INDIANA
DEPARTMENT
OF
ENVIRONMENTAL
MANAGEMENT
We
make
Indiana
a
cleaner,
healthier
place
to
live.

Joseph
E.
Kernan
100
North
Senate
Avenue
Governor
P.
O.
Box
6015
Indianapolis,
Indiana
46206­
6015
Lori
F.
Kaplan
(
317)
232­
8603
Commissioner
(
800)
451­
6027
www.
IN.
gov/
idem
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December
6,
2004
Steve
Rothblatt
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency,
Region
V
77
West
Jackson
Boulevard
Chicago,
Illinois
60604
Re:
PM2.5
Nonattainment
Designations
Dear
Mr.
Rothblatt:

On
December
2,
2004,
I
and
others
from
the
Indiana
Department
of
Environmental
Management,
discussed
with
members
of
your
staff
USEPA's
upcoming
decision
on
PM2.5
attainment
and
nonattainment
designations,
with
particular
attention
on
counties
in
southwestern
Indiana.
This
letter
provides
additional
data
and
analysis
for
your
consideration.

We
understand
that
USEPA
is
evaluating
whether
to
consider
data
from
the
first
three
quarters
of
2004
in
addition
to
the
2001­
2003
annual
averages
as
a
further
indicator
of
whether
air
quality
in
a
given
area
meets
the
PM2.5
health
standard.
We
strongly
urge
USEPA
to
take
these
data
into
account,
as
it
is
clear
that
utility
and
other
clean
air
reduction
programs
implemented
in
recent
years
are
resulting
in
cleaner
air
in
several
Indiana
regions.
Recognizing
that
progress
now,
through
either
an
attainment
or
unclassifiable
designation,
will
avoid
unnecessary
imposition
of
requirements
on
counties
where
air
quality
meets
health
standards
and
emissions
are
not
contributing
to
nonattainment
downwind.
And,
given
the
likelihood
that
these
areas
will
attain
the
standard
once
2004
data
are
fully
quality
assured,
it
does
not
make
sense
to
designate
these
areas
in
December,
only
to
begin
a
public
process
of
redesignation
several
months
later.

One
of
the
areas
where
monitoring
data
show
a
downward
trend,
and
where
2004
data
to
date
strongly
suggest
that
the
2002­
2004
annual
average
will
show
compliance
with
the
health
standard
is
Evansville.
The
data
show
not
only
that
air
quality
is
meeting
the
standard
in
the
Evansville
area,
but
also
that
emissions
from
Vanderburgh
County
are
not
contributing
to
high
PM2.5
values
in
Dubois
County.
Enclosed
with
this
letter
is
further
information
on
this
issue
for
your
consideration
that
supports
the
following
conclusions:
2
 
Wind
rose
analysis
shows
that
on
those
days
where
values
are
particularly
high,
driving
up
the
annual
average,
winds
are
generally
not
from
the
south/
southwest
(
i.
e.
Evansville)
direction;
 
On
days
with
high
values,
PM2.5
concentrations
at
the
Jasper
monitor
do
not
appear
to
increase
relative
to
other
sites
when
the
wind
is
directly
from
Vanderburgh
County;
 
The
Jasper
monitor
shares
the
same
regional
background
as
all
other
sites;
 
Local
influences
such
as
nearby
highway
and
emissions
from
local
industry
are
possible
causes
of
differences
in
Jasper
values
relative
to
other
sites;
 
Power
plant
emissions,
which
are
clearly
a
substantial
contributor
to
regional
values,
are
just
as
high
in
surrounding
counties
relative
to
Vanderburgh
County.

Indiana
is
fully
committed
to
improving
air
quality
for
all
Hoosiers.
Regardless
of
the
outcome
of
the
nonattainment
designations,
there
are
clean
air
measures
on
the
way,
but
not
yet
implemented,
that
will
continue
to
improve
air
quality
across
our
state.
We
strongly
urge
USEPA
to
consider
all
the
data
presented,
including
this
most
recent
information,
prior
to
making
these
critical
policy
determinations.
If
you
or
your
staff
have
questions
about
the
information
in
this
letter
or
the
nonattainment
determinations,
please
contact
me
at
317­
232­
8222
or
Ken
Ritter
at
317­
233­
5682.

Very
truly
yours,

Janet
G.
McCabe
Assistant
Commissioner
Enclosure
cc:
Cheryl
Newton
Jay
Bortzer
John
Summerhays
Joanne
Alexandrovich
Dona
Bergman
