1
BOONE
COUNTY,
KENTUCKY
Boone
County
is
part
of
the
Cincinnati­
Hamilton,
OH­
KY­
IN
Metropolitan
Statistical
Area
(
MSA)
and
is
located
to
the
west
of
Kenton
County,
Kentucky,
to
the
north
of
Grant
County,
Kentucky,
to
the
northeast
of
Gallatin
County,
Kentucky,
and
to
the
southwest
of
Cincinnati,
Ohio.

EPA s
June
29,
2004
proposal
on
appropriate
designations
for
Kentucky
included
Boone
County
as
nonattainment
based
on
the
following
criteria:

 
EPA
indicates
that
Boone
County
has
significant
emissions
and
a
large
power
plant
in
the
County.

 
EPA
indicates
that
the
population
growth
and
VMT
data
for
Boone
County
has
a
potential
to
contribute
to
the
PM2.5
violations
in
the
area.

Emissions
Data
In
Kentucky s
February
recommendations,
1999
NEI
data
was
used
in
the
original
analysis.
As
stated
in
the
General
Comments
portion
of
this
document,
EPA
had
recommended
that
states
use
the
1999
since
it
was
the
latest
available
to
states
at
that
time.

It
is
important
to
note
here
that
EPA,
in
their
review,
used
the
2001
NEI
data,
which
provided
different
data
than
what
EPA
had
recommended
that
states
use.
The
2001
NEI
data,
nor
the
methodology
used
in
the
calculations
for
that
inventory
have
been
made
available
to
states
for
review.

In
EPA s
June
29,
2004
letters
to
states,
EPA
looked
outside
the
original
MSA
boundaries
to
determine
if
large
emissions
contributions
from
adjacent
areas
were
having
an
impact
on
PM2.5
levels
within
the
MSA.
Specifically,
in
the
Cincinnati­
Hamilton
metropolitan
area,
EPA
has
included
Montgomery
County,
Ohio
in
the
analysis
for
the
Cincinnati­
Hamilton
area
and
indicates
that
it
too
will
be
nonattainment,
despite
the
fact
that
Montgomery
County,
Ohio,
is
in
an
entirely
different
MSA,
the
Dayton­
Springfield
MSA.

Hamilton
and
Clermont
Counties
in
Ohio,
and
Dearborn
County
in
Indiana
contribute
88%
of
all
SOx
within
the
counties
EPA
has
recommended
as
nonattainment
for
PM2.5.
By
comparison,
Boone
County
emits
only
6%
of
SOx
emissions
from
the
counties
recommended
by
EPA
as
having
the
potential
to
impact
the
violating
monitors.
A
similar
comparison
can
be
made
with
both
NOx
and
PM.
Boone
County s
NOx
and
PM
emissions
stand
at
8%
of
the
total
EPA
recommended
areas.
In
a
detailed
review
of
EPA s
recommended
areas
to
be
designated
nonattainment,
Boone
County
ranks
consistently
less
than
8%
of
2
combined
emissions
contributions
within
EPA s
proposed
nonattainment
boundaries.
See
Figures
1­
4
below.

Figure
1
NKY
Area
SOx
Emissions
in
EPA
Proposed
Nonattainment
Counties
Dearborn,
IN
22%

Butler,
OH
5%
Kenton,
KY
1%
Campbell,
KY
0%
Warren,
OH
0%

Boone,
KY
6%
Clermont,
OH
32%
Hamilton,
OH
34%

Figure
2
NKY
Area
NOx
Emissions
in
EPA
Proposed
Nonattainment
Counties
Dearborn,
IN
16%

Butler,
OH
10%
Kenton,
KY
4%
Campbell,
KY
3%
Boone,
KY
8%
Warren,
OH
4%
Hamilton,
OH
31%

Clermont,
OH
24%
3
Figure
3
NKY
Area
PM
Emissions
in
EPA
Proposed
Nonattainment
Counties
Dearborn,
IN
14%

Boone,
KY
8%
Campbell,
KY
2%
Kenton,
KY
3%
Butler,
OH
12%
Clermont,
OH
25%
Hamilton,
OH
29%

Warren,
OH
7%

Figure
4
0
20,000
40,000
60,000
80,000
100,000
120,000
140,000
160,000
T
o
n
s
P
e
r
Y
e
a
r
Boone,
KY
Campbell,
KY
Kenton,
KY
Butler,
OH
Clermont,
OH
Hamilton,
OH
Warren,
OH
Dearborn,
IN
EPA
Proposed
Nonattainment
Counties
Emissions
2001
PM
SOx
NOx
VOC
NH3
Carbon
Crustal
Additional
Emission
Reductions
in
Boone
County,
Kentucky
A
factor
not
taken
into
account,
either
in
the
1999
nor
2001
NEI
data
sets,
was
the
implementation
of
additional
NOx
controls
at
the
Cynergy
East
Bend
Power
Plant
in
Boone
County.
In
2002,
NOx
emissions
were
dropped
substantially
by
the
installation
of
SCR
on
Unit
#
2.
The
operation
of
this
control
technology
was
4
responsible
for
a
2,534­
ton
reduction
in
NOx
emissions
during
the
2003
summer
ozone
season,
which
includes
the
quarters
where
Kentucky,
and
the
region,
typically
record
the
highest
PM2.5
levels.
The
implementation
of
these
controls
at
that
facility
further
reduce
the
potential
emission
contribution
to
monitors
in
question
in
Southwestern
Ohio.

It
is
also
important
to
note
that
the
East
Bend
facility
has
existing
controls
to
lower
emissions
of
SO2
and
PM.

Additional
Regional/
National
Controls
The
implementation
of
new
federal
rules
to
decrease
the
amount
of
sulfur
in
both
gasoline
and
diesel
fuel
will
significantly
decrease
the
amount
of
SO2
in
the
entire
area.
Because
of
the
Low
Sulfur
Diesel
Rule,
in
2007,
new
clean
engines
operating
on
15­
ppm
sulfur
diesel
fuel
will
reduce
NOx
emissions
by
50%,
and
reduce
PM
emissions
by
more
than
90%.
Due
to
the
Tier
2
Vehicle
and
Gasoline
Sulfur
program,
by
2006
average
national
gasoline
sulfur
levels
will
be
90%
lower.

Upon
implementation
of
the
Clean
Air
Interstate
Rule
(
CAIR)
SO2
emissions
from
power
plants
will
be
reduced
nationwide
by
3.6
million
tons
in
2010
(
approximately
40
percent
below
current
levels)
and
by
another
2
million
tons
per
year
when
the
rules
are
fully
implemented
(
approximately
70
percent
below
current
levels).
NOx
emissions
would
be
cut
by
1.5
million
tons
nationwide
in
2010
and
1.8
million
tons
annually
in
2015
(
about
65
percent
below
today s
levels).

The
first
phase
of
compliance
under
the
CAIR
rule
to
reduce
both
SO2
and
NOx
emissions
would
be
required
by
2010,
allowing
substantial
emission
reductions
in
the
area,
by
the
proposed
attainment
date
for
PM2.5
nonattainment
areas.

Monitoring
Data
&
Trends
As
can
been
seen
in
Figure
5
below,
the
speciation
data
from
Kentucky s
Covington
speciation
monitor
indicates
that
sulfate
and
organic
carbon
are
the
major
components
of
the
PM2.5
values.
In
Figure
1
above
and
Figure
6
below,
Boone
County,
Kentucky,
contributes
only
6%
of
the
SO2
in
the
area,
and
only
8%
of
the
organic
carbon
(
figure
6
below)
within
EPA s
proposed
nonattainment
counties.
5
Figure
5
Covington
Speciation
Data
2001­
2003
Average
Concentration
(
µ
g/
m
³
)

Elemental
carbon
4%
Crustal
component
3%

Organic
carbon
24%
Ammonium
12%
Sulfate
32%
Nitrate
10%
Other
15%

Figure
6
NKY
Area
Carbon
Emissions
in
EPA
Proposed
Nonattainment
Counties
Campbell,
KY
3%

Kenton,
KY
5%

Butler,
OH
11%

Clermont,
OH
20%
Hamilton,
OH
33%
Warren,
OH
9%
Dearborn,
IN
11%
Boone,
KY
8%

The
monitors
located
in
Campbell
and
Kenton
Counties
for
the
2001­
2003
timeframe
show
attainment
with
the
standard
and
the
annual
concentrations
continue
to
show
a
downward
trend
as
depicted
in
Figure
7
below,
which
utilized
data
from
the
year
2000
through
April
2004.
Monitors
in
Southwestern
Ohio
also
continue
to
show
comparable
downward
trends
in
monitoring
values.
6
Figure
7
Northern
Kentucky
Area
PM
2.5
Trend
11
12
13
14
15
16
17
18
19
20
2000
2001
2002
2003
2004
Year
A
n
n
u
a
l
A
r
i
th
m
e
t
i
c
M
e
a
n
(
m
ic
r
o
g
r
a
m
s
/
c
u
b
i
c
m
e
t
e
r
)

Campbell,
KY
Kenton,
KY
Butler,
OH
Hamilton,
OH
PM2.5
levels
throughout
the
entire
region
have
been
steadily
decreasing
over
the
last
four
years.
Specifically,
the
PM2.5
levels
in
Campbell
County
have
decreased
by
11%,
Kenton
County s
levels
have
decreased
by
12%,
12%
in
Hamilton
County,
and
11%
in
Butler
County
(
See
Figure
8
below).

Figure
8
0.0
2.0
4.0
6.0
8.0
10.0
12.0
14.0
16.0
18.0
20.0
Hamilton,
OH
Butler,
OH
Kenton,
KY
Campbell,
KY
Decline
in
PM
Values
for
NKY
Area
2000
2001
2002
2003
2000­
2003
shows
decrease
of
12%
2000­
2003
shows
decrease
of
12%
2000­
2003
shows
decrease
of
11%
2000­
2003
shows
decrease
of
11%
7
Population
Growth
and
VMT
Levels
EPA
stated
that
Boone
County
had
relatively
high
population
growth
that
had
the
potential
to
impact
PM2.5
violations
in
the
area.
Boone
County
makes
up
only
5%
of
the
population
in
the
entire
MSA,
see
Figure
9
below.

Figure
9
Northern
Kentucky
Area
2002
Population
for
USEPA
Proposed
PM2.5
Nonattainment
Counties
Campbell,
KY
5%
Kenton,
KY
8%
Boone,
KY
5%
Dearborn,
IN
2%

Clermont,
OH
10%
Butler,
OH
18%
Warren,
OH
9%
Hamilton,
OH
43%

Therefore,
Kentucky
believes
that
the
population
in
Boone
County
should
not
be
used
as
a
determining
factor
for
potential
contributions
to
PM2.5
violations
in
Southwestern
Ohio.

Based
on
EPA s
June
29,
2004,
discussion
of
VMT
data
in
the
region,
an
attempt
was
made
to
segregate
county
VMT
data
by
state
rather
than
reviewing
the
data
for
the
region
as
a
whole.
This
is
an
unfair
comparison.
Data
presented
by
EPA
shows
the
overwhelming
contribution
from
VMT
in
the
area
to
be
occurring
outside
of
Boone
County.
Figure
10
below
outlines
total
VMT
per
county
for
the
MSA.
8
Figure
10
Cincinnati­
Hamilton
MSA
VMT
per
year
in
thousands
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
9,000
Hamilton,
OH
Clermont,
OH
Dearborn,
IN
Butler,
OH
Boone,
KY
Warren,
OH
Kenton,
KY
Campbell,
KY
Brown,
OH
Grant,
KY
Pendleton,
KY
Gallatin,
KY
Ohio,
IN
VMT
Conclusions
Based
on
the
factors
discussed
above,
Kentucky
believes
that
Boone
County
should
be
designated
attainment
for
the
PM2.5
standard.

 
Kentucky
believes
that
EPA s
use
of
the
weighted
emissions
scoring
approach
was
skewed.
A
review
of
actual
percentages
of
emissions
contributions
to
an
area
shows
that
Boone
County
does
not
have
the
potential
to
contribute
to
PM2.5
levels
within
the
region.

 
PM2.5
levels
continue
to
decline
throughout
the
entire
region.
From
a
review
of
all
monitors
in
the
region,
an
average
12%
decline
in
PM2.5
levels
has
occurred
from
2000
through
2003.
Every
monitor
in
Kentucky
is
currently
showing
values
well
within
attainment
of
the
annual
PM2.5
standard
using
2002
through
2004
data.

 
The
population
growth
nor
VMT
of
Boone
County
is
significant
enough
to
have
the
potential
to
impact
PM2.5
levels
in
the
region.
Boone
County s
population
actually
represents
only
5%
of
the
actual
MSA.
The
VMT
from
Boone
County
is
substantially
lower
than
other
counties
within
the
MSA.

 
Additional
emission
reductions
on
a
national
and
regional
level
will
provide
substantial
benefits
in
the
region.
The
anticipated
sulfur
reductions
due
to
the
Low
Sulfur
Diesel
Rule,
the
Tier
2
Vehicle
and
9
Gasoline
Sulfur
programs,
and
the
Clean
Air
Interstate
Rule
(
CAIR)
will
further
lower
pollutant
levels
within
this
region.

 
It
appears
EPA
has
included
Boone
County
as
a
potential
nonattainment
area
due
to
an
emissions
contribution
from
the
East
Bend
power
plant.
However,
a
review
of
the
actual
percentage
of
emissions
in
the
entire
area,
shows
that
Boone
County s
contribution
pales
in
comparison
to
other
counties
within
the
proposed
nonattainment
counties.
That
facility
already
has
in
place
existing
controls
for
SO2,
NOx
and
PM.
Including
Boone
County
as
nonattainment
in
order
to
gain
additional
controls
would
serve
no
purpose.

Based
on
the
above
conclusions,
Boone
County,
Kentucky
should
be
designated
attainment
for
the
PM2.5
standard.
To
have
this
county
designated
nonattainment
would
invoke
additional,
substantial,
unnecessary
requirements
on
local
government
planning
agencies
with
little
or
no
benefit
to
the
area.

Substantial
local
emission
reductions
from
Boone
County
have
already
occurred,
or
will
have
occurred
well
before
attainment
dates
for
this
standard.
Drastic
emission
reductions
are
scheduled
to
occur
in
the
mobile
sector
throughout
the
next
several
years
that
will
greatly
impact
pollutant
levels
in
the
area.
Couple
these
changes
with
those
anticipated
by
the
CAIR
provisions,
which
will
further
reduce
SOx
and
NOx
emissions
within
the
region,
and
the
air
monitoring
data
demonstrating
attainment
of
the
PM2.5
Standard,
the
only
conclusion
that
can
be
drawn
is
that
Boone
County,
Kentucky,
should
be
designated
attainment
for
the
PM2.5
Standard.
