1
American
Lung
Association
Environmental
Defense
Clean
Air
Task
Force
U.
S.
Public
Interest
Research
Group
Southern
Alliance
for
Clean
Energy
September
1,
2004
Jeffrey
R.
Holmstead
Assistant
Administrator,
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
N.
W.
(
Mailcode
6101A)
Washington,
D.
C.
20460
Stephen
D.
Page
Director,
Office
of
Air
Quality
Planning
and
Standards
U.
S.
Environmental
Protection
Agency
(
Mailcode
C404­
04)
Research
Triangle
Park,
NC
27711
Dear
Mr.
Holmstead
and
Mr.
Page:

Thank
you
for
your
August
5,
2004
response
to
our
letter
commenting
on
the
state's
PM2.5
boundary
recommendations.
We
recognize
EPA
has
recommended
strengthening
some
of
the
state's
recommendations
for
nonattainment
area
boundaries.
However,
EPA
has
left
many
important
counties
out
of
its
recommended
nonattainment
areas.
Therefore,
the
undersigned
public
health
and
environmental
organizations
are
writing
to
urge
EPA
to
reconsider
and
significantly
strengthen
its
recommended
air
quality
designations
for
particulates
of
2.5
microns
in
size
or
smaller
(
PM2.5).
An
alarming
number
of
the
recommendations
contravene
the
law,
EPA's
long­
standing
policy,
good
science,
and
basic
common
sense.

The
nonattainment
designations
serve
two
essential
public
health
functions.
First,
they
establish
the
framework
for
air
quality
management
plans
across
the
country
to
address
harmful
particulate
pollution
levels.
Second,
the
nonattainment
designations
tell
the
public
whether
the
community
where
they
live
and
are
raising
their
families
has
air
that
is
unhealthful.
Such
information
can
and
does
build
public
support
for
the
measures
needed
to
clean
up
the
air.
If
EPA
further
advances
the
narrow
approach
it
has
recommended,
the
nation
would
suffer
severe
public
health
consequences.
It
would,
simply
put,
undermine
the
fundamental
purposes
of
the
nonattainment
designations.
2
EPA
has
recommended
that
244
counties,
including
11
partial
counties
and
several
cities
and
the
District
of
Columbia
be
designated
nonattainment
for
PM2.5.
Our
analysis
found
that
406
counties
should
be
included
in
the
nonattainment
areas
in
order
to
include
complete
C/
MSAs
and
to
properly
control
emissions.
We
are
especially
concerned
that
EPA's
recommendations
left
out
30
coal­
fired
power
plants
that
are
either
in
or
adjacent
to
nonattaining
C/
MSAs.
The
sulfur
dioxide
(
SO2),
totaling
451,453
tons
per
year,
and
nitrogen
oxides
(
NOX),
totaling
164,569
tons
per
year,
from
these
facilities
contribute
greatly
to
fine
particulate
air
pollution.
Clean
up
of
these
power
plants
must
be
an
integral
part
of
state
implementation
plans
to
restore
healthy
air.

The
analysis
below
identifies
numerous
deficiencies
in
EPA's
recommendations
that
threaten
the
nation's
pressing
need
to
protect
public
health
and
lower
the
harmful
concentrations
of
PM2.5.
We
note
that
in
many
cases
a
single
area
may
have
several
different
deficiencies.
The
failure
to
provide
adequate
designations
for
the
health­
based
PM2.5
standard
will
postpone
critical
pollution
reductions,
delay
timely
attainment,
and
prolong
the
exposure
of
children
and
other
vulnerable
populations
to
unhealthy
levels
of
particulate
pollution.

We
respectfully
urge
EPA
to
correct
these
deficiencies.

PRESUMPTIVE
NONATTAINMENT
BOUNDARIES
THAT
CONSTITUTE
THE
FULL
C/
MSAS
ARE
ESSENTIAL
TO
PROTECT
PUBLIC
HEALTH
FROM
HARMFUL
PARTICULATE
POLLUTION
EPA's
August
29,
2003
draft
staff
assessment
of
the
policy
implications
of
scientific
and
technical
information
about
particulate
matter
or
"
staff
paper,"
acknowledges
that
there
is
a
large
body
of
new
health
effects
studies
for
particulates
(
PM),
indicating
further
evidence
of
the
serious
adverse
health
effects
of
the
pollutant.
These
studies
are
based
on
epidemiologic,
toxicological,
controlled
human
exposure,
and
dosimetry
analyses.
1
Any
delay
in
attainment
of
the
PM2.5
national
ambient
air
quality
standard
will
prolong
these
sensitive
groups'
exposure
to
unhealthy
particulate
pollution
levels.

Unfortunately,
many
of
EPA's
recommended
nonattainment
designations
for
the
PM2.5
standard
do
not
encompass
all
counties
in
a
Metropolitan
Statistical
Area
or
Consolidated
Metropolitan
Statistical
Area
(
C/
MSA)
within
which
a
monitored
violation
of
the
standard
has
occurred.
These
recommendations
are
contrary
to
the
Clean
Air
Act,
lacking
in
any
reasoned
basis,
and
must
be
rejected
in
the
absence
of
a
compelling
technical
justification
for
the
smaller
boundary.

The
failure
of
EPA
to
promulgate
protective
nonattainment
designations
would
threaten
vital
public
health
protections.
Many
urban
centers
are
surrounded
by
rapidly
expanding
suburban
counties.
Timely
attainment
of
the
PM2.5
standard
will
depend
on
comprehensive
boundaries
that
ensure
that
all
pollution
sources,
both
existing
and
new,

1
EPA­
452/
D­
03­
001,
August
2003,
First
Draft,
100.
3
are
subject
to
effective
air
pollution
abatement
measures.
In
the
absence
of
a
nonattainment
designation
for
the
entire
C/
MSA,
both
existing
air
pollution
sources
and
growth
in
counties
that
have
been
designated
attainment
or
unclassifiable
will
result
in
increased
air
pollution
just
outside
the
core
nonattainment
counties.
This
unchecked
air
pollution
could
dramatically
undercut
the
emission
reductions
progress
being
made
in
the
core­
designated
counties.
And
this
would
mean
that
critical
progress
in
lowering
particulate
pollution
levels
will
be
stymied.

Narrow
boundaries
will
also
unfairly
distribute
pollution
control
burdens
among
sources
that
contribute
to
the
nonattainment
problem.
The
private
firms
in
the
counties
designated
nonattainment
will
have
to
make
additional
pollution
reductions
to
compensate
for
pollution
abatement
strategies
that
do
not
in
fact
encompass
all
contributing
pollution
sources.
Comprehensive
boundaries
will,
by
contrast,
help
ensure
all
contributing
sources
are
responsible
for
their
share
of
pollution
reductions.

Accordingly,
section
107(
d)(
1)(
A)(
i)
of
the
Clean
Air
Act
(
CAA)
requires
that
all
areas
that
do
not
meet
the
NAAQS
or
that
contribute
to
ambient
air
quality
in
a
nearby
area
that
does
not
meet
the
standard
should
be
designated
nonattainment.
See
42
U.
S.
C.
§
7407(
d)(
1)(
A)(
i).
EPA's
April
1,
2003
memo
providing
guidance
to
states
("
Designations
for
the
Fine
Particle
National
Ambient
Air
Quality
Standards")
advised
states
to
designate
nonattainment
boundaries
that
encompass
all
counties
in
the
C/
MSA.
EPA's
memorandum
finds:
"
The
presumptive
use
of
metropolitan
area
boundaries
to
define
urban
nonattainment
areas
is
based
on
recent
evidence
that
violations
of
the
PM2.5
air
quality
standards
generally
include
a
significant
urban­
scale
contribution
as
well
as
a
significant
larger­
scale
regional
contribution."

Counties
are
included
in
C/
MSAs
because
they
are
part
of
the
complex
transportation
and
economic
network
in
metropolitan
areas.
The
economic
and
transportation
factors
that
qualify
them
for
inclusion
in
a
C/
MSA
are
the
same
factors
that
contribute
to
the
pollution
in
the
area.
Because
C/
MSAs
generally
experience
higher
particulate
pollution
due
to
population
density,
traffic
and
commuting
patterns,
commercial
and
industrial
development
and
area
growth,
EPA's
presumptive
boundary
is
integral
to
ensure
protection
of
public
health
from
the
adverse
effects
of
particulate
pollution.
Due
to
these
important
factors,
if
a
county
in
a
violating
C/
MSA
has
no
monitor,
it
should
not
be
assumed
to
be
attaining
and
left
out
of
the
nonattainment
area.
Through
our
review
of
EPA's
recommendations,
we
have
identified
many
C/
MSAs
where
counties
with
high
or
rising
PM2.5
contributing
pollutants
have
been
inappropriately
excluded.

EPA
Must
Use
The
Most
Recent
OMB
Metropolitan
Boundary
Lists
For
The
Designation
of
Nonattainment
Boundaries
In
order
to
base
these
designations
on
the
most
representative
data
available,
EPA
must
use
the
most
recent
(
2003)
OMB
metropolitan
boundary
lists
for
its
PM2.5
nonattainment
boundary
designations.
This
must
be
done
in
order
to
reflect
current
populations
and
the
4
emissions
resulting
from
those
populations.
Our
comments
in
this
letter
are
based
on
the
2003
OMB
lists.

Designation
of
Attainment/
Unclassifiable
Areas
Must
Be
Consistent
with
the
Mandates
of
the
Prevention
of
Significant
Deterioration
Program
Our
June
16,
2004
letter
to
you
indicated
our
concerns
regarding
the
recommendation
by
several
states
to
divide
the
remainder
of
the
state
into
numerous
"
postage
stamp"
attainment/
unclassifiable
areas.
This
is
the
case
for
Montana,
Utah
and
Wyoming.
We
are
sending
a
more
extensive
letter
to
you,
under
separate
cover,
regarding
this
matter.
We
hereby
incorporate
this
letter
into
these
comprehensive
comments
on
the
PM2.5
boundaries.

SPECIFIC
COMMENTS
ON
DEFICIENCIES
IN
EPA'S
RECOMMENDATIONS
The
discussion
below
examines
some
of
the
specific
problems
with
EPA's
recommended
air
quality
designations
for
PM2.5.
It
is
incumbent
upon
EPA
to
ensure
that
the
final
air
quality
designations
for
PM2.5
are
protective
and
comprehensive,
as
required
by
the
manifest
terms
of
the
statute
and
EPA's
interpretive
policies,
and
are
consistently
and
rationally
implemented
for
all
areas
across
the
country.
All
of
the
comments
below
rely
on
the
2003
OMB
metropolitan
area
lists
and
respond
to
EPA's
boundary
recommendations
outlined
in
letters
sent
to
the
states
at
the
end
of
June
2004.

Alabama
Atlanta
CMSA:
Chambers
County,
Alabama
is
part
of
the
Atlanta
CMSA
but
EPA
did
not
analyze
the
inclusion
of
this
county
in
the
nonattainment
area.
This
county
must
be
included
in
the
Atlanta
nonattainment
area.

Birmingham
CMSA:
In
its
June
29,
2004
letter
to
Alabama,
EPA
recommended
the
inclusion
of
Jefferson,
Shelby
and
Walker
Counties
in
the
PM2.5
nonattainment
area;
in
addition
to
these
counties,
we
recommend
that
Bibb,
Blount,
Chilton,
Cullman,
Etowah
and
St.
Clair
Counties
be
added
to
the
nonattainment
area.
With
the
exception
of
Etowah
County,
these
counties
are
all
part
of
the
Birmingham
CMSA.
EPA
mentioned
that
Walker
County
"
is
contiguous
to
the
MSA "
and
asked
for
the
state
to
comment
on
which
portion
of
the
county
should
be
designated
nonattainment.
The
2003
OMB
metropolitan
area
list
indicates
that,
Walker
County
is
actually
part
of
the
Birmingham
CMSA
and
therefore,
the
entire
county
must
be
included
in
the
nonattainment
area.
According
to
EPA's
letter,
St.
Clair
and
Blount
Counties
both
experienced
around
30%
population
growth
between
1990
and
2000,
suggesting
that
this
high
rate
of
population
growth
may
contribute
to
the
PM2.5
problem
in
the
area.
5
EPA
did
not
recommend
that
Etowah
County
be
part
of
the
nonattainment
area
despite
its
being
adjacent
to
the
nonattainment
area
and
containing
the
Gadsden
power
plant.
According
to
EPA's
2002
Acid
Rain
Database,
this
plant
has
no
SO2
or
NOX
controls
and
the
2002
SO2
emissions
were
8,741
tons
per
year
while
NOX
emissions
were
1,918
tons
per
year.
2
And
the
three­
year
PM2.5
design
value
for
Etowah
County
is
very
close
to
violating
the
annual
standard,
at
14.8
µ
g/
m3.

Columbus
CMSA:
EPA
recommended
that
Lee
and
Russell
Counties
be
designated
nonattainment;
Macon
County
should
be
included
in
the
nonattainment
area
as
well
since
it
is
part
of
the
CMSA.
EPA
mentioned
that
Lee
County
is,
"
adjacent
to
the
MSA,
has
high
VMT
and
a
large
population;"
this
county
is
actually
part
of
the
CMSA
and
therefore
must
be
included
in
the
nonattainment
area.
Despite
the
fact
that
Macon
County
is
part
of
the
CMSA,
EPA's
analysis
failed
to
consider
the
county
when
analyzing
several
factors
for
determining
the
nonattainment
boundary,
including
population
data
and
growth
and
traffic
data
and
VMT
growth.

Chattanooga
CMSA:
EPA
recommended
that
all
or
a
portion
of
Jackson
County
be
included
in
this
nonattainment
area
due
to
large
contributing
facilities.
EPA
asked
the
state
to
recommend
which
portion(
s)
of
this
county
should
be
included
in
the
nonattainment
area.
Our
analysis
found
that
the
Widows
Creek
power
plant
is
located
in
Jackson
County.
This
facility
emits
almost
44,000
tons
per
year
of
SO2
and
over
25,000
tons
per
year
of
NOX.
3
Jackson
County
in
its
entirety
should
be
included
in
the
nonattainment
area.

California
Los
Angeles
CMSA:
The
CMSA
also
includes
Ventura
County,
which
must
be
part
of
the
nonattainment
area.
The
current
PM2.5
three­
year
annual
average
is
14.5
µ
g/
m3,
which
is
very
close
to
the
annual
standard.
The
air
quality
in
this
area
must
be
protected
along
with
the
rest
of
the
Los
Angeles
nonattainment
area.
EPA
has
also
recommended
the
exclusion
of
parts
of
Los
Angeles,
Riverside
and
San
Bernardino
Counties
due
to
low
emissions,
lower
populations
and
physical
separations
from
the
main
portion
of
the
CMSA.
According
to
EPA's
June
29,
2004
letter
to
California,
total
emissions
from
the
excluded
portions
of
these
four
counties
totals
over
65,000
tons
per
year
of
reactive
organic
gas
(
ROG),
98,000
tons
per
year
of
NOX,
over
3,500
tons
per
year
of
SOX
and
over
20,000
tons
per
year
of
PM2.5.
While
these
emissions
do
not
make
up
the
majority
of
emissions
for
the
nonattainment
area,
they
are
nonetheless
significant
enough
to
impact
the
nonattainment
area.
We
emphasize
again
the
importance
of
including
entire
counties
in
this
nonattainment
area.

2
EPA,
Acid
Rain
Database,
"
2002
Unit
Level
Emissions."
3
EPA,
Acid
Rain
Database,
"
2002
Unit
Level
Emissions."
6
Connecticut
New
York­
Newark­
Bridgeport,
NY­
NJ­
CT­
PA
CMSA:
The
entire
CMSA,
including
Litchfield
County
must
be
designated
nonattainment.
EPA
recommended
the
exclusion
of
Litchfield
County
from
the
nonattainment
area
partially
due
to
a
lack
of
monitored
violations;
however,
there
is
no
PM2.5
monitor
in
the
county,
so
it
is
impossible
to
conclude
that
this
county
does
not
violated
the
standard.

District
of
Columbia
Washington­
Baltimore
CMSA:
EPA
has
failed
to
recommend
that
this
CMSA
be
designated
as
one
nonattainment
area;
this
area
must
be
designated
as
one
nonattainment
area.

Georgia
Athens
MSA:
EPA
did
not
recommend
the
inclusion
of
Oglethorpe
County
in
this
nonattainment
area,
but
this
county
is
part
of
the
MSA
and
must
be
included
in
the
nonattainment
boundary.
There
is
no
monitor
in
Oglethorpe
County
to
prove
that
this
county
is
attaining
despite
the
PM2.5
violations
in
Clarke
County.

Atlanta
CMSA:
EPA
did
not
include
all
or
portions
of
Butts,
Dawson,
Haralson,
Heard,
Jasper,
Lamar,
Meriwether,
Pickens,
Pike,
Polk,
Hall,
Troup
and
Upson
Counties
and
Chambers
County,
Alabama
in
the
Atlanta
nonattainment
boundary.
These
counties
are
all
part
of
the
CMSA
and
must
be
included
in
the
nonattainment
area.
Instead,
EPA
listed
Hall,
Heard
and
Jasper
as
being
adjacent
to
the
CMSA
and
recommended
partial
inclusion
in
the
nonattainment
boundary.
We
agree
that
Putnam
County
should
be
included
in
the
nonattainment
area
due
to
the
Harllee
Branch
power
plant
located
in
the
county,
but
for
planning
purposes,
we
believe
that
the
entire
county
should
be
included
in
the
nonattainment
area.

EPA
has
agreed
with
the
state
to
make
Floyd
County
a
separate
nonattainment
area;
this
county
must
be
included
in
the
Atlanta
CMSA
nonattainment
area.
The
Hammond
power
plant,
located
in
Floyd
County
contributes
to
the
nonattainment
problem
in
the
Atlanta
area.
As
for
the
other
counties
that
are
included
in
the
CMSA,
but
not
recommended
to
be
part
of
the
nonattainment
area,
EPA's
letter
to
the
state
does
not
even
address
most
of
these
other
counties.
Thus,
it
appears
that
no
analysis
has
been
done
for
several
counties
that
are
part
of
the
CMSA
and
these
counties
must
be
included
in
the
nonattainment
area.

Augusta
MSA:
Correspondence
between
the
State
and
EPA
indicates
that
Richmond
County
may
be
on
the
verge
of
nonattainment.
Georgia
had
originally
recommended
that
this
county
be
designated
nonattainment,
but
both
the
State
and
EPA
since
determined
that
incomplete
data
capture
at
one
of
the
monitoring
sites
should
lead
to
an
attainment/
unclassifiable
7
determination.
According
to
the
State's
June
15,
2004
letter
to
EPA,
the
monitor
with
complete
data
(
after
data
substitution)
has
a
design
value
of
14.8
µ
g/
m3,
very
near
the
PM2.5
annual
standard.
EPA's
AirData
website
indicates
that
the
2001­
2003
design
value
for
the
monitor
with
incomplete
data
is
15.2
µ
g/
m3.
While
we
recognize
that
an
area
can
not
be
designated
nonattainment
with
incomplete
data,
we
request
that
EPA
and
the
State
be
diligent
in
collecting
complete
data
for
this
area
in
order
to
determine
whether
this
area
is
indeed
attaining
the
standard.
Due
to
the
monitoring
data
showing
that
are
quality
is
most
likely
poor,
this
area
should
receive
an
unclassifiable
designation
at
the
most.

Columbus
CMSA:
EPA
has
not
recommended
the
inclusion
of
the
CMSA
counties
of
Chattahoochee
and
Marion
in
the
nonattainment
area.
Our
letter
to
you
indicated
that
Troup
County
should
be
analyzed
for
its
impact
on
the
nonattainment
problem.
According
to
EPA's
June
29,
2004
letter
to
Georgia,
Troup
County's
NOX
emissions
were
over
twice
as
high
as
any
of
the
counties
EPA
has
recommended
for
nonattainment
in
this
area.
Primary
PM
and
VOC
emissions
in
Troup
County
also
appear
to
be
high.

Macon
CMSA:
EPA
has
not
recommended
that
Crawford,
Jones,
Peach,
Houston,
and
Twiggs
Counties
be
part
of
the
nonattainment
area
despite
the
fact
that
these
counties
are
all
part
of
the
CMSA.
These
counties
must
be
included
in
the
nonattainment
area.
In
addition,
EPA
has
only
recommended
that
part
of
Monroe
County
be
included
in
the
nonattainment
area;
as
this
county
is
also
part
of
the
CMSA,
the
entire
county
must
be
included
in
the
nonattainment
area.
Although
EPA
has
assumed
that
air
quality
in
the
other
counties
is
clean,
Crawford,
Jones,
Peach
and
Twiggs
Counties
have
no
monitors
in
order
to
determine
whether
those
counties
are
attaining
or
not.
While
Houston
County's
monitor
is
attaining,
at
12.8
µ
g/
m3,
the
county
has
the
second
largest
population
for
the
CMSA,
after
Bibb
County,
at
35%.
In
addition,
Houston
County
is
experiencing
much
faster
growth
than
is
Bibb
County,
with
24%
growth
between
1990
and
2000.

Illinois
Chicago
CMSA:
EPA
failed
to
include
DeKalb,
Kankakee
and
parts
of
Grundy
and
Kendall
Counties
in
its
recommended
nonattainment
boundary
for
the
Chicago
CMSA.
These
areas,
in
entirety,
must
be
included
in
the
nonattainment
area.
In
addition,
adjacent
La
Salle
County
appears
to
have
high
emissions,
while
the
design
value
for
this
area
is
14.1
µ
g/
m3.
This
county
should
be
analyzed
for
its
impact
on
the
nonattainment
problem
in
the
Chicago
area.

St.
Louis
CMSA:
EPA
failed
to
include
Bond,
Calhoun,
Clinton,
Jersey,
Macoupin,
Montgomery,
Morgan
and
Sangamon
Counties
in
its
recommended
nonattainment
area.
EPA
recommended
that
Randolph
County
be
designated
nonattainment
as
part
of
the
St.
Louis
area,
but
is
allowing
for
the
State
to
submit
further
information
documenting
a
justification
for
8
including
only
a
portion
of
the
county
in
the
nonattainment
area.
Although
Montgomery,
Morgan
and
Sangamon
Counties
are
not
part
of
the
CMSA,
they
all
contain
power
plants
that
must
be
analyzed
for
their
impacts
on
the
nonattainment
problem.
In
2002,
these
four
plants
together
emitted
over
78,000
tons
of
SO2
and
over
27,000
tons
of
NOX.
4
Indiana
Chicago
CMSA:
EPA
failed
to
include
Jasper,
La
Porte
and
Newton
Counties
in
its
recommendation
for
the
Chicago
nonattainment
area.
These
counties
are
all
part
of
the
CMSA
and
must
be
designated
nonattainment.
EPA
concluded
that
La
Porte
County
is
adjacent
to
the
CMSA
and
does
not
contribute
to
nonattainment
in
the
Chicago
area.
This
county
is
actually
included
in
the
CMSA,
and
contains
a
coal­
fired
power
plant.
Jasper
County
also
contains
a
coal­
fired
power
plant.
Jasper
and
Newton
Counties
do
not
have
monitors
in
order
to
determine
whether
these
areas
are
attaining.

Cincinnati
CMSA:
EPA
failed
to
recommend
a
portion
of
Dearborn
County
and
Franklin
and
Ohio
Counties
for
nonattainment.
These
counties
are
all
part
of
the
CMSA
and
must
be
included
in
the
nonattainment
area
in
entirety.
It
is
of
particular
importance
that
the
coal­
fired
power
plant
in
Dearborn
County
be
included
within
the
nonattainment
area
boundaries.

Evansville
MSA:
EPA
failed
to
recommend
that
Posey
and
Knox
Counties
be
included
in
the
nonattainment
area.
Posey
County,
inside
the
MSA,
is
home
to
a
coal­
fired
power
plant
and
must
be
included
in
the
nonattainment
area.
In
2002,
the
A.
B.
Brown
facility
emitted
almost
9,000
tons
of
SO2
and
over
7,000
tons
of
NOX.
5
Knox
County,
adjacent
to
the
MSA,
also
contains
a
coal­
fired
power
plant
(
Edwardsport)
that
emitted
over
8,000
tons
of
SO2
and
almost
2,000
tons
of
NOX
in
2002.6
Neither
of
these
counties
contains
monitors.

Indianapolis
CMSA:
EPA
did
not
include
10
counties
in
its
recommended
nonattainment
area
for
the
Indianapolis
CMSA.
Those
counties
are:
Bartholomew,
Boone,
Brown,
Hancock,
Henry,
Jennings,
Madison,
Montgomery,
Putnam,
and
Shelby.
The
entire
CMSA
must
be
designated
as
one
nonattainment
area.

Louisville
CMSA:
EPA
failed
to
recommend
that
Harrison,
Scott
and
Washington
Counties
be
included
in
the
nonattainment
area.
None
of
these
counties
contain
monitors
in
order
to
determine
whether
they
are
attaining,
but
since
they
are
all
part
of
the
CMSA,
they
must
be
included
in
the
nonattainment
area.

4
Id.
5
EPA,
Acid
Rain
Database.
6
Id.
9
Kentucky
Cincinnati
CMSA:
EPA
failed
to
include
Bracken,
Carroll,
Gallatin,
Grant,
Mason
and
Pendleton
Counties
in
its
recommended
nonattainment
area.
Bracken,
Gallatin,
Grant
and
Pendleton
Counties
are
all
part
of
the
nonattainment
area
and
must
be
designated
nonattainment.
Carroll
and
Mason
Counties
are
adjacent
to
the
CMSA,
but
both
contain
high
emitting
coal­
fired
power
plants
and
therefore
should
be
included
in
the
nonattainment
area
due
to
their
probable
contribution
to
the
poor
air
quality
in
the
Cincinnati
area.
EPA's
June
29,
2004
letter
to
the
State
explains
that
these
counties
should
be
designated
attainment/
unclassifiable
despite
their
power
plants
because
they
have
low
population,
population
growth
and
VMT.
These
factors
do
not
change
the
important
fact
that
the
Ghent
electric
generating
facility
in
Carroll
County
produced
over
46,000
of
SO2
and
over
19,000
tons
of
NOX
while
the
H.
L.
Spurlock
power
plant
in
Mason
County
emitted
over
40,000
tons
of
SO2
and
over
8,000
tons
of
NOX
in
2002.7
Regardless
of
population
in
these
counties,
these
high
emitting
plants
must
be
controlled
for
their
impact
on
the
nonattainment
problem
in
the
Cincinnati
area.

Evansville
MSA:
Our
June
16,
2004
letter
to
you
indicated
that
the
Kentucky
portions
of
the
Evansville
MSA
must
be
designated
nonattainment
along
with
the
Indiana
portion
of
this
MSA.
But
EPA
has
failed
to
recommend
that
this
area
be
designated
nonattainment.
Henderson
and
Webster
Counties
must
be
included
in
this
nonattainment
area.
In
addition,
Daviess
County,
adjacent
to
the
MSA,
must
be
included
in
the
nonattainment
area.
There
are
two
coal­
fired
power
plants
in
both
Webster
and
Henderson
Counties
while
the
Elmer
Smith
power
plant
is
located
in
Daviess
County.
Together,
these
facilities
emitted
almost
25,000
tons
of
SO2
and
almost
24,000
tons
of
NOX
in
2002.
These
power
plants
are
most
likely
important
factors
in
the
area's
nonattainment
problem
and
must
be
controlled.
8
Huntington
MSA:
EPA
failed
to
include
Greenup
County,
part
of
the
MSA,
in
its
recommended
nonattainment
area.
There
is
no
monitor
in
this
county
in
order
to
determine
that
this
area
is
attaining
despite
the
violation
in
the
adjacent
county.
This
county
must
be
included
in
the
nonattainment
area.

Lexington
CMSA:
EPA
failed
to
include
10
counties
in
this
nonattainment
area;
those
counties
are:
Anderson,
Bath,
Bourbon,
Franklin,
Jessamine,
Menifee,
Montgomery,
Pulaski,
Rock
Castle
and
Scott.
With
the
exception
of
Pulaski
County,
all
of
these
counties
are
part
of
the
CMSA.
The
entire
CMSA
must
be
designated
nonattainment.
The
Cooper
electric
generating
facility
is
located
in
Pulaski
County;
this
facility
emitted
over
22,000
tons
of
SO2
and
almost
5,000
tons
of
NOX
in
2002.9
Therefore,
this
county
must
be
included
in
the
nonattainment
area
due
to
its
probable
contribution
to
the
poor
air
quality
in
the
area.

7
Id.
8
EPA,
Acid
Rain
Database.
9
Id.
10
Louisville
CMSA:
EPA
failed
to
include
9
counties
(
Hardin,
Henry,
Larue,
Meade,
Nelson,
Oldham,
Shelly,
Spencer
and
Trimble)
in
its
recommended
nonattainment
area
for
the
Louisville
CMSA.
EPA's
analysis
only
indicates
that
Bullitt,
Jefferson
and
Oldham
Counties
are
part
of
the
CMSA,
but
there
are
6
other
counties
that
are
part
of
the
CMSA.
All
of
these
counties
must
be
included
in
the
nonattainment
area.
Hardin
County
is
the
only
county
with
a
monitor
besides
Jefferson
and
Bullitt.
The
2001­
2003
design
value
for
Hardin
County
is
14.1
µ
g/
m3,
which
is
very
near
to
a
violation.

Maryland
Hagerstown­
Martinsburg
MSA:
EPA
has
recommended
that
the
Maryland
portion
of
the
MSA
(
Washington
County)
be
designated
nonattainment.
As
described
in
our
previous
letter
to
EPA,
Alleghany
County
may
also
be
a
significant
source
of
emissions
impacting
the
nonattainment
problem
and
should
be
considered
for
inclusion
in
the
nonattainment
area.
In
2001,
the
county
emitted
over
3,000
tons
of
PM,
over
20,000
tons
of
SO2
and
over
12,000
tons
of
NOX.
10
It
does
not
appear
that
an
analysis
of
this
county's
emissions
has
been
done.

Philadelphia
CMSA:
EPA
failed
to
recommend
that
Cecil
County
be
designated
nonattainment
as
part
of
the
Philadelphia
nonattainment
area.
This
county
is
part
of
the
CMSA
and
must
be
included
in
the
nonattainment
area.
EPA's
documentation
shows
that
Cecil
County's
2001­
2003
design
value
was
13.0
µ
g/
m3,
which
is
attaining,
but
close
to
the
annual
standard.
Because
the
county's
1990
through
2000
growth
rate
was
20%
and
the
percent
VMT
growth
between
1996
and
2002
was
29%,
emissions
in
this
area
will
briskly
increase
in
future
years.

Washington­
Baltimore
CMSA:
EPA
has
failed
to
recommend
that
this
CMSA
be
designated
as
one
nonattainment
area;
this
area
must
be
designated
as
one
nonattainment
area.
EPA
also
failed
to
include
St.
Mary's,
Calvert
and
Queen
Anne's
Counties,
all
part
of
the
CMSA,
in
the
nonattainment
area.
Queen
Anne's
County
has
no
monitor,
but
between
1990
and
2000
the
county
experienced
19%
population
growth
and
between
1996
and
2002
they
experienced
a
25%
increase
in
VMT.
EPA
does
not
appear
to
have
conducted
an
analysis
for
St.
Mary's
County.

Michigan
Detroit
CMSA:
EPA
failed
to
recommend
Genesee
and
Lapeer
Counties
for
nonattainment.
These
counties
are
part
of
the
CMSA
and
must
be
designated
nonattainment.
EPA's
letter
to
the
state
reports
that
NOX
emissions
in
Genesee
County
are
around
20,000
tons
annually.

10
EPA,
OAQPS
spreadsheet.
11
EPA
cites
prevailing
wind
direction
as
a
reason
for
not
including
Genesee
County
in
the
nonattainment
area.
Because
the
PM2.5
standard
is
an
annual
standard
prevailing
wind
direction
does
not
have
as
much
impact
on
the
elevated
values
as
it
would
with
the
24­
hour
standard.
Although
Lapeer
County's
emissions
are
lower,
the
population
growth
between
1990
and
2000
was
18%,
which
may
lead
to
an
increasing
emission
trend
in
the
area.
In
addition,
Ingham
County
in
the
Lansing­
East
Lansing­
Owosso
CMSA
has
high
emissions,
due
to
the
Eckert
Station
power
plant,
which
emitted
over
6,500
tons
of
SO2
and
over
3,500
tons
of
NOX
in
2002.11
This
county
should
be
included
in
the
nonattainment
area
as
well.

Missouri
St.
Louis
CMSA:
St.
Francois
County,
Lincoln,
Warren,
Washington
Counties
and
Sullivan
City
(
in
Crawford
County)
are
not
included
in
the
recommended
nonattainment
area.
Neighboring
Ste.
Genevieve
County's
NOX
emissions
are
projected
to
be
over
18,000
tons
per
year
due
to
new
industrial
growth.
This
county
should
be
included
in
the
nonattainment
area
as
well.

New
Jersey
New
York
CMSA:
Ocean
and
Sussex
Counties
are
not
included
in
EPA's
recommended
nonattainment
area,
despite
their
being
part
of
the
CMSA.
These
counties
must
be
included
in
the
nonattainment
area.

Philadelphia
CMSA:
EPA
failed
to
include
Cape
May,
Cumberland
and
Salem
Counties
in
the
Philadelphia
nonattainment
area.
Cape
May
is
adjacent
to
the
CMSA,
but
is
home
to
the
B.
L.
England
coal­
fired
power
plant,
which
emitted
over
12,000
tons
of
SO2
and
almost
3,000
tons
of
NOX
in
2002.12
Cumberland
and
Salem
Counties
are
within
the
CMSA;
Salem
County
also
contains
a
coal­
fired
power
plant.
In
2002,
the
Deepwater
power
plant
in
Salem
County
emitted
almost
2,500
tons
of
SO2
and
almost
1,000
tons
of
NOX.
13
These
counties
must
not
be
left
out
of
the
nonattainment
area.

New
York
New
York
CMSA:
EPA
has
not
recommended
that
Duchess,
Putnam
and
Ulster
Counties
be
designated
nonattainment.
These
counties
are
all
part
of
the
CMSA
and
must
be
included
in
the
nonattainment
area.

11
EPA,
Acid
Rain
Database.
12
EPA,
Acid
Rain
Database.
13
Id.
12
North
Carolina
Greensboro
CMSA:
Davie,
Surry,
Yadkin,
and
Rockingham
Counties
are
all
part
of
the
CMSA,
but
EPA
has
not
recommended
that
these
areas
be
included
in
the
nonattainment
area.
Rockingham
County
in
particular
is
home
to
the
Dan
River
coal­
fired
power
plant,
which
emitted
almost
3,000
tons
of
SO2
and
over
1,000
tons
of
NOX
in
2002.14
In
addition,
the
adjacent
counties
of
Chatham
and
Rowan
must
be
included
in
the
nonattainment
area
due
to
the
coal­
fired
power
plants
located
within
these
counties
that
contribute
to
the
nonattainment
problem.
The
Cape
Fear
power
plant
emitted
almost
12,000
tons
of
SO2
and
over
2,000
tons
of
NOX
in
2002.15
The
Buck
electric
generating
facility
is
located
in
Rowan
and
must
be
included
in
the
nonattainment
area
as
well
due
to
its
likely
contribution
to
the
poor
air
quality
in
this
area.

Hickory
MSA:
EPA
only
recommended
parts
of
Burke
and
Caldwell
Counties
for
nonattainment
and
did
not
recommend
Alexander,
Cleveland
and
Rutherford
Counties
for
nonattainment.
Cleveland
and
Rutherford
Counties,
adjacent
to
the
MSA,
both
have
higher
emissions
and
must
be
included
in
the
nonattainment
area.
The
Cliffside
coal­
fired
power
plant,
located
in
both
of
these
counties,
emitted
over
22,000
tons
of
SO2
and
almost
4,000
tons
of
NOX
in
2002.16
All
of
these
counties
must
be
included
in
the
nonattainment
area
in
their
entirety.

Ohio
Canton
MSA:
EPA
failed
to
include
Carroll
County
in
this
recommended
nonattainment
area;
this
area
is
part
of
the
MSA
and
must
be
designated
nonattainment
with
the
rest
of
this
area.

Cincinnati
CMSA:
Brown
and
Clinton
Counties
are
not
recommended
for
nonattainment
despite
their
being
part
of
the
CMSA.
The
entire
CMSA
must
be
designated
nonattainment.

Cleveland
CMSA:
The
nearby
Wayne
County
should
be
included
in
the
nonattainment
area
due
to
its
high
emissions
of
SO2,
NOX
and
VOC.
17
Columbus
CMSA:
EPA
failed
to
include
Ross,
Madison,
Morrow,
Pickaway,
Union,
Marion,
Know
and
Fayette
Counties
in
the
recommended
nonattainment
area.
The
Pickway
electric
generating
station
in
Pickaway
County
emitted
over
10,000
tons
of
SO2
in
2002.
Coshocton
County,
adjacent
to
the
CMSA,
is
home
to
the
Conesville
electric
generating
14
Id.
15
Id.
16
Id.
17
EPA
Region
5,
letter
to
Ohio,
29
June
2004.
13
facility.
In
2002
this
facility
emitted
over
135,000
tons
of
SO2
and
almost
27,000
tons
of
NOX.
18
Dayton
CMSA:
Champaign,
Darke,
Miami
and
Preble
Counties
were
left
out
of
EPA's
recommended
nonattainment
area,
but
are
part
of
the
CMSA
and
must
be
included
in
the
nonattainment
area.

Toledo
CMSA:
EPA
failed
to
recommend
that
the
CMSA
counties
of
Fulton,
Ottawa
and
Sandusky
be
designated
nonattainment;
these
areas
must
be
included
in
the
nonattainment
area.

Pennsylvania
Harrisburg
CMSA:
Both
Perry
County
(
inside
the
CMSA)
and
Snyder
County
(
adjacent
to
the
CMSA)
were
not
included
in
EPA's
recommended
nonattainment
area.
The
Sunbury
coal­
fired
power
plant,
located
in
Snyder
County,
emitted
over
25,000
tons
of
SO2
and
over
5,000
tons
of
NOX
in
2002.19
Both
of
these
counties
must
be
included
in
the
nonattainment
area.

New
York
CMSA:
EPA
failed
to
include
Pike
County
in
the
recommended
New
York
nonattainment
area.
This
county
is
part
of
the
CMSA
and
must
be
included.

Philadelphia
CMSA:
Lehigh
and
Northampton
Counties
should
be
designated
nonattainment
due
to
their
likely
contributions
to
nonattaining
C/
MSAs.
Lehigh
County,
adjacent
to
both
the
Philadelphia
CMSA
and
the
Reading
MSA
(
also
recommended
for
nonattainment)
has
high
emissions
of
SO2,
NOX
and
VOC,
according
to
EPA's
June
29,
2004
letter
to
the
State.
Northampton
County
is
home
to
both
the
Martins
Creek
and
Portland
electric
generating
facilities,
which
are
significant
sources
of
SO2
and
NOX
pollution,
emitting
over
46,000
tons
of
SO2
and
over
8,000
tons
of
NOX
in
2002.20
This
county
is
adjacent
to
both
the
New
York
CMSA
and
the
Philadelphia
CMSA.
EPA
and
the
State
should
determine
which
nonattainment
area
these
counties
contribute
to
in
order
to
add
them
to
the
appropriate
nonattainment
area.

Tennessee
Knoxville
CMSA:
EPA
failed
to
include
Campbell
and
Union
Counties
(
both
part
of
the
CMSA)
in
its
recommended
nonattainment
area.
These
areas
must
be
included
as
part
of
the
nonattainment
area.

18
EPA,
Acid
Rain
Database.
19
Id.
20
Id.
14
Virginia
Washington­
Baltimore
CMSA:
EPA
has
failed
to
recommend
that
eight
Virginia
counties
and
cities
(
Clarke,
Fauquier,
Frederick,
Spotsylvania,
Stafford,
and
Warren
Counties;
Fredericksburg
and
Winchester
Cities)
in
this
CMSA
be
designated
as
nonattainment
area;
the
entire
CMSA
must
be
designated
nonattainment.
None
of
these
areas
appear
to
have
monitors
in
order
to
prove
that
they
are
indeed
attaining
the
PM2.5
standard.
According
to
EPA's
letter
to
the
state,
the
Stafford,
Spotsylvania,
Fauquier,
and
Fredericksburg
areas
all
have
a
majority
of
people
commuting
to
another
county.
In
addition,
emissions
in
Fauquier,
Spotsylvania,
Stafford,
and
Warren
Counties
are
not
low
and
need
to
be
taken
into
consideration
in
the
SIP
planning
process.

West
Virginia
Charleston
MSA:
Boone,
Clay
and
Lincoln
Counties
are
all
part
of
the
MSA
and
must
be
included
in
the
nonattainment
area;
EPA
has
failed
to
include
these
counties
in
its
recommendation.

Hagerstown
MSA:
EPA
failed
to
include
Morgan
County
in
the
recommended
nonattainment
area;
this
county
is
part
of
the
MSA
and
must
be
included
in
the
nonattainment
area.

Fairmont
CMSA:
CMSA
counties,
Doddridge
and
Taylor
must
be
included
in
the
nonattainment
area.
In
addition,
Preston
County,
home
to
the
Albright
coal­
fired
power
plant
that
emitted
over
20,000
tons
of
SO2
and
over
4,000
tons
of
NOX
in
2002,21
should
also
be
included
in
the
nonattainment
area.

Parkersburg
MSA:
EPA
failed
to
include
Wirt
County,
part
of
the
MSA,
in
the
recommended
nonattainment
area.
This
county
should
be
included
in
the
nonattainment
area.

We
respectfully
request
EPA
to
strengthen
its
PM2.5
nonattainment
area
recommendations
to
better
protect
the
millions
of
Americans
breathing
unhealthy
particulate
pollution
levels.

21
Id.
15
Thank
you
for
your
consideration
of
our
concerns.

Sincerely,

cc:
Lydia
Wegman,
EPA
OAQPS
Rich
Damberg,
EPA
OAQPS
Larry
Wallace,
EPA
OAQPS
John
L.
Kirkwood
President
and
Chief
Executive
Officer
American
Lung
Association
1150
18th
Street,
N.
W.,
Suite
900
Washington,
D.
C.
20036
202­
785­
3355
Jonathan
Lewis
Staff
Attorney
Clean
Air
Task
Force
18
Tremont
Street,
Suite
530
Boston,
MA
02108
617­
624­
0234
x12
Zachary
Corrigan
Staff
Attorney,
Clean
Air
Advocate
U.
S.
Public
Interest
Research
Group
202­
546­
9707
Cindy
Copeland
Environmental
Defense
2334
North
Broadway
Boulder,
CO
80304
303­
440­
4901
Stephen
Smith
Executive
Director
Southern
Alliance
for
Clean
Energy
28
N.
Market
Street,
Suite
604
Asheville,
NC
