September
8,
2004
Mr.
James
I.
Palmer,
Jr.
Regional
Administrator
U.
S
EPA,
Region
4
61
Forsyth
Street
Atlanta,
Georgia
30303
RE:
PM2.5
Non­
attainment
Designations
Dear
Mr.
Palmer:

In
your
June
29,
2004
letter,
you
provided
North
Carolina
with
EPA's
response
to
our
state's
PM2.5
non­
attainment
boundary
recommendations.
North
Carolina
has
been
a
leader
among
states
with
regard
to
improving
air
quality
and
remains
committed
to
the
continued
improvement
of
air
quality
and
the
protection
of
its
citizens.
The
non­
attainment
boundary
recommendations
made
by
EPA
include
several
counties
that
North
Carolina
continues
to
believe
should
be
designated
attainment
for
PM2.5.
Below,
I
state
why
North
Carolina
believes
that
these
counties
should
be
designated
attainment.
I
also
urge
you
to
consider
again
the
discussion
and
technical
documents
presented
in
our
initial
February
2004
submissions.
In
addition,
please
find
attached
our
PM2.5
Designation
Response
Technical
Support
Document.

In
the
Greensboro/
Winston­
Salem/
High
Point
area,
EPA
recommends
that
the
entire
counties
of
Stokes,
Guilford,
Davidson,
Forsyth
and
Randolph
be
designated
non­
attainment.
North
Carolina
originally
recommended
Davidson
County
only
as
the
PM2.5
non­
attainment
boundary.
We
continue
to
believe
that
only
Davidson
County
should
be
designated
as
nonattainment

North
Carolina
believes
that
Stokes
County
should
be
designated
attainment
for
the
following
reasons.
While
Stokes
County
contains
the
Belews
Creek
power
plant,
an
analysis
of
forward
trajectories
indicates
that
emissions
from
Belews
Creek
do
not
frequently
impact
the
PM2.5
monitor
in
Davidson
County.
There
are
also
PM2.5
monitors
currently
attaining
the
standard
in
Forsyth
County
that
lie
between
Stokes
County
and
the
non­
attaining
monitor
in
Davidson
County.
Even
if
the
Belews
Creek
facility
is
affecting
the
Lexington
area,
significant
NOx
controls
have
already
been
installed
on
the
plant.
Selective
catalytic
reduction
systems
have
already
been
installed
on
units
1
and
2
at
the
Belews
Creek
facility,
and
additional
burner
technology
has
been
added
at
unit
2.
This
NOx
control
technology
began
operation
in
2003
and
2004.
Consequently,
the
NOx
emissions
will
decrease
from
43,567
tons
per
year
to
7,022
tons
per
year
and
new
SO2
controls
will
be
installed
over
the
next
several
years
as
a
result
of
the
Clean
Smokestacks
Act.
SO2
emissions
from
Belews
Creek
will
be
reduced
by
nearly
90%
in
the
next
several
years
as
these
controls
become
fully
operational.
Mr.
James
I.
Palmer,
Jr.
September
8,
2004
Page
2
of
4
Also,
Stokes
County
is
an
extremely
rural
county,
and
therefore
has
very
little
mobile
emissions.
North
Carolina
believes
that
the
current
and
future
controls
on
the
Belews
Creek
facility,
the
apparent
small
impact
of
Belews
Creek
on
Davidson
County,
and
the
rural
nature
of
the
county
support
designating
Stokes
County
in
attainment
for
PM2.5.
If
EPA
continues
to
believe
that
Stokes
County
should
be
designated
non­
attainment
because
of
Belews
Creek,
North
Carolina
recommends
that
only
the
Sauratown
Township
where
the
Belews
Creek
power
plant
is
located
be
designated
non­
attainment.

North
Carolina
believes
that
Randolph
County
should
be
designated
attainment
for
several
reasons.
The
EPA
L­
Factor
ranking
for
Randolph
County
is
the
lowest
of
the
counties
recommended
by
EPA
to
be
designated
non­
attainment.
Randolph
County
is
also
predominately
downwind
of
Davidson
County
during
the
summer
months
when
PM2.5
concentrations
are
the
highest
and
therefore
emissions
from
Randolph
County
would
not
be
expected
to
contribute
significantly
to
PM2.5
concentrations
in
Davidson
County
during
those
months.
The
majority
of
emissions
within
Randolph
County
are
mobile
emissions
and
less
than
5%
of
the
workforce
commutes
into
Davidson
County.
Furthermore,
the
mobile
source
emissions
will
be
addressed
by
federal
rules
such
as
heavy­
duty
engine
standards
and
low
sulfur
diesel.

Guilford
and
Forsyth
counties
each
contain
PM2.5
monitors
that
are
attaining
the
standard
based
on
current
design
values.
The
counties
also
lie
to
the
north
and
northeast
of
Davidson
County,
which
makes
Guilford
and
Forsyth
counties
predominately
downwind
of
Davidson
County
during
the
summer
months
when
PM2.5
is
the
highest.
The
majority
of
emissions
from
these
counties
are
mobile,
and
therefore
these
counties
and
surrounding
counties
will
benefit
from
federal
rules
addressing
mobile
emissions
as
well
as
the
expanded
North
Carolina
motor
vehicle
inspection
program.
They
will
also
benefit
from
local
measures
aimed
at
reducing
mobile
emissions
as
part
of
the
Early
Action
Compact
(
EAC)
effort
in
the
Triad
area.

North
Carolina
has
an
analysis
that
shows
PM2.5
concentration
and
its
relationship
to
population
density
in
the
Triad
area.
The
Lexington
monitor
does
not
behave
the
same
as
surrounding
monitors
when
considering
the
population
around
the
monitoring
site.
The
analysis
suggests
that
the
higher
concentrations
of
PM2.5
in
Davidson
County
are
the
result
of
local
factors
rather
than
broader
population­
related
regional
influences
and
therefore
the
addition
of
counties
beyond
just
Davidson
County
will
not
help
the
monitor
attain
the
standard.
Please
see
appendix
for
details.

Finally,
with
regard
to
the
Lexington
monitor,
there
has
been
a
downward
trend
in
the
PM2.5
concentrations
since
1999.
We
believe
that
this
in
considerable
part
reflects
some
reductions
in
the
emission
of
pollutants
in
certain
upwind
states
over
that
period.
EPA
itself
has
already
concluded
that
these
out­
of­
state
sources
contribute
significantly
to
elevated
PM2.5
in
North
Carolina.
We
expect
that
the
downward
trend
should
continue
at
this
site
as
more
emissions
reductions
are
expected
due
to
implementation
of
the
Clean
Smokestacks
Act,
NOx
SIP
call
rules,
federal
heavy­
duty
engine
standards
and
new
fuel
standards.
We
anticipate
further
improvement
in
Lexington
monitor
air
quality
will
result
from
positive
action
by
EPA
on
North
Carolina's
section
126
petition,
as
well
as
actual
promulgation
of
the
proposed
Clean
Air
Mr.
James
I.
Palmer,
Jr.
September
8,
2004
Page
3
of
4
Interstate
Rule,
both
of
which
will
further
reduce
the
contribution
from
upwind,
out­
of­
state
sources
to
the
Lexington
area's
non­
attainment
and
maintenance
problems.

For
the
reasons
stated
herein,
North
Carolina
believes
that
only
Davidson
County
should
be
designated
non­
attainment,
while
Stokes,
Randolph,
Guilford
and
Forsyth
counties
should
be
designated
as
attainment
for
PM2.5.

With
regard
to
the
non­
attaining
monitor
in
Hickory,
North
Carolina
continues
to
oppose
a
non­
attainment
designation
for
any
area
beyond
the
metropolitan
planning
organization
boundary
of
Catawba
County.
There
is
little
to
be
gained
by
including
the
partial
counties
of
Burke
and
Caldwell
in
the
non­
attainment
area
for
the
Hickory
region
for
several
reasons.
Catawba
County
emissions
are
significantly
higher
than
both
Burke
and
Caldwell
counties
in
the
L­
Factor
analysis.
The
bulk
of
emissions
from
these
counties
is
from
the
mobile
sector
and
therefore
will
benefit
from
state
and
federal
rules
addressing
mobile
emissions.
There
would
be
little
to
no
additional
opportunity
to
reduce
mobile
emissions
by
designating
Burke
and
Caldwell
counties
as
non­
attainment.

A
non­
attainment
designation
for
PM2.5
would
place
significant
additional
burdens
on
Burke
and
Caldwell
counties
since
these
counties
are
already
participating
in
an
EAC
for
ozone.
These
counties
are
making
progressive
strides
to
reduce
emissions
as
part
of
the
EAC
effort
and
North
Carolina
feels
that
a
designation
of
non­
attainment
for
these
counties
would
do
little
to
reduce
PM2.5
in
Catawba
County.
North
Carolina
believes
the
recommendation
to
designate
only
Catawba
County
as
non­
attainment
is
appropriate,
while
Burke,
Caldwell
and
the
non­
MPO
parts
of
Catawba
counties
should
be
designated
as
attainment
for
PM2.5.

Furthermore,
on
the
basis
of
air
quality
data
for
2004
gathered
to
date,
North
Carolina
believes
there
is
a
significant
probability
that
the
Hickory
monitor
will
attain
the
standard
based
on
complete
2002­
2004
data.
We
expect
that
it
will
be
possible
to
maintain
this
attainment
status
as
more
emissions
reductions
are
expected
due
to
implementation
of
the
Clean
Smokestacks
Act,
NOx
SIP
call
rules,
federal
heavy­
duty
engine
standards
and
new
fuel
standards.
We
are
also
anticipating
needed
reductions
from
upwind
out­
of­
state
sources
from
the
proposed
Clean
Air
Interstate
Rule,
North
Carolina's
section
126
petition
and
other
initiatives,
which
will
help
Davidson
County
as
well.
EPA
already
has
concluded
that
these
out­
of­
state
sources
contribute
significantly
to
elevated
PM2.5
in
North
Carolina.

North
Carolina
therefore
suggests
that
EPA
designate
the
Hickory
area
as
"
unclassifiable",
if
the
designation
is
made
before
December
31,
2004.
The
designation
for
this
area
as
attainment
can
then
be
finalized
in
February
2004
using
the
2002­
2004
data,
assuming
that
it
in
fact
shows
what
we
anticipate.
Alternatively,
if
the
designation
is
made
after
December
31,
2004,
the
designation
should
be
based
on
the
2002­
2004
data.
This
approach
would
conserve
significant
federal,
state
and
local
resources
by
avoiding
the
need
for
the
redesignation
demonstration,
as
well
as
transportation
conformity,
in
an
area
that
is
already
attaining
the
PM2.5
standard.
Mr.
James
I.
Palmer,
Jr.
September
8,
2004
Page
4
of
4
Finally,
on
June
21,
2004,
I
wrote
to
the
Administrator
to
register
our
concerns
regarding
the
recently
introduced
emissions­
weighted
approach
for
nonattainment
boundary
delineation.
I
reiterate
those
comments
here.
In
particular,
the
emissions­
weighted
analysis
fails
to
account
for
prevailing
wind
directions
during
the
periods
when
PM2.5
values
are
higher,
assumes
incorrectly
that
emissions
impact
a
monitor
equally
throughout
the
year,
fails
to
consider
distance
between
emissions
and
the
monitors,
and
fails
to
recognize
any
effects
from
the
significant
reductions
resulting
from
North
Carolina's
Clean
Smokestacks
Act.
The
most
glaring
demonstration
of
the
weakness
of
the
emissions­
weighted
approach
is
that
some
counties
EPA
intends
to
designate
as
nonattainment
under
this
approach
actually
are
in
attainment
according
to
monitors
located
in
those
counties.
Moreover,
this
emissions­
weighted
analysis
was
introduced
late
and
so
could
not
be
addressed
by
the
Governors
in
their
initial
recommendations.
This
runs
counter
to
the
statefederal
interactive
process
prescribed
by
law.
For
these
reasons,
the
State
believes
that
the
use
of
the
emissions­
weighted
approach
is
arbitrary
and
should
not
influence
the
final
delineation
of
nonattainment
area
boundaries.

North
Carolina
is
proud
to
be
a
leader
in
the
improvement
of
air
quality
and
is
committed
to
the
continued
improvement
of
air
quality
within
its
borders.
We
have
invested
significant
resources
in
understanding
the
nature
of
our
air
quality
issues
and
feel
confident
that
our
recommendation
to
designate
only
Davidson
and
Catawba
counties
is
sufficient
for
the
state
and
EPA
to
continue
the
work
toward
protecting
the
health
of
our
citizens.
We
know
that
you
and
your
colleagues
will
give
these
comments
careful
attention
as
EPA
evaluates
and
makes
the
final
decisions
on
PM2.5
boundaries
later
this
year.
We
appreciate
that
careful
attention
because
we
also
appreciate
the
nature
and
extent
of
the
challenge
EPA
faces
in
making
these
decisions
across
the
nation.

Sincerely,

William
G.
Ross,
Jr.

Attachment:
PM2.5
Designation
Response
Technical
Support
Document
cc:
Secretary
Lyndo
Tippett
(
w/
o
attachment)
Secretary
James
Fain
(
w/
o
attachment)
Keith
Overcash
(
w/
o
attachment)
