 23, 1995 (60FR15235) an d August 1, 1995 (60FR39115) and includes the Toledo, OH area

. C hapter f ive discusses this requirement in more detail and provides the attainment

demonstration.

iii.) Permanent and enforce able improvement in air quality:

The state must be able to reason ably attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should estimate the percent reduction achieved from federal measures as well as control measures that have been adopted and implemented by the

state.

The Toledo, OH area was designated Moderate N onattainment for ozone as part of the 1990 CAA Amendments re

- evaluation. As a result, Ohio has4

adopted or implemented control measure s beyond the federal measures, the

initial 1979 statewide rules and those 1994 and 1995 rules which applied to

“rural” attainment areas. Chapter s f our and f ive discuss this require ment in more detail and provide the attainment demonstration.

iv.) Section 110 and Part D requirements : For purposes of redesignation, a state must meet all requirements of S ection 110 and part D that were applicable prior to submittal of the complete redesignation request.

Part D consists of general requirements applicable to all areas which are designated nonattainment based on a violat ion of the NAAQS.

i.) Section 172(c) requirements This section contains general requirements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for

attain ment will not apply for redesignations because they only have meaning for areas not attaining the standard. The requirements for an emission inventory will be satisfied by the inventory requirements

of the mainte nance plan. Chapter four discusses this re quirement in

more detail.

ii.) Conformity

The state must work with U.S. EPA to show that its SIP provisions are consistent with section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the

state alr eady has these procedures in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state must commit to follow U.S. EPA ’s conformity regulation upon issuance, as applicable.

v.) Maintena nce plans

. Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan whic h meets the requirements of

S ection 175(A). The maintenance plan will constitute a SIP revision and must provide for mainte nance of the relevant NA AQS in the area for at least

10 years after redesignation. Section 175 (A) further states that the plan shall contain such additional measures, if any, as may be necessary to

ensure such maintenance.

In addition, the maintenance p lan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency measures must5

include a requirement that the state will implement all measures contai ned in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a.) a ttainment inventory ; b.) m aintenance demonstration ;

c. ) m onitoring network ; d.) v erification of c ontinued attainment ; and e.) c ontingency plan

.

Chapter s ix discusses this requirement in more detail and provides the

attainment demonstration.

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### CHAPTER THREE

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

Requirement 1 of 4 : A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, have been attained. Ozone monitoring data must show that violations of the ambient standard are no longer occurring.

Background : There are five monitor s measuri ng ozone concentra tions in this

no nattainm ent area. The monitor located in Wood County is currently operated by the Ohio Environmental Protection Agency (Ohio EPA) Northwest District Office, Division of Air Pollution Control and the monitors located in Lucas County are ope rated by the Toledo Division of

Environmental Services

. The location s of the monitoring site s for this

nonattainment area are shown on Figure 1

.

Demonstration :

Figure 1 Map of Toledo, OH area7

Requirement 2 of 4 : Ambient monitor ing data quality assured in accordance with 40 CFR 58.10, recorded in the U.S. EPA air qua lity system (AQS) data base, and available for public view.

Demonstration : Ohio EPA has quality assu re d all data shown in Appendix A in accordance

with 40 CFR 58.10 and the Ohio Quality Assurance Manual. Ohio EPA has
recorded the data in the AQS database an d therefore data are available to the public.

Requirement 3 of 4 : A showing that the three

- year average of the fourth highest values, based on data from all

moni toring sites in the area or its affected downwind environs, are below 85 parts per billion (ppb). This showing must rely on three (3) complete, consecutive calendar years of quality assured data.

Background : The following information is taken from U.S. EPA 's "Guideline on Data Handling Conventions for the eight

- hour Ozone National Ambient Air Quality Standard (NAAQS)," U.S. EPA

- 454/R

- 98

- 017, December 1998.

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

demonstrate attainment at a mon itoring site. The eight

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

- year average of the annual fourth

highest daily maximum eight

- hour average ozone concentration is less than or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. Three (3) significant digits must be carried in the computations. Because the third decimal digit, in ppm, is rounded, 0.084 ppm is the largest concent ration

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

- hour standard is considered to be 0.085 ppm. Values

below 0.085 ppm meet the standard, values equal to or greater than 0.085 ppm exceed the standard. These data handling procedures are applied on an individual basis at each monitor in the area. An area is in compliance with

the eight

- hour ozone NAAQS if, and only if, every monitoring site in the area meets the NAAQS. An individual site's three (3) year average of the ann ual fourth highest daily maximum eight

- hour average ozone concentration is also

c alled the site's design value.

Table 1 shows the monitoring data for t he thre e most recent years, 2004

- 2006

, in the nonattainment area and was retrieved from the U.S. EPA A QS. Please note that the standard is measured in ppm while the commonly used unit is ppb. For the remainder of this document, ppb will be used.8

Demonstration :

Table 1 : Monitoring Data for Toledo, OH area 2004

– 2006

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

.

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



### Please n ote: 2006 data is not yet validated.

1 st 2 nd 3 rd 4 th 2004

- 2006

SITE ID COUNTY ADDRESS YEAR %OBS 8

- HR 8

- HR 8

- H R 8

- HR AVERAGE

39

- 095

- 0024 Lucas Erie 2004 99 72 72 72 67 74

39

- 095

- 0024 Lucas Erie 2005 100 92 91 84 80

39

- 095

- 0024 Lucas Erie 2006 99 81 79 76 75

39

- 095

- 0027 Lucas Waterville 2004 100 76 76 76 74 75

39

- 095

- 0027 Lucas Waterville 2005 100 89 88 87 8 4

39

- 095

- 0027 Lucas Waterville 2006 100 79 77 72 69

39

- 095

- 0034 Lucas Low Serve 2004 100 90 79 79 78 79

39

- 095

- 0034 Lucas Low Serve 2005 99 108 92 89 87

39

- 095

- 0034 Lucas Low Serve 2006 100 79 77 74 74

39

- 095

- 0081 Lucas Friendship 2004 99 86 79 78 78 79

39

- 095

- 0081 Lucas Friendship 2005 100 101 94 90 87

39

- 095

- 0081 Lucas Friendship 2006 98 80 80 75 74

39

- 173

- 0003 Wood Bowling Gr 2004 100 79 78 77 76 77

39

- 173

- 0003 Wood Bowling Gr 2005 100 92 86 85 84

39

- 173

- 0003 Wood Bowling Gr 2006 100 81 80 75 73 Highest Average 79 pp b

A compr ehensive list of the site ’s design values during the 2004

- 2006 time period is in Appendix A . The area's design value has tr ended downward as

emissions have declined due to such factors as cleaner automobiles and fuels both regionally and locally.

Requirement 4 of 4 : A commitmen t that once redesignated, the s tate will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status.

Demonstration : Ohio commits to contin ue moni toring ozone levels at the site indicated in Figure 1

. Ohio EPA will consult with U.S. EPA Region V staff prior to making changes to the existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58. Connection to a central station and updates to the Ohio EPA W eb site 1 will provide real time availability of the data and knowledge of any exceedances. Ohio EPA will

1
www .epa.state.oh.us/dapc/ Formatted Table9

enter all data into AQ S on a timely basis in accordance with federal guidelines.

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### CHAPTER FOUR

EMISSION INVENTORY

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

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

oz one precursor emissions (VOC and NO

x ) representative of the year when the area

achieves attainment of the ozone air quality standard. Ohio also must demonstrate that the improvement in air quality between the year that violations occurred and the year tha t attainment was achieved is based on permanent and enforceable emission reductions

. Other emissions inventory related requirements include a projection of the emission

inven tory to a year at least 10 years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain the ozone standard; and a commitment to provide future updates of the inventory to enable tracking of emi ssion levels during the ten( 10 ) year maintenance period.

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

year.

Background : The point source data are taken from Ohio's annua l emissions reporting program. The 2002 periodic inventory has been identified as the preferred

data base for SIP dev e lopment and does coincide with nonattainment air quality in the Toledo, OH area

.

Periodic inventories, which include emissions from all sectors

- mobile, area,

non

- road, and point sources

- are prepared every three (3) years.

Demonstration : While ozon e and its precursors are transported into this region from outside

areas, information from current and previous SIP modeling efforts do es provide some indication of the impact from Ohio sources near the nonattainment area. The emissions are decreasing sub stantially in response

to regional and national programs affecting many EGUs such as the Acid Rain program and the NO

x SIP Call.

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

Background : Ohio EPA prepared a comprehensive inventory for the Toledo, OH area

, including area, mobile, and point sources for precursors of ozone (volatile organic compounds and nitrogen oxides) for base year 2002

. The information below describes the procedures Oh io EPA used to generate the11

2002 base inventories and to develop SIP ready modeling inventories and future year projections . These inventories were provided to the Lake Michigan Air Directors' Conso rtium (LADCO) and have been processed to develop summer d ay emissions for use in the air quality analyses. These processed modeling inventories have been identified as the correct iteration of the inventory for use in the redesignation. In this document, references to

LADCO include the Midwest Regional Plannin g Organization.

Area sources were taken from the Ohio 2002 periodic inventory

submitted to U.S. EPA . These projections were made from the U.S. Department of Commerce Bureau of Economic Analysis (BEA) growth factors, with some updated local information.

M obile source emissions were calculated using emissions factors produced with MOBILE6 .2 MOVES2010

. P oint source information was compiled from Ohio EPA’s 2002 annual emissions inventory database and the 2002 U.S. EPA Air Markets

acid rain database 2

. Biogenic emissions are not included in these summaries.

Non

- road emissions were generated using U.S. EPA’s National Mobile Inventory Model (NMIM) 2002 application . To address concerns about the accuracy of some of the categories in U.S. EPA ’s

non

- road emissions mo del, LADCO contracted with two (2 ) companies to review the base data and make recommendations.

One of the contractors als o estimated emissions for three (3 ) non

road categories not included in U.S. EPA ’s non

- road mod el.

Emissions were estimated for aircra ft, commercial marine vessels and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment category were reviewed and updated b ased upon surveys completed in t he Midwest and the temporal allocati on for agricultural sources also was updated.

The report by Pechan generated future year estimates of annual emissions for each source sector using accepted growth surrogates. The on

- r oad mobile source sector however was addressed by specific modeling as addressed below.

Demonstration :

On

- Road Emission Estimations In coordination with the Ohio Dep artment of Transportation ( Ohio DOT O DOT ) the Toledo Metropolitan Area Council of Gov ernments (TMACOG) utilizes a regional

2 http://www.epa.gov/airmarkets/acidrain Formatted: Indent: Left: 0", First line: 0.5"

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travel demand forecast model to simulate traffic in the area and to forecast traffic flows for given growth expectations. The model is primarily used as a long range planning tool to evaluate the transportation system including determination of locations where additional travel capacity may be needed and to determine the infrastructure requirements necessary to meet that need. It is also used as a tool for air quality purposes to estimate the total emissions of pollut ion caused by vehicles in the area. The travel demand forecasting model is used to predict the total daily vehicle miles traveled (VMT) and an U.S EPA computer program called

MOBILE6 .2 MOVES 2010 is used to calculate emissions per mile. The product of

thes e is the total amount of pollution emitted by the on

- road vehicles for the particular analyzed area. In areas outside the regional travel demand model, traffic counts and statewide traffic growth rates are used for the VMT estimates.

Overview Broadly de scribed, MOBILE6.2 MOVES 2010 is used to gen erate “emission factors”,

which are the average emissions per mile (grams/mile) for ozone precursors, NO

x and VOC. The MOBILE6 .2 MOVES 2010 model includes a number of variables that

affect the emission factors. The se variables have national default values, some of which require modification to reasonably reflect local conditions. Some of these variables are discussed here. The vehicle fleet (vehicles on the road) age and the vehicle type have a major effect on th e emission factors. The vehicle source types are traveling on facility road types . Vehicle (MOVES 2010 road types are Rural Restricted Access, Rural Unrestricted Access, Urban Restricted Access, and Urban Unrestricted Access). The vehicle speeds also affec t the emission factor values. Meteorological conditions such as air temperature and humidity also significant ly

affects have a significant effect on emission factors. Emission factors produced by

MOBILE6 .2 MOVES 2010 can also include the effect of emission reduction strategies such as vehicle inspection and maintenance programs, regulation of fuels, etc.

These MOBILE6 .2 MOVES 2010 inputs are estimated using the best available data

and

.

These inputs are reviewed and agreed to by U.S. EPA and transportation a gencies in a formal interagency consultation process. Emission factors are multiplied by

VMT from the travel demand model to estimate the total vehicle emissions.

There are a number of ways emission factors from MOBILE6.2 can be used

with the travel dema nd model information. One of the simplest methods is to input extensive vehicle fleet, area

- specific speed and facility type information MOBILE6.2 to generate a single emission factor that represents the average for all vehicles and facility types in the modeled area. This only requires multiplying this emission factor by the total VMT of the analyzed area to get

the total emissions for the area. Another method is to create multi

dimensional emission factor “look

- up” tables that describe the emission

fac tors by speed, temperature, and facility type. This requires more extensive processing, but the resulting total emissions of this method are Formatted: Indent: Left: 0", First line: 0.5", Right: 0"

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more sensitive to even minor changes in the roadway system. Tables of emission factors are created using MOBILE6. 2 for each facility type, temperature, and speed given the vehicle fleet on that facility. Then, the travel model provides information on each segment of road (or “link”) regarding speed and facility type which is then “looked

- up” in the appropriate

emiss ion factor table. It should be noted that speed is estimated as a post process to the travel demand model. Speeds are not taken directly from the travel demand model. The post process for emissions analysis by Ohio DOT is by hour of day. This emission factor is multiplied by the link’s traffic

volume and length or VMT to get the emissions from that link for that hour. There are other methods as well, each with its advantages and disadvantages. The Toledo, OH area analysis uses the latter more complex

m ethod, a table of emission factors

.

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

Some of the assumptions built into MOBILE6 .2 are : older vehicles have much higher The emission fact ors from MOVES 2010 can be used with the travel demand model information by combining the disaggregate emission rates with VMT, and source type population for each road type, source type and hour of day, and then sum them up to get the total emissions for t he area.

The TMACOG ana lysis method, developed by O DOT, is to aggregate the emission rates by two source types (cars & trucks), then applying VMT and source type population, thereby reducing the intensive processes. In the first step emission

factors are broadly classified into total vehicles, cars and trucks by pollutant, by average speed, road type and hour of day. Then the hourly link volumes generated

from travel demand model are combined with emission factors for each network link

for each hour. The o n

- road vehicle emissions for the area is the sum of all individual

link

- hour emissions. Vehicle

- based emissions are obtained by the combination of corresponding emission factors and source type population. Intrazonal emissions are computed using a separate method to account for those trips that use local roads to travel within a zone. Intrazonal VMT is combined with corresponding emission factors to get intrazonal emissions. Total emissions are sum of on

- road vehicle emissions, vehicle

- based emissions and i ntrazonal emissions.

Automated programs, using FORTRAN and CUBE scripting, were developed by ODOT to generate total emissions. The process uses data on daily and directional traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM). This process also handles the newer model

network formats and MOVES 2010 generated emission factors than newer vehicles, diesel vehicles have much higher NO

x emission factors and lower VOC emission factors than gasoline vehicles, and higher average speeds have lower emission factors except for diesel vehicles which have higher NO

x at higher speeds

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MOBILE6.2

. MOVES2010 input and output files are provided in Appendix C.

Best Available Data

The m ost Most current vehicle age distribution data, temperature data, and fuel properties data , source type distribution data, and I/M data provided by ODOT’s ATRs and WIMs, NOAA, ODPS, and Ohio EPA was were used by Ohio DOT the

O DOT for generating emission factors. Likewise, the most current transportation planning data available from TMACOG and the most current Ohio DOT ODOT count

data was were used by the Ohio DOT O DOT for the emissions estimates . Details

about each data set and how it was used is documented in the “ Technical

Memorandu m TMACOG Redesignation and Maintenance Plan Request (8

- Hour Ozone)” dated December 2006

.

Analysis Years Analysis years for this re designation request include 2002, 2004, 2009, and 2018 to meet the requirements specified by the CAA and U.S. EPA. The travel demand

model presents re presents the transportation system conditions for each of these years. Model runs for each future analysis year contain t he road network TMACOG

and Ohio DOT O DOT expects to exist at the beginning of that year with corresponding soci oeconomic forecasts for that year.

Local Road VMT Most local roads such as subdivision streets are not explicitly modeled in a travel demand model. These local roads are represented as fictitious roadways called

centroid connectors . Local road VMT is included in the Ohio DOT O DOT post process by including the traffic loaded on centroid connectors. In addition, some local road traffic is captured as intra

- zonal trips which travel demand models usually do not assign to roadway segments. The Ohio Dot ODOT post process includes these trips as local road VMT.

Model area VMT For TMACOG, the travel demand model covers the entire MPO and portions of Sandusky County, and also Michigan. VMT for the portion of model which extends beyond Lucas and Wood Counties is removed before total emissions are

calculated.

Emission Estimations

Table 2 contains the results of the emissions analysis for the appropriate

years.

Table 2 Emission Estimations for On

- Road Mobile Sources for Lucas

County , Ohio

Data source: On

- r oad only, TMACOG Travel Demand Model. Formatted: Indent: Left: 0", First line: 0.5"

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Lucas County 2002 2004 2009 2018

VMT (miles/day) 9,508,520 10,302,08

3 9,614,869 10,245,65

0 10, 080,862 320,22

8 10,534,124 9,654,15

9
VOC (tons/day) 19.77 20.51 16.57 17.86 10.94 12.49 6.33 5.20

NO

x (tons/day) 31.51 40.26 27. 05 35.58 18.42 26.41 7.62 9.63

Table 3 Emission Estimations for On

- Road Mobile Sources for Wood

County, Ohio

Data source: On

- road only, TMACOG Travel Demand Model.

Wood County 2002 2004 2009 2018

VMT (miles/day) 5, 249,244 162,33

0 5, 362,131 738,28

6 5, 629 ,172 895,27

0 6,158,775 5,792,23

8
VOC (tons/day) 9. 93 23 8.41 9.00 5.57 6.30 3.41 2.94

NO

x (tons/day) 18.73 19.33 16.26 19.54 10.93 14.27 4.65 5.71

Table 4 Combined VOC and NO
x Emission Estimations for On

- Road

Mobile Sources f or the Toledo, OH area

.

Data sourc e: On

- road only, TMACOG Travel Demand Model.

County VOC 2018 Lucas County, OH VOC 6.33 5.20 Wood County, OH VOC 3.41 2.94

TOTAL VOC 9.74 8.14

County NO
x Lucas County, OH NO

x 7.62 9.63 Wood County, OH NO

x 4.65 5.71

TOTAL NO
x 12.27 15.34

Motor Vehicle Emission Budget

Table 5 contains the motor vehicle emissions budget for the Toledo, OH area

.

Table 5 Mobile Vehicle Emission Budget for Toledo, OH: Lucas and

Wood County Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black16 Data source: On

- road only, TMACOG Travel Demand Mod el.

20 09 2018 VOC (tons/day ) * 18.99 21.61 * *11.20 9.36 *

NO

x (tons/day) * 33.75 46.78 * *14.11 17.64 * *includes 15 percent

This budget includes the emission estimates calculated for 2009 and 20 18

. The emission estimates are derived from the Tranpla n travel demand model

and MOBILE6 .2 MOVES2010 as described above under the expected

TMACOG 2035 Long Range Plan

. The mobile source budget for 2009

include s 18.99 21.61 tons per summer day (tp d) for VOC and 33.75 46.78 tpd for NOx. The mobile source budget for 2018 includes 11.20 9.36 tpd for

VOC and 14.11 17.64 tpd for NO

x . These correspond to a 15 percent
increase from the 20 18 on

- road emissions for both VOC and NO

x . Appendix

C contains data tables and graphs of these emissions.

All methodologies, latest planning assumptions and the safety margins were determined through the interagency consultation process described in the Transportation Conformity Memorandum of Understanding (MOU) for

TMACOG

.

The current 1

- hour budget s will no longer be applicable eit her after the effective date of the approved redesignation or after the effective date of any

U.S. EP A action approving a finding that the eight

- hour conformity budget

inclu ded in this submittal adequate for transportation conformity purposes

whichever dat e comes first

.

Requirement 3 of 5 : A demonstration that the projected level of emissions is sufficient to maintain the ozone

standard.

Background : In consultation with U.S. EPA , Ohio EPA selected the year 2018 as the maintenance year for this redesignat ion request. This document contains projected emissions inventories for 2009 and 2018.

TMACOG performed emission projections for Toledo, OH area using the following approaches.

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

MOBILE6.2 MOVES 2010 model. The analysis is describ e d in more detail in Appendix C . All projections were made in accordance with

“Procedures for P reparing Emissions Projections” U.S. EPA

- 45/4

- 91

- 019. Formatted Table17 Emissions inventories are required to be projected to future dates t o assess the influence growth and future controls will have. LADCO developed growth and control files for point, area, and non

- road categories. These files were used to develop the future year

emissions estimates used in this d ocument. This was done so t he inventories used for redesignation are consistent with modeling performed in the future.

The detailed inventory information for the Toledo, OH area for 2002, 2004

, 2009 and 2018 is in Appendix B . Emission trends are an important gauge for

continued co mpliance with the ozone standard. Therefore, Ohio EPA performed an initial comparison of the inventories for the base year and maintenance years for Lucas and Wood c ounties . M obile source emission

inventories are described in Appendix B

. In addition to the LADCO estimates, point source emissions were projected based upon the state wide

EGU NO

x budgets from the Ohio NO

x rule.

The following tables include sectors Electrical Generating Unit (EGU

- Point),

Non

- Electrical Generating Unit (Non

- EGU), Non

- roa d Mobile (Non

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

- road Mobile (On

- road). Maintenance is demonstrated when the future year projected emission totals (2018 total) are below the 2004 attainment year total.18

Dem onstration :

Table 6 Lucas County VOC Emission Inventory Totals for Base Year

2002

, Estimated 2004 and Projected 2009 and 2018 (tons per

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.

Sector 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Point 0.15 0.15 0.17 0.15

Non

- EGU 7.50 7.29 6.75 7.52

Non

- road 8.17 7.35 5.32 n \ a
Other 22.71 22.78 22.97 25.06

MAR 0.32 0.31 0.30 0.30

On

- road 19.77 20

.51 16.57 17.86 10.94 12.49 6.33 5.20

TOTAL 58.62 5

9.36 54 .45 55.74 46.45 48.0

0 39.36 38.23 15.09 17.5

1

Table 7 Wood County VOC Emission Inventory Totals for Base Year

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

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.

Sector 2002

B ase 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU

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

Non

- EGU 0.49 0.43 0.29 0.32

Non

- road 2.58 2.38 1.90 n/a

Other 7.91 7.77 7.43 7.54

MAR 0.28 0.27 0.26 0.27

On

- road 9. 93 23 8.41 9.00 5.57 6.30 3.41 2.94

TOTA L 21.19 20 19. 26 85 15.45 16.1 11. 54 07 7.72 8.7 Formatted Table

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Formatted: Font: Arial

Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black19 .49 8 8

Table 8 Toledo, OH area VOC Emission Inventory Totals for Base Year

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

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Dem and Model.

2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin Lucas County 58.62

59.36 54.45 55.74 46.45 4

8.00 39.36 38.23

Wood County 21.19

20.49 19. 26 85 15.45 1

6.18 11. 54 07

COMBINED

VOC TOTAL 79. 81

85 73.71 75.59 61.90 6

4.18 50.90 49.30 22.81 2

6.29

Table 9 Lucas County NO
x Emission Inventory Totals for Base Year

2002

, Estimated 2004 and Projected 2009 and 2018 (tons per

summer day)

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

Directors Consortiu m (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.

Sector 2002 Base 2004

Attainment 2009

Inte rim 2018

Maintenanc

e Safety

Margin

EGU

Point 24.91 22.57 16.73 3.83

Non

EGU 13.97 12.97 10.47 9.03

Non

road 8.54 7.96 6.51 n/a Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black

Formatted Table20

Other 0.97 1.03 1.17 1.18

MAR 8.26 7.72 6.37 6.05

On

road 31.51 40.26 27.05 35.58 18.42 26.4

1 7.62 9.63

TOTAL 88.16 96.9

1 79.30 87.83 59. 67 .66 27.71 29.72 51.59 58.1

1 Formatted: Font color: Black21

Table 10 Wood County NO
x Emission Inventory Totals for Base Year

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

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.

Sector 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Point n/a n/a 0.02 0.04

Non

- EGU n/a n/a n/a n/a

Non

- road 3.87 3.63 3.05 n/a

Other 0.64 0.67 0.74 0.79

MAR 6.19 5.51 3.83 3.60

On

- road 18.73 1

9.33 16.26 19.54 10.93 14.27 4.65 5.71

TOTAL 29.43

30.03 26.07 29.35 18.57 21.9

1 9.08 10.14 16.99 19.2

1

Table 11 Toledo, OH area NO
x Emission Inventory Totals for Base Year

2002

, Estimated 2004 and Projected 2009 and 2018 (tons per

summer day)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.

2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin Lucas County 88.16 9

6.91 79.30 87.83 59. 67 .6

6 27.71 29.72

Wood County 29.43 3

0.03 26.07 29.35 18.57 2

1.91 9.08 10.14

COMBINED

NO
x TOTAL 117.59

126.94 105.37 117.

18 78.24 8

9.57 36.79 39.86 68.58 7

7.32 Formatted Table

Formatted Table

Formatted: Font color: Black2223

Table 12 Lucas County Comparison of 2004 attainment year and

2018 projected emission estimates (tons per day, summer)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.

2004 2018 Projected

D ecrease VOC 54.45 55.74 39.36 38.23 15.09 17.51

NO
x 79.30 87.83 27.71 29.72 51.59 58.11

Table 13 Wood County Comparison of 2004 attainment year and

2018 projected emission estimates (tons per day, summer)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Trav el Demand Model.

2004 2018 Projected

Decrease

VOC 19. 26 85 11. 54 07 7.72 8.78

NO
x 26.07 29.35 9.08 10.14 16.99 19.21

Table 14 Toledo, OH area Combined Compar ison of 2004 attainment

year and 2018 projected emission estimates (tons per day,

summer )

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

D ata source: O n

- road only, TMACOG Travel Demand Model.

2004 2018 Projected Change

VOC 73.71 75.59 50.90 49.30 22.81 26.29

NO
x 105.37 117.18 36.79 39.86 68.58 77.32 Formatted Table

Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted Table24

VOC emissions in the non

- attainment ar ea are projected to decrease

26. 29 .65 tons per day (t pd) . Area source emissions and, to a lesser extent, point sources, show an increase due to expectations that the population will grow in this area. However, cleaner vehicles and fuels are expected to be in place in 2009 and 2018 and result in an overall d rop in VO C emissions.

NO

x emissions in the nonattainment area a re projected to decrease by

76.17 77.32 tpd . Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 3

, Highway Heavy

- Duty Engin e Rule 4 and Non

- Road Diesel Engine Rule 5 also factored into the changes. Further, due to implementation of the NO

x SIP Call across the eastern United States, NO

x and ozone levels entering this

area also will be decreased.

Requirement 4 of 5 : A demonst ration that improvement in air quality between the year violations occurred and attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Backgrou nd : A mbient air quality data from the monitoring site indicate s that air quality met the NAAQS for ozone in 2005

. U.S. EPA ’s redesignation g uidance (p 9) states, “A state may generally demonstrate maintenance of the NAAQS by either showing that future emi ssions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the

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

N AAQS.”

In Ohio, major point sources in all countie s are required to submit air emissions information once every three (3) years or annually if VOC potential to emit is greater than 250 tons or NO

x potential to emit is greater than 2500

t ons, in accordance with U.S. EPA ’s Consolidated Emissions Reporting R ule (CERR)

. Ohio EPA prepares a new periodic inventory for all ozone precursor emission sectors every three (3) years. These ozone precursor inventories will be prepared for 2005, 2008, and 2011 as necessary to comply with the inventory reporting require ments established in the CFR

. Emissions information will be compared to the 2002 base year and the 2018 projected maintenance year inventories to assess emission trends, as necessary, to assure continued compliance with the ozone standard.

3 http://www.epa.gov/fedrgstr/EPA

- AIR/2000/February/Day

- 10/a19a.htm

4 http://www.epa.gov/fedrgstr/EPA

- AIR/1997/October/Day

- 21/a27494.htm

5 http://www.epa.gov/fedrgstr/EPA

- AIR/1998/October/Day

- 23/a24836.htm25

Demonstration : Permanent and enforceable reductions of volatile organic compounds and oxides of nitrogen have contributed to the attainment of the eight

- hour ozone
stan dard. Some of these reductions were due to the application of tighter

federal standards on new vehic les. Also , Title IV of the CAA and the NO

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

While no EGU reductions occurred within Toledo, OH area , statewide NO

x reductions from EGUs were over 85 percent due to this program.

Table 1 5 Toledo, OH area Comparison of 2002 base year and 2004

attainment year on

- road and EGU reductions (tons per day, summer)

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

Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

.

Data source: O n

- road only, TMACOG Travel Demand Model.

2002 2004

On

- road VOC 29. 70 74 24.98 26.86

On

- road NO

x 50. 24 59.59 43.31 55.12

EGU NO

x 24.91 22.57

Requirement 5 of 5 : Provisions for future annual updates of the inventory to enable tracking of the emission levels including an annual emission statement from major sources.

Demonstration : As required by Secti on 175A(b) of the CAA , Ohio commits to submit to the Administrator, eight (8) years after redesignation, an additional revision of this SIP. The revision will contain Ohio's plan for maintaining the national primary ozone a ir quality standard for 10 years beyond the first 10 year period after redesignation. Formatted Table

Formatted: Font color: Black2627



### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4 : U.S. EPA approved SIP control strategy that includes RACT re quirements for existing stationary sources covered by Control Technology Guidelines (CTG) as applied in Ohio’s

rural counties.

Background : As required by Section 172 of the 1990 CAA Amendments, in the mid

- 1990’s Ohio promulgated rule requ iring RACT for em issions of VOC s. There were

no s pecific rules required by the CAA such as RACT for existing sources beyond statewide rules.

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

since that time. The Ohio rules are fo und in OAC Chapter 3745

- 21.

Requirement 2 of 4 : Evidence that control measures required in pas t ozone SIP revisions have been f ully implemented.

Background : The U.S. EPA NO

x SI P Call required 22 states to pass rules that would result in significant emis sion reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. Ohio passed this rule in 2001.

Be ginning in 2004, this rule account ed for a reduction of approximately 31 percent of all NO

x emissions state wide compared t o previous uncontrolled

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

The Toledo, OH area also implemented rules as part of the 15 percent rate of progress demonstrati on. These measures included Non

- CTG RACT,

NESHAP and enforcement cases. Th ese rules were also assumed to be in place as part of the maintenance plan following the one

- hour redesignation.

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

attain the eight

- hour ozone standard with the implement ation of the NO

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

Clean Air Markets W eb site, quantifies the gradual NO

x reductions that have28

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 in respon se to the SIP Call. OAC chapter 3745

- 14 regulated EGUs and certain non

- EGUs under a cap and trade program based on an 85 percent reduction of NO

x emissions from EGUs and a 60 percent reduction of NO

x emissions from non

- EGUs, compared to historical levels. This cap will stay in place through 2008, at which time the CAIR program will supersede it.

U.S. EPA has recently published Phase II of the NO

x SIP Call that establishes a budget for large (greater than 1 ton per day emissions) stationary internal comb ustion engines. Ohio EPA’s proposed rule OAC

3745

- 14

- 12 addresses stationary internal combustion engines, all used in natural ga s pipeline transmissions. An 82 percent NO

x reduction from 1995 levels is anticipated. Completion of the compliance plan is expected by May 1, 2006 and the compliance demonstration will begin May 1, 2007. The

2007 controlled NO

x emissions will be 599 tons per day.

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards

In February 2000

, U.S. EPA finalized a fed eral rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and

2009. U.S. EPA has estimated that NO

x emission reductions will be approxima tely 77 percent for passenge r cars, 86 percent for smaller SUVs,

l ight truc ks, and minivans, a nd 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. VOC emission reductions will be ap proximately 12 percent for passen ger cars, 18 percent for smaller SUVs, light trucks, and

min ivans, and 15 percent for larger SUVs, vans, and heavi er trucks.

Heavy

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

- sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy

- duty ga soline

and diesel trucks 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.

Clean Air Non

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

- roa d Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel program. The new standards will cut emissions from non

- road diese l engi nes by more than 90 percent . Non

- road diesel equipment, as described29

in this rule, currently accounts for 47 percent of diesel particulate matter and 25 percent of NO

x from mobile sources nationwide. Sulfur levels will be

reduced in non

- road diesel fuel by 99 percent from current levels, from approximately 3,000 ppm now to 15 ppm in 2009.

Together, these rules will substantially reduce local and regiona l sources of

ozone precursors.

Requirement 3 of 4 : Acceptable provisions to provide for new so urce review.

Background : Ohio has a long standing and fully implemented New Source Review (NSR) program. Thi s is a ddressed in OAC Chapter 3745

- 31. The chapter includes provisions for the Prevention of Significant Deterioration (PSD) permitting

program i n OAC 3745

- 31

- 01 to 3745

- 31

- 20

. Ohio's PSD program was

conditi onally approved on October 10, 2001 (66 FR 51570 ) and received final appro val on January 22, 2003 (68FR 2909 ) by U.S. EPA as part of the

SIP

.

Demonstration : Any facility that is not listed in the 2002 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable permit rule requirement. The review process will be ide ntical to that used for

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

.

Requirement 4 of 4 : Assure that existing controls will remain in effect after redesignation unless the State demonstrates through pho tochemical modeling that the standard can be maintained without one (1) or more controls.

Demonstration : Ohio commits to maintaining the aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or

emission li mits applicable to VOC and/or NO

x sources, as required for

maintenance of the ozone standard in the Toledo, OH area , will be submitted

to U.S. EPA for approval as a SIP revision.

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

necessa ry resources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in the Toledo, OH area

.30

LADCO Modeling Analysis for 8

- Hour O zone Standard Assessment

LADCO performed modeling to evaluate the effect of the NO

x SIP Call and

Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This modeling was originally designed to assess the one

- hour ozone

standard. Further analysis was conducted and documented in the LADCO’s White Paper “8

- Hour Ozone Assessment” dated May 2, 2001. Base year design values used were the average of the design values for the three (3)

three

- year periods (1994

- 1996, 1995

- 1997, and 1996

- 1 998). Base year emissions were taken from 1996 and four (4) ozone episodes were

evaluated: June 22

- 28, 1991; July 14

- 21, 1991

While modeling results were not calculated for the Toledo, OH area

, the average decrease in ozone from the base case modeling ru n with modeling runs that applied emission contro ls required by the CAA

, NO

x SIP Call and

Tier II /low

- sulfur requirements was 15 ppb (2009 Future design v alue of 73.3ppb*.) [* LADCO Base K 2009 Future Base case with on

- the

- books” including CAIR].

LADCO Modeling for CAIR of 2004

On March 10, 2004

, U.S. EPA promulgated CAIR . 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 eastern states and the District of Columbia.

LADCO performed modeling to support the associated emission reductions for CAIR. This modeling was based on 2001

– 2002 design values for Toledo, OH area

. Results of the CAIR modeling show that the Toledo, OH

area will continue to attain the eight

- hour ozone NAAQS well into the future.

Formatted: Left31



### CHAPTER SIX

CONTINGENCY MEASURES

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

Requirement 1 of 4: A commitment to submit a revised plan eight (8) years after redesignation.

Demonstration : Ohio hereby commits to review its maint enance p lan eight (8) years after redesignation, as required by Section 175(A) of the CAA

.

Requirement 2 of 4: A commitment to expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined level s (triggers) or in the

event that future violations of the ambient standards occur.

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

Warning Level Response: A warning lev el r esponse shall be prompted whenever an annual (1

- year) fourth high monitored value of 85 ppb occurs in a single ozone season within the maintenance area. A warning level r esponse will consist of a study to

determine whether the ozone value indicates a t rend toward higher ozone values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and

timin g for implementation as well as economic and social considerations. Implementation of necessary controls in respons e to a warning level

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

later than 12 months from the conclusion of the most recent ozone season (September 30).

Shoul d it be determined through the warning l evel study that action is necessary to reverse the noted trend, the procedures for control selection

and implementation outlined under “ action l evel response ” shall be followed.

Action Level Response :

An Action Level Response shall be prompted whenever a two

- year average fourth high monitored value of 85 parts per billion (ppb) or greater occurs within the maintenance area. A violation of the standard (three

- year average fourth high value of 85 ppb or greater) shall also prompt an action level32

response. In the event that the Action Level is triggered and is not found to be due to an exceptional event, malfunction, or noncompliance with a permit

condition or r ule requirement, Ohio EPA in conjunction with the metropolitan planning organization or regional council of governments, will determine
additional control measures needed to assure future attainment of NAAQS for ozone. In this case, measures that can be i mplemented in a short time will be selected in order to be in place within 18 months from the close of the ozone season that prompted the Action Level. Ohio EPA will also consider the timing of an Action Level Trigger and determine if additional, signific ant new regulations not currently included as part of the maintenance provisions (e.g., AIM and Consumer Products) will be implemented in a timely manner and will constitute our Response.

Control Measure Selection and Implementation :

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

If a new measure/control is already promulgated and scheduled to be implemented at the federal or state level, and that measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessa ry. Furthermore, Ohio will

submit to U.S. EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

Requirement 3 of 4: A list of potential contingency measures that would be implemented in such an event.

Demo nstration : Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the

time the selection is made. The select ion of measures will be based on cost

effectiveness, emission reduction p otential, economic and social

considerations or other factors t hat Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive.

Formatted: Normal, Indent: Left: 0.5", No

bullets or numbering, Tab stops: 0.5", Left + 1", Left + 1.5", Left + 2", Left + 2.5", Left + 3", Left + 3.5", Left + 4", Left + 4.5", Left + 5", Left + 5.5", Left + 6", Left + 6.5", Left33

1) Lower Reid vapor pressure gasoline program.

2) 1) Tighten RACT on exi sting sources covered by U.S. EPA Control Technique Guidelines issued in response to the 1990 CAA

.

3) 2) Apply RA CT to smaller existing sources.

4) 3) One or more transportation control measures sufficient to achieve at least half a percent reduction in actual area wide VOC emissions. Transportation measures will be selected from the following, based upon the factors listed above after consultation with affected local governments:

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

based transportation management plans, area wide rideshare programs, work sche dule changes, and telecommuting;

b) traffic flow and t ransit improvements; and

c) other new or innovative transportation measures not yet in widespread use that affect s state and local governments

deeme d appropriate.

5) 4) Alternative fuel and diesel retrofit programs for fleet vehicle operations.

6) 5) Controls on consumer products consistent with those adopted

elsewhere in the United States.

7) 6) Require VOC or NO

x emission offsets for new and modified major

sources

.

8) 7) Require VOC or NO

x emission offsets for new and modified minor

sources.

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

10) 9) Require VOC or NO

x controls on new minor sources (less than 100 tons).

No contingency measure shall be implemente d without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated. Formatted: Font: Bold, Underline, Font color:

Black

Formatted: Left, Indent: Left: 0", Right: 0",

Tab stops: 0", Left + Not at 6.5"34

Requirement 4 of 4:

A list of VOC and NO

x sources p otentially subject to future controls.

Demonstration : The following is a list of VOC and NO

x sources potentially subject to future

controls.

NO

x RACT

EGUs asphalt batching plants

industrial/commercial and institutional boilers process heaters

internal c ombustion engines

combustion turbines other sources greater than 100 tons per year

VOC RACT consumer products architectural and industrial maintenance coatings stage I gasoline dispensing facilities (including pressure valves) automobile refinishing shops cold cleaner degreasers synthetic organic compound manufacturing organic compound batch processes wood manufacturing

industrial wastewater aerospace industry shipbuilding

bakeries plastic parts coating volatile organic liquid storage

industrial solvent cl eaning offset lithography industrial surface coating other sources greater than 50 tons per year

Formatted: Font: 14 pt, Bold, Font color: Auto

Formatted: Indent: Left: 0", Tab stops: 0",

Left + 0.5", Left + 6.5", Left3536



### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio will publish a published notification for a public hearing and solicitation for public

comment concerning th e draft redesignation peti tion and maintenance plan in several a widely

distributed county publications 30 days prior to the public hearings

.

The p ublic hearing to receive comments on the redesignation request will be was held on February 6

, 2007 April 9

, 2013 at the Toledo Metropolitan Area Council of Governments, 300 Dr. Martin Luther King Jr. Drive Public Library

- South Branch

, 1736 Broadway Street

, Toledo

, Ohio

. The public commen t period will close on February 6 , 2007

. April 9

, 2013

. No

comments were r eceived during the public comment period and no testimony was provided at the hearing. Appendix D will include E include s a copy of the public n otice , certifications of publication, and the hearing transcript from the public hearing

.37



### CHAPTER EIGHT

CONC LUSIONS

The Toledo, OH area basic nonattainment area has attained the NAAQS standard and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of basic ozone nonattainment areas. Documentation to that effect i s contained herein. Ohio EPA has prepared a state implementation and maintenance p lan that meets the requirement of Section 110 (a)(1) of the 1990 CAA

.

Ohio has performed an analysis that shows the air quality improvements are due to permanent and enfo rceable measures. In addition, significant regional NO

x reductions will ensure continued compliance (maintenance) with the standard and that all CAA requirements necessary for redesignation have been met.

Based on this presentation, the Toledo, OH area o zone basic nonattainment area meets the requirements for redesignation under the CAA and U.S. EPA guidance. Furthermore, because this area is subject to significant transport of pollutants, significant regional NO

x reductions will ensure continued complia nce (maintenance) with the standards with an increasing margin of safety.

The State of Ohio hereby requests that the Toledo, OH area ozone basic nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio state imple mentation and m ai ntenance p lan provisions contained herein. In addition, the State of Ohio requests that this maintenance plan satisfy the requirements of CAA Section 175A (b), for subsequent plan revisions required for areas redesignated for the one

- hour ozone standard, as was the case with the Toledo, OH nonattainment area.38 This page left intentionally blank1 

## TOLEDO METROPOLITAN AREA COUNCIL OF GOVERNMENTS

ON-ROAD MOBILE EMISSION ESTIMATES

PREPARED FOR THE SIP INVENTORY

FOR THE 8-HOUR OZONE STANDARD

NOVEMBER 20122 

## Table of Contents

1. Overview ....................................................................................... 3

2. Urban Travel Dema nd Mode ling .................................................. 5

3. Emission Factor Generation ......................................................... 13

4. Post Proce ssing ............................................................................. 21

5. Multiple MPO Cooordi nation Issu es ............................................ 23

Appendix A Interagency Consultati on Documenta tion .............................................. 24

Appendix B

B.1 Post Processing Defau lt Distribu tions .......................................... 29

B.2 Ozone Emission Summa ries ......................................................... 323 

## 1. Overview

This report is intended to document the air quality analyses and underlying assumptions performed by the Ohio Department of Trans portation (ODOT), Divisi on of Transportation System Development-Modeling and Forecasti ng Section and the Toledo Metropolitan Area Council of Governments (TMACOG) for the 8- hour ozone on-road mobile source emission inventories for the Toledo Region State Implementa tion Plan (SIP) revision in coordination with

the Ohio Environmental Pr otection Agency (OEPA).

The Toledo Region is comprised of Lucas and W ood Counties in northwest Ohio. Both counties are designated as a maintenance area for the 8- hour Ozone Standard. TMACOG serves as the Metropolitan Planning Orga nization (MPO) for Lucas and Wood Counties.

The ODOT Modeling and Forecasting section performed the MOVES runs to generate travel

demand model based emission factors as well as the complete air quality analyses for the Toledo region.

Latest Planning Assumptions

The ozone inventory runs meet the latest plan ning assumption requirement. As discussed in Section 2 of this report, the modeling process us ed to develop each MPO emissions is calibrated using the latest population and land use data av ailable and is validated using corresponding traffic count data. Currently, the travel demand models are validated to year 2000. The regional emissions analysis includes emissions for Vo latile Organic Compounds (VOC) and Nitrogen Oxides (NOX).4 

### On Road Mobile Emission Summary

Tables 1 to 4 present a summar y of emissions for the Toledo Re gion for the required precursors VOC and NOX for the requested scenarios: 2002 base, 2004 attainment, 2009 interim and 2018 maintenance. Years 2009 and 2018 are established as budget years.

Table 1 – TMACOG 2002 On-Road Mobile Emissions

2002 Base

Daily VMT VOC (tons/day) NOX (tons/day)

Lucas County Emissions 10,302,083 20.51 40.26

Wood County Emissions 5,162,330 9.23 19.33

TOTAL 15,464,413 29.74 59.59

Table 2 – TMACOG 2004 On-Road Mobile Emissions

2004 Attainment

Daily VMT VOC (tons/day) NOX (tons/day)

Lucas County Emissions 10,245,650 17.86 35.58

Wood County Emissions 5,738,286 9.00 19.54

TOTAL 15,983,936 26.86 55.12

Table 3 – TMACOG 2009 On-Road Mobile Emissions

2009 Interim

Daily VMT VOC (tons/day) NOX (tons/day)

Lucas County Emissions 10,320,228 12.49 26.41

Wood County Emissions 5,895,270 6.30 14.27

TOTAL 16,215,498 18.79 40.68

Table 4 – TMACOG 2018 On-Road Mobile Emissions

2018 Maintenance

Daily VMT VOC (tons/day) NOX (tons/day)

Lucas County Emissions 9,654,159 5.20 9.63

Wood County Emissions 5,792,238 2.94 5.71

TOTAL 15,446,397 8.14 15.345 

## 2. Urban Travel Demand Models

TMACOG maintain the regional travel dema nd forecasting model for use in the urban transportation planning process. The models em ploy the traditional four step modeling process to project existing and future traffic volumes a nd travel patterns on the regional transportation network. The four step process consists of tr ip generation, trip distribution, modal split, and route assignment. Output from the urban models is link-by- link directional 24-hour traffic

volumes.

TMACOG was part of the ODOT Model Task Order for small and medium MPOs which updated the travel demand model. The new mode l includes Lucas and Wood counties, parts of Ottawa and Sandusky counties in Ohio, and the southern three townships in Monroe County, Michigan. The new model uses the Cube/Voyage r interface and improves model functionality. The 2000 Cube/Voyager model with the late st planning assumptions (network and socioeconomic data) is used to calculat e 2008-2035 emissions in the TMACOG Region. Socioeconomic data and network data (Figure 1) are maintained for use in the model. The network data is updated each year to include all projects from the most current TIP.

Figure 1 – TMACOG Travel Demand Model Run Directory Structure

Networks

TMACOG’s modeled networks accurately reflect projects in their respective TIPs and Long Range Transportation Plans. The following networ k files were used to create the 2035 Plan– Update 2011

. Projects included in the various files are li sted in order to track where various plan6 

### projects were included in the analysis. Proj ects in the TIP and 2035 Plan–Update 2011 not listed below were not modeled in the systems analysis. Mo st of these “not modeled” projects are of a nature not easily analyzed in a region-w ide model (Ozone Action Days, traffic signal interconnects, etc.).

The network files are built sequen tially and are listed in se quence order. The files are:

1. Base Network “Official 2010 Validation”

2. 2007-2010 completed projects

a. Monclova Rd. intersection improvements (at Anthony Wayne Trail)

b. Improvements around Fallen Timbers Mall (Russell Rd. and Fallen Timbers Rd.)

c. Sylvania Rd./Holland-Sylvania Rd. intersection improvements

d. Jerome Rd. extension (Monclova Rd. to Technology Dr.)

e. Roundabout at King Rd. and Nebraska Ave.

f. Roundabout at Brint Rd. and Mitchaw Rd.

g. Westwood Ave. vacation (north of South Ave. to south of Hill Ave.)

h. Airport Hwy. widening and intersection improvements (Reynolds Rd. to Byrne Rd.)

i. Detroit Ave. widening (near Arlington Ave.) j. Erie St. conversion to two-way

k. Huron St. conversion to two-way

l. Jefferson St. conversion to two-way

m. Madison St. conversion to two-way

n. Norwood Ave. conversion to two-way

o. Southard Ave. conversion to two-way

p. St. Clair St. conversion to two-way

q. Superior St. conversion to two-way

r. Woodruff Ave. conversion to two-way

s. Superior St. vacation (Madison Ave. to Jefferson St.)

t. Craig Bridge improvements

u. Indiana/Cherry/Findlay intersec tion improvements (Perrysburg)

v. Oregon Rd./CSX grade separation

w. Wheeling St./Starr Ave. intersection improvements

x. Anthony Wayne Trail intersecti on upgrades (Waterville)

y. Holland-Sylvania Rd. roadway reconstructi on (Hill Ave. to Dorr St.) – widen and improve curvature at Nebraska Ave.

z. Coy Rd./Pickle Rd. intersection improvements

aa. Airport Hwy. safety upgrade (Holland- Sylvania Rd. to Reynolds Rd.)

bb. SR 64 intersection improvements (Finzel Rd. and Cemetery Rd.)

cc. Eckel Junction signalization and widening (Ft. Meigs Rd. to SR 199)

dd. Angola Rd. widening (Whisperwood to McCord Rd.)

ee. McCord Rd. widening Phase 2 (Woodlake to Sylvania Ave.)7 

### 3. TIP 2011-2014 Project File

2011

a. Salisbury/I-475 interchange modificati on and Salisbury/Dussel Rd. widening

b. Secor Rd. widening (Alexis R d. to Michigan state line)

c. Roachton Rd. widening with center turn la ne addition and signalization upgrade (Ft. Meigs Rd. to SR 25)

d. N. Main St. widening with center turn lane addition and si gnalization upgrade (Poe Rd. to Bishop Rd.)

e. SR 64/Waterville-Monclova Rd intersection improvements

f. Wheeling St. widening (Navarre Ave. to Pickle St.)

g. Coy Rd./Starr Ave. intersection improvements

2012

h. McCord Rd. widening and left turn lane a dditions (Regents Park to Central Ave.)

2013

i. U.S. 24 Fort to Port freeway project j. I-75/I-475 system interchange Phase 1 (Jeep split)

k. Wales Rd. rail grade separation project

l. Stearns Rd. widening (SR 199 to U.S. 23)

m. Jackson St. reduced to two lanes with boulevard (Erie St . to Summit St.)

2014

n. McCord Rd. rail grade sepa ration project and roundabout

2015

o. Brint Rd./King Rd. roundabout

p. Dorr St./King Rd. roundabout

q. Haskins Rd./Poe Rd. intersection – left turn lanes

r. SR 65 left turn lanes (Col ony Rd. to Lime City Rd.)

s. SR 795 left turn lanes (Valleybrook)

t. Eckel Junction left turn lanes (Carronade Dr.)

u. Toledo-Napoleon Rd. (old U.S. 24) 3 rd 

### lane addition (South to WatervilleMonclova Rd.)

v. SR 64/River Rd. intersection improvements

w. Waterville-Monclova Rd./Dutch Rd. roundabout

x. Buck Rd./Lime City Rd. roundabout

y. Russel Rd. relocation (reconnect to Jerome Rd.)

RESULTS IN 2015 NETWORK

4. TIP Pipeline and 2035 Plan projects constructed by 2018

2016

a. Sylvania Ave. widening (McCord Rd. to Oak Park)8 

### b. Douglas Rd./Dorr St. in tersection improvements

c. Dorr St. widening (Byrne Rd. to Douglas Rd.)

d. Ft. Meigs widening (Five Point Rd. to High School driveway)

e. Coy Rd./Dustin Rd. in tersection improvements

f. Stitt Rd./Waterville-Mo nclova Rd. roundabout

g. Centennial Rd./ Dorr St. roundabout

h. S. Main St./Gypsy Lane Rd. intersection realignment

2017

i. SR 64/Finzel Rd. roundabout j. Hull Prairie Rd. widening (SR 65 to Roachton Rd.)

k. I-75 widen to 6 lanes (Phillips Av. to I-280)

2018

l. Miami/Front St. realignment to elim inate left turn (Yondata to Main)

RESULTS IN 2018 NETWORK

5. 2035 Plan projects constructed by 2025

a. I-75/I-475 systems interchange Phase 2

b. I-475 exit ramp at Corey Rd. (possible roundabout)

c. I-75 widen to 6 lanes (Washington to SR 25)

d. Upgrade I-475/U.S. 23 system interchange

e. Widen I-475 (SR 2 to U.S. 20), improve U.S. 20 interchange, and add Springfield area interchange at Dorr St.

f. Dorr St. roundabouts at Parkside and Upt on (related to previous work in 2016)

g. Douglas/Laskey/Tremainsville roundabout

h. Detroit/Telegraph/Laskey roundabout

i. U.S. 20 turn lanes (at intersections between Perrysburg to SR 420) j. Tracy Rd. widening (SR 795 to Wales Rd.)

k. U.S. 20A relocation and widening ( I-475 to Toledo Express Airport)

RESULTS IN 2025 NETWORK

6. 2035 Plan projects constructed by 2035

a. I-75 Disalle bridge widen and ramp improvements (South Ave. to Miami)

b. I-75 widen to 6 lanes (City of Perry sburg to Hancock County boundary line)

c. I-475 widening (Secor Rd. to Douglas Rd.) and improve interchanges (at Secor Rd., Monroe St., and Douglas Rd.)

d. I-475 widening (Dussel/Salisbury to SR 2)

e. Add braided interchange connection to U.S. 20A from existing Salisbury/I475/U.S. 23 interchange

f. I-475/SR 25 interchange upgrade (Perrysburg)9 

### RESULTS IN 2035 NETWORK

2035 Plan Projects

RANK MODE Project Description Project Sponsor 2015

TIP 2018

Build 2025

Build 2035

Build

C-1 Rail/Roadway Build McCord Road rail grade separation (underpass) ODOT/Lucas

Co. Exempt Exempt Exempt Exempt

C-2 Roadway Build North Baltimore area road improvements toprovide safe travel for increased traffic between I75 and CSX intermodal yard ODOT/Wood

Co. Analyzed Analyzed Analyzed

C-3 Expressway I-75, widen to 6-lanes from Phillips Ave to I-280 ODOT Analyzed Anal yzed Analyzed Analyzed

C-4 Rail/Roadway Build Wales Rd. rail grade separation (overpass) ODOT Exempt Exempt Exempt Exempt

C-5 Expressway/ Roadway Construct I-75/I-475 system s interchange Phase 2 and related improvement s to local arterials including Cherry St. and Phillip Ave. ODOT Analyzed Analyzed

C-6 Roadway Dorr St. safety & pedestrian improvements, Byrne to Upton (widen & signa l modifications ByrneSecor; add median Secor-Douglas; improve Douglas intersection; possible roundabouts Parkside, Upton; improve ped safety/crossings). City of Toledo Exempt Exempt Exempt

C-7 Expressway I-75, widen to 6-lanes, Washington St. to SR25/Anthony Wayne Trail ODOT Analyzed Analyzed

C-8 Roadway Upgrade Buck Rd./Lime City Rd. intersection area,

with roundabout & turn lanes Wood Co./ODOT/City

of Rossford Analyzed Analyzed Analyzed Analyzed

C-9 Roadway Widen Stearns Rd., US-23 to SR-199, to three lanes City of Fostoria Analyzed Analyzed Analyzed Analyzed

C-10 Expressway/

ITS Build ITS freeway manage ment / travel info system ODOT Exempt Ex empt Exempt Exempt

C-11 Transit Provide real time bus arrival information TARTA Ex empt Exempt Ex empt Exempt

C-12 Ped/Bike Build Riverside Trail-Phase 2 from Craig Bridge to

Point Place City of Toledo Exempt Exempt Exempt Exempt

C-13 Roadway Replace/widen Perrysburg-Holland Bridge over

Swan Creek Lucas Co./City

of Toledo Analyzed Analyzed Analyzed Analyzed

C-14 Roadway Waterville-Monclova at Dutch Rd., two

roundabouts Lucas Co./ Village of

Waterville Analyzed Analyzed Analyzed Analyzed

C-15 Roadway Brint & King Rd. roundabout City of Sylvania Analyzed Analyzed Analyzed Analyzed

C-16 Roadway King rd. alignment at Dorr St. intersection improvement Lucas Co. Analyzed Analyzed Analyzed Analyzed

C-17 Roadway Sylvania Ave., widen from McCord Rd. to Oak

Park Dr. Lucas Co. Analyzed Analyzed Analyzed

C-18 Transit Replace TARTA bus fleets (2 cycles of replacement) TARTA Exempt Exempt Exempt Exempt

C-19 Roadway/

Ped/Bike Convert US-24 through Waterville to local street; widen to 3-lanes, add bike/ped path Village of

Waterville Analyzed Analyzed Analyzed Analyzed

C-20 Ped/Bike Complete Sylvania-Metamora Rd. (Erie St.) bike path west of Centennial Park, add bike lanes south

on Kilburn Road to Central Ave. Lucas Co. Exempt Exempt Exempt

C-21 Roadway SR-64 & Finzel Rd. intersection alignment (roundabout) Village of

Whitehouse Analyzed Analyzed Analyzed

1 Expressway Widen I-75 to 6 lanes fro m Hancock Co. line to Perrysburg (part of Findlay to Perrysburg; also part of I-73/74/75 multi-state project) ODOT Analyzed

2 Expressway Upgrade I-475/US-23 systems in terchange ODOT An alyzed Analyzed

3 Expressway Widen I-475, Secor to Douglas, and improve interchanges at Secor, Monroe & Douglas ODOT Analyzed

4 Expressway Widen I-475, SR-2 (Airport Hwy.) to US-20 ODOT Analyzed Analyzed10 2035 Plan Projects

RANK MODE Project Description Project Sponsor 2015

TIP 2018

Build 2025

Build 2035

Build
(Central Ave.), improve US-20 interchange, and add Springfield area interchange (Hill or Dorr)

5 Expressway Widen I-475, Dussel/Salisbury to SR-2, and improve SR-2 interchange ODOT Analyzed

6 Expressway Widen the I-75 Disalle Bridge to improve South Ave. and Miami St. ramps ODOT Analyzed

7 Transit Add intermodal/ transit hub, downtown Toledo TARTA / City

of Toledo Exempt Exempt Exempt Exempt

8 Expressway Add braided interchange connection to US-20A from existing Salisbury/Dussel and I-475/US-23 interchange ODOT (&Lucas Co.?) Analyzed

9 Expressway I-475 at SR-25 interchange upgrades, incl. widen SR-25 bridge and add ped/bike facilities; address
weave, I-475 between SR-25 and I-75 ODOT / City of Perrysburg Analyzed

10 Expressway Upgrade I-75/Miami St. interchange and straighten

curve between Wales & Miami ODOT Analyzed

11 Passenger

Rail Ohio Hub high speed passenger rail implementation, may include passenger rail/ rail overpass in Northwood, new Maumee River bridge, upgrade to MLK Plaza infrastructure & passenger access to multiple rail lines, etc. Ohio Rail Development

Commission Exempt

12 Rail / Roadway Eliminate rail/hwy conflict that impedes access to north Toledo industrial area (rail overpass or relocation) City of Toledo Analyzed Analyzed

13 Roadway Build Douglas/Laskey/ Tremainsville Rds. Intersection improvement s, possibly a roundabout City of Toledo Analyzed Analyzed

14 Ped/Bike “Westside” Trail – buy rail corridor and construct multi-use path, Laskey Rd. to Knight Preserve (excludes bridge reconstruction) Various (UT, Metroparks,

Wood Co.
Parks District, City of Toledo?) Exempt Exempt

15 Roadway Build Detroit/Telegraph/Laskey intersection improvements, possibly a roundabout City of Toledo Analyzed Analyzed

16 Ped/Bike Provide Airport Hwy. bike/ped facilities from Holland-Sylvania Rd. across I-475 and accessing Spring Meadows shopping center ODOT / Lucas

Co. Exempt Exempt

17 Ped/Bike Eliminate constricted areas for ped/bikes (Berdan from Martha to Cherry; De troit and Glendale from Schneider to Harvard; Detroit from Waggoner to Lagrange; Monroe/Alexis/Main St. in Sylvania; and Alexis Road) Cities of

Toledo and Sylvania Exempt Exempt

18 Roadway US-20 – add turn lanes at intersections from City of Perrysburg to SR-420 ODOT Analyzed Analyzed

19 Rail / Roadway

(ITS) Provide advance warning signal for blocked rail crossings (Consaul/NS & CSX, Matzinger/CSX & AA, Summit/CSX) City of Toledo Exempt Exempt Exempt

20 Ped/Bike Eliminate SR-51 (Woodville Rd.) constricted area for ped/bikes from Oak to Curtice Rd. esp. at RR crossing Cities of Toledo, Oregon

& Northwood Exempt

21 Ped/Bike Build Sylvania River Trail multi-use path City of Sylvania Exempt Exempt Exempt

22 Roadway / (&

Rail/ Roadway?) Tracy Rd. improvements – SR-795 to Wales, including intersection improvements at Wales (wider turn radii) and solution to blocked rail crossings (possible grade separation) Wood Co. / City of

Northwood Analyzed

23 Ped/Bike Add pedestrian facilities on Wooster crossing of I- City of Exempt11 2035 Plan Projects

RANK MODE Project Description Project Sponsor 2015

TIP 2018

Build 2025

Build 2035

Build
75 Bowling Green

24 Ped/Bike Complete Oregon bike netw ork (19.6 miles) (partial funding – additional $3.8M needed) City of Oregon Exempt

25 Ped/Bike Riverside Trail-Phase 1, build bike/walk path from downtown Toledo to Craig Bridge City of Toledo Exempt Exempt Exempt Exempt

26 ITS (Transit) Provide signal prioritization for transit and emergency vehicles TARTA,

TARTA

member jurisdictions Exempt Exempt Exempt

27 Ped/Bike Build Eastside Maumee River Trail from Craig Bridge to International Park including ped/bike crossing of Main St. (possibly grade separated) City of Toledo Exempt Exempt

28 Roadway I-475 exit ramp at Corey Rd. low cost interchange improvement (roundabouts) Lucas Co. Analyzed Analyzed

29 Ped/Bike SR-65 – add paved berms from Grand Rapids to Rossford, excluding curb sections and areas within City of Perrysburg (needs additional $1.1M funding) ODOT Exempt

30 Roadway US-20A from I-475 to Toledo Express Airport –
relocate, widen & mana ged access for improved road access to freight te rminals, pending evaluation of environmental impact on Oak Openings region ODOT Analyzed Analyzed



### Landuse and Socio-economic Data

The socioeconomic data used is the set consistent with the current trends scenario used in the development of the year 2035 Plan–Update 2011. Th e population data is consistent with the county totals projected by Ohio Department of Development (ODOD), Office of Strategic Research. The other socioeconomic parameters (d welling units, school atte ndance, vehicles and labor force) were defined usi ng the standard conversion parame ters for either population or employment for Traffic Analysis Zones (T AZs) as defined for the 2035 Plan–Update 2011 development process.

Summaries of TMACOG’s socioeconomic data for Lucas and Wood counties are available in

Tables 5 and 6. Lucas County loses population and em ployment while Wood County gains population and employment. There is a shift in population and employment from Lucas to Wood County. Overall population and households are exp ected to decline in Lucas and Wood counties over the planning period.12 

### Table 5 – TMACOG Socio-Economic Variables (Lucas County)

Variable Lucas County

Total Area type

CBD Urban Suburban Rural

# TAZs 45 288 210 81 624

Acres 1,178 38,010 62,234 121,507 222,931
2000 Population 5,874 229,646 190,119 29,415 455,054

2000 Households 2,630 91,706 78,262 10,249 182,847
2010 Employment 39,240 98,194 75,287 11,597 224,318
2035 Population 4,770 176,923 178,786 47,021 407,500

2035 Households 2,128 70,740 73,122 15,974 161,964
2035 Employment 1,843 76,184 88,728 22,828 189,583
Person per Household 2.23 2.50 2.43 2.87 2.51
Workers per Household 0.87 1.07 1.20 1.40 1.13

Autos per Household 1.04 1.46 1.74 2.14 1.60



### Table 6 – TMACOG Socio-Economic Variables (Wood County)

Variable Wood County

Total Area type

CBD Urban Suburban Rural

# TAZs 5 30 98 97 230

Acres 221 3,111 45,513 348,336 397,181
2000 Population 1,871 23,155 67,208 28,831 121,065

2000 Households 985 7,668 25,937 10,582 45,172
2010 Employment 5,879 7,424 31,977 14,680 59,960
2035 Population 2,109 23,856 85,397 34,000 145,362

2035 Households 1,103 8,028 32,763 12,763 54,657
2035 Employment 1,320 12,252 43,140 17,435 74,147
Person per Household 1.90 3.02 2.59 2.72 2.56
Workers per Household 1.18 1.53 1.31 1.38 1.35

Autos per Household 1.73 1.69 1.90 2.07 1.85



### VMT Trends

Figure 2 shows Vehicle Miles Traveled (VMT ) trends for years 2010- 2018-2025-2035 for the TMACOG region. These values represent un-fact ored travel demand mode l output. For ozone runs, model VMT is factored to represent an aver age summer day using a seasonal factor of 1.08.13 

### Figure 2 – TMACOG VMT Trends



## 3. Emission Factor Generation

Base and Attainment Years

Using MOVES, emission factor files were gene rated for base year-2002 and attainment year2004 to represent the programs being implem ented in the TMACOG Region. Programs and corresponding MOVES parameters were deve loped in consultati on with OEPA.

Future Years

Emission factors were also generated for tw o future year scenarios: 2009 and 2018. All assumptions remain the same as those used to generate 2002 emission f actors and are further illustrated in this section using year 2002 as an example.

Technical Details

Table 7 summarizes the settings used in th e MOVES run specification file and the MOVES County-Data Manager. Further de tails in specific i nputs that are not using default values are provided below. 15000 15200 15400 15600 15800 16000 16200 16400 16600 16800 17000

2010 2018 2025 2035VehicleMilesTraveled(1,000s) 

# Toledo Region VMT Trends

VMT14 

### Table 7 – MOVES Inputs
RunSpec Parameter Settings

MOVES Version MOVES2010A

Scale Custom Domain

MOVES Modeling Technique Emission Factor Method Rates per Profile (grams/vehicle) Rates per Distance (grams/mile) Rates per Vehicle (grams/vehicle) Time Span Time Aggregation: Hour 1 Month representing average summer temperatures All hours of day selected 16 speed bins Weekdays only Geographic Bounds Lucas and Wood Counties

Vehicles/Equipment All source types, gasoline and diesel

Road Type All road types including off-network

Pollutants and Processes Total Gaseous Hydrocar bons, Non-Methane Hydrocarbons, Volitile Organic Compounds, NO

x , NO, NO 2

, Total Energy Consumption Strategies Default values with assumed CNG buses removed

General Output Units = grams, joules and miles

Output Emissions Time = hour, Location = custom area, on-road emission rates by road type and source

use type.

Advance Performance None

County Data Manager Sources

Source Type Population Combination of local and default data Local data (2010) ODOT from motor vehicle registration Default data used for source types 41, 51, 54, 61, and 62 Future year growth rate based on MPO model Household growth rate. Vehicle Type VMT Combination of local and default data HPMSVTypeYear VMT = daily VMT from travel demand model

monthVMTFraction = default dayVMTFraction=default

hourVMTFraction=local I/M Program None

Fuel Formulation Default Fuel Supply Default

Metereology Data Local data obtained from NOAA National Climatic Data Center. Data will consist of monthly high and low temperatures and daily relative humidity for 2002. Ramp Fraction Using the base year travel demand m odel for VHT fractions. Future fractions will be

assumed constant Road Type Distribution Use ODOT county summary VMT categorized by federal functional classes

Age Distribution Combination of local and default data. Local data (2010) ODOT from motor vehicle registration Default data used for source types 41, 51, 54, 61, and 62 The same age distribution will be used for all analysis years Average Speed Distribution Default

Alternative Fuel Type Default15 

### Temperature and Relative Humidity

Temperatures used for the single season appro ach are representative of July 2002 based on

NOAA data from the National Climate Data Cent er webiste. To get the correct fomat for MOVES, the data was entered into a spread sheet provided by EPA which was designed to

convert Mobile6 data to MOVES. The average July hourly temp erature and relative humidity distribution profile can be seen in Table 8.

Table 8 – Temperature and Relative Humidity Data

Hour Average Temperature Average Relative Humidity

1 60.8 82

2 57.2 93

3 57.2 93

4 60.8 82

5 60.8 87

6 62.6 82

7 62.6 82

8 64.4 77

9 66.2 72

10 66.2 72

11 68 68

12 69.8 64

13 69.8 64

14 71.6 60

15 69.8 60

16 69.8 60

17 69.8 64

18 66.2 68

19 66.2 63

20 66.2 68

21 66.2 68

22 64.4 72

23 64.4 72

24 60.8 8216 

### Ramp Fraction

Ramp fractions were derived using the base ye ar travel demand model VHT fractions. Ramp

fractions can be seen in Table 9. Base year fractions were assumed to apply to future years.

Table 9 – Ramp Fractions

roadTypeID roadDesc rampFraction

2 Rural Restricted Access 0.07

4 Urban Restricted Access 0.10



### Source Type Population

Source type population is based on a combination of local and MOVES default data. Local data was provided by ODOT based on 2010 motor vehicle registration. Default data is used for source types 41, 51, 54, 61, and 62. The base year (2002) and the LP year (2035) are used to interpolate the number of cars for the needed analysis years. Table 10 shows source type population for the analyzed counties in 2004.

Table 10 – Source Type Population for year 2004

sourceTypeID sourceTypeName Lucas Wood

11 MotorCycle 12973 4544

21 Passenger Car 189392 58454

31 Passenger Truck 130135 41634

32 Light Commercial Truck 5219 1670

41 Intercity Bus 131 72

42 Transit Bus 70 38

43 School Bus 804 438

51 Refuse truck 102 44

52 Single Unit Short-haul Truck 4201 1809

53 Single Unit Long-haul Truck 536 231

54 Motor Home 490 211

61 Combination Short-haul Truck 1268 932 62 Combination Long-haul Truck 1458 1072



### Vehicle Age Distribution

Vehicle age distribution inform ation was derived using Ohio Bureau of Motor Vehicle registration data for year 2010. The data was gi ven to OEPA who supplied a VIN decoder that allowed ODOT to create correctly formatted MOVES inputs. The registration data for all three

counties in the non-attainment area were combined to create a regional vehicle age distribution file, see Table 11. The same age distribut ion will be used for all analysis years17 

### Table 11 – Vehicle Age Distribution

yearid sourcetypeid ageid ageFraction yearid sourcetypeid ageid ageFraction

2004 11 0 0.0015 2004 21 0 0.0048

2004 11 1 0.0239 2004 21 1 0.0185

2004 11 2 0.0521 2004 21 2 0.0293

2004 11 3 0.0751 2004 21 3 0.0348

2004 11 4 0.0796 2004 21 4 0.0361

2004 11 5 0.0777 2004 21 5 0.038

2004 11 6 0.0698 2004 21 6 0.0399

2004 11 7 0.0701 2004 21 7 0.0441

2004 11 8 0.0541 2004 21 8 0.0462

2004 11 9 0.0522 2004 21 9 0.0437

2004 11 10 0.0438 2004 21 10 0.0464

2004 11 11 0.0344 2004 21 11 0.0504

2004 11 12 0.0265 2004 21 12 0.0483

2004 11 13 0.0208 2004 21 13 0.0513

2004 11 14 0.0216 2004 21 14 0.0497

2004 11 15 0.0201 2004 21 15 0.0555

2004 11 16 0.0149 2004 21 16 0.0469

2004 11 17 0.0119 2004 21 17 0.0402

2004 11 18 0.0098 2004 21 18 0.0305

2004 11 19 0.0065 2004 21 19 0.0277

2004 11 20 0.0072 2004 21 20 0.0199

2004 11 21 0.0071 2004 21 21 0.0209

2004 11 22 0.0075 2004 21 22 0.0156

2004 11 23 0.01 2004 21 23 0.0125

2004 11 24 0.0173 2004 21 24 0.0114

2004 11 25 0.0169 2004 21 25 0.01

2004 11 26 0.0149 2004 21 26 0.0087

2004 11 27 0.0147 2004 21 27 0.0038

2004 11 28 0.0232 2004 21 28 0.0032

2004 11 29 0.0171 2004 21 29 0.0041

2004 11 30 0.0977 2004 21 30 0.107618 

### Road Type Distribution

Road type distribution is based on the 2008 ODOT HPMS VMT data categorized by federal

functional class for TMACOG area. Road t ype distribution can be seen in Table 12.

Table 12 – Road Type Distribution

sourceTypeID roadTypeID roadTypeVMTFraction sourceTypeID roadTypeID roadTypeVMTFraction



### 11 1 0 51 1 0

11 2 0.09 51 2 0.09

11 3 0.11 51 3 0.11

11 4 0.24 51 4 0.24

11 5 0.56 51 5 0.56

21 1 0 52 1 0

21 2 0.09 52 2 0.09

21 3 0.11 52 3 0.11

21 4 0.24 52 4 0.24

21 5 0.56 52 5 0.56

31 1 0 53 1 0

31 2 0.09 53 2 0.09

31 3 0.11 53 3 0.11

31 4 0.24 53 4 0.24

31 5 0.56 53 5 0.56

32 1 0 54 1 0

32 2 0.09 54 2 0.09

32 3 0.11 54 3 0.11

32 4 0.24 54 4 0.24

32 5 0.56 54 5 0.56

41 1 0 61 1 0

41 2 0.09 61 2 0.09

41 3 0.11 61 3 0.11

41 4 0.24 61 4 0.24

41 5 0.56 61 5 0.56

42 1 0 62 1 0

42 2 0.09 62 2 0.09

42 3 0.11 62 3 0.11

42 4 0.24 62 4 0.24

42 5 0.56 62 5 0.56

43 1 0

43 2 0.09

43 3 0.11

43 4 0.24

43 5 0.5619 

### Vehicle Type VMT and VMT Fractions

The first component of the VMT inputs is the Ye arly HPMS VMT, but the travel demand model

was used instead of ODOT’s HMPS data since it was felt that the model would better predict future year VMT. ODOT’s CMS post-processor was run for each year to generate congestion reports, which includes total daily VMT. The ve hicle type percentages of the total VMT were based on ODOT’s weigh-in-motion (WIM) data. Since there are not enough WIM stations for

lower class facilties in the non- attainment area, a statewide average of all ODOT WIM data collectors was used. Daily VMT was then conve rted to yearly. Yearly HPMS VMT for 2004

can be seen in Table 13. The same method was to generate all other analysis years

Table 13 – Yearly HPMS VMT for 2004

HPMSVtypeID yearID HPMSBaseYearVMT baseYearOffNetVMT

10 2004 

### 22066599 0

20 2004 

### 3935403821 0

30 2004 

### 1214260189 0

40 2004 

### 12411356 0

50 2004 

### 91751756 0

60 2004 

### 217835524 0



### Monthly and daily VMT fractions used MOVES de fault data. The hourly VMT fractions were derived from ODOT WIM data. Hourly VMT frac tions vary for each of the five MOVES road types but do not change for each of the 16 MOVES source types. A representative sample of the hour VMT fraction input file can be seen in Table 14, the entire file is too large to include in this

document.20 

### Table 14 – Hourly VMT Fractions

sourceTypeID roadTypeID dayID hourID hourVMTFraction

11 1 5 1 0.0089

11 1 5 2 0.00564

11 1 5 3 0.00424

11 1 5 4 0.00427

11 1 5 5 0.00695

11 1 5 6 0.01798

11 1 5 7 0.03806

11 1 5 8 0.057

11 1 5 9 0.05773

11 1 5 10 0.05538

11 1 5 11 0.05554

11 1 5 12 0.05558

11 1 5 13 0.05584

11 1 5 14 0.06051

11 1 5 15 0.06765

11 1 5 16 0.07755

11 1 5 17 0.08428

11 1 5 18 0.0797

11 1 5 19 0.06012

11 1 5 20 0.04522

11 1 5 21 0.03646

11 1 5 22 0.02912

11 1 5 23 0.02142

11 1 5 24 0.01486



### Output Emission Factors

Table 15 shows the first record in a MOVES sample output (rate per distance) emission file for year 2005 with I/M programs. For any given mont h, day of week, hour of the day, pollutant, and source type; the rate per distance varies by road type and speed bin. Rates per distance emissions are applied to link and intrazonal VMT.

Table 15 – Sample Emission File (Rate per Distance) for year 2005

Heading: MOVESScenarioID MOVESRunID yearID monthID dayID hourID

Record: 2005 7 5 1
Heading: linkID pollutantID processID sourceTypeID SCC fuelTypeID

Record: 87 0 1 0
Heading: modelYearID roadTypeID avgSpeedBinID temperature relHumidity ratePerDistance

Record: 0 2 1 6.9074077621 

### Table 16 shows the first record in a MOVES sample output (rate pe r vehicle) emission file for year 2005 with I/M programs. The rate per vehicl e varies for any combinations of month, day of week, hour of the day, pollutant, and process. Rates per vehicle emissi ons are applied to the vehicle source type population.

Table 16 – Sample Emission File (Rate per Vehicle) for year 2005

Heading: MOVESScenarioID MOVESRunID yearID monthID dayID

Record: 2005 7 5
Heading: hourID zoneID pollutantID processID sourceTypeID

Record: 1 87 1
Heading: SCC fuelTypeID modelYearID temperature ratePerVehicle

Record: 0 0 0.27257887



### Table 17 shows the first record in a MOVES sample output (rate per profile) emission file for year 2005 with I/M programs. The rate per vehicl e varies for any combinations of month, day of week, hour of the day, pollutant, and process. Rates per profile emissi ons are applied to the vehicle souce type population.

Table 17 – Sample Emission File (Rate per Profile) for year 2005

Heading: MOVESScenarioID MOVESRunID yearID monthID dayID

Record: 2005 0 5
Heading: hourID zoneID pollutantID processID sourceTypeID

Record: 1 87 0 1
Heading: SCC fuelTypeID modelYearID temperature ratePerVehicle

Record: 0 0 0.01774139



## 4. Post Processing

Total emissions were computed with the aid of several custom programs by ODOT. The process uses data on daily and directiona l traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM). This process, described below and illustrated in Figure 3, also uses rewritten code able to handle the newer model network formats and MOVES generated em ission factors.

The first step in the the process involves runn ing postcms.exe to calculate hourly link volumes based on the percentage of the daily volume (travel demand model output) determined by a link’s facility and area type. Link speeds from the travel dema nd model are not used in the analysis. The speeds are estimated as a post-pr ocess to the model based on HCM methods using a link’s volume-to-capacity ratio and link group code. The daily to hourly volume conversion percentages and speed tables can be seen in Appendix B.1.

The second step (movesnet.exe) uses a combin ation of the MOVES emission factors and the hourly link volumes that are out put of the postcms.exe progra m. The hourly volumes are

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## 5. Multiple MPO Coordination Issues

TMACOG, ODOT, and OEPA have a l ong history of working together in air quality issues, the Memorandum of Understanding, listed below, doc uments these working relationships. The document is moving through the involved federal agencies for their approval.

• Memorandum of Understanding among the TMACOG, the OEPA, the ODOT, the US EPA-Region 5, the FHWA-Ohio Di vision, and the FTA-Region 5.24 

## Appendix A

Interagency Consultation Documentation25 From: David Gedeon

Sent: Friday, April 20, 2012 4:34 PM

To: 'Brunello, Nino'; PJividen@AkronOhio.gov ; CBaker@akronohio.gov ; Jeff Dutton; Bill Davis; Nick Gill ( NGILL@morpc.org ); aramirez@mvrpc.org ; Saleem Salameh; Lima ( tmazur@lacrpc.com ); smapel@lcounty.com ; 'randy.durst@movrc.org' ( randy.durst@movrc.org ); sschmid@clarkcountyohio.gov ; mikepap@bhjmpc.org ; rsharma@belomar.org ; krodi@eastgatecog.org

Cc: Fred Durham; Dines, Jennifer; Patricia Morris ( Morris.Patricia@epamail.epa.gov ) ( Morris.Patricia@epamail.epa.gov ); Moore, Dave; Byram, Mark Subject: RE: Ozone Summer Day Factors

TMACOG concurs. Thank you for the opportunity to review it.

__________________________________________ David Gedeon, AICP

Director of Commuter Services Transportation Project Manager Toledo Metropolitan Area Council of Governments p: 419.241.9155 ext. 125

www.tmacog.org

TMACOG A forum for regional cooperation since 1968

From: Brunello, Nino [ mailto:Nino.Brunello@dot.state.oh.us ]

Sent: Thursday, April 19, 2012 2:30 PM

To: PJividen@AkronOhio.gov ; CBaker@akronohio.gov ; Jeff Dutton; Bill Davis; Nick Gill ( NGILL@morpc.org ); aramirez@mvrpc.org ; Saleem Salameh; Lima ( tmazur@lacrpc.com ); smapel@lcounty.com ; 'randy.durst@movrc.org' ( randy.durst@movrc.org ); sschmid@clarkcountyohio.gov ; mikepap@bhjmpc.org ; David Gedeon; rsharma@belomar.org ; krodi@eastgatecog.org

Cc: Fred Durham; Dines, Jennifer; Patricia Morris ( Morris.Patricia@epamail.epa.gov ) ( Morris.Patricia@epamail.epa.gov ); Moore, Dave; Byram, Mark Subject: FW: Ozone Summer Day Factors



### All:

After discussions with ODOT , OEPA, WVDEP, and USEPA, we are of the opinion that

there needs to be an additional seasonal factor for summer when calculating ozone pollutants.

There is currently an adjustment for incr easing average daily VMT (+ 8%) which was used in previously when using Moblie6 to generate emission factors. With MOVES, there is a vehicle component used in addition to VMT, so ther e needs to be an adjustment from average number of vehicles to the num ber of vehicles in summer day. We propose

to use the same 8% increase.

We need to have an inter-agency agreement on this, and would pref er to do it via email (to make it easier on all of us). Please respond with your approval and/or questions.

Thanks,26 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Nino Brunello, P.E. Modeling & Forecasting Section Division of Planning Ohio Department of Transportation (614) 752-5742

From: Dines, Jennifer

Sent: Thursday, April 12, 2012 9:04 AM

To: Brunello, Nino; Durham, William F

Cc: Moore, Dave Subject: RE: Ozone Summer Day Factors



### Nino and Fred, talked to Pat and she agrees that BOTH VMT and number of vehicles should have the 1.08 factor applied.

Pat suggested we should have consultation on this. I told her ODOT is taking the lead on this project and I’d let Dave know........she says email is fine.

Thanks,

Jennifer Dines Manager, State Implementation Plan and Rulemaking Section

Division of Air Pollution Control Ohio Environmental Protection Agency Wk (614) 644-3696 Fax (614) 644-3681

From: Brunello, Nino

Sent: Monday, April 09, 2012 12:59 PM

To: Dines, Jennifer; Durham, William F Subject: RE: Ozone Summer Day Factors



### Jennifer/Fred,

There is another item that needs to be disc ussed. Since we now calculate emission rates
for both VMT and number of vehicles, does ther e need to be a summer adjustment factors

for vehicles as well? This was not done with MOBILE, so we have nothing to follow. If I had to guess, I would think that there would be an increase, but I couldn’t guess as to how many or what factor to use. Ma ybe just use 1.08 in absence of anything better? Thoughts?

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Nino Brunello, P.E. Modeling & Forecasting Section Division of Planning Ohio Department of Transportation (614) 752-574227 From: Dines, Jennifer

Sent: Monday, April 09, 2012 8:47 AM

To: Brunello, Nino; Durham, William F Subject: RE: Ozone Summer Day Factors



### I’m available

Jennifer Dines Manager, State Implementation Plan and Rulemaking Section

Division of Air Pollution Control Ohio Environmental Protection Agency Wk (614) 644-3696 Fax (614) 644-3681

From: Brunello, Nino

Sent: Monday, April 09, 2012 8:30 AM

To: Durham, William F; Dines, Jennifer Subject: RE: Ozone Summer Day Factors



### I can call anytime. Will you both be around at 9:00? If not, when would be the next earliest time? (on the half hours)

-Nino

From: Durham, William F [mailto:William.F.Durham@wv.gov]

Sent: Friday, April 06, 2012 8:50 AM

To: Brunello, Nino

Cc: Dines, Jennifer Subject: Ozone Summer Day Factors



### Nino: I spoke with Jenn this morning and outlined the issue of Summer day VMT v. Average daily VMT. We agreed that Pat Morris may be able to shed some light on the question. Jenn & my calendars are open next Mon. and Tues. afternoon. Please give me a call & I’ll patch Jenn in.

Fred28 

## Appendix B29 

## Appendix B.1 Post Processing Default Distributions30HOUR 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23PCTADTURB FWY 0.9 0.6 0.5 0.6 0.9 2.2 5.2 7.3 6.4 5.2 4.9 5.1 5.3 5.5 6.1 7.2 8.0 7.9 5.8 4.2 3.4 2.9 2.2 1.5URB ART 0.7 0.4 0.3 0.3 0.6 1.5 3.5 5.7 5.5 5.1 5.3 6.2 6.5 6.4 6.8 7.6 8.2 8.1 6.2 4.8 4.0 3.0 1.9 1.3RUR FWY 1.4 1.1 0.9 1.0 1.3 2.2 3.7 5.2 5.4 5.4 5.6 5.6 5.7 6.0 6.5 7.1 7.5 7.0 5.6 4.5 3.8 3.2 2.5 2.0RUR ART 0.8 0.5 0.4 0.5 1.0 2.4 4.8 6.2 5.5 5.3 5.5 5.8 6.0 6.0 6.7 7.6 8.1 7.7 5.6 4.2 3.5 2.8 1.9 1.3PCTADT TRKURB FWY 2.1 1.9 1.8 2.0 2.4 3.0 3.9 4.6 5.3 6.0 6.3 6.4 6.4 6.4 6.3 5.8 5.2 4.6 4.1 3.7 3.4 3.1 2.8 2.4URB ART 1.1 0.9 1.0 1.2 1.6 2.3 3.9 5.9 6.9 6.7 7.1 7.6 7.4 7.2 7.4 7.2 6.0 5.0 3.7 2.8 2.3 1.9 1.5 1.3RUR FWY 2.6 2.2 2.1 2.3 2.6 3.1 3.5 4.0 4.5 5.1 5.6 5.8 5.8 5.8 5.8 5.6 5.3 4.9 4.6 4.3 4.0 3.8 3.5 3.1RUR ART 1.5 1.3 1.4 1.6 2.2 3.0 4.2 5.3 6.1 6.7 7.0 7.1 7.0 6.9 6.8 6.3 5.5 4.6 3.8 3.1 2.6 2.3 2.1 1.7PCTDIRURB FWY 38 40 40 46 56 64 70 70 68 62 58 52 52 52 50 46 38 38 46 52 46 42 42 40URB ART 44 46 44 48 54 62 66 68 64 56 54 52 50 50 50 46 40 38 46 52 48 46 46 46RUR FWY 44 46 48 54 60 68 68 64 58 54 52 50 50 52 52 48 42 40 44 48 48 44 46 44RUR ART 40 42 44 48 58 66 72 68 60 56 54 50 50 50 50 46 40 38 46 50 46 44 44 44LOS E VC 0 0.625 1.25 1.875 2.5 3.125 3.75 4.375 5 5.625 6.25 6.875 7.5 8.125 8.75 9.375 10 10.625 11.25 11.875 12.5 13.125 13.75 14.375SPEEDVCcurve1 75 75 75 75 75 75 74.9 74.8 74.6 74.2 73.5 72.3 70.5 67.8 64.2 59.5 54 47.7 41.2 34.9 28.9 23.7 19.2 15.5curve2 70 70 70 70 70 70 70 69.9 69.8 69.6 69.2 68.4 67.1 65.1 62.2 58.2 53 47 40.5 33.9 27.7 22.2 17.6 13.8curve3 65 65 65 65 65 65 65 65 65 64.9 64.8 64.4 63.8 62.6 60.5 57 52 45.4 37.8 29.9 22.7 16.7 12.1 8.6curve4 60 60 60 60 60 60 60 60 60 59.9 59.8 59.6 59.1 58.2 56.7 54.3 50.8 46.1 40.3 33.8 27.3 21.3 16.2 12.2curve5 55 55 55 55 55 55 55 55 55 55 55 54.9 54.7 54.3 53.6 52.3 50 46.5 41.5 35.3 28.5 21.9 16.1 11.5curve6 60 60 60 60 60 60 60 60 59.9 59.8 59.7 59.4 59.1 58.5 57.7 56.5 55 53.1 50.7 47.9 44.7 41.1 37.3 33.4curve7 55 55 55 55 55 55 55 55 54.9 54.9 54.7 54.5 54.2 53.8 53.1 52.2 50.9 49.3 47.3 44.9 42.1 39 35.7 32.2curve8 50 50 50 50 50 50 50 50 49.9 49.9 49.8 49.6 49.4 49 48.5 47.7 46.7 45.4 43.8 41.8 39.5 36.8 33.9 30.9curve9 45 45 45 45 45 45 45 45 45 44.9 44.8 44.7 44.4 44.1 43.6 43 42.1 40.9 39.4 37.6 35.5 33.1 30.5 27.8curve10 50 50 50 50 49.9 49.8 49.7 49.4 49 48.4 47.5 46.5 45.1 43.5 41.7 39.6 37.3 34.9 32.4 29.8 27.3 24.9 22.6 20.4curve11 50 50 50 50 50 49.9 49.7 49.4 48.9 48 46.7 44.9 42.5 39.6 36.2 32.6 28.7 25 21.4 18.2 15.3 12.9 10.8 9curve12 50 50 50 50 50 49.9 49.8 49.6 49.1 48.2 46.8 44.5 41.4 37.5 32.9 28 23.1 18.7 14.9 11.8 9.2 7.2 5.7 4.5curve13 40 40 40 40 40 40 39.9 39.8 39.5 39.2 38.6 37.8 36.7 35.3 33.5 31.4 29 26.4 23.7 21.1 18.5 16.1 13.9 12curve14 40 40 40 40 40 39.9 39.8 39.6 39.1 38.5 37.5 36.1 34.3 32.1 29.4 26.5 23.5 20.5 17.7 15.1 12.8 10.7 9 7.6curve15 40 40 40 40 40 39.9 39.7 39.4 38.8 37.9 36.5 34.7 32.3 29.5 26.4 23.2 20 17 14.3 11.9 9.9 8.2 6.8 5.6curve16 35 35 35 35 35 34.9 34.8 34.5 34 33.2 32.1 30.5 28.5 26.1 23.5 20.6 17.9 15.2 12.8 10.7 8.9 7.4 6.1 5.1curve17 35 35 35 35 35 34.9 34.7 34.4 33.9 33.1 32 30.3 28.3 25.8 23.1 20.3 17.5 14.9 12.5 10.4 8.6 7.2 5.9 4.9curve18 35 35 35 35 35 34.9 34.6 34.2 33.5 32.4 30.9 28.8 26.3 23.4 20.4 17.4 14.6 12.1 9.9 8.1 6.6 5.4 4.4 3.6curve19 30 30 30 30 30 29.9 29.8 29.5 29 28.2 27.1 25.6 23.7 21.5 19.1 16.6 14.2 12 10 8.3 6.8 5.6 4.6 3.8curve20 30 30 30 30 30 29.9 29.7 29.4 28.9 28.1 26.9 25.3 23.4 21.1 18.6 16.1 13.6 11.4 9.5 7.8 6.4 5.3 4.3 3.6curve21 30 30 30 30 30 29.9 29.7 29.3 28.7 27.7 26.2 24.4 22.1 19.6 17 14.4 12 9.9 8.1 6.6 5.4 4.4 3.6 2.9VC RATIO TO LOS CONVERSION (VALUE SHOWN IS LOWER LIMIT FOR THAT LOS)(URBAN ROADS USE SPEED BREAKS BELOW FOR LOS DETERMINATION)(ALL USE THE BASE VC'S TO DETERMINE EXCEEDANCE)BASE RUR2 FWYA 0.00 0.00 0.00B 0.30 0.00 0.25C 0.50 0.10 0.40D 0.70 0.30 0.60E 0.90 0.50 0.80F 1.00 1.00 1.00F+ 1.10 1.10 1.10F++ 1.30 1.30 1.3031SPEED VC RATIO BREAKS FOR URBAN STREETS (HIGHEST SPEED FOR GIVEN LOS & FF SPEED)FFS B C D E F>47 42. 34. 27. 21. 16.>37 35. 28. 22. 17. 13.>32 30. 24. 18. 14. 10.<33 25. 19. 13. 9. 7.LEVEL OF SERVICE THRESHOLD BY AREANUM LOS DEFINITION1 F CINCINNATI,CLEVELAND,COLUMBUS CENTRAL MPO COUNTIES (CUY,FRA,HAM)2 E OTHER TMA MPOS (AKRON,CANTON,DAYTON,TOLEDO,YOUNGSTOWN + NON-CENTRAL COUNTIES FROM 1)3 E OTHER MPOS & PARTS OF AREAS 1 & 2 OUTSIDE URBANIZED AREA4 E RURAL NON MPO COUNTIESPEAK SPREADING MODEL INFO (SET MAX ITERATIONS TO 0 TO DISABLE PEAK SPREADING)MAX VC RATIO FWY: 1.30MAX VC RATIO ART: 1.30MAX ITERATIONS : 1000TRUCK PCE: 2.00AQ SEASON FACTOR: 1.08MODEL CLASS PARAMETERS (MAX 4 CLASSES, HOURS 0-23 W/ NO OVERLAP IN CLASS, ALLOCATE ENTIRE CLASS AS TRUCK(1) OR NOT(0))CLS TRK 0 1 0 0 0 0 0 0 0 0 0 0 0 00 0CLS BEG 0 0 0 0 0 0 0 0 0 0 0 0 0 00 0CLS END 23 23 0 0 0 0 0 0 0 0 0 0 0 00 0CLS NUM 1 3 0 0 0 0 0 0 0 0 0 0 0 00 032 

## Appendix B.2

Ozone Emission Summaries33 

## TMACOG Daily Summary

TYPE YEAR VMT/VEH HC NOX SO2 PM2.5

Link Emissions 2002 15,417,881 16.353 52.108 0.000 0.000

Vehicle Emissions 2002 377,449 13.306 7.295 0.000 0.000

Intrazonal Emissions 2002 46,532 0.080 0.193 0.000 0.000

TOTAL 15,464,413 29.738 59.595 0.000 0.000

TYPE YEAR VMT/VEH HC NOX SO2 PM2.5

Link Emissions 2004 15,937,244 14.012 47.517 0.000 0.000

Vehicle Emissions 2004 376,911 12.784 7.431 0.000 0.000

Intrazonal Emissions 2004 46,692 0.068 0.173 0.000 0.000

TOTAL 15,983,936 26.864 55.120 0.000 0.000

TYPE YEAR VMT/VEH HC NOX SO2 PM2.5

Link Emissions 2009 16,171,948 9.095 34.239 0.000 0.000

Vehicle Emissions 2009 347,793 9.678 6.320 0.000 0.000

Intrazonal Emissions 2009 43,550 0.039 0.116 0.000 0.000

TOTAL 16,215,498 18.812 40.675 0.000 0.000

TYPE YEAR VMT/VEH HC NOX SO2 PM2.5

Link Emissions 2018 15,396,708 2.997 11.534 0.000 0.000

Vehicle Emissions 2018 373,220 5.122 3.756 0.000 0.000

Intrazonal Emissions 2018 49,689 0.016 0.047 0.000 0.000

TOTAL 15,446,397 8.135 15.337 0.000 0.000

### Public Notice Ohio Environmental Protection Agency Redesignation and Maintenance Plan for the Ohio Portion of the Toledo Ozone

Basic Nonattainment Area

Lucas and Wood Counties

Notice is hereby given that the Director of the Ohio Env ironmental Protection Agency, (Ohio EPA) is requesting that the United States Environmental Protection Agency (U.S. EPA) revise the current maintenance plan for the Toledo area, including Lucas and

Wood Counties

, with respect to the 1997 eight

- hour ozone n ational ambient air quality standard (NAAQS)

. Ohio EPA submitted a redesignation request and maintenance plan

for this area on December 22 , 200 6 Subse quently, U.S. EPA approved this requests on August 9, 2007 (72 FR 44784)

. Air quality monitoring data coll ected in the region

demonstrate d attainment of the NAAQS and there was evidence that the improved air quality is due to permanent, e nforceable emission reductions. In addition, existing requirements are sufficient to maintain the 1997 eight

- hour ozone stan dard in this area throughout the maintenance period

.

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budgets based on emission rates generated from

U.S. EPA’s latest mobile emissions model , the Motor Vehicle Emission Simulation (MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s

official emission factor model.

These actions must be noticed to allow public comment and to satisfy U.S. EPA requirements for public involv ement in SIP related activities. This notice addresses Ohio EPA’s reliance on the emission project ion s as evidence of attainment and maintenance and the commitment to institute contingency measures if ambient exceedances or violations trigger the continge ncy plan requirements. Written comments

will be received on or before April 9 , 201 3 at the following address:

E

- mail: erica.fetty@epa.state.oh.us

Mailing address: Erica Fetty

Ohio Environmental Protectio n Agency, DAPC

Lazarus Government Center

P.O. Box 1049 Columbus, Ohio 43216

- 1049

Phone: (614 ) 644

- 2310

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this redesignation request will be conducted as follows: April 9 , 201 3 at 3: 00 P.M., at 1736 Broadway Street, Toledo

, Ohio.

All interested persons are entitled to attend or be represented at the hearings and give

### written or oral comments on these changes. All oral comments presented at the

hearing, and all written statements subm itted at the hearing or to the above address by

the close of business on April 9 , 201 3 will be considered by Ohio EPA prior to final action on this redesignation. Written statements submitted after April 9

, 201 3 may be

considered as time and circumstances permit, but will not be part of the official record of the hearing.

This redesignation and maintenance request is available on Ohio EPA DAPC’s Web page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx

. Questions regarding accessin g the web site should be directed to Arun ee Niamlarb at

614

- 728

- 1342; other questions or comments about this document should be directed to

either Erica Fetty , (614)

- 644

- 2310

, Erica.Fetty @epa.state.oh.us or Jennifer Dines at (614) 644

- 3696, Jennifer. D ines @ epa.state.oh.us or mailed to Erica Fetty or Jennifer

Dines at the above address.

# ORIGINAL

OHIO ENVIRONMENTAL PROTECTION AGENCY

PUBLIC HEARING

RE: Ohio Environmental Protection Agency Redesignation and Maintenance Plan for the Ohio
Portion of the Toledo Ozone Basic Nonattainment

Area

- Lucas and Wood Counties

Proceedings held in the above-entitled

matter, taken before Mary K. Tammarine, Registered

Professional Reporter and Notary Public in and for

the State of Ohio, at the Toledo-Lucas County

Public Library, South Branch, 1736 

### Broadway Street,

Toledo, Ohio, on Tuesday, April 9, 2013, 

### commencing

at 3:00 

### p.m.

c--0 

# llll 

# SEA GATE APR 'I :; l013

Reporting Service, Inc.

405 Madison Avenue, Suire 900

--- Toledo, OH 43604

PHONE: 419-241-2070 TOLL FREE: 888-419-2070 FAX: 419-241-4718 WEB.: 'W\VW.SCagatCrcporting.com

### 1 APPEARANCES:

2 

### On behalf of Ohio Environmental Protection Agency:

3 

### Mary McCarron

Erica Fetty

4 

### Public Interest Center

P.O. Box 1049

5 Columbus, Ohio 43216-1049 (614) 644-2160

6



### 7 

### MS. McCARRON: My name is Mary

8 

### McCarron. I work in public involvement in

9 

### Ohio Environmental Protection Agency's

10 Public Interest Center. I will be

11 

### presiding over today's public hearing.

12 The purpose of the hearing today is

13 to obtain comments from any interested

14 person regarding Ohio EPA's proposed

15 

### action.

16 The State of Ohio is requesting that

17 the U.S. EPA revise the current

18 

### maintenance plan for the Toledo area

19 including Lucas and Wood Counties with

20 respect to the 1997 eight-hour ozone

21 national ambient air quality standard.

22 

### Ohio EPA is now requesting a revision

23 to the maintenance plan to update mobile

24 emission projections and conformity

25 

### budgets based on emission rates generated 2

### 1



### 2

3



### 4

5

6

7



### 8

9



### 10

11



### 12

13

14



### 15



### 16

17



### 18

19



### 20

21

22

23

24



### 25 

### from U.S. EPA's mobile emissions model,

the Motor Vehicle Emission Simulation

2010.

To be included in the official record

written comments must be received by Ohio

EPA by the close of business today,

April 9, 2013.

At this time nobody is present to

provide testimony so we will go off the

record until 3:30.

(Recess taken.)

MS. McCARRON: The time is now 3:30 and

there is nobody present to provide

testimony so this hearing is adjourned.

(Hearing concluded at 3:30p.m.) 3

### 1 C E R T I F I C A T E

2



### STATE OF OHIO

3 

# ss.
COUNTY OF LUCAS

4



### 5 

### I, Mary K. Tammarine, Registered Professional

6 Reporter and Notary Public in and for the State of

7 Ohio, duly commissioned and qualified, do hereby

8 certify that the foregoing is a true, correct, and

9 complete transcript of the proceedings in the foregoing

10 captioned matter taken by me and transcribed from my

11 stenographic notes.

12 IN WITNESS WHEREOF, I have hereunto set my

13 hand and affixed my notarial seal of office at Toledo,

14 Ohio, this lOth day of April, 2013.

15



### 16

17

18



### 19

20

21

22



### 23

24



### 25 \



### MMARINE, Notary ublic in and for the

State of Ohio

My Commission expires September 16, 2013.