1
Fayette
County,
Kentucky
Fayette
County
is
located
in
the
Lexington,
Kentucky
Metropolitan
Statistical
Area
(
MSA)
and
is
located
to
the
east
of
Woodford
County,
to
the
northeast
of
Jessamine
County,
to
the
northwest
of
Madison
County,
to
the
west
of
Clark
County,
to
the
southeast
of
Scott
County,
and
to
the
southwest
of
Bourbon
County.

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

 
EPA
indicates
that
Fayette
County
has
over
10,000
tons
per
year
(
considered
by
EPA
to
be
significant)
of
NOx
and
VOC
emissions;

 
Fayette
County
has
a
violating
PM2.5
monitor;
and
 
EPA
indicates
that
the
population
and
population
density,
expected
growth,
and
vehicle
miles
traveled
(
VMTs)
and
commuters
have
a
potential
to
contribute
to
the
PM2.5
violations
in
the
area.

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

Specifically,
in
the
Lexington
metropolitan
area,
EPA
has
recommended
that
Fayette
County
be
included
as
nonattainment
areas
due
to
the
significant
emissions
in
the
county.
However,
Fayette
County
has
emissions
greater
than
10,000
tpy
of
NOx
and
VOC
only.
In
this
area,
as
shown
by
speciation
data
in
Figure
5,
of
greatest
concern
are
SOx
and
organic
carbon.

With
Mercer
County
included
in
the
recommended
nonattainment
area,
Fayette
County
emits
only
6%
of
SOx
and
19%
of
the
PM
emissions
from
the
eight
county
area
recommended
by
EPA
as
having
the
potential
to
impact
the
violating
monitor.
See
Figures
1­
4
below.
2
Figure
1
Lexington
Area
2001
SOx
Scott,
KY
0%

Jessamine,
KY
0%
Bourbon,
KY
0%
Woodford,
KY
4%
Mercer,
KY
74%

Fayette,
KY
6%
Clark,
KY
14%
Madison,
KY
2%

Figure
2
Fayette
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
2001
PM
Emissions
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
Air
Monitoring
Data
and
Trends
Fayette
County
has
two
PM2.5
monitors,
one
located
in
a
central
urban
area
in
the
midst
of
the
University
of
Kentucky
(
UK)
on
Limestone
Avenue,
and
the
other
is
located
out
on
an
arterial
roadway
1.9
miles
north
of
downtown
(
Newtown
Pike).
4
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
UK
monitor
currently
has
a
design
value
of
15.6
µ
g/
m
3
over
the
2001­
2003
time
period.
However,
the
average
through
April
2004
for
this
monitor
has
declined
to
14.7
µ
g/
m
3.

As
can
been
seen
in
Figure
5
below,
the
speciation
data
from
Kentucky s
Lexington
speciation
monitor
indicates
that
sulfate
and
organic
carbon
are
the
major
components
of
the
PM2.5
values
in
this
area.
As
can
be
seen
in
Figure
1
above,
Fayette
County,
Kentucky,
contributes
only
6%
of
the
SOx
in
the
combined
area.

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%

Although
the
UK
Limestone
monitor
for
the
2001­
2003
timeframe
exceeded
the
annual
standard
(
15.6
µ
g/
m
3),
it
currently
shows
attainment
with
the
PM2.5
standard
with
data
through
April
2004
(
14.7
µ
g/
m
3).
As
well,
the
annual
concentrations
for
the
entire
area
continue
to
show
a
downward
trend
as
depicted
in
Figure
6
below,
which
utilized
data
from
the
year
2000
through
April
2004.
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
Specifically,
the
PM
2.5
levels
have
decreased
in
Fayette
County
by
15%
at
the
Newtown
monitor
and
12%
at
the
Limestone
monitor,
and
by
13%
in
Madison
County
(
See
Figure
7
below).

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
located
only
1.9
miles
from
the
monitor
showing
attainment
of
the
standard
on
Newtown
Pike.

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.
The
University
of
Kentucky
encompasses
a
very
large
campus
with
numerous
buildings.
UK
estimates
that
there
are
approximately
112
boilers
on
campus.
Many
of
these
boilers
are
small,
natural
gas
powered
boilers,
which
could
account
for
a
significant
difference
in
SOx
vs
NOx
emissions
in
the
area.

However,
several
of
these
boilers
are
also
coal
fired
and
have
the
potential
to
impact
PM2.5
levels
in
the
vicinity
of
the
monitor.

Significant
local
impacts
are
occurring
not
only
due
to
the
close
proximity
of
the
boilers,
but
also
from
the
emission
contributions
of
construction
and
delivery
equipment
in
the
area.

In
2003,
the
University
of
Kentucky
completed
construction
of
three
new
buildings
within
close
proximity
to
the
monitor.
These
buildings
included
the
College
of
Engineering s
Ralph
G.
Anderson
Building;
the
College
of
Health
Sciences
Building;
and
the
College
of
Agriculture
Plant
Sciences
Building.

Construction
continues
on
the
Biomedical/
Biological
Science
Research
Building,
the
Linda
and
Jack
Gill
Building,
The
Main
Building
and
Patterson
Plaza,
and
four
new
dormitories.

Without
the
localized
impacts
from
this
vicinity,
Kentucky
believes
that
neither
monitor
would
be
showing
a
violation
of
the
PM2.5
standard
in
Fayette
County.

Population
Density
and
Growth
EPA
stated
that
2002
population
levels
in
Fayette
County
are
3­
11
times
higher
population
than
the
other
counties
under
review
in
this
area
and
that
this
factor
could
contribute
to
PM2.5
problems
in
the
area.
See
Figure
8
below.
7
Figure
8
Lexington
Area
2002
Population
for
USEPA
proposed
PM2.5
Nonattainment
Counties
Fayette
51%

Clark
7%
Madison
14%
Scott
7%
Woodford
5%
Bourbon
4%
Jessamine
8%
Mercer
4%

However,
Fayette
County
was
fifth
in
growth
rate
(
16%),
showing
that
other
counties
within
the
region
are
growing
at
a
more
rapid
rate
than
Fayette
County.
As
discussed
later
in
this
document,
several
national
control
programs
will
be
implemented
within
the
next
three
years
to
reduce
population
related
emissions
that
contribute
to
PM2.5
problems
in
many
of
our
urban
areas,
including
Fayette
County.

Traffic
and
Commuting
Patterns
EPA
noted
that
Fayette
County
has
substantially
large
numbers
of
commuters
and
VMT.

The
potential
of
Fayette
County s
growth
to
contribute
significantly
to
traffic
and
commuting
emissions
will
be
mitigated
by
the
referenced
national
fuel
programs,
the
Low
Sulfur
Diesel
Program
and
the
Tier
2
Vehicle
and
Low
Sulfur
Gasoline
program.

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
8
(
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
if
any
part
of
Fayette
County
should
be
designated
nonattainment
it
should
be
limited
to
the
area
directly
surrounding
the
monitoring
site
within
New
Circle
Road.
Supporting
factors
are
as
follows:

 
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
on
the
University
of
Kentucky
Campus
in
Fayette
County.
The
other
monitor
which
is
located
1.9
miles
away
is
showing
attainment
of
the
standard.

 
EPA
has
suggested
that
one
large
regional
source
in
Mercer
County
is
contributing
to
the
violation
in
Fayette
County.
However,
with
the
monitors
being
located
only
1.9
miles
from
each
other,
with
the
Newtown
Pike
monitoring
site
showing
attainment,
if
this
area
was
receiving
an
impact
from
one
significant
source,
both
monitors
would
be
showing
a
violation.
This
further
identifies
a
localized
impact
on
the
monitor
located
on
the
University
of
Kentucky
campus.

 
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
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.
9
To
have
this
entire
county
designated
nonattainment
would
invoke
additional
substantial
and
unnecessary
requirements
on
local
government
planning
agencies.
Data
exist
to
show
that
a
localized
impact
is
being
seen
on
the
Limestone
monitor.

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
only
a
specific
portion
of
Fayette
County
should
be
designated
as
nonattainment
for
the
PM2.5
standard.
