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

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

 
EPA
indicates
that
Kenton
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
Kenton
County
has
relatively
high
population
values,
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
Kenton
County
shows
attainment
with
the
PM2.5
standard.
For
the
2001­
2003
timeframe
the
design
value
(
14.9
µ
g/
m
3)

demonstrates
attainment
with
the
annual
standard.
The
annual
concentrations
for
the
area
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
over
from
the
year
2000
through
2003.

The
Kenton
County
monitor
is
attaining
the
PM2.5
standard.
The
continuing
downward
trend
in
PM2.5
levels
throughout
the
region
indicate
that
air
quality
is
improving
in
the
region
and
should
continue
to
do
so
over
the
next
several
years.

Population
Growth
and
VMT
Levels
EPA
stated
that
Kenton
County
had
relatively
high
population
density
that
had
the
potential
to
impact
PM2.5
violations
in
the
area.
Kenton
County
makes
up
only
8%
of
the
population
in
the
entire
MSA,
see
Figure
3
below.
3
Figure
3
Northern
Kentucky
Area
2002
Population
for
USEPA
Proposed
PM
2.5
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
density
in
Kenton
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
Kenton
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
Kenton
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,
they
also
state
that
20,200
commuters
traveling
from
Kenton
County
into
Hamilton
County
is
insignificant
when
compared
to
total
Hamilton
County
commuters
in
2002.
Kentucky
agrees
with
EPA
that
commuter
data
is
insignificant
for
Kenton
County
and
therefore
should
not
be
used
as
a
factor
in
determining
nonattainment.

Additionally,
when
reviewing
VMT
data,
it
should
be
noted
that
in
2002
Kenton
County
contributed
only
9.2%
of
the
total
VMT s
in
the
counties
recommended
by
EPA
as
having
the
potential
to
impact
the
violating
monitors.
Due
to
the
small
contribution
from
Kenton
County,
this
factor
should
also
not
be
used
in
determining
a
nonattainment
designation
for
this
county.

Therefore,
it
is
Kentucky s
position
that
Kenton
County
does
not
have
the
population
density
levels,
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
Kenton
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
Kenton
County
monitor
in
the
region
is
currently
showing
attainment
of
the
annual
PM2.5
standard
using
2002
through
2004
data.

 
Contributions
from
commuters
and
vehicle
miles
traveled
in
Kenton
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
for
this
county.

 
Additional
emission
reduction
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.
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
downward
trend
in
monitored
values,
and
the
resulting
conclusion
is
that
Kenton
County,
Kentucky,
should
be
designated
attainment
for
the
PM2.5
Standard.
