Mary A. Gade 

Regional Administrator 

R-l9J USEPA, Region 5 

77 West Jackson Blvd. Chicago, Illinois 60604 

U.S. EPA REGION 5 I UmE~mw U~~PAR~QKM~~ I O~ICE OF REOIONll ADMiNISTRATOB 

Re: Ohio Infrastructure SIP 

Dear Ms. Gade: 

I am writing to confirm that the State of Ohio continues to retain the resources 

necessary to evaluate ambient air quality, develop plans to attain new and existing 

ambient air quality standards, run a complete new source review program and 

effectively enforce all applicable requirements. Specifically, the Ohio EPA can 

implement and satisfactorily complete the Section 1 10 requirements listed below. 

We satisfy these requirements for the current and any prospective future air quality 

standards, including thecurrent and prospective standards for ozone and particulate 

matter. 

The SIP elements listed below are required under section 1 1 O(a). Section 1 10(a) 

provides the procedural and timing requirements for SIPS. Section 11 0(a)(2) lists the 

basic or "infrastructure" elements that all SIPS must contain. Following each element 

is Ohio EPAJs discussion as to the Agency's ability to fulfill the requirement. 

Emission limits and other control measures: Section 11 0(a)(2)(A) requires SIPS 

to include enforceable emission limits and other control measures, means or 

techniques, schedules for compliance and other related matters. EPA notes that the 

specific nonattainment area plan requirements of section 11 0(a)(2) are subject to the 

timing requirement of section 172, not the timing requirement of section 110(a), and 

also that SIPS to meet this section are not covered by the Consent Decree. Ohio EPA Response: Ohio EPA continues to staff and implement needed revisions to the State 

Implementation Plans. Ohio Revised Code 3704.03 provides the Director with the 

authority develop rules and regulations necessary to meet state and federal ambient 

air quality standards. 

@ Pnnted on Recycled Paper 

Ted Strickland, Governor 

Lee Fisher, Lieutenant Governor 

Chris Korleski, Director 

Ohio EPA is an Equal Opportunity Employer 
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2007-2008 summarizes the current plans for continued ambient monitoring as agreed 

to during the recent review of the Region 5 monitoring network. 

Program for enforcement of control measures: Section 1 10(a)(2)(C) requires 

States to include a program providing for enforcement of all SIP measures and the 

regulation of construction of new or modified stationary sources to meet prevention of 

significant deterioration (PSD) and nonattainment NSR requirements. 

Ohio EPA Response: 

Ohio EPA continues to staff and implement a vigorous enforcement program. 

Attachment 1 Summary of the 2006 Enforcement Activities demonstrates Ohio EPA's 

continued commitment to assuring compliance from Ohio entities. Ohio Revised 

Code 3704.03 provides the Director with the authority to continue to implement this 

program as well as the updated new source review provisions within OAC 3745-31. 

lnterstate transport: Section 11 0(a)(2)(D) requires SIPS to include provisions 

prohibiting any source or' other type of emissions activity in one State from 

contributing significantly to nonattainment, or interfering with maintenance, of the 

NAAQs in another State, or from interfering with measures required to prevent 

significant deterioration of air quality or to protect visibility in another State. EPA has 

already issued CAlR to assist States in developing SIPS to meet this requirement for 

purposes of the 8-hour Ozone and PM2.5 NAAQS, and has issued separate 

guidance to all States on how to comply with each prong of this statutory provision. 

Ohio EPA Response: 

Ohio EPA has adopted and implemented the various major programs related to the 

interstate transport of pollution. Ohio Administrative Code (OAC) 3745-16 (Stack 

Height Requirements), 3745-1 03 (Acid Rain Permits and Compliance), 3745-1 4 

(Nitrogen Oxides - Budget Trading Program), 3745-109 (Clean Air lnterstate Rule) 

and 3745-108 (Clean Air Mercury Rule) all address Congressional and U.S. EPA 

concerns over the transport of emissions of regulated pollutants beyond our state 

borders. Ohio has also responded to requests by the States of Indiana and West 

Virginia to implement revisions to OAC 3745-18 (Hamilton County and Jefferson 

County) to alleviate modeled violations due, in part, to sources in Ohio. 

Adequate resources: Section 11 0(a)(2)(E) requires States to provide for adequate 

personnel, funding, and legal authority under State law to carry out its SIP, and 

related issues. 
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periodic emissions reports. 

Ohio EPA Response: Ohio EPA District Offices and Local Air Agencies are currently required to witness 

50% of all source testing and review 100% of all tests. 

Emergency power: Section 11 0(a)(2)(G) requires States to provide for authority 

to address activities causing imminent and substantial endangerment to public 

health, including contingency plans to implement the emergency episode provisions in their SIPS. 

Ohio EPA Response: OAC 3745-25 addresses the requirement to implement emergency action plans in 

the event of an Air Quality Alert (or higher). Such an event has not occ~~rred since 

1978 and these rules are awaiting revision to 1) make them more relevant and 2) to 

incorporate revised significant harm levels which U.S. EPA will determine are necessary to address the revised ozone and PM 2.5 standards. 

Future SIP revisions: Section 110(a)(2)(H) requires States to have the authority to 

revise their SIPS in response to changes in the NAAQS, availability of improved 

methods for attaining the NAAQS, or in response to an EPA finding that the SIP is 

substantially inadequate. 

Ohio EPA Response: 

Ohio Revised Code 3704.03 provides the Director with the authority develop rules 

and regulations necessary to meet ambient air quality standards. As was evidenced 

in our June 15, 2007 submittals addressing the eight-hour ozone standard, Ohio EPA 

continues to make every possible effort to meet these deadlines. 

Consultation with government officials: Section 110(a)(2)(J) requires States to 

provide a process for consultation with local governments and Federal Land 

Managers carrying out NAAQS implementation requirements pursuant to section 121 

relating to consultation. 
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NAAQS are exceeded in an area and to enhance public awareness of measures that 

can be taken to prevent exceedances. 

Ohio EPA Response: 

Ohio EPA's district offices and local air agencies monitor air quality daily, and where 

required, report the daily air quality index to the interested media. In addition, Ohio 

EPA's remotes access of data system (RADS) provides online reports of real time air 

quality data on the internet and feeds raw information to U.S. EPA's AIRNOW 

program. In addition, several of the local stakeholder groups actively participate in 

the AIRNOW forecast program. Ohio EPA prepares an annual report, detailing data from the complete network (2006 

Air Quality Report; attachment 4). 

PSD and visibility protection: Section 1 10(a)(2)(J) also requires States to meet 

applicable requirements of part C related to prevention of significant deterioration and 

visibility protection. 

Ohio EPA Response: Ohio EPA is addressing both the long term requirements to meet natural visibility 

levels by 2064 and the ongoing review of new major sources under Ol~io's approved 

Prevention of Significant Deterioration (PSD) new source review program. Ohio EPA 

will be submitting the regional haze /BART SIP later this year and are in discussions 

with interested FLMs regarding proposed major new sources in Ohio. 

Air quality modeling data: Section 110(a)(2)(K) requires that SIPS provide for 

performing air quality modeling for predicting effects on air quality of emissions from 

any NAAQS pollutant and submission of such data to EPA upon request. 

Ohio EPA Response: 

Ohio EPA reviews the potential impact of major and some minor new sources, 

consistent with Appendix W of 40 CFR (51 and 52) and Ohio EPA Engineering Guide 

69. Modeling data are available upon request by U.S. EPA or other interested 

parties. 

Permitting fees: Section 110(a)(2)(L) requires SIPS to require each major stationary 

source to pay permitting fees to cover the cost of reviewing, approving, 

implementing and enforcing a permit. 
Ohio EPA Response: Ohio EPA follows approved procedures for allowing public participation, consistent 

with OAC 3745-47, which is an approved portion of our SIP. 

I believe that Ohio EPA meets or exceeds all of the necessary infrastructure needs, 

enabling us to continue to satisfy these requirements of the requirements of the 

Clean Air Act. If you have any questions, please feel free to contact Bill Spires of the 

Division of Air Pollution Control (61 4-644-361 8). 

Sincerely, be Chris Korleski 

Director 

Bill Spires, DAPC