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 2013 
This page left intentionally blank
i

TABLE OF CONTENTS

Chapter One

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

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

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

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

Chapter Two

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

Chapter Three

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

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

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

Commitment to continue monitoring............................................................................................... 8

Chapter Four

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

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

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

Demonstration of Maintenance..................................................................................................... 15

Permanent and Enforceable Emissions Reductions .................................................................... 21

Provisions for Future Updates ...................................................................................................... 22

Chapter Five

Control measures and regulations................................................................................................ 23

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

New Source Review Provisions ................................................................................................... 25

Assurance of continued controls .................................................................................................. 25

Chapter Six

Contingency measures ................................................................................................................. 27

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

Commitment for contingency measures ....................................................................................... 27

Potential contingency measures................................................................................................... 28

List of VOC and NOx sources ....................................................................................................... 29

Chapter Seven

Public participation........................................................................................................................ 31

Chapter Eight

Conclusions................................................................................................................................... 32
ii

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-road Mobile Sources for Lucas County ................. 14

Table 3 Emission Estimations for On-road Mobile Sources for Wood County ................. 14

Table 4 Combined Emission Estimations for On-road Mobile Sources ............................ 14

Table 5 Mobile Vehicle Emission Budget .......................................................................... 15

Table 6 VOC 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 NOx Emission Inventory Lucas County................................................................. 18

Table 10 NOx Emission Inventory Wood County................................................................. 19

Table 11 NOx Emission Inventory 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 estimates 2004-2018 Combined VOC/NOx Totals............... 20

Table 15 Combined comparison of 2002 and 2004 On-road and EGU Totals ................... 22

APPENDICES

A Air Quality System (AQS)

B Emission Inventories

C Emissions Analysis Method

D Public Participation Documentation
iii

This page left intentionally blank 
1

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

Introduction

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

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

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

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

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

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

February of 2001.

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

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

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

request nonattainment areas be redesignated to attainment providing certain criteria are 

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

from nonattainment to attainment: 

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

ii) An approved SIP for the area under Section 110(k).

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

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

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

met. 

Background

As part of the 1990 CAA Amendments re-evaluation, the Toledo, OH area was designated 

Moderate Nonattainment for the one-hour ozone standard pursuant to 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 

the 2004 ozone designations, U.S. EPA designated the Toledo, OH area basic 

nonattainment and subject to the eight-hour ozone requirements, including development of 

a plan to reduce volatile organic compounds (VOCs) and oxides of nitrogen (NOx) 
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 nonattainment to attainment for the eight-hour ozone standard. The 

Toledo, OH area has recorded three (3) years of complete, quality-assured ambient air 

quality monitoring data for the years 2004 – 2006 demonstrating attainment of the eighthour ozone standard. 

Geographical Description

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

in northwest Ohio. Lucas County contains the City of Toledo and Wood County contains 

the City of Bowling Green. Lucas County is bordered by Lake Erie to the north and east, 

Wood to the south 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 most recent three (3) years, 2004 through 2006, 

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

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

Chapter four, supports a redesignation to attainment for Toledo, OH area based on

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

CHAPTER TWO

Requirements for Redesignation

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

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

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

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

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

Below is a summary of each redesignation criterion as it applies to 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. The data that are used to 

demonstrate attainment should be the product of ambient monitoring that is 

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

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

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

review.

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

quality modeling. The supplemental modeling 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. Chapter three discusses this requirement in more detail and 

provides the attainment demonstration.

ii.) SIP approval:

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

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

May 9, 1994 (59FR23799), March 23, 1995 (60FR15235) and August 1, 

1995 (60FR39115) and includes the Toledo, OH area. Chapter five

discusses this requirement in more detail and provides the attainment 

demonstration.

iii.) Permanent and enforceable improvement in air quality:

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

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

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

state.

The Toledo, OH area was designated Moderate Nonattainment for ozone as 

part of the 1990 CAA Amendments re-evaluation. As a result, Ohio has 

adopted or implemented control measures beyond the federal measures, the 
4

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

“rural” attainment areas. Chapters four and five discuss this requirement in 

more detail and provide the attainment demonstration.

iv.) Section 110 and Part D requirements:

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

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

redesignation request.

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

designated nonattainment based on a violation of the NAAQS.

i.) Section 172(c) requirements

This section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for

an emission inventory will be satisfied by the inventory requirements 

of the maintenance plan. 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 

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.) Maintenance plans.

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

must fully approve a maintenance plan which meets the requirements of 

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

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

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

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

ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

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

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

the nonattainment SIP prior to redesignation.
5

States seeking redesignation of a nonattainment area should consider the 

following provisions:

a.) attainment inventory;

b.) maintenance demonstration;

c.) monitoring network;

d.) verification of continued attainment; and

e.) contingency plan.

Chapter six discusses this requirement in more detail and provides the 

attainment demonstration.
6

CHAPTER THREE

OZONE MONITORING

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

Requirement 1 of 4: 

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

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

longer occurring.

Background:

There are five monitors measuring ozone concentrations in this 

nonattainment 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 locations of the monitoring sites for this 

nonattainment area are shown on Figure 1.

Demonstration:

Figure 1 Map of Toledo, OH area
7

Requirement 2 of 4: 

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

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

Demonstration:

Ohio EPA has quality assured 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 and therefore data are available to 

the public.

Requirement 3 of 4: 

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

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

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

quality assured data.

Background:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

called the site's design value.

Table 1 shows the monitoring data for the three 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.epa.gov/ttn/airs/airsaqs/index.htm

1

st 2nd 3rd 4th 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 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 ppb

A comprehensive list of the site’s design values during the 2004-2006 time

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

emissions have declined due to such factors as cleaner automobiles and 

fuels both regionally and locally. 

Requirement 4 of 4: 

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

monitoring network to verify the maintenance of the attainment status.

Demonstration:

Ohio commits to continue monitoring 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 Web site1 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 Section107 (d)(3)(E)(iii)

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

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

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

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

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

Other emissions inventory related requirements include a projection of the emission 

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

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

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

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 annual emissions reporting 

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

data base for SIP development and does coincide with nonattainment air 

quality in 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 does

provide some indication of the impact from Ohio sources near the 

nonattainment area. The emissions are decreasing substantially in response 

to regional and national programs affecting many EGUs such as the Acid 

Rain program and the NOx SIP Call. 

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 Ohio EPA used to generate the 
11

2002 base inventories and to develop SIP ready modeling inventories and 

future year projections. These inventories were provided to the Lake 

Michigan Air Directors' Consortium (LADCO) and have been processed to 

develop summer day emissions for use in the air quality analyses. These 

processed modeling inventories have been identified as the correct iteration 

of the inventory for use in the redesignation. In this document, references to 

LADCO include the Midwest Regional Planning Organization.

Area sources were taken from the Ohio 2002 periodic inventory 

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

Department of Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information.

Mobile source emissions were calculated using emissions factors 

produced with MOVES2010.

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

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

acid rain database2.

Biogenic emissions are not included in these summaries.

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

Mobile Inventory Model (NMIM) 2002 application. To address 

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

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

companies to review the base data and make recommendations. 

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

Emissions were estimated for aircraft, commercial marine vessels and 

railroads. Recreational motorboat population and spatial surrogates 

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

The populations for the construction equipment category were 

reviewed and updated based upon surveys completed in the Midwest 

and the temporal allocation for agricultural sources also was updated. 

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 Department of Transportation (ODOT) 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/acidrain
12

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

tool to evaluate the transportation system including determination of locations where 

additional travel capacity may be needed and to determine the infrastructure 

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

purposes to estimate the total emissions of pollution caused by vehicles in the area. 

The travel demand forecasting model is used to predict the total daily vehicle miles 

traveled (VMT) and an U.S EPA computer program called MOVES2010 is used to 

calculate emissions per mile. The product of these is the total amount of pollution 

emitted by the on-road vehicles for the particular analyzed area.

Overview 

Broadly described, MOVES2010 is used to generate “emission factors”, which are 

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

The MOVES2010 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 (MOVES2010 road types are Rural Restricted Access, Rural Unrestricted 

Access, Urban Restricted Access, and Urban Unrestricted Access). The vehicle 

speeds also affect the emission factor values. Meteorological conditions such as air 

temperature and humidity have a significant effect on emission factors. Emission 

factors produced by MOVES2010 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 data.

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

in a formal interagency consultation process. Emission factors are multiplied by 

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

The emission factors from MOVES2010 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 analysis method, developed by ODOT, is to aggregate the emission 

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

population, thereby reducing the intensive processes. In the first step emission 

factors are broadly classified into total vehicles, cars and trucks by pollutant, by 

average speed, road type and hour of day. Then the hourly link volumes generated 

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

for each hour. The on-road vehicle emissions for the area 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 
13

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 the 2000 

Highway Capacity Manual (HCM). This process also handles the newer model 

network formats and MOVES2010 generated emission factors. MOVES2010 input 

and output files are provided in Appendix C.

Best Available Data 

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

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

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

factors. Likewise, the most current transportation planning data available from 

TMACOG and most current ODOT count data were used by ODOT 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. The travel demand model 

represents the transportation system conditions for each of these years. Model runs

for each future analysis year contain the road network TMACOG and ODOT 

expects to exist at the beginning of that year with corresponding socioeconomic 

forecasts for that year. 

Local Road VMT

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

demand model. These local roads are represented as fictitious roadways called 

centroid connectors. Local road VMT is included in the ODOT post process by 

including the traffic loaded on centroid connectors. In addition, some local road 

traffic is captured as intra-zonal trips which travel demand models usually do not 

assign to roadway segments. 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 emissions 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

NOx (tons/day) 40.26 35.58 26.41 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) 5,162,330 5,738,286 5,895,270 5,792,238

VOC (tons/day) 9.23 9.00 6.30 2.94

NOx (tons/day) 19.33 19.54 14.27 5.71

Table 4 Combined VOC and NOx Emission Estimations for On-Road 

Mobile Sources for 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 NOx

Lucas County, OH NOx 9.63

Wood County, OH NOx 5.71

TOTAL NOx

15.34
15

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

Data source: On-road only, TMACOG Travel Demand Model.

2009 2018

VOC (tons/day) 21.61* 9.36*

NOx (tons/day) 46.78* 17.64*

*includes 15 percent 

This budget includes the emission estimates calculated for 2009 and 2018. 

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 includes 21.61 tons 

per summer day (tpd) for VOC and 46.78 tpd for NOx. The mobile source 

budget for 2018 includes 9.36 tpd for VOC and 17.64 tpd for NOx. These 

correspond to a 15 percent increase from the 2018 on-road emissions for 

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

emissions.

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 budgets will no longer be applicable either after the 

effective date of the approved redesignation or after the effective date of any 

U.S. EPA action approving a finding that the eight-hour conformity budget

included in this submittal adequate for transportation conformity purposes 

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 for 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 described in more detail in 

Appendix C. All projections were made in accordance with 

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

019. 

Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. LADCO 

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

categories. These files were used to develop the future year 

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

inventories used for redesignation are consistent with modeling 

performed in the future.

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

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

continued compliance with the ozone standard. Therefore, Ohio EPA

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

maintenance years for Lucas and Wood counties. Mobile source emission 

inventories are described in Appendix B. In addition to the LADCO

estimates, point source emissions were projected based upon the statewide 

EGU NOx budgets from the Ohio NOx 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

Demonstration:

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: On-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 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: On-road only, TMACOG Travel Demand Model.

Sector 2002 

Base

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 9.23 9.00 6.30 2.94

TOTAL 20.49 19.85 16.18 11.07 8.78
18

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: On-road only, TMACOG Travel Demand Model.

2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

Lucas 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 NOx 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: On-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 58.11
19

Table 10 Wood County NOx 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: On-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 NOx 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: On-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 

NOx TOTAL 126.94 117.18 89.57 39.86 77.32
20

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: On-road only, TMACOG Travel Demand Model.

2004 2018 Projected 

Decrease

VOC 55.74 38.23 17.51

NOx 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: On-road only, TMACOG Travel Demand Model.

2004 2018 Projected 

Decrease

VOC 19.85 11.07 8.78

NOx 29.35 10.14 19.21

Table 14 Toledo, OH area Combined Comparison of 2004 attainment

year and 2018 projected emission estimates (tons per day, 

summer)

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

Directors Consortium (LADCO) Web site:

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

Data source: On-road only, TMACOG Travel Demand Model.

2004 2018 Projected Change

VOC 75.59 49.30 26.29

NOx 117.18 39.86 77.32
21

VOC emissions in the non-attainment area 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 grow 

in this area. However, cleaner vehicles and fuels are expected to be in place 

in 2009 and 2018 and result in an overall drop in VOC emissions.

NOx emissions in the nonattainment area are projected to decrease by 77.32 

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

Emissions Standards and Gasoline Sulfur Control Requirements3, Highway 

Heavy-Duty Engine Rule4and Non-Road Diesel Engine Rule5also factored 

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

the eastern United States, NOx and ozone levels entering this area also will 

be decreased. 

Requirement 4 of 5: 

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

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

not on temporary adverse economic conditions or unusually favorable meteorology.

Background:

Ambient air quality data from the monitoring site indicates that air quality met 

the NAAQS for ozone in 2005. U.S. EPA’s redesignation guidance (p 9) 

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

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

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

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

NAAQS.” 

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

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

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

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

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

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

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

comply with the inventory reporting requirements established in the CFR. 

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

projected maintenance year inventories to assess emission trends, as 

necessary, to assure continued compliance with the ozone standard.

 

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.htm
22

Demonstration:

Permanent and enforceable reductions of volatile organic compounds and 

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

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

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

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

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

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

Table 15 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: On-road only, TMACOG Travel Demand Model.

2002 2004

On-road VOC 29.74 26.86

On-road NOx 59.59 55.12

EGU NOx 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 Section 175A(b) of the CAA, Ohio commits to submit to the 

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

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

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

period after redesignation.
23

CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4:

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 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were 

no specific rules required by the CAA such as RACT for existing sources 

beyond statewide rules. 

Demonstration:

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

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

Requirement 2 of 4:

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

implemented.

Background:

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

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

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

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

percent of all NOx emissions statewide compared to previous uncontrolled 

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

The Toledo, OH area also implemented rules as part of the 15 percent rate 

of progress demonstration. 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 modeling that indicated this area would 

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

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

covered by this program have been generally trending downward since 1998 

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

Clean Air Markets Web site, quantifies the gradual NOx reductions that have 
24

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

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

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

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

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

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

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

which time the CAIR program will supersede it. 

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

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

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

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

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

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

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

2007 controlled NOx emissions will be 599 tons per day.

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards

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

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

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

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

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

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

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

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

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

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

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

Heavy-Duty Diesel Engines

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

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

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

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

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

inventory.

Clean Air Non-road Diesel Rule

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

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

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

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

engines by more than 90 percent. Non-road diesel equipment, as described 
25

in this rule, currently accounts for 47 percent of diesel particulate matter and 

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

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

approximately 3,000 ppm now to 15 ppm in 2009. 

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

ozone precursors.

Requirement 3 of 4:

Acceptable provisions to provide for new source review.

Background:

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

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

provisions for the Prevention of Significant Deterioration (PSD) permitting 

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

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

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

SIP.

Demonstration:

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

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

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

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

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

through the PSD program.

Requirement 4 of 4:

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

demonstrates through photochemical modeling that the standard can be maintained 

without one (1) or more controls.

Demonstration:

Ohio commits to maintaining the aforementioned control measures after 

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

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

maintenance of the ozone standard in 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 the 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 NOx SIP Call and 

Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. 

This modeling was originally designed to assess the one-hour ozone 

standard. Further analysis was conducted and documented in the LADCO’s 

White Paper “8-Hour Ozone Assessment” dated May 2, 2001. Base year 

design values used were the average of the design values for the three (3) 

three-year periods (1994-1996, 1995-1997, and 1996-1998). Base year 

emissions were taken from 1996 and four (4) ozone episodes were 

evaluated: June 22-28, 1991; July 14-21, 1991

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

average decrease in ozone from the base case modeling run with modeling 

runs that applied emission controls required by the CAA, NOx SIP Call and 

Tier II /low-sulfur requirements was 15 ppb (2009 Future design value 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. NOx emissions will be cut 

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

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

LADCO performed modeling to support the associated emission reductions 

for CAIR. This modeling was based on 2001 – 2002 design values for 

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) years after redesignation.

Demonstration:

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

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

Requirement 2 of 4:

A commitment to expeditiously enact and implement additional contingency control 

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

event that future violations of the ambient standards occur.

Demonstration:

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances:

Warning Level Response:

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

fourth high monitored value of 85 ppb occurs in a single ozone season within 

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

determine whether the ozone value indicates a trend toward higher ozone 

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

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

measures necessary to reverse the trend taking into consideration ease and 

timing for implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

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

(September 30). 

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

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

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

Action Level Response:

An Action Level Response shall be prompted whenever a two-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 level
28

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

be due to an exceptional event, malfunction, or noncompliance with a permit 

condition or rule requirement, Ohio EPA in conjunction with the metropolitan 

planning organization or regional council of governments, will determine 

additional control measures needed to assure future attainment of 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 consider 

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 our Response.

Control Measure Selection and Implementation:

Adoption of any additional control measures is subject to the necessary 

administrative and legal process. This process will include publication of 

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

Ohio law for rulemaking by state environmental boards. 

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

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

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

additional local measures may be unnecessary. Furthermore, Ohio will 

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

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration:

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the 

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

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

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

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

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

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

below is not comprehensive. 
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 RACT to smaller existing sources.

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

programs, work schedule changes, and telecommuting;

b) traffic flow and transit improvements; and

c) other new or innovative transportation measures not yet in 

widespread use that affects 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 NOx emission offsets for new and modified major 

sources.

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

sources.

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

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

tons).

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

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

be fully evaluated.
30

Requirement 4 of 4:

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

Demonstration:

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

controls.

NOx RACT

EGUs

asphalt batching plants

industrial/commercial and institutional boilers

process heaters

internal combustion engines

combustion turbines

other sources greater than 100 tons per year

VOC RACT

consumer products

architectural and industrial maintenance coatings

stage I gasoline dispensing facilities (including pressure valves)

automobile refinishing shops

cold cleaner degreasers

synthetic organic compound manufacturing

organic compound batch processes

wood manufacturing

industrial wastewater

aerospace industry

shipbuilding

bakeries

plastic parts coating

volatile organic liquid storage

industrial solvent cleaning

offset lithography

industrial surface coating

other sources greater than 50 tons per year
31

CHAPTER SEVEN

PUBLIC PARTICIPATION

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

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

county publications. 

The public 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 comment 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 includes

a copy of the public notice 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 

redesignations of basic ozone nonattainment areas. Documentation to that effect is 

contained herein. Ohio EPA has prepared a state implementation and maintenance plan 

that meets the requirement of Section 110 (a)(1) of the 1990 CAA. 

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

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

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

requirements necessary for redesignation have been met.

Based on this presentation, the 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 pollutants, significant regional NOx

reductions will ensure continued compliance (maintenance) with the standards with an 

increasing margin of safety.

The State of Ohio hereby requests that the Toledo, OH area ozone basic nonattainment 

area be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio

state implementation and maintenance plan provisions contained herein. 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 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.

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

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

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

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

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

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

grammar, and formatting conventions.

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

original submittal, as follows:

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

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

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

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

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

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

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

comment period closed on April 9, 2013. 
REQUEST FOR REDESIGNATION

REQUEST AND 

MAINTENANCE PLAN FOR

OZONE ATTAINMENT

IN THE EIGHT-HOUR OZONE 

BASICTOLEDO, OH

NONATTAINMENT AREA

Toledo, OH:

Lucas and Wood County

Developed By:

Ohio Environmental Protection Agency

Division of Air Pollution Control

December, 2006

Revised April 2013 

Formatted: Subtitle, Left, Tab stops: Not at 0"

+ 0.5" + 1" + 1.5" + 2" + 2.5" + 3" + 3.5"

+ 4" + 4.5" + 5" + 5.5" + 6" + 6.5"

Formatted: Font: 20 pt

This page left intentionally blank
i

TABLE OF CONTENTS

Chapter One

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

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

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

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

Chapter Two

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

Chapter Three

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

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

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

Commitment to continue monitoring............................................................................................... 8

Chapter Four

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

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

Emission Projections................................................................................................................. 1110

Demonstration of Maintenance................................................................................................. 1615

Permanent and Enforceable Emissions Reductions .................................................................... 21

Provisions for Future Updates .................................................................................................. 2122

Chapter Five

Control measures and regulations................................................................................................ 23

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

New Source Review Provisions ................................................................................................... 25

Assurance of continued controls .................................................................................................. 25

Chapter Six

Contingency measures ................................................................................................................. 27

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

Commitment for contingency measures ....................................................................................... 27

Potential contingency measures................................................................................................... 28

List of VOC and NOx sources ....................................................................................................... 29

Chapter Seven

Public participation........................................................................................................................ 31

Chapter Eight

Conclusions............................................................................................................................... 3132
ii

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-road Mobile Sources for Lucas County ................. 14

Table 3 Emission Estimations for On-road Mobile Sources for Wood County ................. 14

Table 4 Combined Emission Estimations for On-road Mobile Sources ........................ 1514

Table 5 Mobile Vehicle Emission Budget .......................................................................... 15

Table 6 VOC 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 NOx Emission Inventory Lucas County................................................................. 18

Table 10 NOx Emission Inventory Wood County................................................................. 19

Table 11 NOx Emission Inventory 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 estimates 2004-2018 Combined VOC/NOx Totals............... 20

Table 15 Combined comparison of 2002 and 2004 On-road and EGU Totals ................... 22

APPENDICES

A Air Quality System (AQS)

B Emission Inventories

C Emissions Analysis Method

D Public Participation Documentation
iii

This page left intentionally blank 
1

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

Introduction

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

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

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

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

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

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

February of 2001.

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

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

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

request nonattainment areas be redesignated to attainment providing certain criteria are 

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

from nonattainment to attainment: 

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

ii) An approved SIP for the area under Section 110(k).

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

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

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

met. 

Background

As part of the 1990 CAA Amendments re-evaluation, the Toledo, OH area was designated 

Moderate Nonattainment for the one-hour ozone standard pursuant to 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 

the 2004 ozone designations, U.S. EPA designated the Toledo, OH area basic 

nonattainment and subject to the eight-hour ozone requirements, including development of 

a plan to reduce volatile organic compounds (VOCs) and oxides of nitrogen (NOx) 
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 nonattainment to attainment for the eight-hour ozone standard. The 

Toledo, OH area has recorded three (3) years of complete, quality-assured ambient air 

quality monitoring data for the years 2004 – 2006 demonstrating attainment of the eighthour ozone standard. 

Geographical Description

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

in northwest Ohio. Lucas County contains the City of Toledo and Wood County contains 

the City of Bowling Green. Lucas County is bordered by Lake Erie to the north and east, 

Wood to the south 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 most recent three (3) years, 2004 through 2006, 

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

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

Chapter four, supports a redesignation to attainment for Toledo, OH area based on

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

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

Formatted: Level 1, Indent: First line: 0"
3

CHAPTER TWO

Requirements for Redesignation

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

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

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

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

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

Below is a summary of each redesignation criterion as it applies to 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. The data that are used to 

demonstrate attainment should be the product of ambient monitoring that is 

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

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

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

review.

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

quality modeling. The supplemental modeling 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. Chapter three discusses this requirement in more detail and 

provides the attainment demonstration.

ii.) SIP approval:

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

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

May 9, 1994 (59FR23799), March 23, 1995 (60FR15235) and August 1, 

1995 (60FR39115) and includes the Toledo, OH area. Chapter five

discusses this requirement in more detail and provides the attainment 

demonstration.

iii.) Permanent and enforceable improvement in air quality:

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

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

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

state.

The Toledo, OH area was designated Moderate Nonattainment for ozone as 

part of the 1990 CAA Amendments re-evaluation. As a result, Ohio has 
4

adopted or implemented control measures beyond the federal measures, the 

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

“rural” attainment areas. Chapters four and five discuss this requirement in 

more detail and provide the attainment demonstration.

iv.) Section 110 and Part D requirements:

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

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

redesignation request.

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

designated nonattainment based on a violation of the NAAQS.

i.) Section 172(c) requirements

This section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for

an emission inventory will be satisfied by the inventory requirements 

of the maintenance plan. 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 

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.) Maintenance plans.

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

must fully approve a maintenance plan which meets the requirements of 

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

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

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

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

ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

violation of the NAAQS. At a minimum, the contingency measures must 
5

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

the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the 

following provisions:

a.) attainment inventory;

b.) maintenance demonstration;

c.) monitoring network;

d.) verification of continued attainment; and

e.) contingency plan.

Chapter six discusses this requirement in more detail and provides the 

attainment demonstration.

Formatted: Font: 14 pt, Bold

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

+ 0.5"
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 monitors measuring ozone concentrations in this 

nonattainment 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 locations of the monitoring sites for this 

nonattainment area are shown on Figure 1.

Demonstration:

Figure 1 Map of Toledo, OH area
7

Requirement 2 of 4: 

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

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

Demonstration:

Ohio EPA has quality assured 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 and therefore data are available to 

the public.

Requirement 3 of 4: 

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

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

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

quality assured data.

Background:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

called the site's design value.

Table 1 shows the monitoring data for the three 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.epa.gov/ttn/airs/airsaqs/index.htm

Please note: 2006 data is not yet validated.

1

st 2nd 3rd 4th 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 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 ppb

A comprehensive list of the site’s design values during the 2004-2006 time

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

emissions have declined due to such factors as cleaner automobiles and 

fuels both regionally and locally. 

Requirement 4 of 4: 

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

monitoring network to verify the maintenance of the attainment status.

Demonstration:

Ohio commits to continue monitoring 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 Web site1 will provide real time 

availability of the data and knowledge of any exceedances. Ohio EPA will 

 

1

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

Formatted Table
9

enter all data into AQS on a timely basis in accordance with federal 

guidelines.

Formatted: Font: 14 pt, Bold

Formatted: Tab stops: 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", Left
10

CHAPTER FOUR

EMISSION INVENTORY

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

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

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

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

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

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

Other emissions inventory related requirements include a projection of the emission 

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

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

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

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 annual emissions reporting 

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

data base for SIP development and does coincide with nonattainment air 

quality in 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 does

provide some indication of the impact from Ohio sources near the 

nonattainment area. The emissions are decreasing substantially in response 

to regional and national programs affecting many EGUs such as the Acid 

Rain program and the NOx SIP Call. 

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 Ohio EPA used to generate the 
11

2002 base inventories and to develop SIP ready modeling inventories and 

future year projections. These inventories were provided to the Lake 

Michigan Air Directors' Consortium (LADCO) and have been processed to 

develop summer day emissions for use in the air quality analyses. These 

processed modeling inventories have been identified as the correct iteration 

of the inventory for use in the redesignation. In this document, references to 

LADCO include the Midwest Regional Planning Organization.

Area sources were taken from the Ohio 2002 periodic inventory 

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

Department of Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information.

Mobile source emissions were calculated using emissions factors 

produced with MOBILE6.2MOVES2010.

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

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

acid rain database2.

Biogenic emissions are not included in these summaries.

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

Mobile Inventory Model (NMIM) 2002 application. To address 

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

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

companies to review the base data and make recommendations. 

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

Emissions were estimated for aircraft, commercial marine vessels and 

railroads. Recreational motorboat population and spatial surrogates 

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

The populations for the construction equipment category were 

reviewed and updated based upon surveys completed in the Midwest 

and the temporal allocation for agricultural sources also was updated. 

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 Department of Transportation (Ohio DOTODOT) the 

Toledo Metropolitan Area Council of Governments (TMACOG) utilizes a regional 

 

2

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

Formatted: Indent: Left: 0", First line: 0.5"

Formatted: Right: 0"
12

travel demand forecast model to simulate traffic in the area and to forecast traffic 

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

planning tool to evaluate the transportation system including determination of 

locations where additional travel capacity may be needed and to determine the 

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

for air quality purposes to estimate the total emissions of pollution caused by 

vehicles in the area. The travel demand forecasting model is used to predict the 

total daily vehicle miles traveled (VMT) and an U.S EPA computer program called 

MOBILE6.2MOVES2010 is used to calculate emissions per mile. The product of 

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

particular analyzed area. In areas outside the regional travel demand model, traffic 

counts and statewide traffic growth rates are used for the VMT estimates.

Overview 

Broadly described, MOBILE6.2MOVES2010 is used to generate “emission factors”, 

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

and VOC. The MOBILE6.2MOVES2010 model includes a number of variables that 

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

which require modification to reasonably reflect local conditions. Some of these 

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

vehicle type have a major effect on the emission factors. The vehiclesource types 

are traveling on facilityroad types. Vehicle (MOVES2010 road types are Rural 

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

Unrestricted Access). The vehicle speeds also affect the emission factor values. 

Meteorological conditions such as air temperature and humidity also significantly 

affectshave a significant effect on emission factors. Emission factors produced by 

MOBILE6.2MOVES2010 can also include the effect of emission reduction strategies 

such as vehicle inspection and maintenance programs, regulation of fuels, etc. 

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

and.

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

in a formal interagency consultation process. Emission factors are multiplied by 

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

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

with the travel demand model information. One of the simplest methods is to 

input extensive vehicle fleet, area-specific speed and facility type information 

MOBILE6.2 to generate a single emission factor that represents the average 

for all vehicles and facility types in the modeled area. This only requires 

multiplying this emission factor by the total VMT of the analyzed area to get 

the total emissions for the area. Another method is to create multidimensional emission factor “look-up” tables that describe the emission 

factors by speed, temperature, and facility type. This requires more 

extensive processing, but the resulting total emissions of this method are 

Formatted: Indent: Left: 0", First line: 0.5",

Right: 0"

Formatted: Indent: Left: 0", First line: 0.5"

Formatted: Right: 0"

Formatted: Indent: Left: 0", First line: 0.5"
13

more sensitive to even minor changes in the roadway system. Tables of 

emission factors are created using MOBILE6.2 for each facility type, 

temperature, and speed given the vehicle fleet on that facility. Then, the 

travel model provides information on each segment of road (or “link”) 

regarding speed and facility type which is then “looked-up” in the appropriate 

emission factor table. It should be noted that speed is estimated as a post 

process to the travel demand model. Speeds are not taken directly from the 

travel demand model. The post process for emissions analysis by Ohio DOT 

is by hour of day. This emission factor is multiplied by the link’s trafficvolume and length or VMT to get the emissions from that link for that hour. 

There are other methods as well, each with its advantages and 

disadvantages. The Toledo, OH area analysis uses the latter more complex 

method, 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 

higherThe emission factors from MOVES2010 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 analysis method, developed by ODOT, is to aggregate the emission 

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

population, thereby reducing the intensive processes. In the first step emission 

factors are broadly classified into total vehicles, cars and trucks by pollutant, by 

average speed, road type and hour of day. Then the hourly link volumes generated 

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

for each hour. The on-road vehicle emissions for the area 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 intrazonal emissions.

Automated programs, using FORTRAN and CUBE scripting, were developed by 

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

traffic distributions as well as more up to date volume/delay functions from the 2000 

Highway Capacity Manual (HCM). This process also handles the newer model 

network formats and MOVES2010 generated emission factors than newer vehicles, 

diesel vehicles have much higher NOx emission factors and lower VOC emission 

factors than gasoline vehicles, and higher average speeds have lower emission 

factors except for diesel vehicles which have higher NOx at higher speeds. 

Formatted: Right: 0"
14

MOBILE6.2. MOVES2010 input and output files are provided in Appendix C.

Best Available Data 

The mostMost current vehicle age distribution data, temperature data, and fuel 

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

ATRs and WIMs, NOAA, ODPS, and Ohio EPA waswere used by Ohio DOTthe 

ODOT for generating emission factors. Likewise, the most current transportation 

planning data available from TMACOG and the most current Ohio DOTODOT count 

data waswere used by the Ohio DOTODOT for the emissions estimates. Details 

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

Memorandum TMACOG Redesignation and Maintenance Plan Request (8-Hour 

Ozone)” dated December 2006.

Analysis Years

Analysis years for this redesignation request include 2002, 2004, 2009, and 2018 to 

meet the requirements specified by the CAA and U.S. EPA. The travel demand 

model presentsrepresents the transportation system conditions for each of these 

years. Model runs for each future analysis year contain the road network TMACOG 

and Ohio DOTODOT expects to exist at the beginning of that year with 

corresponding socioeconomic forecasts for that year. 

Local Road VMT

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

demand model. These local roads are represented as fictitious roadways called 

centroid connectors. Local road VMT is included in the Ohio DOTODOT post 

process by including the traffic loaded on centroid connectors. In addition, some 

local road traffic is captured as intra-zonal trips which travel demand models usually 

do not assign to roadway segments. The Ohio DotODOT 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-road only, TMACOG Travel Demand Model.

Formatted: Indent: Left: 0", First line: 0.5"

Formatted: Heading 2, Right: 0"

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: Font: Times New Roman

Formatted: Normal, Indent: Left: 0", First

line: 0.5"

Formatted: Right: 0"

Formatted: Indent: Left: 0", First line: 0.5",

Right: 0"

Formatted: Indent: Left: 0", First line: 0.5"

Formatted: Font color: Auto

Formatted: Heading 2, Left, Right: 0"
15

Lucas County 2002 2004 2009 2018

VMT (miles/day) 9,508,52010,302,08

3

9,614,86910,245,65

0

10,080,862320,22

8

10,534,1249,654,15

9

VOC (tons/day) 19.7720.51 16.5717.86 10.9412.49 6.335.20

NOx (tons/day) 31.5140.26 27.0535.58 18.4226.41 7.629.63

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) 5,249,244162,33

0

5,362,131738,28

6

5,629,172895,27

0

6,158,7755,792,23

8

VOC (tons/day) 9.9323 8.419.00 5.576.30 3.412.94

NOx (tons/day) 18.7319.33 16.2619.54 10.9314.27 4.655.71

Table 4 Combined VOC and NOx Emission Estimations for On-Road 

Mobile Sources for the Toledo, OH area.

Data source: On-road only, TMACOG Travel Demand Model.

County VOC 2018

Lucas County, OH VOC 6.335.20

Wood County, OH VOC 3.412.94

TOTAL VOC 9.748.14

County NOx

Lucas County, OH NOx 7.629.63

Wood County, OH NOx 4.655.71

TOTAL NOx

12.2715.34

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: Black
16

Data source: On-road only, TMACOG Travel Demand Model.

2009 2018

VOC (tons/day) *18.9921.61* *11.209.36*

NOx (tons/day) *33.7546.78* *14.1117.64*

*includes 15 percent 

This budget includes the emission estimates calculated for 2009 and 2018. 

The emission estimates are derived from the Tranplan travel demand model

and MOBILE6.2MOVES2010 as described above under the expected 

TMACOG 2035 Long Range Plan. The mobile source budget for 2009 

includes 18.99 21.61 tons per summer day (tpd) for VOC and 33.75 46.78

tpd for NOx. The mobile source budget for 2018 includes 11.209.36 tpd for 

VOC and 14.1117.64 tpd for NOx. These correspond to a 15 percent 

increase from the 2018 on-road emissions for both VOC and NOx. Appendix 

C contains data tables and graphs of these emissions.

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 budgets will no longer be applicable either after the 

effective date of the approved redesignation or after the effective date of any 

U.S. EPA action approving a finding that the eight-hour conformity budget

included in this submittal adequate for transportation conformity purposes 

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 for 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.

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

MOBILE6.2MOVES2010 model. The analysis is described in more 

detail in Appendix C. All projections were made in accordance with 

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

019. 

Formatted Table
17

Emissions inventories are required to be projected to future 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 document. 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

continued 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 counties. Mobile source emission 

inventories are described in Appendix B. In addition to the LADCO

estimates, point source emissions were projected based upon the statewide 

EGU NOx budgets from the Ohio NOx 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. 
18

Demonstration:

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: On-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 19.7720

.51

16.5717.86 10.9412.49 6.335.20

TOTAL 58.625

9.36

54.4555.74 46.4548.0

0

39.3638.23 15.0917.5

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 Michigan Air 

Directors Consortium (LADCO) Web site:

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

Data source: On-road only, TMACOG Travel Demand Model.

Sector 2002 

Base

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 9.9323 8.419.00 5.576.30 3.412.94

TOTAL 21.1920 19.2685 15.4516.1 11.5407 7.728.7

Formatted Table

Formatted: Indent: Left: 0.5", Hanging: 1",

Widow/Orphan control

Formatted: Font: Arial

Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black
19

.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: On-road only, TMACOG Travel Demand Model.

2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

Lucas County 58.62

59.36

54.4555.74 46.454

8.00

39.3638.23

Wood County 21.19

20.49

19.2685 15.451

6.18

11.5407

COMBINED 

VOC TOTAL

79.81

85

73.7175.59 61.906

4.18

50.9049.30 22.812

6.29

Table 9 Lucas County NOx 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: On-road only, TMACOG Travel Demand Model.

Sector 2002 Base 2004 

Attainment

2009 

Interim

2018

Maintenanc

e

Safety 

Margin

EGU 

Point

24.91 22.57 16.73 3.83

NonEGU

13.97 12.97 10.47 9.03

Nonroad

8.54 7.96 6.51 n/a

Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black

Formatted Table
20

Other 0.97 1.03 1.17 1.18

MAR 8.26 7.72 6.37 6.05

Onroad

31.5140.26 27.0535.58 18.4226.4

1

7.629.63

TOTAL 88.1696.9

1

79.3087.83 59.67.66 27.7129.72 51.5958.1

1

Formatted: Font color: Black
21

Table 10 Wood County NOx 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: On-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 18.731

9.33

16.2619.54 10.9314.27 4.655.71

TOTAL 29.43

30.03

26.0729.35 18.5721.9

1

9.0810.14 16.9919.2

1

Table 11 Toledo, OH area NOx 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: On-road only, TMACOG Travel Demand Model.

2002 

Base

2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin

Lucas County 88.169

6.91

79.3087.83 59.67.6

6

27.7129.72

Wood County 29.433

0.03

26.0729.35 18.572

1.91

9.0810.14

COMBINED 

NOx TOTAL

117.59

126.94

105.37117.

18

78.248

9.57

36.7939.86 68.587

7.32

Formatted Table

Formatted Table

Formatted: Font color: Black
22
23

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: On-road only, TMACOG Travel Demand Model.

2004 2018 Projected 

Decrease

VOC 54.4555.74 39.3638.23 15.0917.51

NOx 79.3087.83 27.7129.72 51.5958.11

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: On-road only, TMACOG Travel Demand Model.

2004 2018 Projected 

Decrease

VOC 19.2685 11.5407 7.728.78

NOx 26.0729.35 9.0810.14 16.9919.21

Table 14 Toledo, OH area Combined Comparison of 2004 attainment

year and 2018 projected emission estimates (tons per day, 

summer)

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

Directors Consortium (LADCO) Web site:

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

Data source: On-road only, TMACOG Travel Demand Model.

2004 2018 Projected Change

VOC 73.7175.59 50.9049.30 22.8126.29

NOx 105.37117.18 36.7939.86 68.5877.32

Formatted Table

Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted Table
24

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

26.29.65 tons per day (tpd). Area source emissions and, to a lesser extent, 

point sources, show an increase due to expectations that the population will 

grow in this area. However, cleaner vehicles and fuels are expected to be in 

place in 2009 and 2018 and result in an overall drop in VOC emissions.

NOx emissions in the nonattainment area are projected to decrease by

76.1777.32 tpd. Decreases from U.S. EPA rules covering Tier 2 Motor 

Vehicle Emissions Standards and Gasoline Sulfur Control Requirements3, 

Highway Heavy-Duty Engine Rule4and Non-Road Diesel Engine Rule5also 

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

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

area also will be decreased. 

Requirement 4 of 5: 

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

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

not on temporary adverse economic conditions or unusually favorable meteorology.

Background:

Ambient air quality data from the monitoring site indicates that air quality met 

the NAAQS for ozone in 2005. U.S. EPA’s redesignation guidance (p 9) 

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

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

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

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

NAAQS.” 

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

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

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

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

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

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

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

comply with the inventory reporting requirements established in the CFR. 

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

projected maintenance year inventories to assess emission trends, as 

necessary, to assure continued compliance with the ozone standard.

 

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.htm
25

Demonstration:

Permanent and enforceable reductions of volatile organic compounds and 

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

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

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

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

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

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

Table 15 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: On-road only, TMACOG Travel Demand Model.

2002 2004

On-road VOC 29.7074 24.9826.86

On-road NOx 50.2459.59 43.3155.12

EGU NOx 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 Section 175A(b) of the CAA, Ohio commits to submit to the 

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

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

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

period after redesignation.

Formatted Table

Formatted: Font color: Black
26
27

CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4:

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 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were 

no specific rules required by the CAA such as RACT for existing sources 

beyond statewide rules. 

Demonstration:

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

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

Requirement 2 of 4:

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

implemented.

Background:

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

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

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

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

percent of all NOx emissions statewide compared to previous uncontrolled 

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

The Toledo, OH area also implemented rules as part of the 15 percent rate 

of progress demonstration. 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 modeling that indicated this area would 

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

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

covered by this program have been generally trending downward since 1998 

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

Clean Air Markets Web site, quantifies the gradual NOx reductions that have 
28

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

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

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

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

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

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

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

which time the CAIR program will supersede it. 

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

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

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

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

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

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

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

2007 controlled NOx emissions will be 599 tons per day.

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards

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

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

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

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

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

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

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

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

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

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

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

Heavy-Duty Diesel Engines

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

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

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

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

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

inventory.

Clean Air Non-road Diesel Rule

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

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

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

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

engines by more than 90 percent. Non-road diesel equipment, as described 
29

in this rule, currently accounts for 47 percent of diesel particulate matter and 

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

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

approximately 3,000 ppm now to 15 ppm in 2009. 

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

ozone precursors.

Requirement 3 of 4:

Acceptable provisions to provide for new source review.

Background:

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

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

provisions for the Prevention of Significant Deterioration (PSD) permitting 

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

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

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

SIP.

Demonstration:

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

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

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

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

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

through the PSD program.

Requirement 4 of 4:

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

demonstrates through photochemical modeling that the standard can be maintained 

without one (1) or more controls.

Demonstration:

Ohio commits to maintaining the aforementioned control measures after 

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

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

maintenance of the ozone standard in 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 the emission of ozone precursors in the Toledo, OH area.
30

LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment

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

Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. 

This modeling was originally designed to assess the one-hour ozone 

standard. Further analysis was conducted and documented in the LADCO’s 

White Paper “8-Hour Ozone Assessment” dated May 2, 2001. Base year 

design values used were the average of the design values for the three (3) 

three-year periods (1994-1996, 1995-1997, and 1996-1998). Base year 

emissions were taken from 1996 and four (4) ozone episodes were 

evaluated: June 22-28, 1991; July 14-21, 1991

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

average decrease in ozone from the base case modeling run with modeling 

runs that applied emission controls required by the CAA, NOx SIP Call and 

Tier II /low-sulfur requirements was 15 ppb (2009 Future design value 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. NOx emissions will be cut 

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

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

LADCO performed modeling to support the associated emission reductions 

for CAIR. This modeling was based on 2001 – 2002 design values for 

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: Left
31

CHAPTER SIX

CONTINGENCY MEASURES

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

Requirement 1 of 4:

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

Demonstration:

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

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

Requirement 2 of 4:

A commitment to expeditiously enact and implement additional contingency control 

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

event that future violations of the ambient standards occur.

Demonstration:

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances:

Warning Level Response:

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

fourth high monitored value of 85 ppb occurs in a single ozone season within 

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

determine whether the ozone value indicates a trend toward higher ozone 

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

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

measures necessary to reverse the trend taking into consideration ease and 

timing for implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

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

(September 30). 

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

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

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

Action Level Response:

An Action Level Response shall be prompted whenever a two-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 level
32

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

be due to an exceptional event, malfunction, or noncompliance with a permit 

condition or rule requirement, Ohio EPA in conjunction with the metropolitan 

planning organization or regional council of governments, will determine 

additional control measures needed to assure future attainment of 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 consider 

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 our Response.

Control Measure Selection and Implementation:

Adoption of any additional control measures is subject to the necessary 

administrative and legal process. This process will include publication of 

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

Ohio law for rulemaking by state environmental boards.

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

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

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

additional local measures may be unnecessary. Furthermore, Ohio will 

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

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration:

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the 

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

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

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

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

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

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

below is not comprehensive. 

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", Left
33

1) Lower Reid vapor pressure gasoline program.

2)1) Tighten RACT on existing sources covered by U.S. EPA Control 

Technique Guidelines issued in response to the 1990 CAA.

3)2) Apply RACT 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) trip reduction programs, including, but not limited to, employerbased transportation management plans, area wide rideshare 

programs, work schedule changes, and telecommuting;

b) traffic flow and transit improvements; and

c) other new or innovative transportation measures not yet in 

widespread use that affects state and local governments 

deemed 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 NOx emission offsets for new and modified major 

sources.

8)7) Require VOC or NOx 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 NOx controls on new minor sources (less than 100 

tons).

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

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

be fully evaluated.

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 NOx sources potentially subject to future controls.

Demonstration:

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

controls.

NOx RACT

EGUs

asphalt batching plants

industrial/commercial and institutional boilers

process heaters

internal combustion engines

combustion turbines

other sources greater than 100 tons per year

VOC RACT

consumer products

architectural and industrial maintenance coatings

stage I gasoline dispensing facilities (including pressure valves)

automobile refinishing shops

cold cleaner degreasers

synthetic organic compound manufacturing

organic compound batch processes

wood manufacturing

industrial wastewater

aerospace industry

shipbuilding

bakeries

plastic parts coating

volatile organic liquid storage

industrial solvent cleaning

offset lithography

industrial surface coating

other sources greater than 50 tons per year

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

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

Left + 0.5", Left + 6.5", Left
35
36

CHAPTER SEVEN

PUBLIC PARTICIPATION

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

comment 

concerning the draft redesignation petition and maintenance plan in severala widely 

distributed 

county publications 30 days prior to the public hearings. 

The public hearing to receive comments on the redesignation request will bewas held on

February 6, 2007April 9, 2013 at the Toledo Metropolitan Area Council of Governments, 

300 Dr. Martin Luther King Jr. DrivePublic Library- South Branch, 1736 Broadway Street,

Toledo, Ohio. The public comment period will close on February 6, 2007. April 9, 2013. No 

comments were received during the public comment period and no testimony was provided 

at the hearing. Appendix D will includeE includes a copy of the public notice, certifications 

of publication, and the hearing transcript from the public hearing.
37

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 

redesignations of basic ozone nonattainment areas. Documentation to that effect is 

contained herein. Ohio EPA has prepared a state implementation and maintenance plan 

that meets the requirement of Section 110 (a)(1) of the 1990 CAA. 

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

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

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

requirements necessary for redesignation have been met.

Based on this presentation, the 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 pollutants, significant regional NOx

reductions will ensure continued compliance (maintenance) with the standards with an 

increasing margin of safety.

The State of Ohio hereby requests that the Toledo, OH area ozone basic nonattainment 

area be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio

state implementation and maintenance plan provisions contained herein. 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 blank 
1 

TOLEDO METROPOLITAN AREA COUNCIL OF GOVERNMENTS 

ON-ROAD MOBILE EMISSION ESTIMATES 

PREPARED FOR THE SIP INVENTORY 

FOR THE 8-HOUR OZONE STANDARD 

NOVEMBER 2012 

 
2 

Table of Contents 

1. Overview ....................................................................................... 3

2. Urban Travel Demand Modeling .................................................. 5 

3. Emission Factor Generation ......................................................... 13

4. Post Processing ............................................................................. 21

5. Multiple MPO Cooordination Issues ............................................ 23

Appendix A 

Interagency Consultation Documentation .............................................. 24 

Appendix B 

B.1 Post Processing Default Distributions .......................................... 29

B.2 Ozone Emission Summaries ......................................................... 32 
3 

1. Overview 

This report is intended to document the air quality analyses and underlying assumptions 

performed by the Ohio Department of Transportation (ODOT), Division of Transportation 

System Development-Modeling and Forecasting 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 Implementation Plan (SIP) revision in coordination with 

the Ohio Environmental Protection Agency (OEPA). 

The Toledo Region is comprised of Lucas and Wood Counties in northwest Ohio. Both counties 

are designated as a maintenance area for the 8-hour Ozone Standard. TMACOG serves as the 

Metropolitan Planning Organization (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 planning assumption requirement. As discussed in 

Section 2 of this report, the modeling process used to develop each MPO emissions is calibrated 

using the latest population and land use data available 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 Volatile Organic Compounds (VOC) and Nitrogen 

Oxides (NOX). 
4 

On Road Mobile Emission Summary 

Tables 1 to 4 present a summary of emissions for the Toledo Region 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 15.34
5 

2. Urban Travel Demand Models

TMACOG maintain the regional travel demand forecasting model for use in the urban 

transportation planning process. The models employ the traditional four step modeling process 

to project existing and future traffic volumes and travel patterns on the regional transportation 

network. The four step process consists of trip 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 model 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/Voyager interface and improves model functionality. 

The 2000 Cube/Voyager model with the latest planning assumptions (network and 

socioeconomic data) is used to calculate 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 network files were used to create the 2035 Plan–

Update 2011. Projects included in the various files are listed in order to track where various plan 
6 

projects were included in the analysis. Projects in the TIP and 2035 Plan–Update 2011 not listed 

below were not modeled in the systems analysis. Most of these “not modeled” projects are of a 

nature not easily analyzed in a region-wide model (Ozone Action Days, traffic signal 

interconnects, etc.). 

The network files are built sequentially and are listed in sequence 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 intersection improvements (Perrysburg) 

v. Oregon Rd./CSX grade separation 

w. Wheeling St./Starr Ave. intersection improvements 

x. Anthony Wayne Trail intersection upgrades (Waterville) 

y. Holland-Sylvania Rd. roadway reconstruction (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 modification and Salisbury/Dussel Rd. widening 

b. Secor Rd. widening (Alexis Rd. to Michigan state line) 

c. Roachton Rd. widening with center turn lane addition and signalization upgrade 

(Ft. Meigs Rd. to SR 25) 

d. N. Main St. widening with center turn lane addition and signalization 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 additions (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 separation 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 (Colony 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) 3rd 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. intersection 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. intersection improvements 

f. Stitt Rd./Waterville-Monclova 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 eliminate 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 Upton (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 Perrysburg 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 to 

provide 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 Analyzed 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 systems interchange Phase 2 

and related improvements to local arterials 

including Cherry St. and Phillip Ave. 

ODOT Analyzed Analyzed 

C-6 Roadway 

Dorr St. safety & pedestrian improvements, Byrne 

to Upton (widen & signal 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 management / travel info system ODOT Exempt Exempt Exempt Exempt 

C-11 Transit Provide real time bus arrival information TARTA Exempt Exempt Exempt 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 from 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 interchange ODOT Analyzed 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 Analyzed 
10 

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 improvements, 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; Detroit 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 Exempt 
11 

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 network (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 & managed access for improved 

road access to freight terminals, 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. The population data is consistent with the 

county totals projected by Ohio Department of Development (ODOD), Office of Strategic 

Research. The other socioeconomic parameters (dwelling units, school attendance, vehicles and 

labor force) were defined using the standard conversion parameters for either population or 

employment for Traffic Analysis Zones (TAZs) 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 employment 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 expected 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-factored travel demand model output. For ozone 

runs, model VMT is factored to represent an average 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 generated for base year-2002 and attainment year2004 to represent the programs being implemented in the TMACOG Region. Programs and 

corresponding MOVES parameters were developed in consultation with OEPA. 

Future Years 

Emission factors were also generated for two future year scenarios: 2009 and 2018. All 

assumptions remain the same as those used to generate 2002 emission factors and are further 

illustrated in this section using year 2002 as an example. 

Technical Details 

Table 7 summarizes the settings used in the MOVES run specification file and the MOVES 

County-Data Manager. Further details in specific inputs that are not using default values are 

provided below. 

15000

15200

15400

15600

15800

16000

16200

16400

16600

16800

17000

2010 2018 2025 2035

Vehicle Miles Traveled (1,000s)

Toledo Region VMT Trends

VMT
14 

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 Hydrocarbons, Non-Methane Hydrocarbons, Volitile Organic 

Compounds, NOx, NO, NO2, 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 model 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 Default 
15 

Temperature and Relative Humidity 

Temperatures used for the single season approach are representative of July 2002 based on 

NOAA data from the National Climate Data Center webiste. To get the correct fomat for 

MOVES, the data was entered into a spreadsheet provided by EPA which was designed to 

convert Mobile6 data to MOVES. The average July hourly temperature 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 82 
16 

Ramp Fraction 

Ramp fractions were derived using the base year 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 information was derived using Ohio Bureau of Motor Vehicle 

registration data for year 2010. The data was given 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 distribution will be used for all analysis years 
17 

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 0.1076
18 

Road Type Distribution 

Road type distribution is based on the 2008 ODOT HPMS VMT data categorized by federal 

functional class for TMACOG area. Road type 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 0.56
19 

Vehicle Type VMT and VMT Fractions

The first component of the VMT inputs is the Yearly 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 vehicle 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 converted 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 default data. The hourly VMT fractions were 

derived from ODOT WIM data. Hourly VMT fractions 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 month, 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 6.90740776 
21 

Table 16 shows the first record in a MOVES sample output (rate per vehicle) emission file for 

year 2005 with I/M programs. The rate per vehicle varies for any combinations of month, day of 

week, hour of the day, pollutant, and process. Rates per vehicle emissions 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 vehicle varies for any combinations of month, day of 

week, hour of the day, pollutant, and process. Rates per profile emissions 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 directional traffic distributions as well as more up to date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process, described below and 

illustrated in Figure 3, also uses rewritten code able to handle the newer model network formats 

and MOVES generated emission factors. 

The first step in the the process involves running postcms.exe to calculate hourly link volumes 

based on the percentage of the daily volume (travel demand model output) determined by a 

link’s facility and area type. Link speeds from the travel demand model are not used in the 

analysis. The speeds are estimated as a post-process 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 combination of the MOVES emission factors and the 

hourly link volumes that are output of the postcms.exe program. The hourly volumes are 
multiplie

roadtype 

vehicle e

The third

Rate per 

vehicle s

emission

Intrazona

separate 

movesint

intrazona

the avera

combinin

the same

The final

and analy

TMACO

ed by the MO

to calculate

emissions for

d step, (move

Distance an

ource type i

ns for each co

al trips do no

method to ac

tra.exe progr

al trips of eac

age trip lengt

ng MOVES 

as those use

l step is to su

yzed year. D

OG Region ca

OVES emiss

 emissions f

r the area is t

esveh.exe), c

d Rate per P

s based on a

ounty are the

ot get loaded

ccount for th

ram uses intr

ch zone. Th

th for these i

generated em

ed to calcula

ummarize lin

Daily summa

an be found 

Fig

ion factor fo

for every net

the sum of a

calculates ve

Profile files)

a combinatio

e sum of all 

d onto the ne

hose trips tha

razonal trips

he zone is ass

intrazonal tri

missions wit

ated link base

nk, vehicle, a

ary emission

in Appendi

gure 3 – Em

22 

or the corresp

twork link fo

all individual

ehicle-based

for each sou

n of local an

individual h

etwork, so th

at use local r

s to estimate

sumed circu

ips. Intrazon

th estimated 

ed emissions

and intrazon

ns for each p

x B.2. 

mission Calc

ponding hou

or each hour

l link-hour e

d emissions (

urce type for

nd default da

hourly emissi

he fourth step

roads to trav

 VMT using

ular and the r

nal emission

intrazonal V

s. 

nal emissions

ollutant, cou

culation Pro

ur of day, sp

r. The final l

emissions. 

(using a com

r each hour o

ata. The fina

ions for all v

p in the proc

vel within a z

g the area in 

radius of the

ns are then c

VMT. The e

s for each co

unty, and sce

ocess 

eed bin, and

link on road 

mbination of t

of the day. T

al vehicle 

vehicle types

cess requires

zone. The 

square miles

 circle is use

alculated by

emission rate

ounty, pollut

enario year i

d

the 

The 

s. 

s a 

s and 

ed as 

y

es are 

tant, 

in the 
23 

5. Multiple MPO Coordination Issues

TMACOG, ODOT, and OEPA have a long history of working together in air quality issues, the 

Memorandum of Understanding, listed below, documents 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 Division, and the FTA-Region 5. 
24 

Appendix A 

Interagency Consultation Documentation 
25 

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 increasing 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 there needs to be an adjustment 

from average number of vehicles to the number 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 prefer 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 discussed. Since we now calculate emission rates 

for both VMT and number of vehicles, does there 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. Maybe 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) 752-5742
27 

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. 

Fred 
28 

Appendix B 
29 

Appendix B.1 

Post Processing Default Distributions 
30 

HOUR 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 PCTADT URB 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 URB 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 RUR 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 RUR 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 PCTADT TRK URB 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 URB 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 RUR 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 RUR 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 PCTDIR URB FWY 38 40 40 46 56 64 70 70 68 62 58 52 52 52 50 46 38 38 46 URB ART 44 46 44 48 54 62 66 68 64 56 54 52 50 50 50 46 40 38 46 RUR FWY 44 46 48 54 60 68 68 64 58 54 52 50 50 52 52 48 42 40 44 RUR ART 40 42 44 48 58 66 72 68 60 56 54 50 50 50 50 46 40 38 46 LOS 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 SPEEDVC curve1 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 curve2 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 curve3 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 curve4 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 curve5 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 curve6 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 curve7 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 curve8 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 curve9 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 curve10 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 curve11 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 curve12 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 curve13 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 curve14 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 curve15 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 curve16 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 curve17 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 curve18 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 curve19 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 curve20 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 curve21 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 VC 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 DETERMIN BASE RUR2 FWY A 0.00 0.00 0.00 B 0.30 0.00 0.25 C 0.50 0.10 0.40 D 0.70 0.30 0.60 E 0.90 0.50 0.80 F 1.00 1.00 1.00 F+ 1.10 1.10 1.10 F++ 1.30 1.30 1.30 
31 

SPEED 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 AREA NUM LOS DEFINITION 1 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 AREA 4 E RURAL NON MPO COUNTIES PEAK SPREADING MODEL INFO (SET MAX ITERATIONS TO 0 TO DISABLE PEAK SPREADING) MAX VC RATIO FWY: 1.30 MAX VC RATIO ART: 1.30 MAX ITERATIONS : 1000 TRUCK PCE: 2.00 AQ SEASON FACTOR: 1.08 MODEL 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 0 0 0 CLS BEG 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 CLS END 23 23 0 0 0 0 0 0 0 0 0 0 0 0 0 0 CLS NUM 1 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 
32 

Appendix B.2 

Ozone Emission Summaries 
33 

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 Environmental 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 national ambient air quality 

standard (NAAQS). Ohio EPA submitted a redesignation request and maintenance plan 

for this area on December 22, 2006 Subsequently, U.S. EPA approved this requests on

August 9, 2007 (72 FR 44784). Air quality monitoring data collected in the region 

demonstrated attainment of the NAAQS and there was evidence that the improved air 

quality is due to permanent, enforceable emission reductions. In addition, existing 

requirements are sufficient to maintain the 1997 eight-hour ozone standard in this area 

throughout the maintenance period.

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

emission projections and conformity budgets based on emission rates generated from 

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

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

official emission factor model.

These actions must be noticed to allow public comment and to satisfy U.S. EPA 

requirements for public involvement in SIP related activities. This notice addresses 

Ohio EPA’s reliance on the emission projections as evidence of attainment and 

maintenance and the commitment to institute contingency measures if ambient 

exceedances or violations trigger the contingency plan requirements. Written comments 

will be received on or before April 9, 2013 at the following address:

E-mail: erica.fetty@epa.state.oh.us

Mailing address: Erica Fetty

Ohio Environmental Protection Agency, DAPC

Lazarus Government Center

P.O. Box 1049

Columbus, Ohio 43216-1049

Phone: (614) 644-2310

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this 

redesignation request will be conducted as follows: April 9, 2013 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 submitted at the hearing or to the above address by 

the close of business on April 9, 2013 will be considered by Ohio EPA prior to final 

action on this redesignation. Written statements submitted after April 9, 2013 may be 

considered as time and circumstances permit, but will not be part of the official record 

of the hearing.

This redesignation and maintenance request is available on Ohio EPA DAPC’s Web 

page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx. 

Questions regarding accessing the web site should be directed to Arunee Niamlarb at 

614-728-1342; other questions or comments about this document should be directed to 

either Erica Fetty, (614)-644-2310, Erica.Fetty@epa.state.oh.us or Jennifer Dines at 

(614) 644-3696, Jennifer.Dines@epa.state.oh.us or mailed to Erica Fetty or Jennifer 

Dines at the above address.
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.