1
CLARK
COUNTY,
KENTUCKY
Clark
County
is
part
of
the
Lexington­
Fayette
County,
Kentucky
Metropolitan
Statistical
Area
(
MSA)
and
is
on
the
I­
64
east­
west
interstate
corridor.
It
is
located
southwest
of
Montgomery
County,
northwest
of
Powell
County,
northnorthwest
of
Estill
County,
north
of
Madison
County,
east
of
Fayette
County,
and
south
of
Bourbon
County.

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

 
EPA
indicates
that
Clark
County
has
significant
SO
x,
NO
x,
and
PM
emissions
that
potentially
contribute
to
the
violating
MSA
monitor.
EPA
noted
that
10,000
tpy
of
any
pollutant
defines
significant
 
Clark
County
does
not
have
10,000
tpy
of
a
single
pollutant.

Emissions
Data
In
Kentucky s
original
February
recommendations,
1999
NEI
data
was
used
in
the
original
analysis.

However,
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.
EPA
also
used
the
2001
NEI
which
provided
slightly
newer
data
than
had
been
recommended
that
states
use.

Clark
County
emits
only
14%
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.
Clark
County s
NOx
emissions
rank
at
14%
of
the
total
EPA
recommended
areas,
and
PM
at
13%.
In
a
detailed
review
of
EPA s
recommended
areas
to
be
designated
nonattainment,
Clark
County
ranks
consistently
less
than
or
equal
to
15%
of
combined
emissions
contributions
within
EPA s
June
29,
2004,
proposed
nonattainment
boundaries.
See
Figures
1­
4
below.
2
Figure
1
Lexington
Area
SOx
Emissions
in
EPA
Proposed
Nonattainment
Counties
Scott
0%
Jessamine
0%
Bourbon
0%
Madison
2%
Clark
14%
Fayette
6%
Woodford
4%
Mercer
74%

Figure
2
Lexington
Area
2001
NOX
Emissions
Woodford
8%

Mercer
20%
Clark
14%

Madison
12%
Scott
8%
Jessamine
5%
Bourbon
3%
Fayette
30%
3
Figure
3
Fayette
Area
PM
Emissions
in
EPA
Proposed
Nonattainment
Counties
Woodford
6%
Scott
7%
Jessamine
6%

Mercer
34%
Madison
10%
Clark
13%
Fayette
19%
Bourbon
5%

Figure
4
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
50,000
T
o
n
s
P
e
r
Y
e
a
r
Fayette
Clark
Madison
Mercer
Woodford
Scott
Jessamine
Bourbon
Lexington
Area
Counties
Emissions
2001
PM
SOx
NOx
VOC
NH3
Monitoring
Data
and
Trends
As
can
been
seen
in
Figure
5
below,
the
speciation
data
from
Kentucky s
Lexington
speciation
monitor
indicates
that
sulfate
is
the
major
component
of
the
PM2.5
values.
In
Figure
1
above,
Clark
County,
Kentucky,
contributes
only
14%
of
the
SOx
in
the
area
of
proposed
nonattainment
counties
by
EPA.
4
Figure
5
Lexington
Speciation
Monitoring
Data
2001­
2003
Average
Concentration
(
µ
g/
m
³
)

Elemental
carbon
3%
Crustal
component
3%
Other
13%

Organic
carbon
24%

Ammonium
13%
Sulfate
32%
Nitrate
12%

The
MSA
has
three
monitors
located
within
its
boundaries,
two
in
Fayette
County
and
one
in
Madison
County.
PM2.5
monitoring
levels
have
continued
to
decline
at
all
three
monitors
within
this
region.
(
See
Figure
6
below)

Fayette
County
has
two
PM2.5
monitors,
one
located
in
a
central
urban
area
in
the
midst
of
the
downtown,
University
of
Kentucky
campus
(
Limestone),
and
the
other
located
on
an
arterial
roadway
north
of
downtown
(
Newtown
Pike).

The
Newtown
Pike
monitor
shows
attainment
with
the
standard,
having
an
average
of
14.9
µ
g/
m
3
over
the
time
period
2001­
2003,
and
having
an
average
of
13.6
µ
g/
m
3
through
April
2004.

The
latest
average
through
April
2004
for
the
Limestone
monitor
is
14.7
µ
g/
m
3.

The
violation
at
this
monitor
with
an
average
of
15.6
µ
g/
m
3
exists
during
the
2001­
2003
time
period.

Even
though
Clark
County
does
not
have
a
monitor,
the
PM2.5
levels
have
decreased
by
15%
at
the
Newtown
Pike
monitor,
12%
at
the
Limestone
monitor,
and
13%
at
the
Madison
County
monitor
(
See
Figure
7
below).
5
Figure
6
Fayette
Area
PM2.5
Trend
Utilizing
Most
Current
Available
Data
12.0
13.0
14.0
15.0
16.0
17.0
18.0
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
)

Newtown
Limestone
Madison
Figure
7
0.0
2.0
4.0
6.0
8.0
10.0
12.0
14.0
16.0
18.0
20.0
Newtown
Limestone
Madison
Decline
in
PM
Values
for
the
Fayette
Area
2000
2001
2002
2003
2000­
2003
shows
decrease
of
15%
2000­
2003
shows
decrease
of
12%
2000­
2003
shows
decrease
of
13%
6
Localized
vs
Regional
Impacts
It
is
Kentucky s
position
that
the
monitor
located
on
the
UK
Campus
exhibits
an
 
Urban
Core
Phenomenon. 
That
is,
the
monitor s
location
is
at
the
center
of
a
large
public
university
situated
in
a
downtown
metropolitan
area
with
significant
activity
having
a
direct
relationship
to
the
PM2.5
levels
being
monitored.

This
monitor
is
bracketed
by
numerous
large
and
small
boilers
on
the
University
of
Kentucky
campus
and
is
located
adjacent
to
continuing
construction
on
the
campus.
Significant
local
impacts
are
occurring
due
to
not
only
the
close
proximity
of
the
boilers,
but
also
from
the
emission
contributions
of
construction
equipment
in
the
area.
This
monitor
is
located
only
1.9
miles
from
the
monitor
showing
attainment
of
the
standard
on
Newtown
Pike.

If
significant
regional
impacts
from
emissions
from
Clark
County
were
occurring,
they
would
be
expected
throughout
the
regional
monitoring
network
and
not
at
one
specific
monitor
in
downtown
Lexington.

Meteorology
EPA s
response
to
Kentucky
stated
that
the
wind
speed/
wind
direction
data
provided
by
Kentucky
in
the
February
submittal
did
not
play
a
significant
role
in
the
decision
making
process
and
that
the
information
was
for
summertime
winds.
Kentucky
offers
the
following
information.

As
shown
in
the
updated
wind
rose
in
Figure
8
below,
the
majority
of
the
time
the
wind
in
the
Lexington
area
comes
from
the
south
and
the
southwest.
Clark
County
is
east­
southeast
from
the
violating
monitor
in
Fayette
County.
The
wind
rose
data
indicates
that
Clark
County
does
not
impact
this
monitor.
7
Figure
8
Scott
Fayette
Woodford
Mercer
Bourbon
Clark
Madison
Jessamine
8
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
Clark
County
should
be
designated
attainment
for
the
PM2.5
standard.

 
Kentucky
believes
that
EPA s
use
of
the
weighted
emissions
scoring
approach
was
skewed.
EPA
did
not
include
adjacent
county
emissions
in
the
total
emissions
being
analyzed
for
the
area.
If
the
emissions
from
the
entire
area
under
review
were
used,
vs
just
those
within
the
MSA,
a
very
different
result
in
the
weighted
emissions
scores
would
have
occurred.
Clark
County
would
not
have
the
potential
to
contribute
significantly
to
PM2.5
levels
within
the
region.

 
The
only
monitor
showing
a
violation
throughout
the
entire
eight
county
region
is
being
impacted
by
extreme
urban
core
activities
in
a
specific
geographic
location
with
Fayette
County.

 
PM2.5
levels
continue
to
decline
throughout
the
entire
region.
From
a
review
of
all
monitors
in
the
region,
an
average
13%
decline
in
PM2.5
levels
has
occurred
from
2000
through
2003.
Every
monitor
in
the
region
9
is
currently
showing
values
well
within
attainment
of
the
annual
PM2.5
standard
using
2002
through
2004
data.

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

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.
In
addition,
reductions
anticipated
by
the
CAIR
provisions,
the
air
monitoring
data
demonstrating
attainment
of
the
PM2.5
Standard
at
two
of
the
three
monitors
in
the
area,
the
downward
trend
in
monitored
values,
and
Kentucky s
position
that
the
monitored
violation
of
the
standard
in
the
downtown
area
is
the
result
of
a
localized
 
urban
core
phenomenon; 
lead
to
the
conclusion
that
Clark
County,
Kentucky
should
be
designated
attainment
for
the
PM2.5
Standard.
