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, 20071

Revised February 20132

 

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
 

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 i 

TABLE OF CONTENTS 

Chapter One 

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

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

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

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

Chapter Two 

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

Chapter Three 

Ozone monitoring .......................................................................................................................... 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 ........................................................................................ 27 

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 NOx sources...................................................................................................... 33 

Chapter Seven 

Public participation ...................................................................................................................... 35 

Chapter Eight 

Conclusions ................................................................................................................................ 36 
 ii 

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 NOx 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 NOx Emission Inventory Clark County ................................................................. 20 

Table 10 NOx Emission Inventory Greene County ............................................................. 20 

Table 11 NOx Emission Inventory Miami County ................................................................ 21 

Table 12 NOx Emission Inventory Montgomery County ..................................................... 21 

Table 13 NOx 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 Documentation 
 iii 

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 1 

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 air quality standards for ozone replacing the 

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

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

February of 2001. 

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

standard, effective June 15, 2004. Since that time, U.S. EPA has reclassified nine of the 

134 original nonattainment areas to the next lower classification. Section 107(d)(3)(E) of 

the CAA allows states to request nonattainment areas be redesignated to attainment 

providing certain criteria are met. The following are the criteria that must be met in order for 

an area to be redesignated from nonattainment to attainment: 

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

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

110(k).

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

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

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

met. 

 

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 (NOx) 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 attainment 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 located 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 guidance in a document entitled Procedures for 

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

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

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

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

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

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 NOx allowances. This package is under 

review by U.S. EPA. 

 While no replacement package will have 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 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 the replacement programs not be approved, 

modeling has been performed by Ohio University on contract to Ohio EPA to 

evaluate the impact of losing the E-Check program in the Dayton-Springfield 
 4 

area. This report Efficacy of E-Check in Selected Counties in the Dayton 

Ohio Metropolitan Area: Photochemical Grid Model Evaluation, included in 

Appendix D 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. There is significant 

safety margin in the current attainment modeling for the Dayton-Springfield 

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-Springfield, OH area. Chapter five 

discusses this requirement in more detail and provides the attainment 

demonstration. 

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 
 5 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for an 

emission inventory will be satisfied by the inventory requirements of 

the maintenance plan. 

 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 addressing 

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 area 

can attain and maintain the eight-hour ozone standard without the ECheck program. Appendix E in the 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 plan will constitute a SIP revision and 

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

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

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

ensure such maintenance. 

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

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

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

the nonattainment SIP prior to redesignation. 
 6 

States seeking redesignation of a nonattainment area should consider the 

following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 

 Chapter six discusses this requirement in more detail and provides the 

attainment demonstration. 
 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 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 
 8 

Requirement 2 of 4: 

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

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

Demonstration: 

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

with 40 CFR 58.10 and 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-454/R-98-017, December 1998. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

called the site's design value. Table 1 shows the monitoring data for 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. 
 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

 1st 2nd 3rd 4th 2004-2006 

SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE 

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 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 rule 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 NOx SIP Call) has significantly 

reduced emissions from large electric generating units (EGUs), industrial 

boilers, and cement kilns. Ohio's NOx Budget Trading Program Rule was 

approved on May 25, 2004 Ohio Administrative Code (OAC) Chapter 3745-

14. It is expected that 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 monitoring 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 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 site3

 will provide real time availability of the data and knowledge of any 

exceedances. Ohio EPA will enter all data into AQS on a timely basis in 

accordance with federal guidelines. 

 

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 submittal of a comprehensive inventory of 

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

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

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

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

Other emissions inventory related requirements include a projection of the emission 

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

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

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

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 NOx 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 NOx 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 NOx 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. 
 12 

Requirement 2 of 5: 

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

Background: 

Ohio EPA prepared a comprehensive inventory for the Dayton-Springfield, OH area 

including area, mobile, and point sources for precursors of ozone (VOCs and NOx) 

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. 

• 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 emissions beyond December 31, 2005 do 

not include reductions associated 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 database4. 

• Biogenic emissions are not included in these summaries. 

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

Inventory Model (NMIM) 2002 application. To address concerns 

about the accuracy of some of the categories in U.S. EPA’s non-road 

emissions model, LADCO contracted with two (2) companies to 

review the base data and make recommendations. One of the 

contractors also estimated emissions for three (3) non-road categories 

not included in U.S. EPA’s non-road model. Emissions were estimated 

for aircraft, commercial marine vessels and railroads. Recreational 

motorboat population and spatial surrogates (used to assign 

emissions to each county) were significantly updated. The populations 

for the construction equipment category were reviewed and updated 

based upon surveys completed in the Midwest and the temporal 

allocation for agricultural sources also was updated. 

 

 

 

4 http://www.epa.gov/airmarkets/acidrain 
 13 

Demonstration: 

On-Road Emission Estimations 

The Miami Valley Regional Planning Commission (MVRPC) and the Clark CountySpringfield Transportation Coordinating Commission (CCSTCC), in coordination with 

the Ohio Department of Transportation (ODOT), 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 planning tool to 

evaluate the transportation system including determination of locations where 

additional travel capacity may be needed and to determine the infrastructure 

requirements necessary to meet that need. 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 MOVES2010 

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

pollution emitted by the on-road vehicles for the particular analyzed area. 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 (grams/mile) for ozone precursors, NOx and VOC. 

The MOVES2010 model includes a number of variables that affect the emission 

factors. These variables have national default values, some of which require 

modification to reasonably reflect local conditions. Some of these variables are 

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

have a major effect on the emission factors. The source types are traveling on road 

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

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

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

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

factors produced by MOVES2010 can also include the effect of emission reduction 

strategies such as vehicle inspection and maintenance programs, regulation of fuels, 

etc. These MOVES2010 inputs are estimated using the best available data. 

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

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

VMT from both MPO travel demand models to estimate the total vehicle emissions. 

 

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 
 14 

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 intrazonal emissions. Total emissions are sum 

of on-road vehicle emissions, vehicle-based emissions and intrazonal emissions. 

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

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

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

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

network formats and MOVES2010 generated emission factors. MOVES2010 input 

and output files are provided in Appendix C. 

Best Available Data 

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

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

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

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

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 specified 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 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 
 15 

connectors. In addition, some local road traffic 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 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 emissions analysis for the Dayton-Springfield 

area (Clark, Greene, Miami and Montgomery counties). 

Table 2 - Combined VOC and NOx 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 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) 53.37 22.35 

NOx (tons/day) 84.66 32.47 
 16 

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 MOVES2010as 

described above under the expected 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 NOx. These correspond to a 15 percent safety 

margin above the 2018 on-road emissions for both VOC and NOx. Appendix 

C contains data tables and graphs of these emissions. 

All methodologies, latest planning assumptions and the safety margins were 

determined through the interagency consultation process described in the 

Transportation Conformity Memorandum of Understanding (MOU) for 

MVPRC. 

The current one-hour budget will no longer be applicable either after the 

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

U.S. EPA action approving 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 projections for the Dayton-Springfield, OH 

area using the following approaches. 

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

MOVES2010 model. The analysis is described in more detail in 

Appendix C. All projections were made in accordance with 

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

019. 

• Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. LADCO 

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

categories. These files were used to develop the future year 

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

inventories used for redesignation are consistent with modeling 

performed in the future. 
 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 compliance with the ozone standard. 

Therefore, Ohio EPA performed an initial comparison of the inventories for 

the base year and maintenance years. Mobile source emission inventories 

are described in Appendix B. In addition to the LADCO estimates, point 

source emissions were projected based upon the statewide EGU NOx

budgets from the Ohio NOx rule. 

The following tables include sectors Electrical Generating Unit (EGU-Point), 

Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), 

Other (Area), 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 

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 3.09

 
 18 

 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 3.67

 
 19 

 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 

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 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 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 31.39
 20 

 Table 9 Clark County NOx 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 NOx 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 9.75

 
 21 

 Table 11 Miami County NOx 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 NOx 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 37.77

 
 22 

Table 13 Dayton-Springfield, OH area NOx 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. 

 

NOx 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 NOx

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 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 

VOC 21.62 18.53 3.09 

NOx 19.00 7.70 11.30 
 23 

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 16.42 10.93 5.49 

NOx 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 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 14.55 10.88 3.67 

NOx 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 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 62.61 43.47 19.14 

NOx 86.60 48.83 37.77 
 24 

 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 115.20 83.81 31.39 

NOx 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 population or specific industrial sectors will 

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

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

NOx emissions in the nonattainment area are projected to decrease by 64.74 

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

Emissions Standards and Gasoline Sulfur Control Requirements5, Highway 

Heavy-Duty Engine Rule6

 and Non-Road Diesel Engine Rule7 also are 

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

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

area also will be decreased. 

Requirement 4 of 5: 

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

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

not on temporary adverse economic conditions or unusually favorable meteorology. 

Background: 

Ambient air quality data from 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 

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 

 

5 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 6 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 7 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 
 25 

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

NAAQS.” 

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

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

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

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

(CERR). Ohio 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 NOx

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 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 

On-road VOC 61.81 53.37 

On-road NOx 96.45 84.66 

EGU NOx 22.70 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. 

 
 26 

Demonstration: 

As required by Section 175A(b) of the CAA, Ohio commits to submit to the 

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

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

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

period after redesignation. 
 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 existing stationary sources covered by Control 

Technology Guidelines (CTG) as applied in Ohio’s rural counties. 

Background: 

As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were no 

specific rules required by the CAA such as RACT for existing sources beyond 

statewide rules. 

Demonstration: 

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

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

 

Requirement 2 of 4:

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

implemented. 

Background: 

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

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

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

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

percent of all NOx emissions state-wide compared to previous uncontrolled 

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

The Dayton-Springfield area also implemented 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 modeling that indicated this area would 

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

Call. Controls for EGUs formally commenced May 31, 2004. Emissions 
 28 

covered by this program have been generally trending downward since 1998 

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

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

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

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

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

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

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

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

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

which time the CAIR program will supersede it. 

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

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

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

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

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

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

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

2007 controlled NOx emissions will be 599 tons per day. 

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. 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, including sport utility vehicles (SUVs). 

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

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

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

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

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

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

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

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

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

Heavy-Duty Diesel Engines 

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

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

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

diesel trucks and buses. This rule will result in a 40 percent reduction in NOx
 29 

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

inventory. 

Clean Air Non-road Diesel Rule 

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

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

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

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

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

in this rule, currently accounts for 47 percent of diesel particulate matter (PM) 

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

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

approximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New 

engine standards take effect, based on engine horsepower, starting in 2008. 

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

ozone precursors. 

Requirement 3 of 4:

Acceptable provisions to provide for new source review. 

Background: 

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

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

provisions for the Prevention of Significant Deterioration (PSD) permitting 

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

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

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

Demonstration: 

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

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

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

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

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

through the PSD program. 

Requirement 4 of 4:

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

demonstrates through photochemical modeling that the standard can be maintained without 

one (1) or more controls. 

Demonstration: 

Ohio commits to maintaining the aforementioned control measures after 

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

emission limits applicable to VOC and/or NOx sources, as required for 
 30 

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 section, has the legal authority and 

necessary resources to actively enforce any violations of its rules or permit 

provisions. After redesignation, it intends to continue enforcing all rules that 

relate to the emission of ozone precursors in the Dayton-Springfield, OH 

area.

LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment 

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

Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This 

modeling was originally designed to assess the one-hour ozone standard. Further 

analysis was conducted and documented in the LADCO’s White Paper “8-Hour 

Ozone Assessment” dated May 2, 2001. Base year design values used were the 

average of the design values for the three (3) three-year periods (1994-1996, 1995-

1997, and 1996-1998). Base year emissions were taken from 1996 and four (4) 

ozone episodes were evaluated: June 22-28, 1991; July 14-21, 1991; 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. NOx emissions will be cut 

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

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

LADCO performed modeling to support the associated emission reductions for 

CAIR. This modeling was based on 2001 – 2002 design values for 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. 
 31 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4:

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

Demonstration: 

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

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

Requirement 2 of 4:

A commitment to expeditiously enact and implement additional contingency control 

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

that future violations of the ambient standards occur. 

Demonstration: 

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

Warning Level Response: 

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

fourth high monitored value of 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 indicates a trend toward higher ozone 

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

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

necessary to reverse the trend taking into consideration ease and timing for 

implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

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

(September 30). 

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

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

and implementation outlined under action level response shall be followed. 

 
 32 

 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 unnecessary. Furthermore, Ohio will 

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

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration: 

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the time 

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

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

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

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

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

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

below is not comprehensive. 

1) Lower Reid vapor pressure gasoline program. 

2) Tighten RACT on existing sources 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 retrofit programs for fleet vehicle 

operations. 

5) Controls on consumer products consistent with those adopted 

elsewhere in the United States. 

6) Require VOC or NOx emission offsets for new and modified major 

sources. 

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

sources. 

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

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

tons). 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

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

be fully evaluated. 

Requirement 4 of 4:

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

Demonstration: 

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

controls. 

NOx RACT 

• EGUs 

• asphalt batching plants 

• industrial/commercial and institutional boilers 

• process heaters 

• internal combustion engines 

• combustion turbines 

• other sources greater than 100 tons per year 
 34 

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 year 
 35 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

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

concerning the draft redesignation petition and maintenance plan. 

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

31, 2013, at the Ohio EPA Southwest District Office located at 401 East Fifth Street, 

Dayton, Ohio. The public comment period closed on January 31, 2013. No comments were 

received. A copy of the public notice and the transcript from the public hearing is included in 

Appendix D. 
 36 

CHAPTER EIGHT 

CONCLUSIONS

The Dayton-Springfield, OH basic nonattainment area has attained the NAAQS standard 

and complied with the applicable provisions of the 1990 Amendments to the CAA regarding 

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

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

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

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

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

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

requirements necessary for redesignation have been met. 

Based on this presentation, the Dayton-Springfield, 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 NOx reductions will ensure continued compliance (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 attainment simultaneously with U.S. EPA approval 

of the Ohio state implementation and maintenance plan provisions contained herein. In 

addition, the State of Ohio requests that this maintenance plan satisfy the requirements of 

CAA Section 175A (b), for subsequent plan revisions required for areas redesignated for 

the one-hour ozone standard, as was the case with the Dayton-Springfield, OH 

nonattainment area. 

 
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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 approved this requests on 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. 

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

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

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

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

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

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

grammar, and formatting conventions. 

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

original submittal, as follows: 

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

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

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

modeling protocol document submitted in 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 contains 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 and 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

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March 8, 20071

 

 

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

request
 

Revised February 20132

 

2 Revised- update mobile emissions budgets using MOVES2010 model
 

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 i 

TABLE OF CONTENTS 

Chapter One 

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

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

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

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

Chapter Two 

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

Chapter Three 

Ozone monitoring .......................................................................................................................... 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 ........................................................................................ 27 

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 NOx sources...................................................................................................... 33 

Chapter Seven 

Public participation ...................................................................................................................... 35 

Chapter Eight 

Conclusions ............................................................................................................................ 3536
 ii 

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 NOx 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 NOx Emission Inventory Clark County ................................................................. 20 

Table 10 NOx Emission Inventory Greene County ............................................................. 20 

Table 11 NOx Emission Inventory Miami County ................................................................ 21 

Table 12 NOx Emission Inventory Montgomery County ..................................................... 21 

Table 13 NOx 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 Ohio University Report (E-Check) 

E Modeled Attainment Demonstration 

FD Public Participation Documentation 
 iii 

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 1 

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 air quality standards for ozone replacing the 

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

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

February of 2001. 

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

standard, effective June 15, 2004. Since that time, U.S. EPA has reclassified nine of the 

134 original nonattainment areas to the next lower classification. Section 107(d)(3)(E) of 

the CAA allows states to request nonattainment areas be redesignated to attainment 

providing certain criteria are met. The following are the criteria that must be met in order for 

an area to be redesignated from nonattainment to attainment: 

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

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

110(k).

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

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

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

met. 

 

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 (NOx) 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 attainment 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 located 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 guidance in a document entitled Procedures for 

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

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

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

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

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

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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 NOx allowances. This package is under 

review by U.S. EPA. 

 While no replacement package will have 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 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 the replacement programs not be approved, 

modeling has been performed by Ohio University 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. There 

is 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-Springfield, 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 redesignations because they only have 

meaning for areas not attaining the standard. The requirements for an 

emission inventory will be satisfied by the inventory requirements of 

the maintenance plan. 

 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 addressing 
 6 

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 area 

can 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 will implement all measures contained in 

the nonattainment SIP prior to redesignation. 

States seeking redesignation of a nonattainment area should consider the 

following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 

 Chapter six discusses this requirement in more detail and provides the 

attainment demonstration. 
 7 
 8 

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 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 

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 9 

Requirement 2 of 4: 

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

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

Demonstration: 

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

with 40 CFR 58.10 and 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-454/R-98-017, December 1998. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

called the site's design value. Table 1 shows the monitoring data for 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

1st 2nd 3rd 4th 2004-2006 

SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE 

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 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 rule 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 NOx SIP Call) has significantly 

reduced emissions from large electric generating units (EGUs), industrial 

boilers, and cement kilns. Ohio's NOx Budget Trading Program Rule was 

approved on May 25, 2004 Ohio Administrative Code (OAC) Chapter 3745-

14. It is expected that 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. 

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Demonstration: 

 Ohio EPA commits to continue monitoring 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 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 site3

 will provide real time availability of the data and knowledge of any 

exceedances. Ohio EPA will enter all data into AQS on a timely basis in 

accordance with federal guidelines. 

 

3

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

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CHAPTER FOUR 

EMISSION INVENTORY

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

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

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

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

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

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

Other emissions inventory related requirements include a projection of the emission 

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

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

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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 NOx 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 NOx 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 NOx 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 comprehensive inventory for the Dayton-Springfield, OH area 

including area, mobile, and point sources for precursors of ozone (VOCs and NOx) 

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 compiled from Ohio EPA’s 2002 annual 

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

acid rain database4

. 

• Biogenic emissions are not included in these summaries. 

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

Inventory Model (NMIM) 2002 application. To address concerns 

about the accuracy of some of the categories in U.S. EPA’s non-road 

emissions model, LADCO contracted with two (2) companies to 

review the base data and make recommendations. One of the 

contractors also estimated emissions for three (3) non-road categories 

not included in U.S. EPA’s non-road model. Emissions were estimated 

for aircraft, commercial marine vessels and railroads. Recreational 

motorboat population and spatial surrogates (used to assign 

emissions to each county) were significantly updated. The populations 

for the construction equipment category were reviewed and updated 

based upon surveys completed in the Midwest and the temporal 

allocation for agricultural sources also was updated. 

 

 

Demonstration: 

On-Road Emission Estimations 

The Miami Valley Regional Planning Commission (MVRPC) and the Clark CountySpringfield Transportation Coordinating Commission (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 

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planning tool to evaluate the transportation system including determination of 

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

infrastructure requirements necessary to meet that need. 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 areas 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, NOx

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

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

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

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

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

are traveling on facilityroad types (MOBILE6.2 facilityMOVES2010 road types are 

Freeway, Arterial, LocalRural Restricted Access, Rural Unrestricted Access, Urban 

Restricted Access, and Ramp) and theUrban Unrestricted Access). The vehicle 

speeds also affect the emission factor values. Meteorological conditions 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 and agreed to by U.S. EPA and 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 the total VMT of the analyzed area to get 

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

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

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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 vehicle fleet on that facility. Then, the 

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

regarding traffic volumes and facility type which is then “looked-up” in the 

appropriate emission factor table. It should be noted that speed is estimated 

as a post process to the travel demand model. Speeds are not taken directly 

from the travel demand model. The post process for emissions analysis by 

Ohio DOT is by hour of day. This emission factor is multiplied by the link’s 

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 analyzed will have different emission 

factors, volumes, speeds and roadway networks. 

Some of the assumptions built into MOBILE6.2 are: older vehicles have much higher 

emission factors than newer vehicles, diesel vehicles have much higher NOx 

emission factors and lower VOC emission factors than gasoline vehicles, and higher 

average speeds have lower emission factors except for diesel vehicles which have 

higher NOx at higher speeds. 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 intrazonal emissions. Total emissions are sum 

of on-road vehicle emissions, vehicle-based emissions and intrazonal emissions. 

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

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

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

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

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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, 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 request include 2002, 2005, 2009, and 2018 to 

meet the requirements specified by the 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 contain 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 emissions analysis for the Dayton-Springfield 

area (Clark, Greene, Miami and Montgomery counties). Please note the 

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analysis includes a scenario for 2005 showing results without an 

Inspection/Maintenance (I/M) program.

Table 2 - Combined VOC and NOx 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

NOx (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 

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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 NOx. These 

correspond to a 15 percent safety margin above the 2018 on-road emissions 

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

emissions. 

The 2005 budget which will 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 longer 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 projections for the Dayton-Springfield, OH 

area using the following approaches. 

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

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

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

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

019. 

• Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. LADCO 

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

categories. These files were used to develop the future year 

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

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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 initial 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 NOx

budgets from the Ohio NOx rule. 

The following tables include sectors Electrical Generating Unit (EGU-Point), 

Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), 

Other (Area), 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

Other (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

 

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 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 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

Other (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

 

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 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

Other (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 55.574

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

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 Table 9 Clark County NOx 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 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 NOx 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 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

 

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 Table 11 Miami County NOx 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 NOx 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 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

 

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Table 13 Dayton-Springfield, OH area NOx 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. 

 

NOx 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 NOx

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 

VOC 18.2521.62 17.4518.53 0.803.09

NOx 15.8319.00 6.357.70 9.4811.30

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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

NOx 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 

VOC 12.1214.55 10.2888 1.843.67

NOx 11.8514.01 78.09 4.765.92

Table 17 Montgomery 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 48.2762.61 39.2243.47 9.0519.14

NOx 74.8486.60 43.3148.83 31.5337.77

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 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

NOx 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. However, cleaner vehicles and fuels are 

expected to be in place in 2009 and 2018 and result in an overall drop in 

VOC emissions. 

NOx emissions in the nonattainment area are projected to decrease by 

53.6564.74 tons. Decreases from U.S. EPA rules covering Tier 2 Motor 

Vehicle Emissions Standards and Gasoline Sulfur Control Requirements5, 

Highway Heavy-Duty Engine Rule6

 and Non-Road Diesel Engine Rule7 also 

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

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

area also will be decreased. 

Requirement 4 of 5: 

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

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

not on temporary adverse economic conditions or unusually favorable meteorology. 

Background: 

Ambient air quality data from 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-AIR/2000/February/Day-10/a19a.htm 6 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 7 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 

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

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

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

NAAQS.” 

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

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

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

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

(CERR). Ohio 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 NOx

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 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 NOx 7896.45 63.8884.66 65.44

EGU NOx 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. 

 

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Demonstration: 

As required by Section 175A(b) of the CAA, Ohio commits to submit to the 

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

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

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

period after redesignation. 

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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 existing stationary sources covered by Control 

Technology Guidelines (CTG) as applied in Ohio’s rural counties. 

Background: 

As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were no 

specific rules required by the CAA such as RACT for existing sources beyond 

statewide rules. 

Demonstration: 

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

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

 

Requirement 2 of 4:

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

implemented. 

Background: 

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

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

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

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

percent of all NOx emissions state-wide compared to previous uncontrolled 

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

The Dayton-Springfield area also implemented 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 modeling that indicated this area would 

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

Call. Controls for EGUs formally commenced May 31, 2004. Emissions 
 35 

covered by this program have been generally trending downward since 1998 

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

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

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

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

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

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

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

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

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

which time the CAIR program will supersede it. 

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

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

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

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

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

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

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

2007 controlled NOx emissions will be 599 tons per day. 

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. 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, including sport utility vehicles (SUVs). 

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

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

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

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

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

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

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

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

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

Heavy-Duty Diesel Engines 

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

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

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

diesel trucks and buses. This rule will result in a 40 percent reduction in NOx
 36 

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

inventory. 

Clean Air Non-road Diesel Rule 

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

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

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

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

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

in this rule, currently accounts for 47 percent of diesel particulate matter (PM) 

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

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

approximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New 

engine standards take effect, based on engine horsepower, starting in 2008. 

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

ozone precursors. 

Requirement 3 of 4:

Acceptable provisions to provide for new source review. 

Background: 

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

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

provisions for the Prevention of Significant Deterioration (PSD) permitting 

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

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

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

Demonstration: 

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

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

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

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

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

through the PSD program. 

Requirement 4 of 4:

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

demonstrates through photochemical modeling that the standard can be maintained without 

one (1) or more controls. 

Demonstration: 

Ohio commits to maintaining the aforementioned control measures after 

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

emission limits applicable to VOC and/or NOx sources, as required for 
 37 

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 section, has the legal authority and 

necessary resources to actively enforce any violations of its rules or permit 

provisions. After redesignation, it intends to continue enforcing all rules that 

relate to the emission of ozone precursors in the Dayton-Springfield, OH 

area.

LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment 

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

Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This 

modeling was originally designed to assess the one-hour ozone standard. Further 

analysis was conducted and documented in the LADCO’s White Paper “8-Hour 

Ozone Assessment” dated May 2, 2001. Base year design values used were the 

average of the design values for the three (3) three-year periods (1994-1996, 1995-

1997, and 1996-1998). Base year emissions were taken from 1996 and four (4) 

ozone episodes were evaluated: June 22-28, 1991; July 14-21, 1991; 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. NOx emissions will be cut 

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

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

LADCO performed modeling to support the associated emission reductions for 

CAIR. This modeling was based on 2001 – 2002 design values for 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 implement additional contingency control 

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

that future violations of the ambient standards occur. 

Demonstration: 

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

Warning Level Response: 

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

fourth high monitored value of 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 indicates a trend toward higher ozone 

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

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

necessary to reverse the trend taking into consideration ease and timing for 

implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

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

(September 30). 

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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 unnecessary. Furthermore, Ohio will 

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

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration: 

Contingency measures to be considered will be selected from a 

comprehensive list of measures deemed appropriate and effective at the time 

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

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

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

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

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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 sources 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 retrofit programs for fleet vehicle 

operations. 

5) Controls on consumer products consistent with those adopted 

elsewhere in the United States. 

6) Require VOC or NOx emission offsets for new and modified major 

sources. 

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

sources. 

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

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

tons). 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

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

be fully evaluated. 

Requirement 4 of 4:

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

Demonstration: 

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

controls. 

NOx RACT 

• EGUs 
 41 

• asphalt batching plants 

• industrial/commercial and institutional boilers 

• process heaters 

• internal combustion engines 

• combustion turbines 

• other sources greater than 100 tons per year 

VOC RACT 

• consumer products 

• architectural and industrial maintenance coatings 

• stage I gasoline dispensing facilities (including pressure valves) 

• automobile refinishing shops 

• cold cleaner degreasers 

• 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 year 
 42 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

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

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

county publications on October 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 included 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. 

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CHAPTER EIGHT 

CONCLUSIONS

The Dayton-Springfield, OH basic nonattainment area has attained the NAAQS standard 

and complied with the applicable provisions of the 1990 Amendments to the CAA regarding 

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

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

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

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

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

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

requirements necessary for redesignation have been met. 

Based on this presentation, the Dayton-Springfield, 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 NOx reductions will ensure continued compliance (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 attainment simultaneously with U.S. EPA approval 

of the Ohio state implementation and maintenance plan provisions contained herein. In 

addition, the State of Ohio requests that this maintenance plan satisfy the requirements of 

CAA Section 175A (b), for subsequent plan revisions required for areas redesignated for 

the one-hour ozone standard, as was the case with the Dayton-Springfield, OH 

nonattainment area. 

 

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Technical Memorandum 

MVRPC/Clark County-Springfield TCC SIP Inventory 

Mobile Emissions Estimate (OZONE) 

March 2012 

(Revised November 2012) 

By MVRPC and Ohio Department of Transportation 

In Coordination with Clark County-Springfield 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 Transportation (ODOT), Division of Transportation 

System Development-Modeling and Forecasting Section and the Miami Valley Regional 

Planning Commission (MVRPC) for 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 Springfield Transportation Coordinating Committee (CCS-TCC) serves 

as the Metropolitan Planning Organization (MPO) for Clark County while MVRPC serves as the 

MPO for the remainder counties: Greene, 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 planning assumption requirement. As discussed in 

Section 2 of this report, the modeling process used to develop each MPO emissions is calibrated 

using the latest population and land use data available and is validated using corresponding 

traffic count data. Currently, the travel demand models are validated to year 2000 (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 includes 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 requested 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 demand forecasting models for use in the urban 

transportation planning process. The models employ the traditional four step modeling process 

to project existing and future traffic volumes and travel patterns on the regional transportation 

network. The four step process consists of trip generation, trip distribution, modal split, and 

route assignment. Output from the urban models is link-by-link directional 24-hour traffic 

volumes. 

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 functionality. 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 validated 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 horizon 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 Analyses 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/Springfield_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 been included in this technical memo. 

Figure 2 – CCS-TCC Travel Demand Model Run Directory Structure 

Networks 

Both CCS-TCC and MVRPC’s modeled networks accurately reflect projects in their respective 

TIPs and Long Range Transportation Plans. Project lists can be found online as listed below: 

CCS-TCC 

http://www.clarktcc.com/LRP/2040%20LRP/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 Greene 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 consultation partners (see Appendix A for interagency consultation 

documentation). 

On the employment side, adjustments were made primarily to account for manufacturing job 

loses between 2000 and 2010, recognizing that the local economy is moving away from a 

manufacturing base and to account for 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 any 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 are expected to decline in the older urban 

areas of the region as the trend to develop in the suburban fringes 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 developed for the 2040 LRTP based on the 2000 

Census variables, 2000 employment from QCEW, and 2030 population projections from the 

Ohio Department of Development. Projections were updated and extended to 2040 for the 2012 

Plan based on 2010 census results and known employment changes including: school enrollment, 

hotels, educational and recreational employment, and area type. Independent variables (land 

use/socio-economic data) as provided by CCS-TCC are available for every analysis year. These 

variables are used by ODOT to generate new trip tables for the analysis years: 2002, 2005, 2009, 

2018, and 2040. 

Table 7 shows a summary of CCS-TCC’s socio-economic data. This summary shows a slight 

decline in population, while households and 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) trends for each of the analysis years 2002- 2018-

2040 for the MVRPC (Greene and Montgomery Counties) and CCS-TCC (Clark County) Areas. 

These values represent un-factored travel demand model output. For ozone runs, model VMT is 

factored to represent an average summer day using a seasonal factor of 1.08. Table 8 shows 

VMT for every analyzed year by County. 

Figure 3 – Dayton/Springfield 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 generated for base year-2002 and attainment year2005 to represent the programs being implemented in the D/S Region. Programs and 

corresponding MOVES parameters were developed 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 future 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 generate 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 the MOVES run specification file and the MOVES 

County-Data Manager. Further details in specific inputs that are not using default values are 

provided below. 

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, Miami, 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, NOx, NO, NO2, Total Energy 

Consumption 

Strategies Default values with assumed CNG buses removed 

General Output Units = grams, joules and miles 
Output Emissions Time = hour, Location = custom area, on-road emission rates by 

road type and source use type. 

Advance Performance None 

County Data Manager Sources 

Source Type Population Combination of local and default data 

Local data (2010) ODOT from motor vehicle registration 

Default data used for source types 41, 51, 54, 61, and 62 

Future year growth rate based on MPO model Household 

growth rate. 

Vehicle Type VMT Combination of local and default data 

HPMSVTypeYear VMT = daily VMT from travel demand 

model 

monthVMTFraction = default 

dayVMTFraction=default 

hourVMTFraction=local 

I/M Program I/M program information 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 from NOAA National Climatic Data Center. 

Data will consist of monthly high and low temperatures and 

daily relative humidity for 2002. 

Ramp Fraction Using the base year travel demand model for VHT fractions. 

Future fractions will be assumed constant 

Road Type Distribution Use ODOT county summary VMT categorized by federal 

functional classes 

Age Distribution Combination of local and default data. 

Local data (2010) ODOT from motor vehicle registration 

Default data used for source types 41, 51, 54, 61, and 62 

The same age distribution will be used for all analysis years 

Average Speed Distribution Default 

Alternative Fuel Type Default 
Temperature and Relative Humidity 

Temperatures used for the single season approach are representative of July 2002 based on 

NOAA data from the National Climate Data Center webiste. Data for Wright Patterson AFB 

was used because it was the most complete compared 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 data to MOVES. The average July hourly 

temperature and relative humidity distribution 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 year travel demand model VHT fractions. Ramp 

fractions can be seen in Table 11. Base year fractions were assumed 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 growth rate is based on MPO model household 

growth rate which is 0% in MVRPC. In Clark County cars are an independent 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 adjusted from average number of vehicles to the 

number of vehicles in a summer day. In the absence of data, a 1.08 factor, 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 96,932 105,808 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 2002/2005 input files based on an ASM 2525, biennial 

I/M program, for gasoline-powered 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 information was derived using Ohio Bureau of Motor Vehicle 

registration data for year 2010. The data was given to OEPA who supplied a VIN decoder that 

allowed ODOT to create correctly formatted MOVES inputs. MOVES default data is used for 
source types 41, 51, 54, 61, and 62. The registration data for all three counties in the nonattainment area were combined to create a regional vehicle 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 0.0734
yearid 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 0.0129
yearid 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 0.0443
yearid 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-attainment area. Road type 

distribution can be seen in Table 14.

Table 14 – Road Type Distribution 

sourceTypeID roadTypeID roadTypeVMTFraction 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 Yearly HPMS VMT, but the travel demand model 

was used instead of ODOT’s HMPS data since it was felt that the model would better predict 

future year VMT. ODOT’s CMS post-processor was run for each year to generate congestion 

reports, which includes total daily VMT. The vehicle type percentages of the total VMT were 

based on ODOT’s weigh-in-motion (WIM) data. Since there are not enough WIM stations for 

lower class facilties in the non-attainment area, a statewide average of all ODOT WIM data 

collectors was used. Daily VMT was then converted to yearly. Yearly HPMS VMT for 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 fractions vary for each of the five MOVES road 

types but do not change for each of the 16 MOVES source types. A representative sample of the 

hour VMT fraction input file can be seen in Table 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 0.06051 
sourceTypeID 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 0.00363 
sourceTypeID 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 0.06062 
sourceTypeID 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 month, day of week, hour of the day, pollutant, and 

source type; the rate per distance varies by road type and speed bin. Rates per distance emissions 

are applied to link and intrazonal VMT. 

Table 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 per vehicle) emission file for 

year 2005 with I/M programs. The rate per vehicle varies for any combinations of month, day of 

week, hour of the day, pollutant, and process. Rates per vehicle emissions are applied to the 

vehicle source type population. 

Table 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 vehicle varies for any combinations of month, day of 

week, hour of the day, pollutant, and process. Rates per profile emissions are applied to the 

vehicle souce type population. 

Table 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 directional traffic distributions as well as more up to date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process, described below and 

illustrated in Figure 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 running postcms.exe to calculate hourly link volumes 

based on the percentage of the daily volume (travel demand model output) determined by a 

link’s facility and area type. Link speeds from the travel demand model are not used in the 

analysis. The speeds are estimated as a post-process to the model based on HCM methods using 

a link’s volume-to-capacity ratio and link group code. The daily to hourly volume conversion 

percentages and speed tables can be seen in Appendix B.1. 

The second step (movesnet.exe) uses a combination of the MOVES emission factors and the 

hourly link volumes that are output of the postcms.exe program. The hourly volumes are 

multiplied by the MOVES emission factor for 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 sum of all individual link-hour emissions. 

The third step, (movesveh.exe), calculates vehicle-based emissions (using a combination of the 

Rate per Distance and Rate per Profile files) for each source type for each 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 network, so the fourth step in the process requires a 

separate method to account for those trips that use 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 the 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 estimated intrazonal VMT. The emission rates are 

the same as those used to calculated link based emissions. 

The final step is to summarize link, vehicle, and 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 history of working together in air quality 

issues, the Memorandum of Understanding, listed below, documents these working relationships. 

The document is in the process of being signed by all parties involved. 

• Memorandum of Understanding among the MVRPC, 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, Monica Drake, Mark Byram, Nino Brunello, 

and Andrew Shepler, Jennifer Hunter - OEPA, 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/Springfield 8-Hour Ozone SIP Maintenance Plan. 

The SIP revision will update the mobile source HC and NOx budgets to reflect US EPA’s 

new MOVES software emission results. The SIP revision will be reviewed and approved 

via the federal register process. 

Pat Morris confirmed that a full SIP revision is needed. She also confirmed that only the 

mobile source emissions will be updated, not point, area, etc. 

Analysis years will be consistent 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. Temperature minimum and 

maximum were provided by OEPA, correspondence is on file at ODOT and included in 

technical MPO memos. For MOBILE6 runs, hourly temperatures were established based 

on a daily profile ODOT developed from 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 conditions based on the 2010 Census and current 

Transportation Plan. 

Emissions parameters will be consistent with 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 completed. 2005 will also be looked at prior to 

submission of the SIP. 

Nino requested that for Ozone emissions, MOVES emission factors by source type (ie 

vehicle class) be used instead of the aggregated 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 request was approved. MVRPC agreed contingent 

on the results of comparisons between aggregate versus disaggregate emission factor 

methods. To insure deadlines are met, Nino will run the aggregate methodology first in 

case he runs into problems 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 submitted to OEPA & US EPA by mid-November. 

3) The deadline for approved budgets is mid-February. OEPA will need three 

months to process. 

4) US EPA will complete as much as possible concurrently with OEPA. Pat Morris 

stated that she will need 90 days and will 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 Manager are shown below. Further details in specific inputs that 

are not using default values are provided below. 

Parameters used for ozone analyses are similar to those used for PM analyses with the 

exception of: pollutants, additional profile emissions, analysis 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, Miami, 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, NOx, NO, 

NO2, 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 Combination of local and default data 

Local data (2010) ODOT from motor vehicle 

registration 

Default data used for source types 41, 51, 54, 61, and 

62 

Future year growth rate based on MPO model 

Household growth rate. 

Vehicle Type VMT Combination of local and default data 

HPMSVTypeYear VMT = daily VMT from travel 

demand model 

monthVMTFraction = default 

dayVMTFraction=default 

hourVMTFraction=local 

I/M Program I/M program information 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 year travel demand model for VHT 

fractions. Future fractions will be assumed constant 

Road Type Distribution Use ODOT county summary VMT categorized by federal 

functional classes 

Age Distribution Combination of local and default data. 

Local data (2010) ODOT from motor vehicle 

registration 

Default data used for source types 41, 51, 54, 61, and 

62 

The same age distribution will be used for all analysis 

years 

Average Speed Distribution Default 

Alternative Fuel Type Default 
From: Brunello, Nino [mailto:Nino.Brunello@dot.state.oh.us] 

Sent: Thursday, April 19, 2012 2:30 PM 

To: PJividen@AkronOhio.gov; CBaker@akronohio.gov; Jeff Dutton; Bill Davis; Nick Gill 

(NGILL@morpc.org); Ramirez, Ana; Saleem Salameh; Lima (tmazur@lacrpc.com); 

smapel@lcounty.com; 'randy.durst@movrc.org' (randy.durst@movrc.org); 

sschmid@clarkcountyohio.gov; mikepap@bhjmpc.org; David Gedeon; 

rsharma@belomar.org; krodi@eastgatecog.org 

Cc: Fred Durham; Dines, Jennifer; Patricia Morris (Morris.Patricia@epamail.epa.gov) 

(Morris.Patricia@epamail.epa.gov); Moore, Dave; Byram, Mark 

Subject: FW: Ozone Summer Day Factors 

All: 

After discussions with ODOT, OEPA, WVDEP, and USEPA, we are of the opinion that 

there needs to be an additional seasonal factor for summer when calculating ozone 

pollutants. 

There is currently an adjustment for increasing average daily VMT (+ 8%) which was 

used in previously when using Moblie6 to generate emission factors. With MOVES, 

there is a vehicle component used in addition to VMT, so there needs to be an 

adjustment from average number of vehicles to the number of vehicles in summer day. 

We propose to use the same 8% increase. 

We need to have an inter-agency agreement on this, and would prefer to do it via email 

(to make it easier on all of us). Please respond with your approval and/or questions. 

Thanks, 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

Nino Brunello, P.E. 

Modeling & Forecasting Section 

Division of Planning 

Ohio Department of Transportation 

(614) 752-5742 

From: Dines, Jennifer 

Sent: Thursday, April 12, 2012 9:04 AM 

To: Brunello, Nino; Durham, William F 

Cc: Moore, Dave 

Subject: RE: Ozone Summer Day Factors 

Nino and Fred, talked to Pat and she agrees that BOTH VMT and number of vehicles 

should have the 1.08 factor applied. 

Pat suggested we should have consultation on this. I told her ODOT is taking the lead on 

this project and I’d let Dave know........she says email is fine. 

Thanks, 

Jennifer Dines 

Manager, State Implementation Plan and Rulemaking Section 
Division of Air Pollution Control 

Ohio Environmental Protection Agency 

Wk (614) 644-3696 

Fax (614) 644-3681 

From: Brunello, Nino 

Sent: Monday, April 09, 2012 12:59 PM 

To: Dines, Jennifer; Durham, William F 

Subject: RE: Ozone Summer Day Factors 

Jennifer/Fred, 

There is another item that needs to be discussed. Since we now calculate emission 

rates for both VMT and number of vehicles, does there need to be a summer adjustment 

factors for vehicles as well? This was not done with MOBILE, so we have nothing to 

follow. If I had to guess, I would think that there would be an increase, but I couldn’t 

guess as to how many or what factor to use. Maybe just use 1.08 in absence of 

anything better? Thoughts? 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

Nino Brunello, P.E. 

Modeling & Forecasting Section 

Division of Planning 

Ohio Department of Transportation 

(614) 752-5742 

From: Dines, Jennifer 

Sent: Monday, April 09, 2012 8:47 AM 

To: Brunello, Nino; Durham, William F 

Subject: RE: Ozone Summer Day Factors 

I’m available 

Jennifer Dines 

Manager, State Implementation Plan and Rulemaking Section 

Division of Air Pollution Control 

Ohio Environmental Protection Agency 

Wk (614) 644-3696 

Fax (614) 644-3681 

From: Brunello, Nino 

Sent: Monday, April 09, 2012 8:30 AM 

To: Durham, William F; Dines, Jennifer 

Subject: RE: Ozone Summer Day Factors 

I can call anytime. Will you both be around at 9:00? If not, when would be the next 

earliest time? (on the half hours) 

-Nino 
From: Durham, William F [mailto:William.F.Durham@wv.gov] 

Sent: Friday, April 06, 2012 8:50 AM 

To: Brunello, Nino 

Cc: Dines, Jennifer 

Subject: Ozone Summer Day Factors 

Nino: 

I spoke with Jenn this morning and outlined the issue of Summer day VMT v. Average 

daily VMT. 

We agreed that Pat Morris may be able to shed some light on the question. 

Jenn & my calendars are open next Mon. and Tues. afternoon. Please give me a call & 

I’ll patch Jenn in. 

Fred
Appendix B 
Appendix B.1 

Post Processing Default Distributions 
HOUR 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 

PCTADT URB FWY 0.9 0.6 0.5 0.6 0.9 2.2 5.2 7.3 6.4 5.2 4.9 5.1 5.3 5.5 6.1 7.2 8.0 7.9 5.8 URB ART 0.7 0.4 0.3 0.3 0.6 1.5 3.5 5.7 5.5 5.1 5.3 6.2 6.5 6.4 6.8 7.6 8.2 8.1 6.2 RUR FWY 1.4 1.1 0.9 1.0 1.3 2.2 3.7 5.2 5.4 5.4 5.6 5.6 5.7 6.0 6.5 7.1 7.5 7.0 5.6 RUR ART 0.8 0.5 0.4 0.5 1.0 2.4 4.8 6.2 5.5 5.3 5.5 5.8 6.0 6.0 6.7 7.6 8.1 7.7 5.6 PCTADT TRK URB FWY 2.1 1.9 1.8 2.0 2.4 3.0 3.9 4.6 5.3 6.0 6.3 6.4 6.4 6.4 6.3 5.8 5.2 4.6 4.1 URB ART 1.1 0.9 1.0 1.2 1.6 2.3 3.9 5.9 6.9 6.7 7.1 7.6 7.4 7.2 7.4 7.2 6.0 5.0 3.7 RUR FWY 2.6 2.2 2.1 2.3 2.6 3.1 3.5 4.0 4.5 5.1 5.6 5.8 5.8 5.8 5.8 5.6 5.3 4.9 4.6 RUR ART 1.5 1.3 1.4 1.6 2.2 3.0 4.2 5.3 6.1 6.7 7.0 7.1 7.0 6.9 6.8 6.3 5.5 4.6 3.8 PCTDIR URB FWY 38 40 40 46 56 64 70 70 68 62 58 52 52 52 50 46 38 38 46 URB ART 44 46 44 48 54 62 66 68 64 56 54 52 50 50 50 46 40 38 46 RUR FWY 44 46 48 54 60 68 68 64 58 54 52 50 50 52 52 48 42 40 44 RUR ART 40 42 44 48 58 66 72 68 60 56 54 50 50 50 50 46 40 38 46 LOS E VC 0 0.625 1.25 1.875 2.5 3.125 3.75 4.375 5 5.625 6.25 6.875 7.5 8.125 8.75 9.375 10 10.625 11.25 SPEEDVC curve1 75 75 75 75 75 75 74.9 74.8 74.6 74.2 73.5 72.3 70.5 67.8 64.2 59.5 54 47.7 41.2 curve2 70 70 70 70 70 70 70 69.9 69.8 69.6 69.2 68.4 67.1 65.1 62.2 58.2 53 47 40.5 curve3 65 65 65 65 65 65 65 65 65 64.9 64.8 64.4 63.8 62.6 60.5 57 52 45.4 37.8 curve4 60 60 60 60 60 60 60 60 60 59.9 59.8 59.6 59.1 58.2 56.7 54.3 50.8 46.1 40.3 curve5 55 55 55 55 55 55 55 55 55 55 55 54.9 54.7 54.3 53.6 52.3 50 46.5 41.5 curve6 60 60 60 60 60 60 60 60 59.9 59.8 59.7 59.4 59.1 58.5 57.7 56.5 55 53.1 50.7 curve7 55 55 55 55 55 55 55 55 54.9 54.9 54.7 54.5 54.2 53.8 53.1 52.2 50.9 49.3 47.3 curve8 50 50 50 50 50 50 50 50 49.9 49.9 49.8 49.6 49.4 49 48.5 47.7 46.7 45.4 43.8 curve9 45 45 45 45 45 45 45 45 45 44.9 44.8 44.7 44.4 44.1 43.6 43 42.1 40.9 39.4 curve10 50 50 50 50 49.9 49.8 49.7 49.4 49 48.4 47.5 46.5 45.1 43.5 41.7 39.6 37.3 34.9 32.4 curve11 50 50 50 50 50 49.9 49.7 49.4 48.9 48 46.7 44.9 42.5 39.6 36.2 32.6 28.7 25 21.4 curve12 50 50 50 50 50 49.9 49.8 49.6 49.1 48.2 46.8 44.5 41.4 37.5 32.9 28 23.1 18.7 14.9 curve13 40 40 40 40 40 40 39.9 39.8 39.5 39.2 38.6 37.8 36.7 35.3 33.5 31.4 29 26.4 23.7 curve14 40 40 40 40 40 39.9 39.8 39.6 39.1 38.5 37.5 36.1 34.3 32.1 29.4 26.5 23.5 20.5 17.7 curve15 40 40 40 40 40 39.9 39.7 39.4 38.8 37.9 36.5 34.7 32.3 29.5 26.4 23.2 20 17 14.3 curve16 35 35 35 35 35 34.9 34.8 34.5 34 33.2 32.1 30.5 28.5 26.1 23.5 20.6 17.9 15.2 12.8 curve17 35 35 35 35 35 34.9 34.7 34.4 33.9 33.1 32 30.3 28.3 25.8 23.1 20.3 17.5 14.9 12.5 curve18 35 35 35 35 35 34.9 34.6 34.2 33.5 32.4 30.9 28.8 26.3 23.4 20.4 17.4 14.6 12.1 9.9 curve19 30 30 30 30 30 29.9 29.8 29.5 29 28.2 27.1 25.6 23.7 21.5 19.1 16.6 14.2 12 10 curve20 30 30 30 30 30 29.9 29.7 29.4 28.9 28.1 26.9 25.3 23.4 21.1 18.6 16.1 13.6 11.4 9.5 curve21 30 30 30 30 30 29.9 29.7 29.3 28.7 27.7 26.2 24.4 22.1 19.6 17 14.4 12 9.9 8.1 VC RATIO TO LOS CONVERSION (VALUE SHOWN IS LOWER LIMIT FOR THAT LOS)(URBAN ROADS USE SPEED BREAKS BELOW FOR LOS DETERMINATION) (ALL USE THE BASE VC'S TO DETERMIN BASE RUR2 FWY A 0.00 0.00 0.00 B 0.30 0.00 0.25 C 0.50 0.10 0.40 D 0.70 0.30 0.60 E 0.90 0.50 0.80 F 1.00 1.00 1.00 F+ 1.10 1.10 1.10 F++ 1.30 1.30 1.30 
SPEED VC RATIO BREAKS FOR URBAN STREETS (HIGHEST SPEED FOR GIVEN LOS & FF SPEED) 

FFS B C D E F >47 42. 34. 27. 21. 16. >37 35. 28. 22. 17. 13. >32 30. 24. 18. 14. 10. <33 25. 19. 13. 9. 7. LEVEL OF SERVICE THRESHOLD BY AREA NUM LOS DEFINITION 1 F CINCINNATI,CLEVELAND,COLUMBUS CENTRAL MPO COUNTIES (CUY,FRA,HAM) 2 E OTHER TMA MPOS (AKRON,CANTON,DAYTON,TOLEDO,YOUNGSTOWN + NON-CENTRAL COUNTIES FROM 1) 3 E OTHER MPOS & PARTS OF AREAS 1 & 2 OUTSIDE URBANIZED AREA 4 E RURAL NON MPO COUNTIES PEAK SPREADING MODEL INFO (SET MAX ITERATIONS TO 0 TO DISABLE PEAK SPREADING) MAX VC RATIO FWY: 1.30 MAX VC RATIO ART: 1.30 MAX ITERATIONS : 1000 TRUCK PCE: 2.00 AQ SEASON FACTOR: 1.00 MODEL CLASS PARAMETERS (MAX 4 CLASSES, HOURS 0-23 W/ NO OVERLAP IN CLASS, ALLOCATE ENTIRE CLASS AS TRUCK(1) OR NOT(0)) CLS TRK 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 CLS BEG 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 CLS END 23 23 0 0 0 0 0 0 0 0 0 0 0 0 0 0 CLS NUM 1 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 
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 Agency 

Revisions 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 Environmental Protection Agency (U.S. 

EPA) revise the current maintenance plan for the Dayton-Springfield area, including 

Clark, Greene, Miami and Montgomery Counties, with respect to the 1997 eight-hour 

ozone national ambient air quality standard (NAAQS). Ohio EPA submitted a 

redesignation request and maintenance plan for this area on November 6, 2006 

Subsequently, U.S. EPA approved this requests on August 13, 2007 (72 FR 45169). Air 

quality monitoring data collected in the region demonstrated attainment of the NAAQS 

and there was evidence that the improved air quality is due to permanent, enforceable 

emission reductions. In addition, existing requirements are sufficient to maintain the 

1997 eight-hour ozone standard in this area throughout the maintenance period. 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile 

emission projections and conformity budgets based on emission rates generated from 

U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation 

(MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s 

official emission factor model. 

These actions must be noticed to allow public comment and to satisfy U.S. EPA 

requirements for public involvement in SIP related activities. This notice addresses 

Ohio EPA’s reliance on the emission projections as evidence of attainment and 

maintenance and the commitment to institute contingency measures if ambient 

exceedances or violations trigger the contingency plan requirements. Written comments 

will be received on or before 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 conducted 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 attend or be represented at the hearings and give 
written or oral comments on these changes. All oral comments presented at the 

hearing, and all written statements submitted at the hearing or to the above address by 

the close of business on January 31, 2013 will be considered by Ohio EPA prior to final 

action on this redesignation. Written statements submitted after January 31, 2013 may 

be considered as time and circumstances permit, but will not be part of the official 

record of the hearing. 

This redesignation and maintenance request is available on Ohio EPA DAPC’s Web 

page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx. 

Questions regarding accessing the web site should be directed to Arunee Niamlarb at 

614-728-1342; other questions or comments about this document should be directed to 

either Erica Fetty, (614)-644-2310, Erica.Fetty@epa.state.oh.us or Jennifer Dines at 

(614) 644-3696, Jennifer.Dines@epa.state.oh.us or mailed to Erica Fetty or Jennifer 

Dines at the above address. 
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 

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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.

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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 

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hearing is adjourned. 

Thank you.

(The audiotaped public hearing was 

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

* * *

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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.

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