John R. Kasich, Governor Mary Taylor, Lt. Governor Scott J. Nally, Director



## FEB 112013

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 Dayton-Springfield 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 Dayton-Springfield area (Clark, Greene, Miami and Montgomery Counties) with respect to the 1997 eight-hour ozone standard. Ohio EPA submitted a redesignation request and maintenance plan for this area on November 6, 2006. U.S. EPA approved this requests August 13, 2007 (72 FR 45169).

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 Miami Valley Regional Planning Commission. The public hearing for this package was held on January 31, 2013 in Dayton, 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 o Suite 700 o P.O. Box 1049 o Columbus, OH 43216-1049 www.epa.ohio.gov • (614) 644·3020 • (614) 644·3184 (fax)

### If you have any questions, please contact Jennifer Dines in the Division of Air Pollution Control at (614) 644-3696.

Sincerely,

G,lly

Director

enclosures

cc: Bob Hodanbosi, DAPC Jennifer Dines, DAPC

# REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR OZONE ATTAINMENT IN THE EIGHT-HOUR OZONE NONATTAINMENT AREA

Dayton-Springfield, OH (Clark, Greene, Miami and Montgomery Counties)



# Prepared By: Ohio Environmental Protection Agency Division of Air Pollution Control

November 2006 Revised March 8, 2007 1 

# Revised February 2013 2

1 Revised – includes Title V point sources with emissions of < 100 tons per year, per U.S. EPA Region 5 request 2 Revised- update mobile emissions budgets using MOVES2010 model

### This page left intentionally blanki 

## TABLE OF CONTENTS

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

Chapter Two Requirements for redesignation ................................................................................................ .... 3

Chapter Three Ozone monitoring .......................................................................................................................... 7 Ambient data quality assured ........................................................................................................ 8 Three complete years of data .................................................................................................. ..... 8 Commitment to continue monitoring ............................................................................................. 9

Chapter Four Emission Inventory ............................................................................................................ .......... 11 Base Year Inventory ........................................................................................................... ........ 11 Emission Projections ................................................................................................................... 12 Demonstration of Maintenance .................................................................................................. . 16 Permanent and Enforceable Emissions Reductions ................................................................... 24 Provisions for Future Updates ................................................................................................. ... 25

Chapter Five Control measures and regulations .............................................................................................. 27 Implementation of Past SIP Revisions ........................................................................................ 2 7 New Source Review Provisions ................................................................................................. 29 Assurance of continued controls ............................................................................................... .. 29

Chapter Six Contingency measures .......................................................................................................... ..... 31 Commitment to revise plan ..................................................................................................... .... 31 Commitment for contingency measures ..................................................................................... 31 Potential contingency measures ................................................................................................ . 32 List of VOC and NO x sources...................................................................................................... 33

Chapter Seven Public participation .......................................................................................................... ............ 35

Chapter Eight Conclusions ................................................................................................................... ............. 36ii FIGURES

Figure 1 Dayton-Springfield, OH Basic Nonattainment Area ............................................... 7

TABLES

Table 1 Monitoring Data for Dayton-Springfield, OH 2004 – 2006 ..................................... 9 Table 2 Combined VOC and NO x Emission Estimations for On-road Mobile Sources .... 15 Table 3 Mobile Vehicle Emission Budgets ....................................................................... 15 Table 4 VOC Emission Inventory Clark County ................................................................ 17 Table 5 VOC Emission Inventory Greene County ............................................................ 18 Table 6 VOC Emission Inventory Miami County .............................................................. 18 Table 7 VOC Emission Inventory Montgomery County .................................................... 19 Table 8 VOC Emission Inventory Dayton-Springfield Total .............................................. 19 Table 9 NO x Emission Inventory Clark County ................................................................. 20 Table 10 NO x Emission Inventory Greene County ............................................................. 20 Table 11 NO x Emission Inventory Miami County ................................................................ 21 Table 12 NO x Emission Inventory Montgomery County ..................................................... 21 Table 13 NO x Emission Inventory Dayton-Springfield Total ............................................... 22 Table 14 Projected emission estimates 2005-2018 Clark County ...................................... 22 Table 15 Projected emission estimates 2005-2018 Greene County .................................. 23 Table 16 Projected emission estimates 2005-2018 Miami County ..................................... 23 Table 17 Projected emission estimates 2005-2018 Montgomery County .......................... 23 Table 18 Projected emission estimates 2005-2018 Combined VOC/NOx Total ................ 24 Table 19 Combined comparison of 2002 and 2005 On-road and EGU Totals ................... 25

APPENDICES

A Air Quality System (AQS) Data B Emission Inventories C Emissions Analysis Method D Public Participation Documentationiii 

### This page left intentionally blank1 

### REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR OZONE ATTAINMENT IN THE EIGHT-HOUR OZONE BASIC NONATTAINMENT AREA

Dayton-Springfield, OH



## 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 ai r 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 nonatta inment areas for t he eight-hour ozone standard, effective June 15, 2004. Since that time, U.S. EPA has reclassified nine of the 134 original nonattainment areas to the next lowe r classification. Se ction 107(d)(3)(E) of the CAA allows states to request nonattainm ent areas be redesignated to attainment providing certain criteria are met. The following ar e 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 a ttained the eight-hour ozone standard. ii) An approved State Implementation Plan (SIP) for the area under Section 110(k). iii) A determination that the improvement in air qua lity is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other f ederal 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-eval uation, the Dayton-Spri ngfield, OH area was designated as Moderate Nonattainment for the one-hour ozone standar d pursuant to the CAA and subsequently approved a redesignation to Attainment/Maintenance in 1995 (60FR22289) May 5, 1995. As a result of the 2004 ozone designations, U.S. EPA designated the Dayton-Springfield, OH area bas ic nonattainment and t herefore subject to the eight-hour ozone requirement s, including development of a plan to reduce volatile organic compounds (VOCs) and oxides of nitrogen (NO x 

### ) emissions and a demonstration that the area will meet the federal eight-hour air quality st andard for ozone by June 2009.2 

### This document is intended to support Ohio’s r equest that the Dayton-Springfield, OH area be redesignated from nonattainment to attainm ent for the eight-hour ozone standard. The Dayton-Springfield, OH area has recorded thr ee (3) years of complete, quality-assured ambient air quality monitoring data for the years 2004 – 2006 dem onstrating attainment of the eight-hour ozone standard.

Geographical Description The Dayton-Springfield, OH area is locat ed in southwest Ohio and includes Clark, Montgomery, Miami and Green count ies. The Dayton-Springfield 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 N AAQS for ozone in this basic nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter four, supports a redesi gnation to attainment for the Dayton-Springfield, 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 gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Directo rs. This request for redesignation and maintenance plan is based on t he 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 DaytonSpringfield, OH area.

1) Attainment of the standard There are two components involved in ma king this demonstration. The first component relies on ambient air quality data. The data that are used to demonstrate attainment should be the pr oduct of ambient monitoring that is representative of the area of highest concentration. The data should be collected and quality-assured in acco rdance with 40 CFR 58 and recorded in the Air Quality System (AQS) in order fo r it to be available to the public for review. The AQS data is provided in Appendix B.

The second component relies upon s upplemental U.S. EPA-approved air quality modeling. This supplemental modeling is not normally required for ozone nonattainment areas seeking redesi gnation. In this case, though, a portion of the observed air quality improvement is due to an automobile inspection/maintenance program (E-Check) . There is currently a request to replace this program wit h equivalent emission reduction, including rules requiring high volume low pressure auto repaint requirements, tighter standards on cold cleaner/ degreasers and either 7.8 Reid vapor pressure (RVP) gasoline or retirement of utility NO x 

### allowances. This package is under review by U.S. EPA.

While no replacement package will hav e the exact air quality benefits, existing air quality performed as part of the Midwest Regional Planning Organization (RPO) indicates that the Dayton area will be well below the eight-hour ozone standard in the Basic nonattainment area demonstration year of 2008. This modeling assumes that the E-Check pr ogram is still the applicable requirement, not the repl acement measures. The maximum predicted 2008 design concentration in t he Dayton region is 79.9 parts per billion (ppb).

In a worst case scenario, should the replacement programs not be approved, modeling has been performed by Ohio Univ ersity on contract to Ohio EPA to evaluate the impact of losi ng the E-Check program in the Dayton-Springfield4 

### area. This report Efficacy of E-Che ck in Selected Counties in the Dayton Ohio Metropolitan Area: Photochemical Grid Model Evaluation, included in Appendix D in the November 6, 2006 s ubmittal demonstrated that the change in air quality associated with the loss of the E-Check program would be less than a 0.08 percent increase in ozone c oncentrations. There is significant safety margin in the current attainm ent modeling for the Dayton-Springfield area. As stated above, the peak 2008 des ign value of 79.9 ppb is over 5 percent below the necessary design concentration of 85 ppb. Chapter three discusses this requirement in mo re detail and provides the attainment demonstration.

2) SIP approval The SIP for the area must be fully approved under Section 110(k) and must satisfy all requirements that apply to t he area. Ohio’s SIP was approved on May 9, 1994 (59FR23799) March 23, 1995 (60FR15235), and May 5, 1995 (60FR22289) and includes the Dayton-Spri ngfield, OH area. Chapter five discusses this requirement in more detail and provides the attainment demonstration.

3) Permanent and enforceable im provement in air quality The state must be able to reasonably a ttribute the improvement in air quality to emission reductions which are pe rmanent and enforceabl e. 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 Dayton-Springfield, OH area wa s designated nonattainment for ozone as part of the 1990 CAA Amendments re-eval uation. As a result, Ohio has adopted or implemented control measures beyond the federal measures, the initial 1979 statewide rules and thos e 1994 and 1995 rules which applied to “rural” attainment areas. Chapter s four and five discuss the control measures and the attainment demonstration in more detail.

4) Section 110 and Part D requirements For purposes of redesignation, a state mu st meet all requir ements of Section 110 and part D that were applicable prio r to submittal of the complete redesignation request.

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

i) Section 172(c) requirements This section contains general r equirements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for5 

### attainment will not apply for redesi gnations because they only have meaning for areas not attaining the standard. The r equirements for an emission inventory will be satisfied by the inventory requirements of the maintenance plan.

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 mu st commit to follow U.S. EPA’s conformity regulation upon issuance, as applicable. Chapter five discusses this requirement in more detail and provides the attainment demonstration.

iii) Modeling As stated in paragraph i) above, while modeling is not specifically required for the redesignation, the ambient demonstration addressing projected air quality without an E-C heck program is necessary to confirm that air quality benefits a ssociated with the E-Check program were not critical to the air quality st atus of this area and that the area can attain and maintain the eight -hour ozone standard without the ECheck program. Appendix E in t he November 6, 2006 submittal contained information and addressed the air quality modeling analyses.

5) 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 pl an will constitute a SIP revision and must provide for maintenance of the rele vant 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 mini mum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.6 

### States seeking redesignat ion of a nonattainment ar ea 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 requirem ent in more detail and provides the attainment demonstration.7 

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

Background : There are five monitors measur ing ozone concentrations in this nonattainment area. A listing of t he four (4) highest readings from 2004 through 2006 is shown in Table 1. Thes e readings were retrieved from the U.S. EPA air quality system (AQS). The locations of the monitoring sites for this nonattainment area are shown on Figure 1.

Demonstration :
Figure 1 Dayton-Springfield, OH area8 

### Requirement 2 of 4 : Ambient monitoring data quality assured in acco rdance 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 all other federal require ments. 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 affect ed downwind environs, is below 85 ppb. This showing must rely on three (3) complete, c onsecutive 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 oz one monitoring data are required to demonstrate attainment at a monitori ng site. The eight-hour primary and secondary ozone ambient air quality st andards are met at an ambient air quality monitoring site when the three- year average of t he annual fourthhighest daily maximum eight-hour aver age 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 ca rried in the computations. Because the third decimal digit, in ppm , is rounded, 0.084 ppm is th e largest concentration that is less than or equal to 0.08 ppm. Therefore, for the purposes of this request, the eight-hour standard is cons idered 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 dat a handling procedures are applied on an individual basis at each monitor in t he 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 concen tration is also called the site's design value. Tabl e 1 shows the monitoring data for 2004 – 2006 and was retrieved from the U.S. EPA AQS. The air quality design value for the area is the highest design val ue among all sites in the area. Please note that the standard is measured in ppm while the commonly used unit is ppb. For the remainder of this document, ppb will be used.9 

### Demonstration :
Table 1 Monitoring Data for Dayton-Springfield, OH 2004 – 2006

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

1 s t 2 n d 3 r d 4 th 2004-2006 AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR 39-023-0001 Clark County Springfield 2004 100 88 84 80 79

80 39-023-0001 Clark County Springfield 2005 99 95 90 87 86 39-023-0001 Clark County Springfield 2006 86 91 81 77 76 39-023-0003 Clark County Mud Run 2004 99 80 79 77 73

76 39-023-0003 Clark County Mud Run 2005 99 96 87 84 81 39-023-0003 Clark County Mud Run 2006 86 87 81 78 74 39-057-0006 Greene County Xenia 2004 100 84 81 75 75

79 39-057-0006 Greene County Xenia 2005 100 90 89 83 83 39-057-0006 Greene County Xenia 2006 86 85 82 81 79 39-109-0005 Miami County Miami 2004 99 80 79 75 75

75 39-109-0005 Miami County Miami 2005 100 85 81 81 79 39-109-0005 Miami County Miami 2006 85 88 76 74 73 39-113-0033 Montgomery Co Webster 2004 98 73 71 68 67

73 39-113-0033 Montgomery Co Webster 2005 100 95 85 82 82 39-113-0033 Montgomery Co Webster 2006 86 84 77 74 71 Highest Average 80 ppb



### A comprehensive list of the site’s des ign 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 both regionally and locally. U.S. EPA’s rule to control nitrogen oxides from specific source categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and refe rred to as the NO x 

### SIP Call) has significantly reduced emissions from large electric generating units (EGUs), industrial boilers, and cement kilns. Ohio's NO x 

### Budget Trading Program Rule was approved on May 25, 2004 Ohio Admini strative Code (OAC) Chapter 3745- 14. It is expected t hat this downward trend will continue as the above programs continue and some form of the U.S. EPA Clean Air Interstate Rule (CAIR) is implemented.

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.10 

### Demonstration : Ohio EPA commits to continue monitori ng ozone levels at the sites indicated in Figure 1. Ohio EPA will consult with U.S. EPA Region 5 prior to making changes to the existing monitori ng network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirem ents of 40 CFR 58 and all other federal requirements. Connection to a centra l station and updates to the Ohio EPA Web site 3 

### will provide real time availabilit y of the data and knowledge of any exceedances. Ohio EPA will enter all data into AQS on a timely basis in accordance with federal guidelines.

3 www.epa.state.oh.us/dapc/11 

## CHAPTER FOUR

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

U.S. EPA’s redesignation guidance requires the s ubmittal of a compr ehensive inventory of ozone precursor emissions (VOC and NO x 

### ) representative of t he year when the area achieves attainment of the oz one air quality standard. Ohio also must demonstrate that the improvement in air qua lity between the year that violat ions occurred and the year that attainment was achieved is based on pe rmanent and enforceable emission reductions. Other emissions inventory related requirem ents include a projection of the emission inventory to a year at least 10 years follo wing redesignation; a dem onstration that the projected level of emi ssions is sufficient to maintain the ozone standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the 10 year maintenance period.

Requirement 1 of 5 : A comprehensive emission inventory of the pr ecursors of ozone completed for the base year.

Background : The point source data are taken fr om 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 Dayton-Springfield, OH area.

As part of the NO x 

### SIP Call, the states were r equired to adopt into their rules a budget for all large EGUs. Ohio’s budget is adopted at OAC Chapter 3745- 14. The budget represent s a statewide cap on NO x 

### emissions. These emissions, capped by the state rule, should remain at least this low through the maintenance period covered by this request.

Periodic inventories, which include emissi ons from all sectors - mobile, area, non-road, and point sources - are prepared every three (3) years.

Demonstration : While ozone and its precursors are transpor ted into this region from outside areas, this information 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 NO x 

### SIP Call. Other sectors of the inventory also impact ozone formati on, but large regional sources such as EGUs have a substantial impact on the formation of ozone.12 

### Requirement 2 of 5 : A projection of the emi ssion inventory to a year at leas t 10 years following redesignation.

Background : Ohio EPA prepared a comprehensive inventory for the Dayton-Springfield, OH area including area, mobile, and point sources for precursors of ozone (VOCs and NO x 

### ) for base year 2002. The information below describes the procedures Ohio EPA used to generate the 2002 base invent ories. These inventories were provided to Lake Michigan Air Directors Consortium (L ADCO) and have been processed to develop summer day emissions for use in the air quality analyses. These processed modeling inventories have been i dentified as the correct iter ation of the inventory for use in the redesignation. In this doc ument, references to LADCO include the Midwest RPO.

• 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 from MOVES2010produced emission factors. Projected em issions beyond December 31, 2005 do not include reductions associat ed with the E-Check program.

• Point source information was compiled from Ohio EPA’s 2002 annual emissions inventory database and the 2002 U.S. EPA Air Markets acid rain database 4



### .

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generated using U.S. EPA’s National Mobile Inventory Model (NMIM) 2002 applicat ion. To address concerns about the accuracy of some of t he categories in U.S. EPA’s non-road emissions model, LADCO contract ed with two (2) companies to review the base data and make recommendations. One of the contractors also estimated emissions for three (3) non-road categories not included in U.S. EPA’s non-road mo del. Emissions were estimated for aircraft, commercial marine ve ssels and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were si gnificantly updated. The populations for the construction equipment cat egory were reviewed and updated based upon surveys completed in the Midwest and the temporal allocation for agricultural sources also was updated.

4 http://www.epa.gov/airmarkets/acidrain13 

### Demonstration :

On-Road Emission Estimations
The Miami Valley Regional Planning Co mmission (MVRPC) and the Clark CountySpringfield Transportation Coordinating Co mmission (CCSTCC), in coordination with the Ohio Department of Transportation (ODOT), utilize regi onal travel demand forecast models to simulate traffic in the area and to forecast traffic flows for given growth expectations. The models are primarily used as a long range planning tool to evaluate the transportation system includi ng determination of locations where additional travel capacity may be needed and to determine the infrastructure requirements necessary to meet that need. They are also used as a tool for air quality purposes to estimate the total emissi ons of pollution caused by vehicles in the area. The travel demand forecasting m odels are used to predict the total daily vehicle miles traveled (VMT) and a U.S. EPA computer progr am called MOVES2010 is used to calculate emissions per mile. The product of thes e is the total amount of pollution emitted by the on-road vehicles fo r the particular analyz ed area. In areas outside the regional travel demand models, traffic counts and statewide traffic growth rates are used for the VMT estimates.

Overview

Broadly described, MOVES2010 is used to generate “emission factors”, which are the average emissions per mile (gra ms/mile) for ozone precursors, NO x 

### and VOC. The MOVES2010 model includes a number of va riables 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 (vehicl es 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 Rest ricted Access, Rural Unrestricted Access, Urban Restricted Access, and Ur ban Unrestricted Access). The vehicle speeds also affect the emissi on factor values. Meteorological conditions such as air temperature and humidity have a significant effect on emission factors. Emission factors produced by MOVES2010 can also in clude the effect of emission reduction strategies such as vehicle inspection and maintenance programs, r egulation of fuels, etc. These MOVES2010 inputs are estima ted using the best available data.

These inputs are reviewed and agreed to by U.S. EPA and transportation agencies in a formal interagency consultation proce ss. Emission factors are multiplied by VMT from both MPO travel dem and models to estimate the total vehicle emissions.

The emission factors from MOVES2010 can be used with the travel demand models information by combining the disaggregat e emission rates with VMT, and source type population for each road type, source type and hour of day, and then sum them14 

### up to get the total emissions for the area. The MVRPC/CCSTCC analysis method, devel oped by ODOT, is to aggregate the emission rates by two source types (car s & trucks), then applying VMT and source type population, thereby reducing the intensive processes. In the first step emission factors are broadly classified into total v ehicles, cars and trucks by pollutant, by average speed, road type and hour of day. Then the hourly link volumes generated from travel demand models are combined with emission factors for each network link for each hour. The on-road vehicle emi ssions 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 wit hin a zone. Intrazonal VMT is combined with corresponding emission factors to get intraz onal 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 pr ocess 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, fu el properties data, source type distribution dat a, 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 mo st current transportation planning data available from MVRPC and CCSTCC and most current ODOT count data were used by ODOT for the emissions estimates.

Analysis Years
Analysis years for this re-designation request include 2002, 2005, 2009, and 2018 to meet the requirements spec ified by the CAA and U.S. EPA. The travel demand models represent the transportation system conditions for each of these years. Model runs for each future analysis year contain the road network MVRPC and CCSTCC expect to exist at the beginni ng of that year with corresponding socioeconomic forecasts for that year.

Local Road VMT

Most local roads such as subdivision street s are not explicitly modeled in a travel demand model. Local road VMT is included by using traffic loaded on zonal centroid15 

### connectors. In addition, some local road tra ffic is captured as intra-zonal trips which travel demand models usually do not assign to roadway segments. ODOT post process includes these trips as local road VMT.

Model area VMT

For the MVRPC, the travel demand model co vers the entire MPO and also the OKI region. VMT for the portion of model which extends beyond Greene, Miami, and Montgomery Counties is removed befor e total emissions are calculated.

Emission Estimations Table 2 contains the results of the em issions analysis for the Dayton-Springfield area (Clark, Greene, Miami and Montgomery counties).

Table 2 - Combined VOC and NO x 

### Emission Estimations for On-Road Mobile Sources for the Dayton-Springfield area

Data source: MVRPC modeling section Data source: Ohio DOT Modeling and Forecasting Section

2002 2005 2009 * 2018 * VMT (miles/day) 22,922,722 23,242,593 23,773,267 25,840,329
VOC (tons/day) 61.81 53.37 43.02 19.44

NOx (tons/day) 96.45 84.66 69.00 28.23

*No I/M program

Motor Vehicle Emission Budget

Table 3 contains the motor vehicle emi ssions budgets for the Dayton-Springfield, OH area.

Table 3 Mobile Vehicle Emissions Budgets for the Dayton-Springfield, OH area

2005 2018 VOC (tons/day) 53.37 22.35 NO x 

### (tons/day) 84.66 32.4716 

### These budgets include the emission estima tes calculated for 2005 and 2018. The 2005 budget does not include a margin of safety while the 2018 budget does include 15 percent margin of safety. The emission estimates are derived from the most recent travel demand model and MOVES2010as described above under the expec ted MVRPC and CCSTCC 2030 Long Range Plans. The 2018 mobile source budget includes 22.35 tons/day for VOC and 32.47 tons/day for NO x 

### . These correspond to a 15 percent safety margin above the 2018 on-road emissions for both VOC and NO x 

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

All methodologies, latest planning assump tions and the safety margins were determined through the interagency cons ultation process described in the Transportation Conformity Memor andum of Understanding (MOU) for MVPRC.

The current one-hour budget will no longer be applicable either after the effective date of the approved redesignati on or after the effective date of any U.S. EPA action approving finding the ei ght-hour conformity budget included in this submittal adequate.

Requirement 3 of 5 : A demonstration that the projec ted 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 redesignati on request. This document contains projected emissions inventories for 2009 and 2018.

Ohio DOT performed emission projecti ons for the Dayton-Springfield, OH area using the following approaches.

• Mobile source emission proj ections 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 futu re controls will have. LADCO has developed growth and control f iles 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 redesignati on are consistent with modeling performed in the future.17 

### The detailed inventory information for the Dayton-Springfield, OH area for 2002, 2005, 2009 and 2018 is in Appendix B. Emission trends are an important gauge for continued comp liance with the ozone standard. Therefore, Ohio EPA performed an initia l comparison of the inventories for the base year and maintenance years. Mobile source emission inventories are described in Appendix B. In additi on to the LADCO estimates, point source emissions were projec ted based upon the statewide EGU NO x 

### budgets from the Ohio NO x 

### rule.

The following tables include sectors Elec trical Generating Unit (EGU-Point), Non-Electrical Generating Unit (Non- EGU), Non-road Mobile (Non-road), Other (Area), Marine, Aircraft, Ra il (MAR), On-road Mobile (On-road).

Demonstration :
Table 4 Clark County VOC Emissi on Inventory Totals for Base Year 2002, Estimated 2005 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, Ohio DOT Modeling and Forecasting Section.



### Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU n/a n/a n/a n/a Point Title V < 100 tpy 0.55 0.50 0.47 0.48 Non-road 1.89 1.63 1.29 1.03 Other (Area) 

### 10.40 11.02 11.84 13.87 MAR 0.05 0.05 0.05 0.05 On-road 9.65 8.42 6.74 3.10 TOTAL 22.54 21.62 20.39 18.53 3.0918 

### Table 5 Greene County VOC Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.



### Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU 0.01 0.01 0.01 0.01 Point Title V < 100 tpy 0.04 0.04 0.04 0.04 Non-road 1.78 1.59 1.35 1.02 Other (Area) 

### 5.98 6.08 6.21 6.64 MAR 0.01 0.01 0.01 0.01 On-road 10.09 8.70 7.06 3.22 TOTAL 17.90 16.42 14.67 10.93 5.49

Table 6 Miami County VOC Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.



### Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a 0.01 0.01 Non-EGU n/a n/a n/a n/a Point Title V < 100 tpy 0.29 0.30 0.33 0.39 Non-road 1.71 1.52 1.28 0.93 Other (Area) 

### 6.34 6.46 6.62 7.29 MAR 0.03 0.03 0.03 0.03 On-road 7.15 6.24 4.96 2.23 TOTAL 15.52 14.55 13.23 10.88 3.6719 

### Table 7 Montgomery County VOC Emi ssion Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.



### Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point 0.09 0.13 0.19 0.20 Non-EGU 1.81 1.77 1.71 1.79 Point Title V < 100 tpy 0.71 0.70 0.71 0.80 Non-road 8.39 7.12 5.42 4.63 Other (Area) 

### 22.35 22.67 23.09 24.95 MAR 0.23 0.21 0.19 0.21 On-road 34.92 30.01 24.26 10.89 TOTAL 68.50 62.61 55.57 43.47 19.14

Table 8 Dayton-Springfield, OH ar ea VOC Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section. Data source: On-road Clark County only, Ohio DOT Modeling and Forecasting Section.



### VOC 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin Clark 22.54 21.62 20.39 18.53 Greene 17.90 16.42 14.67 10.93 Miami 15.52 14.55 13.23 10.88 Montgomery 68.50 62.61 55.57 43.47 COMBINED VOC TOTAL 124.46 115.20 103.86 83.81 31.3920 

### Table 9 Clark County NO x 

### Emission Inventory Totals for Base Year 2002, Estimated 2005 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, Ohio DOT Modeling and Forecasting Section.



### Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU n/a n/a n/a n/a Point Title V < 100 tpy 0.11 0.11 0.11 0.11 Non-road 2.70 2.42 2.04 1.13 Other (Area) 

### 0.70 0.75 0.82 0.88 MAR 0.86 0.74 0.59 0.56 On-road 17.00 14.98 12.09 5.02 TOTAL 21.37 19.00 15.65 7.70 11.30

Table 10 Greene County NO x 

### Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.



### Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU 9.30 8.75 8.02 9.57 Point Title V < 100 tpy 0 0 0 0 Non-road 3.48 3.19 2.81 1.45 Other (Area) 

### 0.67 0.72 0.79 0.85 MAR 0.22 0.18 0.13 0.13 On-road 15.64 13.74 11.36 4.83 TOTAL 29.31 26.58 23.11 16.83 9.7521 

### Table 11 Miami County NO x 

### Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.



### Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a 2.45 2.45 Non-EGU n/a n/a n/a n/a Point Title V < 100 tpy 0.05 0.05 0.05 0.05 Non-road 2.77 2.47 2.07 1.13 Other (Area) 

### 0.53 0.56 0.61 0.65 MAR 0.72 0.60 0.44 0.42 On-road 11.58 10.33 8.29 3.39 TOTAL 15.65 14.01 13.91 8.09 5.92

Table 12 Montgomery County NO x 

### Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.



### Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point 22.70 21.62 20.19 20.30 Non-EGU 3.34 2.87 2.24 2.26 Point Title V < 100 tpy 3.28 3.24 3.18 3.19 Non-road 10.16 8.94 7.31 3.72 Other (Area) 

### 2.43 2.62 2.87 3.07 MAR 2.01 1.70 1.29 1.30 On-road 52.23 45.61 37.26 14.99 TOTAL 96.15 86.60 74.34 48.83 37.7722 

### Table 13 Dayton-Springfield, OH area NO x 

### Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section. Data source: On-road Clark County only, Ohio DOT Modeling and Forecasting Section.



### NO x 

### 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin Clark 21.37 19.00 15.65 7.70 Greene 29.31 26.58 23.11 16.83 Miami 15.65 14.01 13.91 8.09 Montgomery 96.15 86.60 74.34 48.83 COMBINED NO x 

### TOTAL 162.48 146.19 127.01 81.45 64.74

Table 14 Clark County Comparison of 2005 attainment year and 2018 projected emission estimates (tons per summer day)

Data source: Midwest Regional Planning Or ganization (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, Ohio DOT Modeling and Forecasting Section.



### 2005 2018 Projected Change VOC 21.62 18.53 3.09 NO x 

### 19.00 7.70 11.3023 

### Table 15 Greene County Comparison of 2005 attainment year and 2018 projected emission estimates (tons per summer day)

Data source: Midwest Regional Planning Or ganization (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, MVRPC modeling section.



### 2005 2018 Projected Change VOC 16.42 10.93 5.49 NO x 

### 26.58 16.83 9.75

Table 16 Miami County Comparison of 2005 attainment year and 2018 projected emission estimates (tons per summer day)

Data source: Midwest Regional Planning Or ganization (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, MVRPC modeling section.


### 2005 2018 Projected Change VOC 14.55 10.88 3.67 NO x 

### 14.01 8.09 5.92

Table 17 Montgomery County Comparison of 2005 attainment year and 2018 projected emission estimates (tons per summer day)

Data source: Midwest Regional Planning Or ganization (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, MVRPC modeling section.


### 2005 2018 Projected Change VOC 62.61 43.47 19.14 NO x 

### 86.60 48.83 37.7724 

### Table 18 Dayton-Springfield, OH area Comparison of 2005 attainment year and 2018 projected emission estimates (tons per summer day)

Data source: Midwest Regional Planning Or ganization (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, MVRPC modeling section. Data source: On-road Clark County only, Ohio DOT Modeling and Forecasting Section.


### 2005 2018 Projected Decrease VOC 115.20 83.81 31.39 NO x 

### 146.19 81.45 64.74

VOC emissions in the non-attainment area are projected to decrease by 31.39 tons. Area source emissions and point sources show an increase due to expectations that either the populat ion or specific industrial sectors will grow in this area. However, cleaner v ehicles and fuels are expected to be in place in 2009 and 2018 and result in an overall drop in VOC emissions.

NO x 

### emissions in the nonattainment area are projected to decrease by 64.74 tons. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 5 

### , Highway Heavy-Duty Engine Rule 6 

### and Non-Road Diesel Engine Rule 7 

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

### SIP Call across the eastern United States, NO x 

### and ozone levels entering this area also will be decreased.

Requirement 4 of 5 : A demonstration that improvem ent 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 all monitoring sites indicate that air quality met the NAAQS for ozone in 2004. U.S. EPA’s redesignation guidance (p 9) states, “A state may generally demons trate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment invent ory, or by modeling to show that the

5 http://www.epa.gov/fedrgstr/EPA-AIR /2000/February/Day-10/a19a.htm 6 http://www.epa.gov/fedrgstr/EPA-A IR/1997/October/Day-21/a27494.htm 7 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm25 

### future mix of sources and emissions ra tes 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 NO x 

### potential to emit is greater than 2500 tons, in accordance with U.S. EPA’s C onsolidated Emissions Reporting Rule (CERR). Ohio U.S. EPA prepares a new periodic inventory for all ozone precursor emission sectors every thr ee (3) years. These ozone precursor inventories will be prepared for 2005, 2008, and 2011 as necessary to comply with the inventory reporting r equirements established in the CFR. Emissions information will be compared to the 2002 base year and the 2018 projected maintenance year inventor ies to assess emission trends, as necessary, to assure continued compliance with the ozone standard.

Demonstration : Permanent and enforceable reductions of volatile organic compounds and oxides of nitrogen have contributed to t he attainment of t he eight-hour ozone standard. Some of these reductions we re due to the applic ation of tighter federal standards on new vehicles. Al so, Title IV of the CAA and the NO x 

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

Table 19 Dayton-Springfield, OH area Combined Comparison of 2002 base year and 2005 attainment year on-road and EGU reductions

Data source: Midwest Regional Planning Or ganization (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, MVRPC modeling section. Data source: On-road Clark County only, Ohio DOT Modeling and Forecasting Section.



### 2002 2005 On-road VOC 61.81 53.37 On-road NO x 

### 96.45 84.66 EGU NO x 

### 22.70 21.62

Requirement 5 of 5 : Provisions for future annual updates of the in ventory to enable tracking of the emission levels including an annual emission st atement from major sources.26 

### Demonstration : As required by Section 175A(b) of the C AA, 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.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: A U.S. EPA approved SIP control strategy that includes Reasonably Available Control Technology (RACT) requirements for existi ng 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 NO x 

### 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 easte rn United States. Ohio passed this rule in 2001. Beginning in 2004, this rule account s for a reduction of approximately 31 percent of all NO x 

### emissions state-wide compar ed to previous uncontrolled years. The other 21 states also have adopted these rules.

The Dayton-Springfield area also implem ented rules as part of the 15 percent rate of progress demonstration. These measures included the E-Check program, Stage II vapor recovery, enforcem ent cases, archit ectural coatings (National rule) and removal of the 100 ton per year cut-off for RACT requirements in the rural portion of t he nonattainment area (including Stage I). 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 implement ation of the NO x 

### SIP Call. Controls for EGUs formally commenced May 31, 2004. Emissions28 

### covered by this program have been gener ally 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 NO x 

### reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x 

### SIP Call Rule. Ohio developed the NO x 

### Budget Trading Program rules in OAC Chapter 3745-14 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 r eduction of NOx emissions from EGUs and a 60 percent reduction of NO x 

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

U.S. EPA has recently pub lished Phase II of the NO x 

### SIP Call that establishes a budget for large (great er than 1 ton per day emissions) stationary internal combustion engines . Ohio EPA’s proposed rule OAC 3745-14-12 addresses stationar y internal combustion engines, all used in natural gas pipeline transmissions. An 82 percent NO x 

### reduction from 1995 levels is anticipated. Completion of the compliance plan is expected by May 1, 2006 and the compliance demonstrat ion will begin May 1, 2007. The 2007 controlled NO x 

### emissions will be 599 tons per day.

The requirements under the 15 percent rate of progress revisions and subsequent one-hour maintenance plan are still being implemented with the exception of the E-Check program. Th is requirement is being transferred to the one-hour contingency portion of the redesignation maintenance plan and is the subject of a separate submittal and rulemaking.

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, in cluding sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NO x 

### emission reductions will be 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 emissi on 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 issu ed a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur di esel 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 NO x29 

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

### inventory. Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industrie s 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. N on-road diesel equipment, as described in this rule, currently accounts for 47 per cent of diesel particulate matter (PM) and 25 percent of NO x 

### from mobile sources nation wide. Sulfur levels will be reduced in non-road diesel fuel by 99 percent from current levels, from approximately 3,000 parts per million ( ppm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starting in 2008. Together, these rules will substantially reduce local and regional sources of ozone precursors.

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

Background : Ohio has a long standing and fully impl emented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-31. T he chapter includes provisions for the Prevention of Signi ficant 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 lis ted in the 2002 emission invent ory, or for the closing of which credit was taken in demonstrat ing attainment, will not be allowed to construct, reopen, modify, or recons truct without meeting all applicable permit rule requirement. The review pr ocess will be identical to that used for new sources. Once the area is r edesignated, 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 af orementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicabl e to VOC and/or NO x 

### sources, as required for30 

### maintenance of the ozone standard in t he Dayton-Springfield, OH area will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal secti on, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it int ends to continue enforcing all rules that relate to the emission of ozone precur sors in the Dayton-Springfield, OH

area.
LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment

LADCO performed modeling to ev aluate the effect of the NO x 

### SIP Call and Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This modeling was originally designed to asse ss the one-hour ozone st andard. 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 thr ee (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; June 13-25, 1995; and July 7-18, 1995.

Modeling was completed for the Dayton-Spri ngfield, OH area. In addition, Ohio University completed a project entitled “Efficacy of E-Check in Dayton.” The modeling and the project are included in Appendix C.

LADCO Modeling for CAIR of 2004

On March 10, 2004, the U.S. EPA promulgated the CAIR. NO x 

### emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 eastern states and the District of Columbia.

LADCO performed modeling to support t he associated emission reductions for CAIR. This modeling was based on 2001 – 2002 design values for the DaytonSpringfield, OH area. Results of t he CAIR modeling show that the DaytonSpringfield, OH area will continue to attain the eight-hour ozone NAAQS well into the future.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 im plement additional contingency control measures in response to exceeding specified pr edetermined levels (triggers) or in the event that future violations of the ambient standards occur.

Demonstration : Ohio hereby commits to adopt and ex peditiously 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 va lue of 88 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 i ndicates 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, t he control measures necessary to reverse the trend taking in to consideration ease and timing for implementation as well as econom ic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expediti ously 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 warn ing 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.32 

### Action Level Response

An action level response shall be prom pted whenever a two (2) year average fourth high monitored value of 85 ppb o ccurs within the maintenance area. In the event that the action level is triggered and is not due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA will determine addi tional control measures needed to assure future attainment of NAAQS fo r ozone. In this case, measures that can be implemented in a short time will be selected in order to be in place within eighteen (18) mont hs from the close of the ozone season that prompted the action level.

Control Measure Sele ction and Implementation

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

If a new measure/control is al ready promulgated and scheduled to be implemented at the federal or state level, and t hat measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnec essary. Furthermore, Ohio will submit to U.S. EPA an analysis to dem onstrate the proposed measures are adequate to return the area to attainment.

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

Demonstration : Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appr opriate and effective at the time the selection is made. The select ion 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 cont ingency measures. Because it is not possible at this time to determine w hat control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive.

1) Lower Reid vapor pressure gasoline program.

2) Tighten RACT on existing source s covered by U.S. EPA Control Technique Guidelines issued in response to the 1990 CAA.33 

### 3) Apply RACT to smaller existing sources.

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

5) Controls on consumer products consistent with those adopted elsewhere in the United States.

6) Require VOC or NO x 

### emission offsets for new and modified major

sources.
7) Require VOC or NO x 

### emission offsets for new and modified minor

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

9) Require VOC or NO x 

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

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

Requirement 4 of 4: A list of VOC and NO x 

### sources potentially subject to future controls.

Demonstration : The following is a list of VOC and NO x 

### sources potentially subject to future controls.

NO x 

### RACT

• EGUs

• asphalt batching plants

• industrial/commercial and institutional boilers

• process heaters

• internal combustion engines

• combustion turbines

• other sources greater than 100 tons per year34 

### VOC RACT

• consumer products

• architectural and industrial maintenance coatings

• stage I gasoline dispensing facilities (including pressure valves)

• automobile refinishing shops

• cold cleaner degreasers

• portable fuel containers

• 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 year35 

## CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hear ing and solicitation for public comment concerning the draft redesignation petition and maintenance plan.

The public hearing to receive comments on t he redesignation request was held on January 31, 2013, at the Ohio EPA Sout hwest District Office located at 401 East Fifth Street, Dayton, Ohio. The public comment period cl osed on January 31, 2013. No comments were received. A copy of the public notice and the tran script from the public hearing is included in Appendix D.36 

## CHAPTER EIGHT

CONCLUSIONS

The Dayton-Springfield, OH basic nonattainm ent 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 ar eas. Documentation to that effect is contained herein. Ohio EPA has prepared a state implement ation and maintenance plan that meets the requirement of Sect ion 110 (a)(1) of the 1990 CAA.

Ohio has performed an analysis that shows the air quality impr ovements are due to permanent and enforceable measures. In addition, significant regional NO x 

### reductions will ensure continued compliance (maintenance) with the standard an d that all CAA requirements necessary for redesignation have been met.

Based on this presentation, the Dayton-Springfield, OH ozone basic nonattainment area meets the requirements fo r redesignation under the CAA and U.S. EPA guidance. Furthermore, because this area is subject to si gnificant transport of po llutants, significant regional NO x 

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

The State of Ohio hereby requests that the Dayton-Springfield, OH ozone basic nonattainment area be redesignated to attain ment simultaneously wit h U.S. EPA approval of the Ohio state implement ation and maintenance plan provis ions contained herein. In addition, the State of Ohio r equests that this maintenance pl an satisfy the requirements of CAA Section 175A (b), for subsequent plan re visions required for areas redesignated for the one-hour ozone standard, as was the case with the Dayton-Springfield, OH nonattainment area.

### This page left intentionally blank

### Synopsis of Changes Revised Dayton-Springfield Maintenance Plan under the 1997 Ozone Standard

The original redesignation request and maintenance plan document was submitted to U.S. EPA on November 6, 2006. U.S. EPA appr oved this requests on August 13, 2007 (72 FR 45169).

Ohio EPA is now requesting a revision to the maintenanc e 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 an d 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 ma de to conform to current terminology, grammar, and formatting conventions.

In addition to this document, additional ch anges were also made to the Appendices of the original submitta l, 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 2009. Both the original and revised documents are available on Ohio EPA’s website under the “Appendix” link.

• Appendix D: this appendix contains documents relevant to the public comment period and the public hearing. This cont ains 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 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.”

# REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR OZONE ATTAINMENT IN THE EIGHT-HOUR OZONE BASIC NONATTAINMENT AREA

Dayton-Springfield, OH (Clark, Greene, Miami a nd Montgomery Counties)



## Prepared By: Ohio Environmental Protection Agency Division of Air Pollution Control

November 2006 Revised – includes Title V point sources with emissions of < 100 tons per year, per U.S. EPA Region 5 request Formatted: Level 1

Formatted: Font color: Auto

## March 8, 2007 1

1 Revised – includes Title V point sources with emissions of < 100 tons per year, per U.S. EPA Region 5 request

## Revised February 2013 2

2 Revised- update mobile emissions budgets using MOVES2010 modelThis page left in tentionally blanki 

### TABLE OF CONTENTS

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

Chapter Two Requirements for redesignation ................................................................................................ .... 3

Chapter Three Ozone monitoring .......................................................................................................................... 7 Ambient data quality assured ........................................................................................................ 8 Three complete years of data ..........................

........................................................................ ..... 8 Commitment to continue monitoring ............................................................................................. 9

Chapter Four Emission Inventory ...................................................................................................................... 11 Base Year Inventory ........................................................................................................... ........ 11 Emission Projections ................................................................................................................... 12 Demonstration of Maintenance .................................................................................................. . 16 Permanent and Enforceable Emissions Reductions ................................................................... 24 Provisions for Future Updates .........................

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

Chapter Five Control measures and regulation s .............................................................................................. 27 Implementation of Past SIP Revisions ........................................................................................ 2 7 New Source Review Provisions ................................................................................................. 29 Assurance of continued controls ............................................................................................... .. 29

Chapter Six Contingency measures .......................................................................................................... ..... 31 Commitment to revise plan ..................................................................................................... .... 31 Commitment for contingency measures ..................................................................................... 31 Potential contingency measures ................................................................................................ . 32 List of VOC and NO x sources...................................................................................................... 33

Chapter Seven Public participation .......................................................................................................... ............ 35

Chapter Eight Conclusions ...................................................................................................................

......... 3536ii FIGURES

Figure 1 Dayton-Springfield, OH Basic Nonattainment Area ............................................... 7

TABLES

Table 1 Monitoring Data for Dayton-Springfie ld, OH 2004 – 2006 ..................................... 9 Table 2 Combined VOC and NO x Emission Estimations for On-road Mobile Sources .... 15 Table 3 Mobile Vehicle Emission Budgets ....................................................................... 15 Table 4 VOC Emission Inventory Clark County ................................................................ 17 Table 5 VOC Emission Inventory Greene County ............................................................ 18 Table 6 VOC Emission Inventory Miami County .............................................................. 18 Table 7 VOC Emission Inventory Montgomery County .................................................... 19 Table 8 VOC Emission Inventory Dayton-Springfield Total .............................................. 19 Table 9 NO x Emission Inventory Clark County ................................................................. 20 Table 10 NO x Emission Inventory Greene County ............................................................. 20 Table 11 NO x Emission Inventory Miami County ................................................................ 21 Table 12 NO x Emission Inventory Montgomery County ..................................................... 21 Table 13 NO x Emission Inventory Dayton-Springfield Total ............................................... 22 Table 14 Projected emission estimates 2005-2018 Clark County ...................................... 22 Table 15 Projected emission estimates 2005-201 8 Greene County .................................. 23 Table 16 Projected emission estimates 2005-2018 Miami County ..................................... 23 Table 17 Projected emission estimates 2005-201 8 Montgomery County .......................... 23 Table 18 Projected emission estimates 2005-201 8 Combined VOC/NOx Total ................ 24 Table 19 Combined comparison of 2002 and 200 5 On-road and EGU Totals ................... 25

APPENDICES

A Air Quality System (AQS) Data B Emission Inventories C Emissions Analysis Method D Ohio University Report (E-Check) E Modeled Attainment Demonstration FD Public Participation Documentationiii This page left intentionally blank1 REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR OZONE ATTAINMENT IN THE EIGHT-HOUR OZONE BASIC NONATTAINMENT AREA

Dayton-Springfield, OH



### CHAPTER ONE

Introduction The Clean Air Act (CAA) requir es 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 ai r 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, effective June 15, 20 04. 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 ar e 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 a ttained the eight-hour ozone standard. ii) An approved State Implementation Pl an (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 Dayton-Springfield, OH area was designated as Moderate Nonattainment for the one-hour ozone standard pursuant to the CAA and subsequently approved a redesignation to Attainment/Maintenance in 1995 (60FR22289) May 5, 1995. As a result of the 2004 ozone designations, U.S. EPA designated the Dayton-Springfield, OH area basic nonattainment and therefore subject to the eight-hour ozone requirements, including development of a plan to reduce volatile organic compounds (VOCs) and oxides of nitrogen (NO x ) emissions and a demonstration that the area will meet the federal eight-hour air quality standard for ozone by June 2009.2 This document is intended to support Ohio’s request that the Dayton-Springfield, OH area be redesignated from nonattainment to attain ment for the eight-hour ozone standard. The Dayton-Springfield, 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 eight-hour ozone standard.

Geographical Description The Dayton-Springfield, OH area is locate d in southwest Ohio and includes Clark, Montgomery, Miami and Green counties. The Dayton-Springfield 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 the Dayton-Springfield, 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 gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Direct ors. This request for redesignation and maintenance plan is based on the redesignation guidance, supplemented with additional guidance received from st aff of U.S. EPA Region V.

Below is a summary of each redesignation criterion as it applies to the DaytonSpringfield, OH area.

1) 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 Formatted: Font: Times New Roman

Formatted: Left, Indent: First line: 0", No widow/orphan control, Page break before, Tab stops: Not at 0" + 0.5" + 1" + 1.5" + 2" + 2.5" + 3" + 3.5" + 4" + 4.5" + 5" + 5.5" + 6"4 the Air Quality System (AQS) in order for it to be available to the public for review. The AQS data is provided in Appendix B.

The second component relies upon supplemental U.S. EPA-approved air quality modeling. This supplemental modeling is not normally required for ozone nonattainment areas seeking redesignation. In this case, though, a portion of the observed air quality improvement is due to an automobile inspection/maintenance program (E-Check) . There is currently a request to replace this program with equivalent emission reduction, including rules requiring high volume low pressure auto repaint requirements, tighter standards on cold cleaner/degreasers and either 7.8 Reid vapor pressure (RVP) gasoline or retirement of utility NO x allowances. This package is under review by U.S. EPA.

While no replacement package will have the exac t air quality benefits, existing air quality performed as part of the Midwest Regional Planning Organization (RPO) indicates that th e Dayton area will be well below the eight-hour ozone standard in the Basic nonattainment area demonstration year of 2008. This modeling assume s that the E-Check program is still the applicable requirement, not the replacement measures. The maximum predicted 2008 design concentration in the Dayton region is 79.9 parts per billion (ppb).

In a worst case scenario, should th e replacement programs not be approved, modeling has been performed by Ohio Un iversity on contract to Ohio EPA to evaluate the impact of losing the E-Check program in the Dayton-Springfield area. This report Efficacy of E-Check in Selected Counties in the Dayton Ohio Metropolitan Area: Photochemical Grid Model Evaluation, included in Appendix D , demonstrates in the November 6, 2006 submittal demonstrated that the change in air quality associated with the loss of the E-Check program would be less than a 0.08 percent increase in ozone concentrations. Thereis significant safety margin in the current attainment modeling for the DaytonSpringfield area. As stated above, the peak 2008 design value of 79.9 ppb is over 5 percent below the necessary design concentration of 85 ppb. Chapter three discusses this requirement in more detail and provides the attainment demonstration.

2) 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 May 5, 1995 (60FR22289) and includes the Dayton-S pringfield, OH area. Chapter five discusses this requirement in more detail and provides the attainment demonstration.5 3) 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 Dayton-Springfield, OH area was designated 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 initial 1979 statewide rules and those 1994 and 1995 rules which applied to “rural” attainment areas. Chapters four and five discuss the control measures and the attainment demonstration in more detail.

4) 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 redesi gnations 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.

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. Chapter five discusses this requirement in more detail and provides the attainment demonstration.

iii) Modeling As stated in paragraph i) above, while modeling is not specifically required for the redesignation, the ambient demonstration addressing6 projected air quality without an E-Check program is necessary to confirm that air quality benefits associated with the E-Check program were not critical to the air quality status of this area and that the areacan attain and maintain the eight-hour ozone standard without the ECheck program. Appendix E containsin the November 6, 2006 submittal contained information and addressesaddressed the air quality modeling analyses.

5) 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 w ill implement all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a no nattainment 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.78 

### 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, has been attained. Ozone monitoring data must show th at violations of the ambient standard are no longer occurring.

Background : There are five monitors measuring ozone concentrations in this nonattainment area. A listing of the four (4) highest readings from 2004 through 2006 is shown in Table 1. These readings were retrieved from the U.S. EPA air quality system (AQS). The locations of the monitoring sites for this nonattainment area are shown on Figure 1.

Demonstration :
Figure 1 Dayton-Springfield, OH area Formatted: Page break before9 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) databa se, 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 all other federal requirements. 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, is below 85 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-45 4/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 airquality 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 co nsidered 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 2004 – 2006 and was retrieved from the U.S. EPA AQS. The air quality design value for the area is the highest design value among all sites in the area. Please note that the standard is measured in ppm while the commonly used unit is ppb. For the remainder of this document, ppb will be used.10 Demonstration :
Table 1 Monitoring Data for Dayton-Springfield, OH 2004 – 2006

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

1 s t 2 n d 3 r d 4 th 2004-2006 AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR 39-023-0001 Clark County Springfield 2004 100 88 84 80 79 80 39-023-0001 Clark County Springfield 2005 99 95 90 87 86 39-023-0001 Cla r k County Springfield 2006 86 91 81 77 76 39-023-0003 Clark County Mud Run 2004 99 80 79 77 73 76 39-023-0003 Clark County Mud Run 2005 99 96 87 84 81 39-023-0003 Clark County Mud Run 2006 86 87 81 78 74 39-057-0006 Greene County Xenia 2004 100 84 81 75 75 79 39-057-0006 Greene County Xenia 2005 100 90 89 83 83 39-057-0006 Greene County Xenia 2006 86 85 82 81 79 39-109-0005 Miami County Miami 2004 99 80 79 75 75 75 39-109-0005 Miami County Miami 2005 100 85 81 81 79 39-109-0005 Miami County Miami 2006 85 88 76 74 73 39-113-0033 Montgomery Co Webster 2004 98 73 71 68 67 73 39-113-0033 Montgomery Co Webster 2005 100 95 85 82 82 39-113-0033 Montgomery Co Webster 2006 86 84 77 74 71 Highest Average 80 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 both regionally and locally. U.S. EPA’s ru le to control nitrogen oxides from specific source categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the NO x SIP Call) has significantly reduced emissions from large electric generating units (EGUs), industrial boilers, and cement kilns. Ohio's NO x Budget Trading Program Rule was approved on May 25, 2004 Ohio Administrative Code (OAC) Chapter 3745- 14. It is expected that this down ward trend will continue as the above programs continue and some form of the U.S. EPA Clean Air Interstate Rule (CAIR) is implemented.

Requirement 4 of 4 : A commitment that once redesignated, the st ate will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status. Formatted Table

Formatted: Font: Bold, Underline

Formatted: Indent: Left: 0.5", Keep with next, Tab stops: Not at 0" + 0.5"11 Demonstration : Ohio EPA commits to continue monitoring ozone levels at the sites indicated in Figure 1. Ohio EPA will consult wi th U.S. EPA Region 5 prior to making changes to the existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. Connection to a central station and updates to the Ohio EPA Web site 3 will provide real time availability of the data and knowledge of any exceedances. Ohio EPA will enter all da ta into AQS on a timely basis in accordance with fe deral guidelines.

3 www.epa.state.oh.us/dapc/ Formatted: Keep with next12 

### 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 NO x ) representative of the year when the area achieves attainment of the ozone air quality st andard. Ohio also must demonstrate that the improvement in air quality between the year th at 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 Formatted: Font: 14 pt, Bold

Formatted: Page break before, 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", Left13 to provide future updates of the inventory to enable tracking of emission levels during the 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 Dayton-Springfield, OH area.

As part of the NO x SIP Call, the states were required to adopt into their rules a budget for all large EGUs. Ohio’s budget is adopted at OAC Chapter 3745- 14. The budget represents a statewide cap on NO x emissions. These emissions, capped by the state rule, should remain at least this low through the maintenance period covered by this request.

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, this information 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 NO x SIP Call. Other sectors of the inventory also impact ozone formation, but large regional sources such as EGUs have a substantial impact on the formation of ozone.

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

Background : Ohio EPA prepared a compre hensive inventory for the Dayton-Springfield, OH area including area, mobile, and point sources for precursors of ozone (VOCs and NO x ) for base year 2002. The information below describes the procedures Ohio EPA used to generate the 2002 base inventories. These inventories were provided to 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 RPO.14 • 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 from MOBILE6.2 producedMOVES2010produced emission factors. Projected emissions beyond December 31, 2005 do not include reductions associated with the E-Check program.

• Point source information was comp iled from Ohio EPA’ s 2002 annual emissions inventory database an d the 2002 U.S. EPA Air Markets acid rain database 4

.

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generated us ing U.S. EPA’s National Mobile Inventory Model (NMIM) 2002 application. To address concerns about the accuracy of some of the categories in U.S. EPA’s non-road emissions model, LADCO contracted with two (2) companies to review the base data and make recommendations. One of the contractors also estimated emissions for three (3) non-road categories not included in U.S. EPA’s non-road model. Emissions were estimated for aircraft, commercial marine vessels and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment category were reviewed and updated based upon surveys completed in the Midwest and the temporal allocation for agricultural sources also was updated.

Demonstration :

On-Road Emission Estimations
The Miami Valley Regional Planning Commission (MVRPC) and the Clark CountySpringfield Transportation Coordinating Comm ission (CCSTCC), in coordination with the Ohio Department of Transportation ( Ohio DOTODOT ), utilize regional travel demand forecast models to simulate traffic in the area and to forecast traffic flows for given growth expectations. The models are primarily used as a long range

4 http://www.epa.gov/airmarkets/acidrain Formatted: Left, Right: 0", No widow/orphan control

Formatted: Left, Indent: Left: 0", Space After: 10 pt, Line spacing: Multiple 1.15 li

Formatted: Space After: 10 pt, Line spacing: Multiple 1.15 li

Formatted: Right: 0"15 planning tool to evaluate the transportation system including determination of locations where additional travel capaci ty may be needed and to determine the infrastructure requirements necessary to meet that need. They are 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 models are used to predict the total daily vehicle miles traveled (VMT) and a 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 area s outside the regional travel demand modelmodels

, 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, NO x 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 vehicl e 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 ( MOBILE6.2 facilit yMOVES2010 road types are Freeway, Arterial, LocalRural Restricted Access, Rural Unrestri cted Access, Urban Restricted Access, and Ramp) and theUrban Unrestricted Access). The vehicle speeds also affect the emission factor valu es. Meteorological co nditions such as air temperature and humidity hashave a significant affecteffect 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 MOBILE6.2MOVES2010 inputs are estimated using the best available data.

These inputs are reviewed an d agreed to by U.S. EPA an d transportation agencies in a formal interagency consultation process. Emission factors are multiplied by VMT from theboth MPO travel demand modelmodels 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 th e total VMT of the analyzed area to getthe 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 Formatted: Space After: 10 pt, Line spacing: Multiple 1.15 li

Formatted: Right: 0"

Formatted: Right: 0"16 extensive processing, but the resulting total emissions of this method are 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 vehicl e fleet on that facility. Then, the travel model provides information on each segment of road (or “link”) regarding traffic volumes and facility ty pe 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 em ission factor is multiplied by the link’s traffic-volume and length or VMT to get the emissions from that link for that hour. There are other methods as well, each with its advantages and disadvantages. The Dayton-Springfield, OH area analysis uses the latter more complex method, a table of emission factors.

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

Some of the assumptions built into MOBILE6.2 are: older vehicles have much higher emission factors than newer vehicles, diesel vehicles have much higher NO x emission factors and lower VOC emission factors than gasoline vehicles, and higher average speeds have lower emission factors except for diesel vehicles which have higher NO x at higher speeds. MOBILE6.2 The emission factors from MOVES2010 can be used with the travel demand models 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 MVRPC/CCSTCC 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 models 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 intraz onal emissions. Total emissions are sum of on-road vehicle emissions, vehicle-based emissions a nd 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 Formatted: Right: 0"17 network formats and MOVES2010 generated emission factors. MOVES2010 input and output files are provided in Appendix C.

Best Available Data

Most current vehicle age distri bution 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 MVRPC and CCSTCC was used for the emissions estimates. Details about each data set and how it was used is documented in the “MVRPC document titled, “ Technical Memorandum MVRPC/Clark County-Springfield TCC SIP Inventory Mobile Emissions Estimate (8-Hour Ozone) ” dated October 2006and most current ODOT count data were used by ODOT for the emissions estimates

.

Analysis Years
Analysis years for this re-designation r equest include 2002, 2005 , 2009, and 2018 to meet the requirements specified by th e CAA and U.S. EPA. The travel demand model presentsmodels represent the transportation system conditions for each of these years. Model runs for each future analysis year contai n the road network MVRPC and CCSTCC expect 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. Local road VMT is included by using traffic loaded on zonal 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. Ohio DOTODOT post process includes these trips as local road VMT.

Model area VMT

For the MVRPC, the travel demand model covers the entire MPO and also the OKI region. VMT for the portion of model which extends beyond Greene, Miami, and Montgomery Counties is removed before total emissions are calculated.

Emission Estimations Table 2 contains the results of the emissi ons analysis for the Dayton-Springfield area (Clark, Greene, Miami and Montgomery counties). Please note the Formatted: Space After: 10 pt, Line spacing: Multiple 1.15 li

Formatted: No underline

Formatted: Heading 2, Right: 0", Space After: 10 pt, Line spacing: Multiple 1.15 li Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: No underline

Formatted: Space After: 10 pt, Line spacing: Multiple 1.15 li

Formatted: Right: 0"

Formatted: Space After: 10 pt, Line spacing: Multiple 1.15 li

Formatted: Normal, Indent: Left: 0"18 analysis includes a scenario for 2005 showing results without an Inspection/Maintenance (I/M) program.

Table 2 - Combined VOC and NO x Emission Estimations for On-Road Mobile Sources for the Dayton-Springfield area

Data source: MVRPC modeling section Data source: Ohio DOT Modeling and Forecasting Section

2002 2005 2005

* 2009 * 2018 *

VMT (miles/day) 22, 924 ,68892 2,722 23, 244,6082 42,593 23, 2 44,6 0877 3,26

7 23,7 75,2 44 25, 272,178 840,329

VOC (tons/ day) 38.5 8 29.1 9 31.3 4 22.7 6 1261

. 81 53.37 43.02 19.44

NOx (tons/day) 7896 .4 5 63.8884.66 65.4469.00 46. 992 8.2 3 18.6 2

*No I/M program

Motor Vehicle Emission Budget

Table 3 contains the motor vehicle emissions budgets for the Dayton-Springfield, OH area.

Table 3 Mobile Vehicle Emissions Budgets for the Dayton-Springfield, OH area

2005 2018 VOC (tons/day) 29.1953.37 14.7322.35 NO x (tons/day) 63.8884.66 21.4232.47

These budgets include the emission estimates calculated for 2005 and 2018. The 2005 budget does not include a margin of safety while the 2018 budget does include 15 percent margin of safety. The emission estimates are derived from the most recent travel demand model and MOBILE6.2 Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black

Formatted: Font color: Black

Formatted Table Formatted: Font color: Black

Formatted: Font: Not Bold

Formatted: Heading 2

Formatted: Justified, Right: 0.5", Tab stops: 6", Left19 asMOVES2010as described above under the expected MVRPC and CCSTCC 2030 Long Range Plans. The 2018 mobile source budget includes 14.7322.35 tons/day for VOC and 21.4232.47 tons/day for NO x . These correspond to a 15 percent safety margin above the 2018 on-road emissions for both VOC and NO x . Appendix C contains data tables and graphs of these emissions.

The 2005 budget which w ill be used for conformity purposes assumes the ECheck program was in place in 2005. While this is not only an accurate representation of 2005, it also provides a more conservative target to be met for future conformity determinations.

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 MVPRC.

The current one-hour budget will no lo nger be applicable either after the effective date of the approved redesignation or after the effective date of any U.S. EPA action approving finding the eight-hour conformity budget included in this submittal adequate.

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.

Ohio DOT performed emission projecti ons for the Dayton-Springfield, OH area using the following approaches.

• Mobile source emission projec tions are based on the U.S. EPA MOBILE6.2MOVES2010 model. The analysis is described in more detail in Appendix C. All projecti ons were made in accordance with “Procedures for Preparing Emission s Projections” U.S. EPA-45/4-91- 019.

• Emissions inventories are required to be projected to future dates to assess the influence growth and fu ture controls w ill have. LADCO has developed growth and control files for point, area, and non-road categories. These files were used to develop the future year emissions estimates used in this document. This was done so the Formatted: Font: Bold, Underline

Formatted: Indent: Left: 0.5", Tab stops: Not at 0"20 inventories used for redesignation are consistent with modeling performed in the future.

The detailed inventory information for the Dayton-Springfield, OH area for 2002, 2005, 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 initia l comparison of the inventories for the base year and maintenance years. 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 NO x budgets from the Ohio NO x rule.

The following tables include sectors Elec trical Generating Unit (EGU-Point), Non-Electrical Generating Unit (Non -EGU), Non-road Mo bile (Non-road), Other (Area), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road).

Demonstration :
Table 4 Clark County VOC Emission Inventory Totals for Base Year 2002, Estimated 2005 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, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU n/a n/a n/a n/a Point Title V < 100 tpy 0.55 0.50 0.47 0.48

Non-road 1.89 1.63 1.29 1.03 Othe r (Area) 10.40 11.02 11.84 13.87 MAR 0.05 0.05 0.05 0.05 On-road 6.629.65 4.988.42 4.056.74 2.403.10 TOTAL 19.5122.54 18.1821.62 17.7020.39 17.8318.53 0.353.09 Formatted Table21 Table 5 Greene County VOC Emission Inventory Totals for Base Year 2002, Estimated 2005 and Pr ojected 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, MVRPC modeling section.

Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU 0.01 0.01 0.01 0.01 Point Title V < 100 tpy 0.04 0.04 0.04 0.04

Non-road 1.78 1.59 1.35 1.02 Othe r (Area) 5.98 6.08 6.21 6.64 MAR 0.01 0.01 0.01 0.01 On-road 6.2210.09 4.748.70 3.777.06 2.153.22 TOTAL 14.0417.90 12.4716.42 11.3914.67 9.8710.93 2.605.49

Table 6 Miami County VOC Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.

Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a 0.01 0.01 Non-EGU n/a n/a n/a n/a Point Title V < 100 tpy 0.29 0.30 0.33 0.39

Non-road 1.71 1.52 1.28 0.93 Othe r (Area) 6.34 6.46 6.62 7.29 MAR 0.03 0.03 0.03 0.03 On-road 4.957.15 3.816.24 2.784.96 1.632.23 TOTAL 13.3215.52 12.1214.55 11.0513.23 10. 2888 1.843.67 Formatted: Page break before

Formatted Table

Formatted Table

Formatted: Font color: Black2223 Table 7 Montgomery County VOC Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.

Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point 0.09 0.13 0.19 0.20 Non-EGU 1.81 1.77 1.71 1.79 Point Title V < 100 tpy 0.71 0.70 0.71 0.80

Non-road 8.39 7.12 5.42 4.63 Othe r (Area) 22.35 22.67 23.09 24.95 MAR 0.23 0.21 0.19 0.21 On-road 20.8034.92 15.6630.01 12.1624.26 6.6410.89 TOTAL 54.3868.50 48.2662.61 43.4755.57 43.4739.22 9.0419.14

Table 8 Dayton-Springfield, OH area VOC Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section. Data source: On-road Clark County only, Ohio DOT Modeling and Forecasting Section.

VOC 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin Clark 19.512 2.54 21.6218.18 17.702 0.39 17.8318.53

Greene 14.041 7.90 12.4716.42 11.391 4.67 9.8710.93

Miami 13.321 5.52 12.1214.55 11.051 3.23 10. 2888

Montgomery 54.386 8.50 48.2662.61 55.57 4 3.47 39.2243.47

COMBINED VOC TOTAL 101.25 124.46 91.03115.20 83.611 03.86 77.283.81 13.833 1.39 Formatted: Page break before

Formatted Table

Formatted: Font: Bold, Font color: Black

Formatted Table

Formatted: Font color: Black

Formatted: Font: Bold, Font color: Black2425 Table 9 Clark County NO x Emission Inventory Totals for Base Year 2002, Estimated 2005 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, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU n/a n/a n/a n/a Point Title V < 100 tpy 0.11 0.11 0.11 0.11

Non-road 2.70 2.42 2.04 1.13 Othe r (Area) 0.70 0.75 0.82 0.88 MAR 0.86 0.74 0.59 0.56 On-road 14.5417.00 11.8214.98 9.0312.09 3.765.02 TOTAL 18.9121.37 15.8419.00 12.5915.65 6.447.70 9.411.30

Table 10 Greene County NO x Emission Inventory Totals for Base Year 2002, Estimated 2005 and Proj ected 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, MVRPC modeling section.

Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU 9.30 8.75 8.02 9.57 Point Title V < 100 tpy 0 0 0 0

Non-road 3.48 3.19 2.81 1.45 Other (Area) 0.67 0.72 0.79 0.85 MAR 0.22 0.18 0.13 0.13 On-road 12.2615.64 10.0413.74 7.4511.36 3.004.83 TOTAL 25.9329.31 22.8826.58 19.2023.11 15.0016.83 7.889.75 Formatted: Page break before

Formatted Table

Formatted Table26 Table 11 Miami County NO x Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.

Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a 2.45 2.45 Non-EGU n/a n/a n/a n/a Point Title V < 100 tpy 0.05 0.05 0.05 0.05

Non-road 2.77 2.47 2.07 1.13 Other (Area) 0.53 0.56 0.61 0.65 MAR 0.72 0.60 0.44 0.42 On-road 9.8811.58 8.1710.33 5.878.29 23 .39 TOTAL 13.9515.65 11.8514.01 11.4913.91 78 .09 4.765.92

Table 12 Montgomery County NO x Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section.

Sector 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point 22.70 21.62 20.19 20.30 Non-EGU 3.34 2.87 2.24 2.26 Point Title V < 100 tpy 3.28 3.24 3.18 3.19

Non-road 10.16 8.94 7.31 3.72 Othe r (Area) 2.43 2.62 2.87 3.07 MAR 2.01 1.70 1.29 1.30 On-road 41.7752.23 33.8545.61 24.6437.26 9.4714.99 TOTAL 85.6996.15 74.8486.60 61.7274.34 43.3148.83 31.5337.77 Formatted: Page break before

Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted Table2728 Table 13 Dayton-Springfield, OH area NO x Emission Inventory Totals for Base Year 2002, Estimated 2005 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, MVRPC modeling section. Data source: On-road Clark County only, Ohio DOT Modeling and Forecasting Section.

NO x 2002 Base 2005 Attainment 2009 Interim 2018 Maintenance Safety Margin Clark 18.912 1.37 15.8419.00 12.591 5.65 6.447.70

Greene 25.932 9.31 22.8826.58 19.223. 11 1516.83

Miami 13.951 5.65 11.8514.01 11.491 3.91 78 .09

Montgomery 85.699 6.15 74.8086.60 61.727 4.34 43.3248.83

COMBINED NO x TOTAL 14416 2 .48 125.37146. 19 105127 .01 71.8581.45 53.526 4.74

Table 14 Clark County Comparison of 2005 attainment year and 2018 projected emission estimates (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, Ohio DOT Modeling and Forecasting Section.

2005 2018 Projected Change V OC 18.2521.62 17.4518.53 0.803.09 NO x 15.8319.00 6.357.70 9.4811.30 Formatted: Page break before

Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted Table2930 Table 15 Greene County Comparison of 2005 attainment year and 2018 projected emission estimates (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, MVRPC modeling section.

2005 2018 Projected Change VOC 12.4716.42 9.8710.93 2.605.49 NO x 22.8826.58 15.0016.83 7.889.75

Table 16 Miami County Comparison of 2005 attainment year and 2018 projected emission estimates (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, MVRPC modeling section.

2005 2018 Projected Change V OC 12.1214.55 10. 2888 1.843.67 NO x 11.8514.01 78 .09 4.765.92

Table 17 Montgomery County Comparison of 2005 attainment year and 2018 projected emission esti mates (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, MVRPC modeling section.

2005 2018 Projected Change V OC 48.2762.61 39.2243.47 9.0519.14 NO x 74.8486.60 43.3148.83 31.5337.77 Formatted: Page break before

Formatted Table

Formatted Table

Formatted: Font color: Black

Formatted: Font color: Black

Formatted Table31 Table 18 Dayton-Springfield, OH area Comparison of 2005 attainment year and 2018 projected emission estimates (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, MVRPC modeling section. Data source: On-road Clark County only, Ohio DOT Modeling and Forecasting Section.

2005 2018 Projected Decrease VOC 91.11115.20 76.8283.81 14.2931.39 NO x 125.40146.19 71.7581.45 53.6564.74

VOC emissions in the non-attainment area are projected to decrease by 14.2931.39 tons. Area source emissions and point sources show an increase due to expectations that either the population or specific industrial sectors will grow in this area. Howe ver, cleaner vehicles and fuels are expected to be in place in 2009 and 2018 and result in an overall drop in VOC emissions.

NO x emissions in the nonattainment ar ea are projected to decrease by 53.6564.74 tons. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 5

, Highway Heavy-Duty Engine Rule 6 and Non-Road Diesel Engine Rule 7 also are factored into the changes. Further, due to implementation of the NO x SIP Call across the eastern United States, NO x and ozone levels entering this area also will be decreased.

Requirement 4 of 5 : A demonstration that improvement in air quality between the year violations occurred and attainment was achieved is based on perm anent and enforceable em ission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background : Ambient air quality data from all monitoring sites indicate that air quality met the NAAQS for ozone in 2004. U.S. EPA’s redesignation guidance (p 9) states, “A state may generally demonstrate maintenance of the NAAQS by

5 http://www.epa.gov/fedrgstr/EPA-A IR/2000/February/Day-10/a19a.htm 6 http://www.epa.gov/fedrgstr/EPA-A IR/1997/October/Day-21/a27494.htm 7 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm Formatted: Page break before

Formatted Table32 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 ra tes 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 NO x potential to emit is greater than 2500 tons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio U.S. 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.

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 NO x SIP Call required the reduction of oxides of nitrogen from utility sources.

Table 19 Dayton-Springfield, OH area Combined Comparison of 2002 base year and 2005 attain ment year on-road and EGU reductions

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, MVRPC modeling section. Data source: On-road Clark County only, Ohio DOT Modeling and Forecasting Section.

2002 2005 2005 No I/M On-road VOC 38.5861.81 29.1953.37 31.34 On-road NO x 7896 .45 63.8884.66 65.44 EGU NO x 22.70 21.62 21.62

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. Formatted Table

Formatted: Font color: Black33 Demonstration : As required by Section 175A(b) of the CAA, Ohio commits to submit to the Administrator, eight (8) ye ars 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: Font color: Black

Formatted: Normal, None, Tab stops: Not at 6" + 6.5"34 

### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS CAA Section107 d)(3)(E)(ii), 10 7(d)(3)(iv) & 107(d)(3)(E)(v)

Requirement 1 of 4: A U.S. EPA approved SIP control strategy th at includes Reasonab ly Available Control Technology (RACT) requirements for existing stationary sources covered by Control Technology Guidelines (CTG) as ap plied 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 NO x 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 accounts for a reduction of approximately 31 percent of all NO x emissions state-wide compared to previous uncontrolled years. The other 21 states also have adopted these rules.

The Dayton-Springfield area also implem ented rules as part of the 15 percent rate of progress demonstration. These measures included the E-Check program, Stage II vapor recovery, enforcement cases, architectural coatings (National rule) and removal of the 100 ton per year cut-off for RACT requirements in the rural portion of the nonattainment area (including Stage I). 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 modelin g that indicated this area would attain the eight-hour ozone standard with the implementation of the NO x SIP Call. Controls for EGUs formally commenced May 31, 2004. Emissions35 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 NO x reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 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 NO x emissions from non-EGUs, compared to historical levels. This c ap will stay in plac e through 2008, at which time the CAIR program will supersede it.

U.S. EPA has recently pub lished Phase II of the NO x SIP Call that establishes a budget for large (great er than 1 ton per day emissions) stationary internal comb ustion engines. Ohio EPA’s proposed rule OAC 3745-14-12 addresses stationary internal combustion engines, all used in natural gas pipeline transmissions. An 82 percent NO x reduction from 1995 levels is anticipated. Completion of the compliance plan is expected by May 1, 2006 and the complianc e demonstration will begi n May 1, 2007. The 2007 controlled NO x emissions will be 599 tons per day.

The requirements under the 15 perc ent rate of progress revisions and subsequent one-hour maintenance plan are still being implemented with the exception of the E-Check program. This requirement is being transferred to the one-hour contingency portion of the redesignation maintenance plan and is the subject of a separate submittal and rulemaking.

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, in cluding sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make clea ner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NO x emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. 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 NO x36 from diesel trucks and buses, a large sector of the mobile sources NO x inventory. Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Ai r Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleane r fuel standard similar to the highway diesel program. The new standards w ill cut emissions from non-road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this rule, currently accounts for 47 per cent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwi de. Sulfur levels will be reduced in non-road diesel fuel by 99 percent from current levels, from approximately 3,000 parts per million (p pm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starting in 2008. Together, these rules will su bstantially 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, 200 1 (66 FR 51570) and received final approval on January 22, 20 03 (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 demonstrat ing 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 redesign ated, 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 applicab le to VOC and/or NO x sources, as required for37 maintenance of the ozone standard in the Dayton-Springfield, OH area will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal sect ion, 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 Dayton-Springfield, OH

area.
LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment

LADCO performed modeling to evaluate the effect of the NO x SIP Call and Tier II / Low Sulfur rule for future year 2007 ozone in the Lake 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; June 13-25, 1995; and July 7-18, 1995.

Modeling was completed for the Dayton-Springfield, OH area. In addition, Ohio University completed a project entitled “Efficacy of E-Check in Dayton.” The modeling and the project are included in Appendix C.

LADCO Modeling for CAIR of 2004

On March 10, 2004, the U.S. EPA promulgated the CAIR. NO x emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 eastern states and the District of Columbia.

LADCO performed modeling to support the associated emission reductions forCAIR. This modeling was based on 2001 – 2002 design values for the DaytonSpringfield, OH area. Results of the CAIR modeling show that the DaytonSpringfield, OH area will continue to attain the eight-hour ozone NAAQS well into the future.38 

### 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 im plement 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 88 ppb occurs in a single ozone season within the maintenance area. A wa rning level respon se 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 expe ditiously as possible, but in no event later than 12 months from the conclusion of the most recent ozone season (September 30). Formatted: Left, Page break before39 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 (2) year average fourth high monitored value of 85 ppb occurs within the maintenance area. In the event that the action level is triggered and is not due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA 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 eighteen (18) months from the close of the ozone season that prompted the action level.

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 unne cessary. Furthermore, Ohio will submit to U.S. EPA an analysis to de monstrate 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 cons idered 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 Formatted: Don't keep with next

Formatted: Keep with next40 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.

1) Lower Reid vapor pressure gasoline program.

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

3) Apply RACT to smaller existing sources.

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

5) Controls on consumer products consistent with those adopted elsewhere in the United States.

6) Require VOC or NO x emission offsets for new and modified major

sources.
7) Require VOC or NO x emission offsets for new and modified minor

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

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

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

Requirement 4 of 4: A list of VOC and NO x sources potentially subject to future controls.

Demonstration : The following is a list of VOC and NO x sources potentially subject to future controls.

NO x RACT

• EGUs41 • asphalt batching plants

• industrial/commercial an d 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 (inc luding pressure valves)

• automobile refinishing shops

• cold cleaner degreasers

• portable fuel containers

• 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 year42 

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification fo r a public hearing and solicitation for public comment concerning the draft redesignation petition and maintenance plan in the widely distributed county publications on October 31, 2006

. The public hearing to receive comments on the redesignation request will bewas held on December 5, 2006January 31, 2013 , at the Ohio EPA

, Southwest District Office located at 401 E.East Fifth Street in, Dayton, Ohio. The public comment period will close on December 6, 2006. Commentsclosed on January 31, 2013. No comments were received during the public comment period will be includ ed with the final package. Appendix F will include a. A copy of the public notice , certifications of publication, and the transcript from the public hearing is included in Appendix D

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

Formatted: Indent: Left: 0", Page break before, Tab stops: 0", Left + 0.5", Left + 6.5", Left43 

### CHAPTER EIGHT

CONCLUSIONS

The Dayton-Springfield, OH basic nonattainme nt 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 implem entation 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 NO x reductions will ensure continued compliance (maintenance) with the standard and that all CAA requirements necessary for redesignation have been met.

Based on this presentation, the Dayton-Spr ingfield, OH 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 NO x reductions will ensure continued comp liance (maintenance) with the standards with an increasing margin of safety.

The State of Ohio hereby requests that the Dayton-Springfield, OH ozone basic nonattainment area be redesign ated to attainment simultane ously 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 Dayton-Springfield, OH nonattainment area. Formatted: Page break beforeThis page left in tentionally blank Formatted: Page break before

## Technical Memorandum MVRPC/Clark County-Springf ield TCC SIP Inventory Mobile Emissions Estimate (OZONE)

March 2012 (Revised November 2012)

By MVRPC and Ohio Department of Transportation

In Coordination with Clark County-Sprin gfield TCC and the Ohio Environmental Protection Agency

## Table of Contents

1. Overview 2. Urban Travel Demand Modeling 3. Emission Factor Generation 4. Post Processing 5. Multiple MPO Cooordination Issues

Appendix A Interagency Consultation Documentation

Appendix B B.1 Post Processing Default Distributions B.2 Ozone Emission Summaries

## 1. Overview

This memorandum is intended to document the air quality analyses and underlying assumptions performed by the Ohio Department of Trans portation (ODOT), Divisi on of Transportation System Development-Modeling and Forecasti ng Section and the Miami Valley Regional Planning Commission (MVRPC) fo r the 8-hour ozone on-road mobile source emission inventories for the Dayton-Springfield Region (D/S Region) State Implementation Plan (SIP) revision in coordination with the Ohio Environmental Protection Agency (OEPA).

The D/S Region is comprised of the counties of Clark, Greene, Miami, and Montogomery in west-central Ohio. All four counties are designated non-attainment for the 8-hour Ozone Standard. Clark County Springf ield Transportation Coordinati ng Committee (CCS-TCC) serves as the Metropolitan Planning Or ganization (MPO) for Clark Count y while MVRPC serves as the MPO for the remainder counties: Gr eene, Miami, and Montgomery.

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 Clark County. Using ODOT generated emission factors, MVRPC completed the air quality analyses for Greene, Miami, and Montgomery Counties.

Latest Planning Assumptions

The ozone inventory runs meet the latest plan ning assumption requirement. As discussed in Section 2 of this report, the modeling process us ed to develop each MPO emissions is calibrated using the latest population and land use data av ailable and is validated using corresponding traffic count data. Currently, the travel dema nd models are validated to year 2000 (CCS-TCC) or year 2005 (MVRPC) depending on available data.

U.S. EPA’s most recent emissions software, MOVES, is used for all mobile source emission analyses with MOVES inputs being established at various interagency consultation meetings between August 2011 and February 2012 (See Appendix A)

Finally, the regional emissions analysis incl udes emissions for Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOX).

### On Road Mobile Emission Summary

Tables 1 to 5 present a summary of emissions by county as well as the entire D/S Region for the required precursors VOC and NOX for the reque sted scenarios: 2002 base, 2005 attainment, 2009 interim, and 2018 maintenance. Years 2005 and 2018 are established as budget years. Year 2040 emissions are provided for comparison with the horizon year of the Long Range Transportation Plan. The remainder of the document focuses on the assumptions behind the analyses.

Table 1 – Dayton/Springield Region On-Road Mobile Emissions
2002 Base COUNTY VOC (tons/day) NOX (tons/day)
Clark 9.6498 16.9997
Greene 10.0855 15.6383
Miami 7.1497 11.5819 Montgomery 34.9158 52.2251
TOTAL 61.8008 96.4450

Table 2 – Dayton/Springield Region On-Road Mobile Emissions
2005 Attainment COUNTY VOC (tons/day) NOX (tons/day)
Clark 8.4192 14.9811
Greene 8.6954 13.7348
Miami 6.2373 10.3292 Montgomery 30.0133 45.6078
TOTAL 53.3652 84.6529

Table 3 – Dayton/Springield Region On-Road Mobile Emissions
2009 Maintenance COUNTY VOC (tons/day) NOX (tons/day)
Clark 6.7448 12.0907
Greene 7.0589 11.3633
Miami 4.9588 8.2858 Montgomery 24.2552 37.2558
TOTAL 43.0177 68.9956

### Table 4 – Dayton/Springield Region On-Road Mobile Emissions
2018 Maintenance COUNTY VOC (tons/day) NOX (tons/day)
Clark 3.0953 5.0193
Greene 3.2205 4.8311
Miami 2.2310 3.3930 Montgomery 10.8916 14.9918
TOTAL 19.4384 28.2352

Table 5 – Dayton/Springield Region On-Road Mobile Emissions
2040 Plan Horizon Year COUNTY VOC (tons/day) NOX (tons/day)
Clark 2.0201 2.5457
Greene 1.9947 2.3905
Miami 1.3849 1.6994 Montgomery 6.6242 7.1104
TOTAL 12.0239 13.7460

## 2. Urban Travel Demand Models

CCS-TCC and MVRPC maintain regional travel de mand forecasting models for use in the urban transportation planning process. The models em ploy the traditional four step modeling process to project existing and future traffic volumes a nd travel patterns on the regional transportation network. The four step process consists of tr ip generation, trip distribution, modal split, and route assignment. Output from the urban models is link-by- link directional 24-hour traffic volumes.

During 2000-2002 MVRPC, in cooperation with the Ohio Kentucky Indiana Regional Council of Governments, updated its travel demand model. The new model includes the combined regions under the jurisdictions of OKI and MVRPC. In 2005, the combined model was updated again to incorporate the results of a household interview survey in the MVRPC Region, change the model interface to Cube Voyager, and improve model f unctionality. The changes primarily affected trip generation distribution functions in the MVRPC Region. In 2007 in preparation for the 2008 Transportation Plan Update the model was valida ted using circa 2005 traffic counts counts and in 2011 in preparation for the 2012 Plan Update the socioeconomic data was updated with 2010 census information and extended to the 2040 horiz on year. The 2005 Cube Voyager model with the latest planning assumptions (networks and socio-economic data) is used to calculate 2002- 2018-2040 emissions in the MVRPC Region. MVRPC inventory emission analyses directory structure can be seen in Figure 1.

Figure 1 – MVRPC Emission Anal yses Runs Directory Structure

### Similarly, the Springfield Region also has a new travel demand model that combined with the latest planning assumptions was used to generate emissions in Clark County. The new travel demand model now covers all of Clark County and was validated in December 2005, more information is available at http://www.dot.state.oh.us /urban/data/to_docs/Spri ngfield_model_userguide.doc . Figure 2 shows the directory structure or model run location. Due to the number of files and complexity, travel demand model run details have not b een included in this technical memo.

Figure 2 – CCS-TCC Travel Demand Mo del Run Directory Structure

Networks

Both CCS-TCC and MVRPC’s modele d networks accurately reflect projects in their respective TIPs and Long Range Transportation Plans. Proj ect lists can be found on line as listed below:

CCS-TCC http://www.clarktcc.com/LRP/2040%20L RP/DRAFT%202012%20LRP%20Project%20 List%20093011.pdf

MVRPC http://www.mvrpc.org/sites/default/files/ 2012%20Draft%20Project%20Inventory%20Lis t.pdf

### Landuse and Socio-economic Data

Both CCS-TCC and MVRPC’s socio-economic model variables reflect the current and expected future regional land uses.

MVRPC’s socio-economic variables were developed for the May 2012 2040 LRTP Update and are based on 2000/2010 Census variables and 2040 county-level Ohio Department of Development population projections with the exception of Green e County. In Greene County, the 2040 ODOD population projection was lower than the 2010 Census population count, MVRPC proposed an alternative projection that was accepted for use in the Transportation Plan by the interagency consultati on partners (see Appendix A fo r interagency consultation documentation).

On the employment side, adjustments were ma de primarily to account for manufacturing job loses between 2000 and 2010, recognizing that th e local economy is moving away from a manufacturing base and to account fo r known planned development efforts.

Independent variables are available for 4 analysis years (2000, 2005, 2010, and 2040) and the travel demand model has the ability of interpolating data for a ny year between available data sets. A summary of MVRPC’s socio-economic data is available in Table 6. As can be seen from the Table, population, households, and employment are expected to make modest gains between 2010 and 2040. Both households and employment ar e expected to decline in the older urban areas of the region as the trend to develop in the suburban frin ges and rural areas continues.

Table 6 – MVRPC Socio-Economic Variables

Variable Area Type
CBD Urban Suburban Rural Total
# of TAZs 65 209 413 130 817 Acres 880 30,675 297,967 495,879 825,401 2005 Population 805,816 2005 Households 1,838 88,631 209,117 26,351 325,937 2005 Employment 27,942 95,363 304,111 14,574 441,990 2010 Census Population - - - - 799,232
2010 Households 2,151 77,584 220,039 27,856 327,630 2010 Employment 28,042 94,306 303,504 15,541 441,393 2040 ODOD Population - - - - 820,227
2040 Households 2,280 70,336 229,678 32,550 334,844 2040 Employment 29,653 87,835 329,415 16,730 463,633 2005 Persons per Household 1.30 2.33 2.41 2.66 2.40 2005 Workers per Household 0.61 1.11 1.27 1.41 1.22 2005 Autos per Household 0.63 1.42 1.82 2.26 1.74 Note: Includes Greene, Miami, and Montgomery Counties.

### CCS-TCC's socio-economic variables were de veloped for the 2040 LRTP based on the 2000 Census variables, 2000 employment from QC EW, and 2030 population projections from the Ohio Department of Development. Projecti ons were updated and extended to 2040 for the 2012 Plan based on 2010 census results and known empl oyment changes including: school enrollment, hotels, educational and recreati onal employment, and area type. Independent variables (land use/socio-economic data) as provided by CCS-TCC ar e available for every analysis year. These variables are used by ODOT to generate new tr ip tables for the anal ysis years: 2002, 2005, 2009, 2018, and 2040.

Table 7 shows a summary of CCS-TCC’s socio-ec onomic data. This summary shows a slight decline in population, while households a nd employment show a moderate gain.

Table 7 – CCS-TCC Socio-Economic Variables Area Type (2000)
CBD Urban Suburban Rural Total # of TAZs 9 67 104 123 303 2000 Population 2,893 23,046 64,021 54,912 144,872 2000 Households 1,143 8,587 25,840 21,127 56,697 2000 Employment 4,204 15,511 27,104 18,037 64,856 Area Type (2010)
CBD Urban Suburban Rural Total # of TAZs 9 67 106 121 303 2010 Population 3,195 20,765 61,638 56,013 141,611 2010 Households 1,282 8,406 25,915 22,038 57,641 2010 Employment 2,641 11,662 27,842 14,140 56,285 Area Type (2040) CBD Urban Suburban Rural Total # of TAZs 9 67 106 121 303 2040 Population 3,212 20,580 61,841 58,940 144,573 2040 Households 1,327 9,349 27,961 24,220 62,857 2040 Employment 2,816 13,172 29,058 17,203 62,249

### VMT Trends

Figure 3 shows Vehicle Miles Traveled (VMT) tr ends for each of the analysis years 2002- 2018- 2040 for the MVRPC (Greene and Montgomery Coun ties) and CCS-TCC (Clark County) Areas. These values represent un-factored travel dema nd model output. For ozone runs, model VMT is factored to represent an average su mmer day using a seasonal factor of 1.08. Table 8 shows VMT for every analyzed year by County.

Figure 3 – Dayton/Springfie ld Region VMT Trends

Table 8 – Dayton/Springfield Region VMT

COUNTY 2002 2005 2009 2018 2040 Clark 4,077,939 4,125,028 4,361,567 4,886,265 5,717,303 Greene 3,699,424 3,772,608 3,885,992 4,505,806 5,592,691 Miami 2,781,320 2,853,082 2,928,990 3,241,290 4,096,994 Montgomery 12,364,039 12,491,875 12,596,718 13,206,968 14,932,076 TOTAL 22,922,722 23,242,593 23,773,267 25,840,329 30,339,064

## 3. Emission Factor Generation

Base and Attainment Years

Using MOVES, emission factor files were gene rated for base year-2002 and attainment year2005 to represent the programs being impl emented in the D/S Region. Programs and corresponding MOVES parameters were develope d in consultation with OEPA. The emission factors for Montgomery and Greene Counties include an I/M program.

Future Years

Emission factors were also generated for two fu ture year scenarios: 2009 and 2018. Future year scenarios assume no I/M since the program was terminated in 2005 but assume 7.8 rvp gasoline during since the SIP Ozone Maintenance Plan includes a commitment to implement 7.8 RVP fuel in the Dayton/Springfield area during the months of June through September 15, beginning in 2008. All other assumptions remain the same as those used to gene rate 2002 emission factors and are further illustrated in this section using year 2002 as an example.

Technical Details

Table 9 summarizes the settings used in th e MOVES run specification file and the MOVES County-Data Manager. Further de tails in specific i nputs that are not using default values are provided below.

Table 9 – 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 Clark, Greene, Mi ami, and Montgomery 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, NO x 

### , NO, NO 2, 

### Total Energy Consumption Strategies Default values w ith 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 Combinatio n 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 I/M program inform ation applied for 2002/2005 where applicable for all counties except Miami (Miami Co. is never had an I/M program) Fuel Formulation Default Fuel Supply Reformulated gas ( 7.8 RVP) for summer analyses Metereology Data Local data obtained fr om 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 tr avel demand model for VHT fractions. Future fractions will be assumed constant Road Type Distribution Use ODOT count y 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

### Temperature and Relative Humidity

Temperatures used for the single season appro ach are representative of July 2002 based on NOAA data from the National Climate Data Center webiste. Data for Wright Patterson AFB was used because it was the most complete comp ared to other airports in the non-attainment area. To get the correct fomat for MOVES, the data was entered into a spreadsheet provided by EPA which was designed to convert Mobile6 da ta to MOVES. The average July hourly temperature and relative humidity distri bution profile can be seen in Table 10.

Table 10 – Temperature and Relative Humidity Data

Hour Average Temperature Average Relative Humidity 1 71.3367 78 2 70.0883 78 3 69.1075 80 4 68.3942 81 5 67.8592 83 6 67.2350 85 7 66.7000 81 8 67.1458 76 9 69.8208 69 10 74.1008 63 11 78.4700 58 12 82.2150 54 13 85.5142 50 14 87.2975 48 15 87.9217 47 16 88.1000 46 17 87.6542 47 18 86.4058 50 19 84.2658 54 20 81.5017 60 21 78.7375 66 22 76.3300 70 23 74.6358 71 24 72.9417 76



### Ramp Fraction

Ramp fractions were derived using the base ye ar travel demand model VHT fractions. Ramp fractions can be seen in Table 11. Base year fractions were assu med to apply to future years.

Table 11 – Ramp Fractions roadTypeID roadDesc rampFraction
2 Rural Restricted Access 0.04
4 Urban Restricted Access 0.11

### 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. Future year gr owth rate is based on MPO model household growth rate which is 0% in MVRPC. In 

### Clark County cars are an inde pendent variable to the travel demand model. The base year (2000) and the LP year (2040) are used to interpolate the number of cars for the needed analysis years in Clark County. Table 12 shows source type population for the analyzed counties in 2005.

Similar to VMT, the vehicle population is adjust ed from average number of vehicles to the number of vehicles in a summer day. In the absence of data, a 1.08 f actor, as agreed via interagency consultation and the same as for VMT is used. (Appendix A)

Table 12 – Source Type Population for year 2005 sourceTypeID sourceTypeName Clark Greene Miami Montgomery 11 MotorCycle 8,341 9,014 7,967 25,096 21 Passenger Car 96,93 2 105,808 71,041 395,925 31 Passenger Truck 44,885 53,557 37,861 172,425 32 Light Commercial Truck 1,129 1,235 698 4,614 41 Intercity Bus 71 52 47 178 42 Transit Bus 17 14 7 66
43 School Bus 256 356 245 1,187
51 Refuse truck 44 36 28 138 52 Single Unit Short-haul Truck 68 46 26 119 53 Single Unit Long-haul Truck 133 124 238 169
54 Motor Home 214 172 136 665
61 Comb Short-haul Truck 877 478 443 1,789 62 Comb Long-haul Truck 1,009 550 510 2,058



### I/M Program

I/M program information was applied to 2002/2 005 input files based on an ASM 2525, biennial I/M program, for gasoline-pow ered passenger cars and trucks and light commercial trucks, assuming a 98 percent compliance rate. The I/M program was turned “off” for analyses years after 2005 and emission factor in Miami County.

Vehicle Age Distribution

Vehicle age distribution inform ation was derived using Ohio Bureau of Motor Vehicle registration data for year 2010. The data was gi ven to OEPA who supplied a VIN decoder that allowed ODOT to create correctly formatted MOVE S inputs. MOVES default data is used for

### source types 41, 51, 54, 61, and 62. The registrati on data for all three counties in the nonattainment area were combined to create a regional ve hicle age distribution file, see Table 13. The same age distribution will be used for all analysis years

Table 13 – Vehicle Age Distribution yearid sourcetypeid ageid ageFraction sourcetypeid ageid ageFraction sourcetypeid ageid ageFraction

2005 11 0 0.0018 21 17 0.0364 32 3 0.0708
2005 11 1 0.0214 21 18 0.0330 32 4 0.0678
2005 11 2 0.0551 21 19 0.0256 32 5 0.0341
2005 11 3 0.0702 21 20 0.0211 32 6 0.0268
2005 11 4 0.0831 21 21 0.0174 32 7 0.0330
2005 11 5 0.0782 21 22 0.0133 32 8 0.0332
2005 11 6 0.0617 21 23 0.0098 32 9 0.0367
2005 11 7 0.0775 21 24 0.0087 32 10 0.0497
2005 11 8 0.0569 21 25 0.0067 32 11 0.0525
2005 11 9 0.0506 21 26 0.0051 32 12 0.0406
2005 11 10 0.0429 21 27 0.0026 32 13 0.0411
2005 11 11 0.0328 21 28 0.0016 32 14 0.0348
2005 11 12 0.0241 21 29 0.0015 32 15 0.0745
2005 11 13 0.0205 21 30 0.0444 32 16 0.0526
2005 11 14 0.0215 31 0 0.0062 32 17 0.0408
2005 11 15 0.0164 31 1 0.0255 32 18 0.0354
2005 11 16 0.0136 31 2 0.0463 32 19 0.0267
2005 11 17 0.0124 31 3 0.0558 32 20 0.0215
2005 11 18 0.0089 31 4 0.0650 32 21 0.0245
2005 11 19 0.0082 31 5 0.0782 32 22 0.0156
2005 11 20 0.0079 31 6 0.0722 32 23 0.0135
2005 11 21 0.0086 31 7 0.0708 32 24 0.0102
2005 11 22 0.0091 31 8 0.0674 32 25 0.0107
2005 11 23 0.0125 31 9 0.0545 32 26 0.0066
2005 11 24 0.0186 31 10 0.0579 32 27 0.0039
2005 11 25 0.0172 31 11 0.0569 32 28 0.0014
2005 11 26 0.0147 31 12 0.0507 32 29 0.0007
2005 11 27 0.0169 31 13 0.0452 32 30 0.0094
2005 11 28 0.0249 31 14 0.0407 41 0 0.0000
2005 11 29 0.0168 31 15 0.0424 41 1 0.0282
2005 11 30 0.0950 31 16 0.0350 41 2 0.0466
2005 21 0 0.0063 31 17 0.0298 41 3 0.0791
2005 21 1 0.0237 31 18 0.0215 41 4 0.0819
2005 21 2 0.0347 31 19 0.0166 41 5 0.0819
2005 21 3 0.0428 31 20 0.0123 41 6 0.0636
2005 21 4 0.0439 31 21 0.0114 41 7 0.0734yearid sourcetypeid ageid ageFraction sourcetypeid ageid ageFraction sourcetypeid ageid ageFraction
2005 21 5 0.0478 31 22 0.0096 41 8 0.0381
2005 21 6 0.0504 31 23 0.0072 41 9 0.0678
2005 21 7 0.0527 31 24 0.0057 41 10 0.0664
2005 21 8 0.0548 31 25 0.0038 41 11 0.0438
2005 21 9 0.0523 31 26 0.0026 41 12 0.0297
2005 21 10 0.0571 31 27 0.0016 41 13 0.0226
2005 21 11 0.0570 31 28 0.0006 41 14 0.0212
2005 21 12 0.0519 31 29 0.0004 41 15 0.0480
2005 21 13 0.0518 31 30 0.0062 41 16 0.0367
2005 21 14 0.0489 32 0 0.0063 41 17 0.0155
2005 21 15 0.0535 32 1 0.0418 41 18 0.0071
2005 21 16 0.0432 32 2 0.0828 41 19 0.0353
2005 41 20 0.0226 43 6 0.0595 51 23 0.0086
2005 41 21 0.0056 43 7 0.0584 51 24 0.0086
2005 41 22 0.0056 43 8 0.0623 51 25 0.0000
2005 41 23 0.0071 43 9 0.0639 51 26 0.0086
2005 41 24 0.0085 43 10 0.0611 51 27 0.0043
2005 41 25 0.0155 43 11 0.0823 51 28 0.0000
2005 41 26 0.0127 43 12 0.0656 51 29 0.0000
2005 41 27 0.0014 43 13 0.0506 51 30 0.0385
2005 41 28 0.0056 43 14 0.0183 52 0 0.0043
2005 41 29 0.0042 43 15 0.0222 52 1 0.0343
2005 41 30 0.0243 43 16 0.0183 52 2 0.0343
2005 42 0 0.0103 43 17 0.0167 52 3 0.1159
2005 42 1 0.0000 43 18 0.0178 52 4 0.0730
2005 42 2 0.0515 43 19 0.0178 52 5 0.0472
2005 42 3 0.0412 43 20 0.0167 52 6 0.0472
2005 42 4 0.0309 43 21 0.0156 52 7 0.0815
2005 42 5 0.0928 43 22 0.0117 52 8 0.1373
2005 42 6 0.0309 43 23 0.0133 52 9 0.0429
2005 42 7 0.0412 43 24 0.0117 52 10 0.0386
2005 42 8 0.0412 43 25 0.0078 52 11 0.0472
2005 42 9 0.1237 43 26 0.0044 52 12 0.0386
2005 42 10 0.0412 43 27 0.0061 52 13 0.0343
2005 42 11 0.0412 43 28 0.0006 52 14 0.0129
2005 42 12 0.0515 43 29 0.0028 52 15 0.0258
2005 42 13 0.0515 43 30 0.0093 52 16 0.0258
2005 42 14 0.0515 51 0 0.0043 52 17 0.0172
2005 42 15 0.0412 51 1 0.0343 52 18 0.0258
2005 42 16 0.0412 51 2 0.0343 52 19 0.0258
2005 42 17 0.0103 51 3 0.1159 52 20 0.0129yearid sourcetypeid ageid ageFraction sourcetypeid ageid ageFraction sourcetypeid ageid ageFraction
2005 42 18 0.0412 51 4 0.0730 52 21 0.0043
2005 42 19 0.0515 51 5 0.0472 52 22 0.0043
2005 42 20 0.0206 51 6 0.0472 52 23 0.0086
2005 42 21 0.0000 51 7 0.0815 52 24 0.0086
2005 42 22 0.0309 51 8 0.1373 52 25 0.0000
2005 42 23 0.0103 51 9 0.0429 52 26 0.0086
2005 42 24 0.0106 51 10 0.0386 52 27 0.0043
2005 42 25 0.0103 51 11 0.0472 52 28 0.0000
2005 42 26 0.0103 51 12 0.0386 52 29 0.0000
2005 42 27 0.0000 51 13 0.0343 52 30 0.0385
2005 42 28 0.0103 51 14 0.0129 53 0 0.0043
2005 42 29 0.0000 51 15 0.0258 53 1 0.0343
2005 42 30 0.0107 51 16 0.0258 53 2 0.0343
2005 43 0 0.0534 51 17 0.0172 53 3 0.1159
2005 43 1 0.0361 51 18 0.0258 53 4 0.0730
2005 43 2 0.0400 51 19 0.0258 53 5 0.0472
2005 43 3 0.0539 51 20 0.0129 53 6 0.0472
2005 43 4 0.0523 51 21 0.0043 53 7 0.0815
2005 43 5 0.0495 51 22 0.0043 53 8 0.1373
2005 53 10 0.0386 54 26 0.0226 62 11 0.0716
2005 53 11 0.0472 54 27 0.0151 62 12 0.0508
2005 53 12 0.0386 54 28 0.0108 62 13 0.0339
2005 53 13 0.0343 54 29 0.0064 62 14 0.0329
2005 53 14 0.0129 54 30 0.1363 62 15 0.0277
2005 53 15 0.0258 61 0 0.0015 62 16 0.0195
2005 53 16 0.0258 61 1 0.0124 62 17 0.0102
2005 53 17 0.0172 61 2 0.0270 62 18 0.0080
2005 53 18 0.0258 61 3 0.0335 62 19 0.0052
2005 53 19 0.0258 61 4 0.0436 62 20 0.0058
2005 53 20 0.0129 61 5 0.0460 62 21 0.0056
2005 53 21 0.0043 61 6 0.0550 62 22 0.0026
2005 53 22 0.0043 61 7 0.0601 62 23 0.0009
2005 53 23 0.0086 61 8 0.0536 62 24 0.0017
2005 53 24 0.0086 61 9 0.0496 62 25 0.0017
2005 53 25 0.0000 61 10 0.0533 62 26 0.0013
2005 53 26 0.0086 61 11 0.0527 62 27 0.0002
2005 53 27 0.0043 61 12 0.0453 62 28 0.0004
2005 53 28 0.0000 61 13 0.0489 62 29 0.0002
2005 53 29 0.0000 61 14 0.0407 62 30 0.0013
2005 53 30 0.0385 61 15 0.0439
2005 54 0 0.0048 61 16 0.0443yearid sourcetypeid ageid ageFraction sourcetypeid ageid ageFraction sourcetypeid ageid ageFraction
2005 54 1 0.0148 61 17 0.0315
2005 54 2 0.0268 61 18 0.0307
2005 54 3 0.0365 61 19 0.0282
2005 54 4 0.0423 61 20 0.0237
2005 54 5 0.0482 61 21 0.0273
2005 54 6 0.0504 61 22 0.0278
2005 54 7 0.0431 61 23 0.0179
2005 54 8 0.0413 61 24 0.0183
2005 54 9 0.0418 61 25 0.0130
2005 54 10 0.0499 61 26 0.0096
2005 54 11 0.0487 61 27 0.0056
2005 54 12 0.0454 61 28 0.0046
2005 54 13 0.0336 61 29 0.0034
2005 54 14 0.0355 61 30 0.0470
2005 54 15 0.0381 62 0 0.0045
2005 54 16 0.0292 62 1 0.0448
2005 54 17 0.0235 62 2 0.0074
2005 54 18 0.0171 62 3 0.1062
2005 54 19 0.0148 62 4 0.1088
2005 54 20 0.0169 62 5 0.1557
2005 54 21 0.0209 62 6 0.0692
2005 54 22 0.0234 62 7 0.0424
2005 54 23 0.0230 62 8 0.0478
2005 54 24 0.0200 62 9 0.0504
2005 54 25 0.0188 62 10 0.0813

### Road Type Distribution

Road type distribution is based on the 2008 ODOT, county summary, HPMS VMT data categorized by federal functional class for the three county non-at tainment area. Road type distribution can be seen in Table 14.

Table 14 – Road Type Distribution sourceTypeID roadTypeID roadTypeVMTFractio n sourceTypeID roadTypeID roadTypeVMTFraction
11 1 0 43 4 0.29
11 2 0.06 43 5 0.52
11 3 0.13 51 1 0
11 4 0.29 51 2 0.06
11 5 0.52 51 3 0.13
21 1 0 51 4 0.29
21 2 0.06 51 5 0.52
21 3 0.13 52 1 0
21 4 0.29 52 2 0.06
21 5 0.52 52 3 0.13
31 1 0 52 4 0.29
31 2 0.06 52 5 0.52
31 3 0.13 53 1 0
31 4 0.29 53 2 0.06
31 5 0.52 53 3 0.13
32 1 0 53 4 0.29
32 2 0.06 53 5 0.52
32 3 0.13 54 1 0
32 4 0.29 54 2 0.06
32 5 0.52 54 3 0.13
41 1 0 54 4 0.29
41 2 0.06 54 5 0.52
41 3 0.13 61 1 0
41 4 0.29 61 2 0.06
41 5 0.52 61 3 0.13
42 1 0 61 4 0.29
42 2 0.06 61 5 0.52
42 3 0.13 62 1 0
42 4 0.29 62 2 0.06
42 5 0.52 62 3 0.13
43 1 0 62 4 0.29
43 2 0.06 62 5 0.52
43 3 0.13

### Vehicle Type VMT and VMT Fractions

The first component of the VMT inputs is the Ye arly HPMS VMT, but the travel demand model was used instead of ODOT’s HMPS data since it was felt that the model would better predict future year VMT. ODOT’s CMS post-processor was run for each year to generate congestion reports, which includes total daily VMT. The ve hicle type percentages of the total VMT were based on ODOT’s weigh-in-motion (WIM) data. Since there are not enough WIM stations for lower class facilties in the non- attainment area, a statewide average of all ODOT WIM data collectors was used. Daily VMT was then conve rted to yearly. Yearly HPMS VMT for 2005 can be seen in Table 15. The same method was to generate all other analysis years

Table 15 – Yearly HPMS VMT for 2005 HPMSVtypeID yearID HPMSBaseYearVMT baseYearOffNetVMT
10 2005 30590102 0
20 2005 5455503318 0
30 2005 1683283544 0
40 2005 17205399 0
50 2005 127192033 0
60 2005 301977250 0



### Monthly and daily VMT fractions used MOVES default data. The hourly VMT fractions were derived from ODOT WIM data. Hourly VMT frac tions vary for each of the five MOVES road types but do not change for each of the 16 MOVES source types. A representative sample of the hour VMT fraction input file can be seen in Table 16, the entire file is too large to include in this document.

Table 16 – Hourly VMT Fractions sourceTypeID roadTypeID dayID hourID hourVMTFraction
11 1 2 1 0.0089
11 1 2 2 0.00564
11 1 2 3 0.00424
11 1 2 4 0.00427
11 1 2 5 0.00695
11 1 2 6 0.01798
11 1 2 7 0.03806
11 1 2 8 0.057
11 1 2 9 0.05773
11 1 2 10 0.05538
11 1 2 11 0.05554
11 1 2 12 0.05558
11 1 2 13 0.05584
11 1 2 14 0.06051sourceTypeID roadTypeID dayID hourID hourVMTFraction
11 1 2 15 0.06765
11 1 2 16 0.07755
11 1 2 17 0.08428
11 1 2 18 0.0797
11 1 2 19 0.06012
11 1 2 20 0.04522
11 1 2 21 0.03646
11 1 2 22 0.02912
11 1 2 23 0.02142
11 1 2 24 0.01486

11 2 2 1 0.0089
11 2 2 2 0.00564
11 2 2 3 0.00424
11 2 2 4 0.00427
11 2 2 5 0.00695
11 2 2 6 0.01798
11 2 2 7 0.03806
11 2 2 8 0.057
11 2 2 9 0.05773
11 2 2 10 0.05538
11 2 2 11 0.05554
11 2 2 12 0.05558
11 2 2 13 0.05584
11 2 2 14 0.06051
11 2 2 15 0.06765
11 2 2 16 0.07755
11 2 2 17 0.08428
11 2 2 18 0.0797
11 2 2 19 0.06012
11 2 2 20 0.04522
11 2 2 21 0.03646
11 2 2 22 0.02912
11 2 2 23 0.02142
11 2 2 24 0.01486

11 3 2 1 0.00655
11 3 2 2 0.0037
11 3 2 3 0.00304
11 3 2 4 0.00363sourceTypeID roadTypeID dayID hourID hourVMTFraction
11 3 2 5 0.00792
11 3 2 6 0.02343
11 3 2 7 0.04899
11 3 2 8 0.06319
11 3 2 9 0.05402
11 3 2 10 0.05121
11 3 2 11 0.0528
11 3 2 12 0.05608
11 3 2 13 0.05814
11 3 2 14 0.05875
11 3 2 15 0.06676
11 3 2 16 0.07812
11 3 2 17 0.08469
11 3 2 18 0.08152
11 3 2 19 0.05852
11 3 2 20 0.04343
11 3 2 21 0.03606
11 3 2 22 0.02829
11 3 2 23 0.01883
11 3 2 24 0.01233

11 4 2 1 0.00752
11 4 2 2 0.0044
11 4 2 3 0.00354
11 4 2 4 0.00374
11 4 2 5 0.00705
11 4 2 6 0.02123
11 4 2 7 0.054
11 4 2 8 0.0768
11 4 2 9 0.06545
11 4 2 10 0.05114
11 4 2 11 0.04692
11 4 2 12 0.04916
11 4 2 13 0.05112
11 4 2 14 0.0534
11 4 2 15 0.06105
11 4 2 16 0.07421
11 4 2 17 0.08321
11 4 2 18 0.08385
11 4 2 19 0.06062sourceTypeID roadTypeID dayID hourID hourVMTFraction
11 4 2 20 0.04229
11 4 2 21 0.03442
11 4 2 22 0.0292
11 4 2 23 0.02137
11 4 2 24 0.01431

11 5 2 1 0.00678
11 5 2 2 0.00378
11 5 2 3 0.00295
11 5 2 4 0.0029
11 5 2 5 0.00498
11 5 2 6 0.01422
11 5 2 7 0.03449
11 5 2 8 0.05728
11 5 2 9 0.05435
11 5 2 10 0.04991
11 5 2 11 0.05261
11 5 2 12 0.06098
11 5 2 13 0.06457
11 5 2 14 0.06387
11 5 2 15 0.06812
11 5 2 16 0.07672
11 5 2 17 0.08274
11 5 2 18 0.08284
11 5 2 19 0.06344
11 5 2 20 0.04866
11 5 2 21 0.0407
11 5 2 22 0.03083
11 5 2 23 0.01966
11 5 2 24 0.01262

### Output Emission Factors

Table 17 shows the first record in a MOVES sample output (rate per distance) emission file for year 2005 with I/M programs. For any given mont h, day of week, hour of the day, pollutant, and source type; the rate per distance varies by road type and speed bin. Rates per distance emissions are applied to link and intrazonal VMT.

Table 17 – 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



### Table 18 shows the first record in a MOVES sample output (rate pe r vehicle) emission file for year 2005 with I/M programs. The rate per vehicl e varies for any combinations of month, day of week, hour of the day, pollutant, and process. Rates per vehicle emissi ons are applied to the vehicle source type population.

Table 18 – 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 19 shows the first record in a MOVES sample output (rate per profile) emission file for year 2005 with I/M programs. The rate per vehicl e varies for any combinations of month, day of week, hour of the day, pollutant, and process. Rates per profile emissi ons are applied to the vehicle souce type population.

Table 19 – Sample Emission File (Rate per Profile) for year 2005 Heading: MOVESScenarioID MOVESRunID yearID monthID dayID

Record: 2005 0 5 Heading: hourID zoneID pollutantID processID sourceTypeID

Record: 1 87 0 1 Heading: SCC fuelTypeID modelYearID temperature ratePerVehicle

Record: 0 0 0.01774139

## 4. Post Processing

Total emissions were computed with the aid of several custom programs by ODOT. The process uses data on daily and directiona l traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM). This process, described below and illustrated in Figure 4, 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 runn ing postcms.exe to calculate hourly link volumes based on the percentage of the daily volume (travel demand model output) determined by a link’s facility and area type. Link speeds from the travel dema nd model are not used in the analysis. The speeds are estimated as a post-pr ocess to the model based on HCM methods using a link’s volume-to-capacity ratio and link group code. The daily to hourly volume conversion percentages and speed tables can be seen in Appendix B.1.

The second step (movesnet.exe) uses a combin ation of the MOVES emission factors and the hourly link volumes that are out put of the postcms.exe progra m. The hourly volumes are multiplied by the MOVES emission factor fo r the corresponding hour of day, speed bin, and roadtype to calculate emissions for every network link for each hour. The final link on road vehicle emissions for the area is the su m of all individual link-hour emissions.

The third step, (movesveh.exe), calculates vehi cle-based emissions (using a combination of the Rate per Distance and Rate per Profile files) fo r each source type for eac h hour of the day. The vehicle source type is based on a combination of local and default data. The final vehicle emissions for each county are the sum of all individual hourly emissions for all vehicle types.

Intrazonal trips do not get loaded onto the networ k, so the fourth step in the process requires a separate method to account for those trips that us e local roads to travel within a zone. The movesintra.exe program uses intrazonal trips to estimate VMT using the area in square miles and intrazonal trips of each zone . The zone is assumed circular and th e radius of the circle is used as the average trip length for these intrazonal trips. Intrazonal emissions are then calculated by combining MOVES generated emissions with estim ated intrazonal VMT. The emission rates are the same as those used to calculated link based emissions.

The final step is to summarize link, vehicle, a nd intrazonal emissions for each county, pollutant, and analyzed year. Daily summary emissions for each pollutant, county, and scenario year in the Dayton Springfield Region can be found in Appendix B.2.

### Figure 4 – Emission Calculation Process



## 5. Multiple MPO Coordination Issues

CCS-TCC, MVRPC, ODOT, and OEPA have a long hi story of working together in air quality issues, the Memorandum of Understanding, listed be low, documents these working relationships. The document is in the process of be ing signed by all parties involved.

• Memorandum of Understanding among the MV RPC, the CCS-TCC, the OKI Regional Council of Governments, the OEPA, the ODOT, the US EPA-Region 5, the FHWA-Ohio Division, and the FTA-Region 5.

## Appendix A

Interagency Consultation Documentation

### Dayton-Springfield Ozone SIP MOVES Update Minutes 8/24/2011

Attending: ODOT employees Dave Moore, Mo nica Drake, Mark Byram, Nino Brunello, and Andrew Shepler, Jennifer Hunter - OE PA, Pat Morris – US EPA, Ana Ramirez – MVRPC, Scott Schmidt – CCSTCC, Lamar Daniel – CCSTCC.

This air quality interagency consultation conference call was held to coordinate development of revision to the Dayton/Springf ield 8-Hour Ozone SIP Maintenance Plan. The SIP revision will update the mobile sour ce HC and NOx budgets to reflect US EPA’s new MOVES software emission results. The SI P revision will be reviewed and approved via the federal register process.

Pat Morris confirmed that a full SIP revision is needed. She also c onfirmed that only the mobile source emissions will be updated, not point, area, etc. Analysis years will be consiste nt with the existing Ozone SIP:

• 2002 - base year

• 2005 - attainment and budget year

• 2009 - interim non-budget analysis year

• 2018 - out year budget Pat Morris confirmed that these four years are acceptable. When asked about using fewer years, Pat stated that it is helpful to have the runs for all four years.

Temperature and humidity inputs for the Ozone SIP Update will be consistent with the existing Ozone SIP, reflecting an average day in July. The existing SIP reflected temperature data from the ten hottest days of summer, 2002. Temp erature minimum and maximum were provided by OEPA, corresponde nce is on file at ODOT and included in technical MPO memos. For MOBILE6 runs, hour ly temperatures were established based on a daily profile ODOT developed fro m NOAA data. The MOBILE to MOVES translator applies a daily temperature profile in a similar manner and will be used for this SIP update.

Ana Ramirez asked Nino Brunello to prepare a protocol document recording the analysis input parameters to use as a guide for the technical documentation that MVRPC will produce. Nino agreed to transmit the document the week of August 29.

Latest Planning Assumptions: Latest land use and population assumptions will be used. Therefore, 2018 forecasts will reflect the latest socio-economic conditi ons based on the 2010 Census and current Transportation Plan.

Emissions parameters will be consistent w ith the MOBILE based SIP runs, as follows: 2002 & 2005 will reflect E-check 2009 & 2018 will reflected RVP 7.8

### A safety margin was not included in 2005. Pat Morris said that a safety margin could be added in future years if necessary. It was determined that the safety margins would be added if necessary after the runs are comple ted. 2005 will also be looked at prior to submission of the SIP.

Nino requested that for Ozone emissions, M OVES emission factors by source type (ie vehicle class) be used instead of the aggregat ed emission factors that have been used for PM2.5 analyses. This is a more detailed approach which should produce more accurate results, more defensible results. This re quest was approved. MVRP C agreed contingent on the results of comparisons between aggreg ate versus disaggregate emission factor methods. To insure deadlines are met, Nino will run the aggregate methodology first in case he runs into proble ms with the more detailed disaggregate methodology.

The schedule was discussed. 1) Emission factors will be provided to MVRPC by ODOT by mid-September. 2) Information would need to be submitte d to OEPA & US EPA by mid-November. 3) The deadline for approved budgets is mi d-February. OEPA will need three months to process. 4) US EPA will complete as much as possibl e concurrently with OEPA. Pat Morris stated that she will need 90 days and w ill need approval by OPEA to complete the budgets for approval. 5) The conformity finding needs to be complete by August 1, 2012.

The meeting concluded following the schedule discussion.

### MOVES Ozone Inputs Technical Details

The summaries and the settings used in the MOVES run specification file and the MOVES County-Data Mana ger are shown below. Further de tails in specific inputs that are not using default valu es are provided below.

Parameters used for ozone analyses are simila r to those used for PM analyses with the exception of: pollutants, addi tional profile emissions, anal ysis month, and the use of consecutive hourly temperature differences for calculation of the vapor venting process.

Instead of using average emission rates for the entire vehicle fleet, total emissions by individual source types will be calculated.

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 Clark, Greene, Mi ami, and Montgomery 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, NO x 

### , NO, NO 2

, 

### Total Energy Consumption Strategies None 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 Combinatio n 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 ra te 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 I/M program inform ation applied for 2002/2005 where applicable for all counties except Miami (Miami Co. is never had an I/M program) Fuel Formulation Default Fuel Supply Reformulated gas (RVP) for summer analyses 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 y ear travel demand model for VHT fractions. Future fractions will be assumed constant Road Type Distribution Use ODOT count y 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 DefaultFrom: Brunello, Nino [mailto:Nino.Brunello@dot.state.oh.us] Sent: Thursday, April 19, 2012 2:30 PM To: PJividen@AkronOhio.gov; CBaker@akronohi o.gov; Jeff Dutton; Bill Davis; Nick Gill (NGILL@morpc.org); Ramirez, Ana; Saleem Salameh; Lima (tmazur@lacrpc.com); smapel@lcounty.com; 'randy.durst@mov rc.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,

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 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 SectionDivision 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

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)

-NinoFrom: 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

## Appendix B

## Appendix B.1 Post Processing Default DistributionsHOUR 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23PCTADTURB FWY 0.9 0.6 0.5 0.6 0.9 2.2 5.2 7.3 6.4 5.2 4.9 5.1 5.3 5.5 6.1 7.2 8.0 7.9 5.8 4.2 3.4 2.9 2.2 1.5URB ART 0.7 0.4 0.3 0.3 0.6 1.5 3.5 5.7 5.5 5.1 5.3 6.2 6.5 6.4 6.8 7.6 8.2 8.1 6.2 4.8 4.0 3.0 1.9 1.3RUR FWY 1.4 1.1 0.9 1.0 1.3 2.2 3.7 5.2 5.4 5.4 5.6 5.6 5.7 6.0 6.5 7.1 7.5 7.0 5.6 4.5 3.8 3.2 2.5 2.0RUR ART 0.8 0.5 0.4 0.5 1.0 2.4 4.8 6.2 5.5 5.3 5.5 5.8 6.0 6.0 6.7 7.6 8.1 7.7 5.6 4.2 3.5 2.8 1.9 1.3PCTADT TRKURB FWY 2.1 1.9 1.8 2.0 2.4 3.0 3.9 4.6 5.3 6.0 6.3 6.4 6.4 6.4 6.3 5.8 5.2 4.6 4.1 3.7 3.4 3.1 2.8 2.4URB ART 1.1 0.9 1.0 1.2 1.6 2.3 3.9 5.9 6.9 6.7 7.1 7.6 7.4 7.2 7.4 7.2 6.0 5.0 3.7 2.8 2.3 1.9 1.5 1.3RUR FWY 2.6 2.2 2.1 2.3 2.6 3.1 3.5 4.0 4.5 5.1 5.6 5.8 5.8 5.8 5.8 5.6 5.3 4.9 4.6 4.3 4.0 3.8 3.5 3.1RUR ART 1.5 1.3 1.4 1.6 2.2 3.0 4.2 5.3 6.1 6.7 7.0 7.1 7.0 6.9 6.8 6.3 5.5 4.6 3.8 3.1 2.6 2.3 2.1 1.7PCTDIRURB FWY 38 40 40 46 56 64 70 70 68 62 58 52 52 52 50 46 38 38 46 52 46 42 42 40URB ART 44 46 44 48 54 62 66 68 64 56 54 52 50 50 50 46 40 38 46 52 48 46 46 46RUR FWY 44 46 48 54 60 68 68 64 58 54 52 50 50 52 52 48 42 40 44 48 48 44 46 44RUR ART 40 42 44 48 58 66 72 68 60 56 54 50 50 50 50 46 40 38 46 50 46 44 44 44LOS E VC 0 0.625 1.25 1.875 2.5 3.125 3.75 4.375 5 5.625 6.25 6.875 7.5 8.125 8.75 9.375 10 10.625 11.25 11.875 12.5 13.125 13.75 14.375SPEEDVCcurve1 75 75 75 75 75 75 74.9 74.8 74.6 74.2 73.5 72.3 70.5 67.8 64.2 59.5 54 47.7 41.2 34.9 28.9 23.7 19.2 15.5curve2 70 70 70 70 70 70 70 69.9 69.8 69.6 69.2 68.4 67.1 65.1 62.2 58.2 53 47 40.5 33.9 27.7 22.2 17.6 13.8curve3 65 65 65 65 65 65 65 65 65 64.9 64.8 64.4 63.8 62.6 60.5 57 52 45.4 37.8 29.9 22.7 16.7 12.1 8.6curve4 60 60 60 60 60 60 60 60 60 59.9 59.8 59.6 59.1 58.2 56.7 54.3 50.8 46.1 40.3 33.8 27.3 21.3 16.2 12.2curve5 55 55 55 55 55 55 55 55 55 55 55 54.9 54.7 54.3 53.6 52.3 50 46.5 41.5 35.3 28.5 21.9 16.1 11.5curve6 60 60 60 60 60 60 60 60 59.9 59.8 59.7 59.4 59.1 58.5 57.7 56.5 55 53.1 50.7 47.9 44.7 41.1 37.3 33.4curve7 55 55 55 55 55 55 55 55 54.9 54.9 54.7 54.5 54.2 53.8 53.1 52.2 50.9 49.3 47.3 44.9 42.1 39 35.7 32.2curve8 50 50 50 50 50 50 50 50 49.9 49.9 49.8 49.6 49.4 49 48.5 47.7 46.7 45.4 43.8 41.8 39.5 36.8 33.9 30.9curve9 45 45 45 45 45 45 45 45 45 44.9 44.8 44.7 44.4 44.1 43.6 43 42.1 40.9 39.4 37.6 35.5 33.1 30.5 27.8curve10 50 50 50 50 49.9 49.8 49.7 49.4 49 48.4 47.5 46.5 45.1 43.5 41.7 39.6 37.3 34.9 32.4 29.8 27.3 24.9 22.6 20.4curve11 50 50 50 50 50 49.9 49.7 49.4 48.9 48 46.7 44.9 42.5 39.6 36.2 32.6 28.7 25 21.4 18.2 15.3 12.9 10.8 9curve12 50 50 50 50 50 49.9 49.8 49.6 49.1 48.2 46.8 44.5 41.4 37.5 32.9 28 23.1 18.7 14.9 11.8 9.2 7.2 5.7 4.5curve13 40 40 40 40 40 40 39.9 39.8 39.5 39.2 38.6 37.8 36.7 35.3 33.5 31.4 29 26.4 23.7 21.1 18.5 16.1 13.9 12curve14 40 40 40 40 40 39.9 39.8 39.6 39.1 38.5 37.5 36.1 34.3 32.1 29.4 26.5 23.5 20.5 17.7 15.1 12.8 10.7 9 7.6curve15 40 40 40 40 40 39.9 39.7 39.4 38.8 37.9 36.5 34.7 32.3 29.5 26.4 23.2 20 17 14.3 11.9 9.9 8.2 6.8 5.6curve16 35 35 35 35 35 34.9 34.8 34.5 34 33.2 32.1 30.5 28.5 26.1 23.5 20.6 17.9 15.2 12.8 10.7 8.9 7.4 6.1 5.1curve17 35 35 35 35 35 34.9 34.7 34.4 33.9 33.1 32 30.3 28.3 25.8 23.1 20.3 17.5 14.9 12.5 10.4 8.6 7.2 5.9 4.9curve18 35 35 35 35 35 34.9 34.6 34.2 33.5 32.4 30.9 28.8 26.3 23.4 20.4 17.4 14.6 12.1 9.9 8.1 6.6 5.4 4.4 3.6curve19 30 30 30 30 30 29.9 29.8 29.5 29 28.2 27.1 25.6 23.7 21.5 19.1 16.6 14.2 12 10 8.3 6.8 5.6 4.6 3.8curve20 30 30 30 30 30 29.9 29.7 29.4 28.9 28.1 26.9 25.3 23.4 21.1 18.6 16.1 13.6 11.4 9.5 7.8 6.4 5.3 4.3 3.6curve21 30 30 30 30 30 29.9 29.7 29.3 28.7 27.7 26.2 24.4 22.1 19.6 17 14.4 12 9.9 8.1 6.6 5.4 4.4 3.6 2.9VC RATIO TO LOS CONVERSION (VALUE SHOWN IS LOWER LIMIT FOR THAT LOS)(URBAN ROADS USE SPEED BREAKS BELOW FOR LOS DETERMINATION) (ALL USE THE BASE VC'S TO DETERMINE EXCEEDANCE)BASE RUR2 FWYA 0.00 0.00 0.00B 0.30 0.00 0.25C 0.50 0.10 0.40D 0.70 0.30 0.60E 0.90 0.50 0.80F 1.00 1.00 1.00F+ 1.10 1.10 1.10F++ 1.30 1.30 1.30SPEED VC RATIO BREAKS FOR URBAN STREETS (HIGHEST SPEED FOR GIVEN LOS & FF SPEED)FFS B C D E F>47 42. 34. 27. 21. 16.>37 35. 28. 22. 17. 13.>32 30. 24. 18. 14. 10.<33 25. 19. 13. 9. 7.LEVEL OF SERVICE THRESHOLD BY AREANUM LOS DEFINITION1 F CINCINNATI,CLEVELAND,COLUMBUS CENTRAL MPO COUNTIES (CUY,FRA,HAM)2 E OTHER TMA MPOS (AKRON,CANTON,DAYTON,TOLEDO,YOUNGSTOWN + NON-CENTRAL COUNTIES FROM 1)3 E OTHER MPOS & PARTS OF AREAS 1 & 2 OUTSIDE URBANIZED AREA4 E RURAL NON MPO COUNTIESPEAK SPREADING MODEL INFO (SET MAX ITERATIONS TO 0 TO DISABLE PEAK SPREADING)MAX VC RATIO FWY: 1.30MAX VC RATIO ART: 1.30MAX ITERATIONS : 1000TRUCK PCE: 2.00AQ SEASON FACTOR: 1.00MODEL CLASS PARAMETERS (MAX 4 CLASSES, HOURS 0-23 W/ NO OVERLAP IN CLASS, ALLOCATE ENTIRE CLASS AS TRUCK(1) OR NOT(0))CLS TRK 0 1 0 0 0 0 0 0 0 0 0 0 0 00 0CLS BEG 0 0 0 0 0 0 0 0 0 0 0 0 0 00 0CLS END 23 23 0 0 0 0 0 0 0 0 0 0 0 0 0 0CLS NUM 1 3 0 0 0 0 0 0 0 0 0 0 0 00 0

## Appendix B.2 Ozone EmissionSummaries

## Clark County Daily Summary

CLARK VOC (tons/day) NOX (tons/day) Link Emissions 3.7781 14.2914 Vehicle Emissions 5.8521 2.6580 Intrazonal Emissions 0.0196 0.0503 TOTAL 9.6498 16.9997

CLARK VOC (tons/day) NOX (tons/day) Link Emissions 2.9722 12.1557 Vehicle Emissions 5.4320 2.7830 Intrazonal Emissions 0.0150 0.0424 TOTAL 8.4192 14.9811

CLARK VOC (tons/day) NOX (tons/day) Link Emissions 2.0595 9.3562 Vehicle Emissions 4.6749 2.7009 Intrazonal Emissions 0.0104 0.0336 TOTAL 6.7448 12.0907

CLARK VOC (tons/day) NOX (tons/day) Link Emissions 0.7060 3.4341 Vehicle Emissions 2.3862 1.5746 Intrazonal Emissions 0.0031 0.0106 TOTAL 3.0953 5.0193

CLARK VOC (tons/day) NOX (tons/day) Link Emissions 0.4415 1.6157 Vehicle Emissions 1.5770 0.9262 Intrazonal Emissions 0.0016 0.0038 TOTAL 2.0201 2.5457 2040 (No I/M)

2002 (I/M)

2005 (I/M)

2009 (No I/M)

2018 (No I/M)

## Greene County Daily Summary

GREENE VOC (tons/day) NOX (tons/day) Link Emissions 3.6983 12.6750 Vehicle Emissions 6.3501 2.8685 Intrazonal Emissions 0.0371 0.0948 TOTAL 10.0855 15.6383

GREENE VOC (tons/day) NOX (tons/day) Link Emissions 2.9075 10.7301 Vehicle Emissions 5.7586 2.9225 Intrazonal Emissions 0.0293 0.0822 TOTAL 8.6954 13.7348

GREENE VOC (tons/day) NOX (tons/day) Link Emissions 2.0473 8.4135 Vehicle Emissions 4.9910 2.8836 Intrazonal Emissions 0.0206 0.0662 TOTAL 7.0589 11.3633

GREENE VOC (tons/day) NOX (tons/day) Link Emissions 0.7338 3.1705 Vehicle Emissions 2.4794 1.6360 Intrazonal Emissions 0.0073 0.0246 TOTAL 3.2205 4.8311

GREENE VOC (tons/day) NOX (tons/day) Link Emissions 0.4529 1.4776 Vehicle Emissions 1.5378 0.9032 Intrazonal Emissions 0.0040 0.0097 TOTAL 1.9947 2.3905 2002 (I/M)

2005 (I/M)

2009 (No I/M)

2018 (No I/M)

2040 (No I/M)

## Miami County Daily Summary

MIAMI VOC (tons/day) NOX (tons/day) Link Emissions 2.6641 9.4498 Vehicle Emissions 4.4407 2.0170 Intrazonal Emissions 0.0449 0.1151 TOTAL 7.1497 11.5819

MIAMI VOC (tons/day) NOX (tons/day) Link Emissions 2.1190 8.1391 Vehicle Emissions 4.0837 2.0922 Intrazonal Emissions 0.0346 0.0979 TOTAL 6.2373 10.3292

MIAMI VOC (tons/day) NOX (tons/day) Link Emissions 1.4639 6.2047 Vehicle Emissions 3.4715 2.0057 Intrazonal Emissions 0.0234 0.0754 TOTAL 4.9588 8.2858

MIAMI VOC (tons/day) NOX (tons/day) Link Emissions 0.4988 2.2291 Vehicle Emissions 1.7245 1.1379 Intrazonal Emissions 0.0077 0.0260 TOTAL 2.2310 3.3930

MIAMI VOC (tons/day) NOX (tons/day) Link Emissions 0.3113 1.0618 Vehicle Emissions 1.0697 0.6282 Intrazonal Emissions 0.0039 0.0094 TOTAL 1.3849 1.6994 2040 (No I/M) 2002 (No I/M)

2005 (No I/M)

2009 (No I/M)

2018 (No I/M)

## Montgomery County Daily Summary

MONTGOMERY VOC (tons/day) NOX (tons/day) Link Emissions 12.4577 41.9321 Vehicle Emissions 22.3876 10.1129 Intrazonal Emissions 0.0705 0.1801 TOTAL 34.9158 52.2251

MONTGOMERY VOC (tons/day) NOX (tons/day) Link Emissions 9.6580 35.1555 Vehicle Emissions 20.3022 10.3034 Intrazonal Emissions 0.0531 0.1489 TOTAL 30.0133 45.6078

MONTGOMERY VOC (tons/day) NOX (tons/day) Link Emissions 6.6238 26.9760 Vehicle Emissions 17.5961 10.1662 Intrazonal Emissions 0.0353 0.1136 TOTAL 24.2552 37.2558

MONTGOMERY VOC (tons/day) NOX (tons/day) Link Emissions 2.1395 9.1866 Vehicle Emissions 8.7411 5.7679 Intrazonal Emissions 0.0110 0.0373 TOTAL 10.8916 14.9918

MONTGOMERY VOC (tons/day) NOX (tons/day) Link Emissions 1.1970 3.9130 Vehicle Emissions 5.4218 3.1844 Intrazonal Emissions 0.0054 0.0130 TOTAL 6.6242 7.1104 2040 (No I/M)

2002 (I/M)

2005 (I/M)

2009 (No I/M)

2018 (No I/M)

### Public Notice Ohio Environmental Protection AgencyRevisions of Redesignation and Maintenance Plan for the former DaytonSpringfield Ozone Nonattainment Area
Clark, Greene, Miami and Montgomery Counties

Notice is hereby given that the Director of the Ohio Environmental Protection Agency, (Ohio EPA) is requesting that the United States Environment al Protection Agency (U.S. EPA) revise the current maintenance plan fo r the Dayton-Springfield area, including Clark, Greene, Miami and Montgomery Counties, with respect to the 1997 eight-hour ozone national ambient air quality st andard (NAAQS). Ohio EPA submitted a redesignation request and maintenance plan for this area on November 6, 2006 Subsequently, U.S. EPA approved this requests on August 13, 2007 (72 FR 45169). Air quality monitoring data collected in the regi on demonstrated attainme nt of the NAAQS and there was evidence that the improved air quality is due to permanent, enforceable emission reductions. In addition, existing requi rements are sufficient to maintain the 1997 eight-hour ozone standard in this ar ea throughout the maintenance period.

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budget s 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 r eplaced 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 involvem ent in SIP related activities. This notice addresses Ohio EPA’s reliance on the emission projec tions as evidence of attainment and maintenance and the commitment to institute contingency measures if ambient exceedances or violations trigger the cont ingency plan requirements. Written comments will be received on or before January 31, 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 conduc ted as follows: January 31, 2013 at 3:00 P.M., Ohio EPA Southwest District Office located at 401 East Fifth Street, Dayton, Ohio.

All interested persons are entitled to att end 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 January 31, 2013 will be considered by Ohio EPA prior to final action on this redesignation. Written stat ements submitted after January 31, 2013 may be considered as time and circumstances pe rmit, 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.

### BEFORE THE OHIO EPA

- - -

IN RE: :

: Revisions of Redesignation and : Maintenance Plan for the Former : Dayton-Springfield Ozone : Nonattainment Area - Clark, Greene, : Miami, and Montgomery Counties :

- - -
Audiotaped public Hearing before

Moderator Darla Peele, taken at the Ohio EPA

Southwest District Office, 401 East Fifth Street,

Dayton, Ohio, at 3:00 p.m. on January 31, 2013.

FRALEY, COOPER & ASSOCIATES 222 East Town Street, Second Floor Columbus, Ohio 43215-4620 (614) 228-0018 - (614) 852-6163 Fax - (614) 224-5724

- - -

### P-R-O-C-E-E-D-I-N-G-S

MODERATOR PEELE: The date is January

31, 2013. My name is Darla Peele. I'm a public

involvement coordinator for Ohio Environmental

Protection Agency, Southwest District Office. I

will be presiding over today's public hearing.

Thank you for taking the time to attend this

hearing before Ohio Environmental Protection

Agency.

The purpose of the hearing today is to

obtain comments from any interested person

regarding Ohio EPA's proposed action.

The State of Ohio is requesting that the

U.S. EPA revise the current maintenance plan for

the Dayton-Springfield area, which includes

Clark, Greene, Miami, and Montgomery Counties,

with respect to the 1996 eight-hour ozone

national ambient air quality standard.

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

Emissions Simulation 2010. In December 2009 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

### MOVES replaced MOBILE6.2 as the U.S. EPA's

official emission factor model.

All interested persons are entitled to

attend or be represented and to resent oral

and/or written comments concerning the proposed

action. All written and oral comments received

as a part of the official record will be

considered by the Director of Ohio EPA.

To be included in the official record,

written comments must be received by Ohio EPA by

the close of business today, January 31, 2013.

The comments may be filed with me today or

e-mailed to erica.fetty@epa.ohio.gov.

All written comments submitted for the

record receive the same consideration as oral

testimony given today. Written statements

submitted after today may be considered as time

and circumstances permit but will not be a part

of the official record of the hearing.

If you wish to present oral testimony at

this hearing today and have not already signed

the registration sheet, please do so at this

time. The sheet is available at the registration

table. 3

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

### Persons will be called in the order in

which they have registered. There is no

cross-examination of speakers or of

representatives of Ohio EPA in public hearings

such as this.

Ohio EPA hearings such as this afford

citizens the opportunity to provide comments on

the official record. Therefore, we will not be

able to answer questions during the hearing.

However, members of the panel may ask

clarifying questions of the person testifying to

ensure the record is as complete and accurate as

possible.

I will now go off the record seeing that

there are no citizens available who wish to

provide testimony. The time is now 3:08 p.m.

(Break taken until 3:30 p.m.)

MODERATOR PEELE: I am going back on the

record at 3:30 p.m.

Seeing no one request testimony, I want

to remind you that the written comments can be

submitted through 5 p.m. today. Thank you for

attending.

The time is now 3:30 p.m., and this 4

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

### hearing is adjourned.

Thank you.

(The audiotaped public hearing was

adjourned at 3:30 p.m. on January 31, 2013.)

* * * 5

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

### C E R T I F I C A T E

- - -

STATE OF OHIO : SS: COUNTY OF FRANKLIN :

I, Jennifer L. Parish, Registered

Professional Reporter and Notary Public in and

for the State of Ohio, do hereby certify that the

foregoing is a true, correct, and complete

transcription of the above-mentioned audiotaped

public hearing before the Ohio Environmental

Protection Agency to the best of my ability.

DATED this 6th day of February, 2013.

_________________________ JENNIFER L. PARISH, RPR NOTARY PUBLIC-STATE OF OHIO

My Commission Expires: November 23, 2014. 6

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24