1
Bullitt
County,
Kentucky
Bullitt
County
is
part
of
the
Louisville,
KY­
IN
Metropolitan
Statistical
Area
(
MSA)
and
is
on
the
I­
65
South
interstate
corridor.
It
is
located
directly
south
of
Jefferson
County,
southwest
of
Spencer
County,
northwest
of
Nelson
County,
and
northeast
of
Hardin
County.

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

 
EPA
indicates
that
Bullitt
County
has
significant
emissions
and
close
proximity
to
the
violating
MSA
monitors.

 
EPA
indicates
that
Bullitt
County
has
monitoring
data
very
close
to
the
PM2.5
standard,
and
that
this
indicates
a
potential
to
contribute
to
the
PM2.5
violations
in
the
area;

 
EPA
states
that
Bullitt
County
has
relatively
high
traffic
and
commuting
patterns;

 
EPA
states
that
Bullitt
County s
population
growth
is
significant
enough
to
contribute
to
PM2.5
violations
in
Jefferson
County.

Emissions
Data
In
Kentucky s
original
February
recommendations,
1999
NEI
data
was
used
in
the
original
analysis.
That
data
documented
that
Bullitt
County
did
not
contribute
a
significant
amount
of
suspect
emissions
in
the
seven
county
Metropolitan
Statistical
Area
(
MSA),
mandated
for
review
by
U.
S.
EPA.

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
in
many
of
the
areas.
EPA
also
used
the
2001
NEI
which
provided
slightly
newer
data
than
had
been
recommended
that
states
use.

Based
on
EPA s
2001
NEI
data
supplied
to
states,
Bullitt
County
does
not
emit
any
pollutant
over
10,000
TPY.
In
fact,
Bullitt
County
emits
less
than
1%
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.
Bullitt
County s
NOx
emissions
stand
at
3%
and
PM
at
5%
of
the
total
EPA
recommended
areas.
In
a
detailed
review
of
EPA s
recommended
nonattainment
areas,
Bullitt
County
ranks
consistently
low
in
potential
emissions
contributions
within
EPA s
proposed
nonattainment
boundaries
(
See
Figures
1­
4
below).
Based
on
this
data,
Kentucky
strongly
objects
to
EPA s
characterization
of
emissions
from
Bullitt
County
as
being
significant.
2
Figure
1
Louisville
Area
2001
SOx
Emissions
Floyd,
IN
43%
Jefferson,
KY
57%
Oldham,
KY
0%

Clark,
IN
0%

Bullitt,
KY
0%
Harrison,
IN
0%
Scott,
IN
0%

Figure
2
Louisville
Area
2001
NOx
Emissions
Jefferson,
KY
76%

Bullitt,
KY
3%
Scott,
IN
1%
Harrison,
IN
3%
Clark,
IN
5%
Floyd,
IN
9%
Oldham,
KY
3%
3
Figure
3
Louisville
Area
2001
PM
Emissions
Jefferson,
KY
47%
Oldham,
KY
5%
Bullitt,
KY
5%
Scott,
IN
3%
Harrison,
IN
5%
Clark,
IN
10%

Floyd,
IN
25%

Figure
4
­
5,000
5,000
15,000
25,000
35,000
45,000
55,000
65,000
75,000
85,000
Bullitt,
KY
Jefferson,

KY
Oldham,
KY
Floyd,
IN
Clark,
IN
Harrison,
IN
Scott,
IN
T
o
n
s
p
e
r
Y
e
a
r
Louisville
Area
2001
Emissions
PM
SOx
NOx
VOC
NH3
Carbon
Crustal
In
Figure
5
below,
the
data
from
Jefferson
County s
speciation
monitor
on
Barret
Avenue
indicates
that
sulfates
and
organic
carbon
are
the
major
components
of
the
PM2.5
values
in
the
area.
As
can
be
seen
in
Figure
1
above,
Bullitt
County,
Kentucky,
contributes
less
than
1%
of
the
SO2
and
approximately
8%
of
the
total
organic
carbon
emissions
(
Figure
6
below)
in
the
counties
recommended
by
EPA
as
having
the
potential
to
impact
the
violating
monitor.
In
both
instances,
every
other
county
with
the
exception
of
Oldham
County,
Kentucky
and
Harrison
County,
Indiana
has
a
higher
potential
to
contribute
to
the
problem.
4
Figure
5
LMAPCD
(
Barret)
AIRS
Code
212270007
POC
5
(
ROUTINE)
Date(
s):
1/
3/
03
 
12/
29/
03
Average
Concentration
(
µ
g/
m
3)

Elemental
Carbon
4%
Crustal
Component
3%
Other
15%

Organic
Carbon
25%

Ammonium
12%
Sulfate
31%
Nitrate
10%

Figure
6
Louisville
Area
2001
Carbon
Emissions
Jefferson,
KY
49%
Bullitt,
KY
8%

Oldham,
KY
5%
Floyd,
IN
17%
Scott,
IN
3%
Harrison,
IN
5%
Clark,
IN
13%

Monitoring
Data
and
Trends
The
monitor
located
in
Bullitt
County
shows
attainment
with
the
PM2.5
standard.
For
the
2001­
2003
timeframe
the
design
value
(
14.9
µ
g/
m
3)

approaches
the
annual
standard
but
continues
to
demonstrate
attainment.
The
5
annual
concentrations,
for
both
the
Bullitt
County
monitor
and
for
the
entire
area
continue
to
show
a
downward
trend
as
depicted
in
Figures
7
and
8,
which
utilized
data
from
the
year
2000
through
April
2004.

Figure
7
Louisville
Area
PM2.5
Trend
Utilizing
Most
Current
Available
Data
12.0
13.0
14.0
15.0
16.0
17.0
18.0
19.0
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
)
Bullitt
37th
&

Southern
Barret
Beecher
Watson
As
depicted
in
Figure
8
below,
monitoring
data
for
the
Louisville
area
shows
a
7%
­
12%
decrease,
depending
on
monitor
location,
from
the
year
2000
through
2003.

Monitoring
data
shows
that
Bullitt
County
is
attaining
the
PM2.5
standard.
Based
on
the
continuing
decline
in
PM2.5
levels
throughout
the
region,
all
monitors
within
this
region
are
anticipated
to
attain
the
PM2.5
standard
without
any
additional
controls
being
imposed
on
the
area.
The
monitor
with
the
highest
design
value
in
the
entire
region,
located
on
37
th
and
Southern
in
Jefferson
County
is
anticipated
to
be
in
compliance
with
the
standard
by
the
end
of
2005,
if
levels
continue
to
decline
as
they
have
in
the
past.
Based
on
air
monitoring
data
so
far
in
2004,
levels
may
decline
more
rapidly
than
in
the
past
few
years.
6
Figure
8
0.0
2.0
4.0
6.0
8.0
10.0
12.0
14.0
16.0
18.0
20.0
Bullitt
37th
&
Southern
Barret
Beecher
Watson
PM
Decreases
in
the
Louisville
Area
2000
2001
2002
2003
2004
2000­
2003
shows
decrease
of
12%
2000­
2003
shows
decrease
of
7%
2000­
2003
shows
decrease
of
11%
2000­
2003
shows
decrease
of
8%
2000­
2003
shows
decrease
of
8%

Population
Density
and
Growth
EPA
stated
that
2002
population
levels
indicated
Bullitt
County
had
the
potential
to
impact
PM2.5
violations
in
the
area.
However,
while
Bullitt
County
has
the
fourth
highest
population
in
the
MSA,
the
county
itself
comprises
approximately
only
6%
of
the
entire
MSA,
and
only
7%
of
the
counties
recommended
by
EPA
as
having
the
potential
to
impact
the
violating
monitors.
See
Figure
9
below.
7
Figure
9
Traffic
and
Commuting
Patterns
EPA s
position
on
traffic
and
commuting
patterns
in
the
June
29
th
letter
noted
that
Bullitt
County
has
potentially
significant
numbers
of
commuters
impacting
the
area.
However,
further
in
the
document
under
a
specific
discussion
of
population
levels,
EPA
states
that
population
is
not
a
factor
in
any
county
except
Jefferson.
In
2002
Bullitt
County
contributed
only
7%
of
the
VMT s
in
the
area
recommended
by
EPA
as
having
the
potential
to
impact
the
violating
monitors.
Based
on
data
used
by
EPA
in
their
analysis,
Bullitt
County
had
19,730
commuters
traveling
into
Jefferson
County.
This
number
is
insignificant
(
6.5%)
when
compared
to
303,624
Jefferson
County
commuters
in
2002.

It
is
important
to
note
that
any
possible
impacts
from
population
or
commuter
contributions
from
Bullitt
County
would
be
mitigated
in
the
near
future
by
national
fuel
programs
referenced
later
in
this
document.

Therefore,
Kentucky
believes
that
Bullitt
County
does
not
have
the
population,
commuter,
or
VMT
potential
to
contribute
to
PM2.5
violations
in
the
area.

Additional
Information
A
further
review
of
wind
rose
data
shows
that
predominant
winds
generally
come
from
the
south­
southwest,
which
would
typically
show
a
contribution
coming
from
Bullitt
County
(
See
Figure
10).
However,
previous
documented
Louisville
Area
2002
Population
for
USEPA
Proposed
PM2.5
Nonattainment
Counties
Jef
f
erson,
KY
74%

Floyd,
IN
8%
Bullit
t
,
KY
7%

Clar
k,
IN
11%
8
data
outlining
emissions
contribution
percentages
in
the
area,
population
and
commuter
data
show
that
activities
actually
occurring
in
Bullitt
County
would
have
little
impact
on
PM2.5
levels
within
that
county
or
on
other
counties
within
the
MSA.
Rather,
it
appears
that
the
monitor
located
in
Bullitt
County
is
being
impacted
by
emissions
from
other
areas.

Clark
Jefferson
Floyd
Harrison
Oldham
Bullitt
Scott
Figure
10
9
Using
the
NOAA
HYSPLIT
Model,
a
review
of
some
of
the
highest
PM2.5
level
24­
hour
periods
was
performed
to
attempt
to
determine
possible
contributions
from
Bullitt
County.
A
separate
analysis
was
performed
on
days
when
monitoring
levels
were
high
in
Bullitt
County
and
days
when
monitoring
levels
were
high
in
other
monitors
within
the
region.

As
can
be
seen
in
Attachments
A
through
C
on
days
when
monitored
values
were
highest
in
Bullitt
County,
wind
patterns
indicate
a
potential
impact
from
both
Jefferson
County
and
Southern
Indiana.

A
separate
review
of
days
when
monitored
values
were
highest
in
Jefferson
County
and
Southern
Indiana,
again
show
no
impact
coming
from
Bullitt
County.
See
attachments
D
through
L.

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.

Conclusions
Based
on
the
factors
discussed
above,
Kentucky
believes
that
Bullitt
County
should
be
designated
attainment
for
the
PM2.5
standard.

 
Kentucky
believes
that
EPA s
use
of
the
weighted
emissions
scoring
approach
was
skewed.
Although
attempting
to
have
a
standardized
process
to
review
violations
of
the
PM2.5
standard
throughout
the
nation
10
on
the
surface
appears
to
make
sense,
each
area
is
actually
very
different
and
emission
contribution
ratios
are
just
one
factor
and
should
not
alone
be
used
to
determine
impacts.

 
Emissions
data,
population,
and
commuter
data
show
that
the
actual
percentage
of
contribution
from
Bullitt
County
itself
is
exceptionally
low
compared
to
other
counties
within
the
region.
This
analysis
actually
points
to
the
Bullitt
County
monitor
being
impacted
by
emissions
from
other
counties
within
the
region.

 
PM2.5
levels
continue
to
decline
throughout
the
entire
region.
From
a
review
of
all
monitors
in
the
region,
an
average
9%
decline
in
PM2.5
levels
has
occurred
from
2000
through
2003.
The
Bullitt
County
monitor
in
the
region
is
currently
showing
attainment
of
the
annual
PM2.5
standard
using
2002
through
2004
data
and
other
monitors
are
projected
to
come
into
compliance
within
a
short
period
of
time.

 
A
review
of
trajectory
analysis
on
both
days
when
the
Bullitt
County
monitor
is
showing
high
PM2.5
values,
as
well
as
a
separate
review
of
a
sampling
of
days
when
PM2.5
values
are
highest
at
other
monitors
within
the
region,
show
that
Bullitt
County
is
not
impacting
violating
monitors
on
days
when
the
levels
are
highest.

 
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
and
the
Tier
2
Vehicle
and
Gasoline
Sulfur
programs,
and
the
Clean
Air
Interstate
Rule
(
CAIR)
will
further
lower
pollutant
levels
within
this
region.

Based
on
the
above
conclusions,
Bullitt
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.
Especially
since
a
thorough
review
of
information
shows
that
Bullitt
County
is
being
impacted
by
emissions
coming
from
outside
the
county.
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,
the
air
monitoring
data
demonstrating
attainment
of
the
PM2.5
Standard,
and
the
downward
trend
in
monitored
values,
and
the
conclusion
must
be
that
Bullitt
County,
Kentucky,
should
be
designated
attainment
for
the
PM2.5
Standard.
