1
Campbell
County,
Kentucky
Campbell
County
is
part
of
the
Cincinnati­
Hamilton,
OH­
KY­
IN
Metropolitan
Statistical
Area
(
MSA)
and
is
located
to
the
east
of
Kenton
County,
Kentucky,
to
the
north
of
Pendleton
County,
Kentucky,
and
to
the
southeast
of
Cincinnati,
Ohio.

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

 
EPA
indicates
that
Campbell
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
Campbell
County
has
relatively
high
population,
VMT
and
commuting
patterns
that
are
significant
enough
to
contribute
to
PM2.5
violations
in
the
MSA.

Monitoring
Data
and
Trends
The
monitor
located
in
Campbell
County
shows
attainment
with
the
PM2.5
standard
and
has
the
lowest
design
value
of
any
monitor
within
the
region.
For
the
2001­
2003
timeframe
the
design
value
(
13.9
µ
g/
m
3)
demonstrates
attainment
with
the
annual
standard.
The
annual
concentrations
for
the
area
also
continue
to
show
a
downward
trend
as
depicted
in
Figure
1,
which
utilized
data
from
the
year
2000
through
April
2004.

Figure
1
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
)

Campbel,
KY
Kenton,
KY
Butler
,
OH
Hamilton,
OH
2
Figure
2
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%

As
depicted
in
Figure
2
above,
monitoring
data
for
the
Northern
Kentucky
area
shows
an
11­
12%
decrease
from
the
year
2000
through
2003.

Kentucky
believes
Campbell
County
is
attaining
the
PM2.5
standard
and
that
the
continuing
downward
trend
in
PM2.5
levels
indicate
no
potential
to
impact
the
violations
in
the
MSA.

Population,
VMT,
and
Commuting
Patterns
EPA
stated
that
Campbell
County
had
relatively
high
population
levels
that
had
the
potential
to
impact
PM2.5
violations
in
the
area.
Campbell
County
makes
up
only
5%
of
the
population
in
the
entire
MSA,
see
Figure
3
below.
3
Figure
3
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,
it
is
Kentucky s
position
that
the
population
in
Campbell
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
Campbell
County.
Figure
4
below
outlines
total
VMT
per
county
for
the
MSA.

Figure
4
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
4
EPA s
position
on
traffic
and
commuting
patterns
in
the
June
29
th
letter
noted
that
Campbell
County
has
potentially
significant
numbers
of
commuters
impacting
Hamilton
County.

Although
EPA
stated
that
commuting
patterns
may
play
a
role
in
PM2.5
levels
throughout
the
region.
EPA
states
that
a
notable
number
of
commuters
from
Kenton
and
Campbell
Counties
commute
into
Hamilton
County.
However,
that
statement
is
contradicted
where
they
state
further
that 
14,946
commuters
traveling
from
Campbell
County
into
Hamilton
County
is
insignificant
compared
to
total
Hamilton
County
commuters
in
2002.
Based
on
total
number
of
commuters
within
the
entire
region
and
total
VMT
data,
Kentucky
agrees
with
EPA
that
commuter
data
is
insignificant
and
should
not
be
a
factor
in
determining
nonattainment
designations
for
Campbell
County.

Additionally,
when
reviewing
VMT
data,
it
should
be
noted
that
in
2002
Campbell
County
contributed
only
5.6%
of
the
total
VMT s
in
the
counties
recommended
by
EPA
as
having
the
potential
to
impact
the
violating
monitors.
This
factor
should
also
not
be
used
in
determining
a
nonattainment
designation
for
Campbell
County.

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

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

 
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.
The
Campbell
monitor
in
the
region
is
currently
showing
attainment
of
the
annual
PM2.5
standard
and
has
the
lowest
design
value
of
any
monitor
within
the
region.

 
Contributions
from
commuters
and
vehicle
miles
traveled
in
Campbell
County
have
been
shown
to
have
no
potential
to
impact
PM2.5
levels
within
the
region
when
compared
to
the
levels
from
other
counties
and
therefore
should
not
be
used
to
determine
nonattainment
status.

 
Additional
emission
reductions
on
a
national
and
regional
level
will
provide
substantial
additional
emission
reductions
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,
Campbell
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.
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,
the
resulting
conclusion
should
be
that
Campbell
County,
Kentucky,
be
designated
attainment
for
the
PM2.5
Standard.
