Georgia
Department
of
Natural
Resources
2
Martin
Luther
King,
Jr.
Drive,
S.
E.,
Suite
1152
East
Tower,
Atlanta,
Georgia
30334­
9000
Noel
Holcomb,
Commissioner
Carol
A.
Couch,
PhD.,
Director
Environmental
Protection
Division
404/
656­
4713
September
1,
2004
James
I.
Palmer,
Jr.
Regional
Administrator
U.
S.
EPA,
Region
4
161
Forsyth
Street,
SW
Atlanta,
Georgia
30303­
3104
Re:
PM2.5
Nonattainment
Area
Designations
Additional
Information
for
Consideration
Dear
Mr.
Palmer:

The
United
States
Environmental
Protection
Agency
(
EPA)
promulgated
a
new
Fine
Particle
National
Ambient
Air
Quality
Standard
(
PM2.5).
Section
107
(
d)(
1)
of
the
Clean
Air
Act
requires
each
state
to
submit
to
the
EPA
its
recommended
designation
of
each
area
of
the
State
as
attainment/
unclassifiable
or
nonattainment
under
the
standard.
On
February
13,
2004,
the
Georgia
Environmental
Protection
Division
(
the
Division)
submitted
initial
recommendations
for
the
designation
status
of
each
county
in
Georgia.
Revised
recommendations
with
supporting
information
were
submitted
to
EPA
on
June
15,
2004,
and
June
17,
2004.
On
June
29,
2004,
EPA
submitted
a
letter
to
Governor
Sonny
Perdue
notifying
him
of
EPA's
intent
to
modify
Georgia's
PM2.5
nonattainment
recommendations.
This
letter
and
the
attached
supporting
information
are
submitted
in
response
to
that
letter.

The
Division
is
for
the
most
part
pleased
that
U.
S.
EPA
has
accepted
most
of
Georgia
EPD's
recommendations
for
PM2.5
nonattainment
boundaries.
However,
there
are
still
a
few
counties
which
EPD
has
determined
should
not
be
included
in
any
PM2.5
nonattainment
area.
Additional
information
relating
to
these
counties
is
contained
in
or
attached
to
this
letter.
In
addition,
Georgia
EPD
had
not
completed
its
analysis
of
the
Georgia
portion
of
the
Chattanooga
PM2.5
nonattainment
area
when
we
revised
our
PM2.5
nonattainment
recommendations
on
June
17,
2004.
This
analysis
has
been
complete
and
is
included
for
your
consideration.

EPA's
June
29th
letter
did
not
address
much
of
the
information
included
in
EPD's
June
17,
2004,
submission
including
the
revised
L­
Score
methodology
and
much
of
the
"
other
factors"
considered
by
EPD.
We
continue
to
believe
that
U.
S.
EPA
should
consider
the
level
of
control
of
emission
sources
as
significant
in
the
decision
making
process.
Georgia
EPD
supplied
detailed
information
concerning
existing
control
measures
that
go
beyond
those
required
across
the
state
and
which
are
already
in
place
in
most
of
the
counties
analyzed.
Georgia
urges
U.
S.
EPA
to
reconsider
the
information
included
in
EPD's
June
17th
submittal
and
is
willing
to
meet
with
EPA
staff
to
discuss
these
analyses.
James
I.
Palmer,
Jr.
page
two
Based
on
additional
analysis
explained
in
attached
documents,
EPD
is
revising
its
recommended
designations
and
responds
to
EPA's
proposed
modifications
of
EPD's
classification
recommendations
as
follows:

Recommendations
that
Certain
Areas
be
Classified
as
"
unclassifiable"

Based
on
PM2.5
monitoring
trends
through
mid­
2004,
it
is
very
possible
that
the
2002­
2004
data
will
indicate
attainment
for
the
Athens
monitor,
the
Macon
Allied
Chemical
monitor
(
the
Macon
Forestry
Office
monitor
already
shows
attainment),
and
the
Rossville
monitor.
Data
indicating
these
trends
is
included
in
attachment
3.
We
will
have
more
complete
data
later
this
Fall,
before
U.
S.
EPA's
expected
November
action.
If
these
monitoring
trends
continue,
EPD
recommends
that
Clarke
County,
Bibb
County,
the
partial
county
area
of
Monroe
County
that
includes
Plant
Scherer,
and
Walker
County
be
designated
as
"
unclassifiable."

Chattanooga
PM2.5
Nonattainment
Area
U.
S.
EPA's
June
29,
2004
letter
included
all
of
the
Georgia
Counties
that
are
part
of
the
Chattanooga
MSA
in
the
Chattanooga
PM2.5
nonattainment
area.
It
is
our
understanding
that
this
was
due
in
part
to
the
fact
that
EPD
had
not
submitted
an
analysis
of
this
area
prior
to
EPA's
June
29th
letter.
EPD
has
completed
this
analysis
and
it
is
attached.
EPD
has
recommended
above
that
Walker
County
be
designated
unclassifiable
and
further
recommends
that
Catoosa
County
and
Dade
County
be
classified
as
"
attainment".
Should
additional
data
available
this
fall
not
indicate
that
the
Rossville
monitor
will
attain
the
PM2.5
standard
using
2002­
2004
data
or
should
U.
S.
EPA
reject
EPD's
unclassifiable
recommendation
for
Walker
County,
we
recommend
that
the
portion
of
Walker
County
as
described
below
be
included
in
the
Chattanooga
PM2.5
nonattainment
area.

From
the
west
Walker
County
line
¾
of
a
mile
south
of
Lookout
Mtn.
city
limits,
the
boundary
travels
southeast
to
the
3700
block
of
Lula
Lake
Rd.
Boundary
then
travels
south
intersecting
the
2200
block
of
Nick­
a­
Jack
Rd.
and
continues
south
1
½
miles.
Boundary
then
travels
east
to
7600
block
of
Hwy
193
at
N.
Cedar
Ln.
intersection.
Boundary
then
travels
east
following
southern
right
of
way
of
Walker
Hollow
Rd.
to
1500
block
of
N.
Marbletop
Rd.
Boundary
then
travels
southeast
intersecting
400
block
of
Childress
Hollow
Rd.
and
continuing
east
to
east
right
of
way
of
McCarty
Rd.
Boundary
then
travels
south
½
mile.
Boundary
then
travels
east
to
north
right
of
way
of
Peter
Lewis
Trl.
Boundary
then
travels
southeast
to
1100
block
of
S.
Hwy
341
at
Garretts
Chapel
Rd.
intersection.
Boundary
then
travels
southeast
to
southern
right
of
way
of
Hames
Rd.
and
Driftwood
Dr.
Boundary
then
travels
east
to
intersect
800
block
of
Lofton
Ln.
Boundary
then
travels
northeast
to
100
block
of
Glass
Mill
Rd.
at
Old
Bethel
Rd.
intersection.
Boundary
then
travels
east
along
southern
right
of
way
of
Glass
Mill
Rd.
Boundary
then
intersects
500
block
of
Old
LaFayette
Rd.
at
Glass
Mill
Rd.
intersection.
Boundary
continues
east
intersecting
9900
block
of
N.
Hwy
27,
300
block
of
Arnold
Rd.,
and
500
block
of
Long
Hollow
Rd.
Boundary
continues
east
to
1200
block
of
Peaving
Rd.
at
E.
Long
Hollow
Rd.
intersection.
Boundary
continues
east
along
southern
right
of
way
of
Peavine
Rd.
to
east
Walker
County
line.

Clearly
the
opportunity
for
a
partial
county
designation
is
something
EPA
is
willing
to
consider
(
EPA's
June
29,
2004
suggestion
regarding
both
Putnam
and
Jasper
counties,
for
example).
In
evaluating
this
recommendation,
EPA
should
consider
Walker
County's
geography,
the
location
of
James
I.
Palmer,
Jr.
page
three
the
emission
sources,
other
factors
we
have
analyzed,
and
the
fact
that
the
northern
urbanized
area
is
not
unlike
the
localized
stationary
sources
EPA
refers
to
in
Jasper
and
Putnam
counties.

The
complete
analysis
and
a
map
of
the
partial
county
area
are
included
in
attachment
4.

Atlanta
PM2.5
Nonattainment
Area
U.
S.
EPA's
June
29,
2004
letter
added
Jasper
and
Putnam
Counties
to
Georgia
EPD's
recommendation
for
the
Atlanta
PM2.5
nonattainment
area.
EPA's
letter
also
suggested
that
EPD
submit
partial
county
recommendations
for
those
counties.
EPD
has
determined
that
it
is
not
practical
to
design
partial
county
nonattainment
boundaries
for
Jasper
and
Putnam
County.
We
have
also
conducted
additional
analysis
using
EPA's
wind
direction
frequency
data
that,
together
with
information
submitted
with
our
June
17th
recommendation,
supports
EPD's
earlier
recommendation
that
neither
Jasper
nor
Putnam
County
be
included
in
the
Atlanta
PM2.5
nonattianment
area.
Also,
by
designating
Jasper
and
Putnam
County
"
attainment"
for
PM2.5,
the
Atlanta
PM2.5
nonattainment
boundary
will
be
basically
identical
to
the
Atlanta
8­
hour
ozone
nonattainment
boundary
ensuring
more
efficient
air
quality
and
transportation
planning.
EPD's
additional
analysis
of
Putnam
County
is
included
in
attachment
5.

Athens
PM2.5
Nonattainment
Area
U.
S.
EPA's
June
29,
2004
letter
added
Madison
and
Oconee
Counties
to
Georgia
EPD's
recommendation
for
the
Athens
PM2.5
nonattainment
area.
In
our
June
17th
submission,
EPD
did
not
analyze
Oconee
County
for
the
7
"
other
factors,"
since
EPD's
Updated
L­
Score
analysis
indicated
that
the
urban
excess
from
Oconee
County
did
not
significantly
impact
on
the
Athens
area.
Since
U.
S.
EPA
has
included
Oconee
County
in
its
recommendation
for
the
Athens
PM2.5
nonattainment
area,
EPD
has
conducted
additional
analysis
for
Oconee
County.
Also,
EPD
has
conducted
an
analysis
of
meterological
factors
that
was
not
included
in
our
June
17th
submittal.
Both
of
these
analyses,
together
with
the
information
already
submitted
to
U.
S.
EPA
on
June
17th,
indicate
that
neither
Oconee
nor
Madison
should
be
included
in
the
Athens
PM2.5
nonattainment
area.
Additionally,
should
EPA
accept
EPD's
recommendation
that
Clarke
County
be
designated
as
unclassifiable,
then
Madison
and
Oconee
Counties
should
be
designated
either
as
attainment
or
unclassifiable.
The
additional
analyses
for
Oconee
and
Madison
Counties
are
contained
in
attachment
6.

Columbus/
Phenix
City
Nonattainment
Area
EPD
does
not
agree
with
U.
S.
EPA's
recommended
boundary.
However,
On
July
28,
2004,
EPD,
in
cooperation
with
Alabama's
Department
of
Environmental
Management,
submitted
a
request
for
revision
to
the
PM2.5
Monitoring
Plan
for
the
Columbus/
Phenix
City
area.
U.
S.
EPA's
prompt
action
on
this
request
will
result
in
the
attainment
designation
for
the
entire
Columbus/
Phenix
City
area,
including
both
Muscogee
and
Harris
County
in
Georgia.
James
I.
Palmer,
Jr.
page
four
State
Recommendations
A
table
indicating
Georgia
EPD's
revised
recommendations
for
all
counties
and
partial
counties
in
the
state
and
a
map
indicating
EPD's
revised
designations
is
attached.

Please
note
that
during
this
evaluation,
EPD
discovered
that
the
vehicle
miles
traveled
(
VMT)
data
posted
on
EPA's
PM2.5
technical
information
web
site
and
used
by
both
EPA
and
Georgia
EPD
in
attainment
designation
analysis
is
incorrect.
EPD
has
used
correct
VMT
data
for
the
analyses
created
for
this
response.
EPD
will
be
checking
the
VMT
data
utilized
in
the
data
supporting
our
June
17,
2004,
submittal
and
will
notify
EPA
if
the
updated
VMT
data
alters
any
of
those
analysis
results.

If
you
have
any
questions
or
need
more
information,
please
contact
Ron
Methier
at
(
404)
363­
7016
or
Jimmy
Johnston
at
(
404)
363­
7014.

Sincerely,

Carol
A.
Couch,
Ph.
D
Director
CAC:
jpj
no
attachments
c:
Kay
Prince,
U.
S.
EPA
(
w.
attachments)
Ron
Methier
Jimmy
Johnston
