6­
137
6.4
Region
4
Nonattainment
Areas
6.4.1
EPA
9­
Factor
Analyses
for
Alabama
for
the
Designation
of
PM2.5
Nonattainment
Areas
6.4.1.1
Birmingham
Area
MSA
The
following
is
the
9
factor
analysis
for
Birmingham
MSA
and
surrounding
Counties.
Alabama's
submittal
in
February
2004,
recommended
Jefferson
County
be
designated
nonattainment
for
the
fine
particulate
matter
(
PM2.5),
based
on
2001
­
2003
monitoring
data.
Based
on
the
following
analysis
EPA
believes
that
Jefferson,
Shelby
and
Walker
Counties
should
be
included
in
the
PM2.5
nonattainment
area.
Jefferson
County
has
a
violating
monitor
and
the
State
recommended
it
as
nonattainment.
Shelby
County
is
within
the
MSA,
has
high
PM,
SOx,
NOx,
and
VOC
emissions,
approximately
52
percent
of
its
commuters
commute
to
Jefferson
County,
has
relatively
high
population
and
VMT,
and
has
a
power
plant
within
the
County.
Walker
County
has
high
SOx
and
NOx
emissions
from
a
power
plant.
We
have
included
in
our
recommended
nonattainment
area
Walker
County
that
is
contiguous
to
the
MSA
with
a
violating
monitor,
that
is
generally
rural
in
character,
and
that
contains
an
identifiable
large
emitting
facility
or
facilities
(
e.
g.,
power
plants)
which
we
believe
contributes
to
the
nearby
nonattainment
problem.
We
have
included
this
County
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
County,
including
such
large
facilities,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invite
you
to
submit
to
us
a
recommendation
as
to
what
portion
of
Walker
County,
encompassing
the
large
facility
or
facilities,
should
be
designated
nonattainment.
Based
on
the
following
analysis,
EPA
agrees
that
Blount,
St.
Clair,
Calhoun,
Talladega,
Tuscaloosa
and
Morgan
Counties
should
be
recommended
attainment/
unclassifiable
for
PM2.5.
Blount
County
has
no
major
sources,
has
relative
low
emissions
and
has
the
lowest
population
and
VMT
in
the
Birmingham
area.
St.
Clair
County
has
relatively
low
SOx
and
PM
emissions
and
has
a
small
population.
Calhoun
County
has
no
major
sources,
84
percent
of
its
commuters
commute
within
its
County
and
it
is
adjacent
to
the
MSA.
Talladega
County
has
a
small
population,
an
attaining
monitor
(
14.7
DV),
low
VMT
and
it
is
adjacent
to
the
MSA.
Tuscaloosa
County
has
no
major
sources,
89
percent
of
its
commuters
commute
within
its
County,
has
an
attaining
monitor
(
11.6
DV)
and
it
is
adjacent
to
the
MSA.
Morgan
County
has
an
attaining
monitor,
is
part
of
another
MSA,
72
percent
of
its
commuters
commute
within
its
County
and
is
several
Counties
away
from
Jefferson
County.

Area
EPA
Recommendation
State
Recommendation
Birmingham,
AL
Full
Counties:
Jefferson,
Shelby
and
Walker
Full
Counties:
Jefferson
The
following
is
a
brief
summary
of
the
9
criteria
for
the
Birmingham
MSA
and
surrounding
Counties.
These
analyses
were
based
on
existing
available
data.
6­
138
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
2001
PM2.5,
SO2,
NOx,
VOC,
and
NH3
emissions
in
tons,
and
weighted
emissions
scores
for
the
Birmingham
Area
and
surrounding
counties.
The
MSA
counties
are
in
bold.

Birmingham
MSA
and
Surrounding
Counties
Emissions
County
PM
SO2
NOX
VOC
NH3
Weighted
Emissions
Score
Cumulative
Weighted
Emissions
Score
Jefferson
12,772
56,703
69,364
44,782
1,198
50.3
27.5
Shelby
8,780
126,125
42,095
9,650
386
40.9
91.2
St
Clair
976
1,087
7,159
4,673
1,395
4.8
96.0
Blount
937
454
3,054
2,781
4,049
3.9
99.9
Walker
3,916
59,256
23,982
4,750
1,491
19.2
Tuscaloosa
2,065
5,183
11,252
14,752
915
12.8
Morgan
2,386
10,949
12,012
17,639
2,183
11.0
Etowah
2,193
11,850
8,487
7,089
1,842
9.9
Calhoun
2,000
2,271
7,115
9,452
1,098
9.5
Talladega
1,968
12,270
8,593
6,065
769
9.1
Dallas
1,505
3,296
4,124
3,670
411
6.2
Cullman
1,459
1,004
5,433
6,612
8,408
6.0
Marshall
1,294
1,525
4,749
7,283
4,275
5.5
Autauga
1,069
2,569
4,897
3,099
249
5.3
Lawrence
1,429
2,422
5,981
2,946
1,649
5.3
Elmore
1,014
517
4,443
4,368
326
4.8
Chilton
777
486
3,621
3,260
300
4.3
Bibb
613
189
1,260
1,433
169
3.8
Winston
574
320
1,547
3,311
1,336
3.4
Marion
567
450
2,835
3,151
742
3.1
Fayette
456
306
1,246
1,509
346
2.8
Coosa
408
152
791
1,410
102
2.4
Hale
430
156
2,373
1,462
215
2.3
Perry
415
218
589
799
166
2.3
Based
on
the
analysis
for
this
factor,
there
appears
to
be
emissions
in
Shelby
and
Walker,
Counties
that
contribute
to
the
air
quality
in
Jefferson
County,
resulting
in
a
violating
monitor
there.
6­
139
Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
Birmingham
MSA
and
Surrounding
Counties
Design
Value
(
DV)

County
2001­
2003
DV
Jefferson
18.0
Shelby
14.4
Walker
12.8
Tuscaloosa
11.6
**
Morgan
17.6
Etowah
14.8
Talladega
14.7
Jefferson
County
has
6
monitors,
only
one
monitor
exceeded
the
PM2.5
standard
(
North
Birmingham/
Wylam).
Shelby,
Walker,
Tuscaloosa,
Etowah,
and
Talladega
counties
all
have
monitors
that
show
attainment
of
the
PM2.5
standard.

**
Morgan
County
has
a
violating
monitor,
however,
the
Decatur,
Alabama,
fine
particulate
matter
(
PM2.5)
monitoring
site
(
AQS
#
01­
103­
0010)
began
operating
in
January
1999,
and
was
terminated
in
August
2001.
A
new
site
(
AQS
#
01­
103­
0011)
was
selected
in
the
Decatur
area
and
monitoring
begain
in
August
2001.
The
State
of
Alabama
requested
and
received
Region
4
concurrence
for
these
network
design
changes.
The
changes
were
approved
due
to
a
local
diesel
source
impacting
the
initial
monitoring
site.
The
data
from
the
initial
monitoring
site
was
left
in
the
Air
Quality
System
(
AQS)
database
and
is
in
the
current
calculations
for
the
Decatur
area.
Data
sets
from
each
of
the
sites
are
incomplete
when
considered
individually.
When
the
data
sets
are
combined
the
calculations
demonstrate
the
Decatur
area
to
be
below
the
level
of
the
PM2.5
NAAQS.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
counties
in
the
Birmingham
MSA
and
adjacent
Counties.

Birmingham
MSA
and
Surrounding
Counties
Population
&
Area
County
Population
2002
Percent
in
MSA
Population
Density
2002
Jefferson
661,153
71
594
Shelby
153,832
16
193
St
Clair
67,215
7
106
Blount
59,968
6
82
Walker
70,655
89
Tuscaloosa
166,512
126
Morgan
111,725
192
Etowah
103,105
193
Calhoun
111,616
183
Talladega
80,638
109
6­
140
Of
the
MSA
population,
87
percent
resides
in
Jefferson
County
(
661,153)
and
Shelby
County
(
153,832).
Blount
and
St.
Clair
Counties
have
a
much
lower
population
and
population
density
than
Jefferson
and
Shelby
Counties.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
­
Following
is
an
analysis
of
the
commuting
in
the
Birmingham
MSA
and
adjacent
Counties.

Jefferson
County,
an
MSA
county,
has
a
total
of
288,136
commuters.
­
Commuters
who
remain
in
Jefferson
County
265,661
(
92%)

Shelby
County,
an
MSA
county,
has
a
total
of
70,873
commuters.
­
Commuters
from
Shelby
County
to
Jefferson
County
37,119
(
52%)
­
Commuters
who
remain
in
Shelby
County:
32,573
(
46%)

St.
Clair
County
has
a
total
of
27,773
commuters.
­
Commuters
from
St.
Clair
County
to
Jefferson
County
12,870
(
46%)
­
Commuters
who
remain
in
St.
Clair
County:
10,648
(
38%)

Blount
County
has
a
total
of
22,255
commuters.
­
Commuters
from
Blount
County
to
Jefferson
County
9,669
(
43%)
­
Commuters
who
remain
in
Blount
County:
8,966
(
40%)

Walker
County
has
a
total
of
27,448
commuters.
­
Commuters
from
Walker
County
to
Jefferson
County
6,746
(
25%)
­
Commuters
who
remain
in
Walker
County:
17,293
(
63%)

Tuscaloosa
County
has
a
total
of
73,292
commuters.
­
Commuters
from
Tuscaloosa
County
to
Jefferson
County
4,385
(
6%)
­
Commuters
who
remain
in
Tuscaloosa
County:
65,331
(
89%)

Morgan
County
has
a
total
of
49,769
commuters.
­
Commuters
who
remain
in
Morgan
County:
36,005
(
72%)

Etowah
County
has
a
total
of
42,636
commuters.
­
Commuters
from
Etowah
County
to
Jefferson
County
1,658
(
4%)
­
Commuters
who
remain
in
Etowah
County:
32,181
(
75%)

Calhoun
County
has
a
total
of
47,181
commuters.
­
Commuters
from
Calhoun
County
to
Jefferson
County
842
(
2%)
­
Commuters
who
remain
in
Calhoun
County:
39,856
(
84%)

Talladega
County
has
a
total
of
31,443
commuters.
­
Commuters
from
Talladega
County
to
Jefferson
County
2,292
(
7%)
­
Commuters
who
remain
in
Talladega
County:
20,563
(
65%)
6­
141
The
following
Counties
have
significant
commuters
commuting
to
Jefferson
County
on
a
percentage
basis:
Shelby
(
52%),
Walker
(
25%),
St.
Clair
(
46%)
and
Blount
County
(
43%).
Although
a
relatively
high
percentage
of
commuters
in
Blount
and
St.
Clair
Counties
go
to
Jefferson
County,
they
only
contribute
3%
and
4%
respectively.

Birmingham
MSA
and
Surrounding
Counties
VMT
County
VMT
2002
VMT
Growth
02­
10
Jefferson
8,242
3,485
Shelby
1,449
345
St.
Clair
1,111
­
331
Blount
594
134
Walker
851
212
Tuscaloosa
2,430
176
Morgan
1,296
816
Etowah
1,235
500
Calhoun
1,525
431
Talladega
801
39
Jefferson
County
has
over
70%
of
the
VMT
in
the
MSA
6­
142
Factor
5:
Expected
growth.

The
following
table
has
the
population
and
population
growth
figures
for
the
Birmingham
MSA
and
Surrounding
Counties.

Birmingham
MSA
and
Surrounding
Counties
Population/
Growth
County
Population
Growth
90­
00
Percent
Growth
Jefferson
661,153
10,522
2
Shelby
153,832
43,935
44
St.
Clair
67,215
14,733
29
Blount
59,968
11,776
30
Walker
70,655
3,043
4
Tuscaloosa
166,512
14,353
10
Morgan
111,725
11,021
11
Etowah
103,105
3,619
4
Calhoun
111,616
­
3,785
­
3
Talladega
80,638
6,214
8
Blount
County
had
one
of
the
higher
population
growth
(
30
percent)
in
the
MSA,
however,
its
population
(
59,968)
is
small
compared
to
that
of
the
entire
CMSA
(
942,168)
or
to
either
Jefferson
County
(
661,153)
and
Shelby
County
(
153,832).
St.
Clair
County
had
a
fairly
high
population
growth
(
29
percent),
its
population
(
67,215)
is
small
compared
to
that
of
the
entire
CMSA
(
942,168)
and
is
only
one­
tenth
the
population
of
Jefferson
County
(
661,153)
and
less
than
half
the
population
of
Shelby
County
(
153,832).
Shelby
County
had
a
high
population
growth
(
44
percent).

Factor
6:
Meteorology
Not
a
significant
factor
in
the
analyses.

Factor
7:
Geography/
topography
Not
a
significant
factor
in
the
analyses.

Factor
8:
Jurisdictional
boundaries
The
Birmingham
8­
hour
ozone
nonattainment
area
consist
of
Jefferson
and
Shelby
Counties.

Factor
9:
Level
of
control
of
emission
sources
Reasonable
Available
Control
Technology
for
VOC
has
been
in
place
since
1979
Stage
1
Vapor
Recovery
has
been
in
place
since
1990
1­
Hour
Attainment
Demonstration
required
further
NOx
reductions
from
electric
generating
plants
Gorgas
and
Miller,
totaling
68.2
tons
per
day
of
NOx
reductions
(
seasonal).
Tier
II
National
Fuel
Standard
(
starting
2004)
6­
143
NOx
SIP
Call
requires
large
reductions
in
NOx
emissions
from
major
utilities,
large
industrial
boilers,
gas
turbines
and
cement
kilns
(
seasonal).
As
a
result
Gaston,
Gorgas
and
Miller
power
plants
have/
will
install
the
following
controls:

Miller
Units
1
&
2
Selective
Catalytic
Reduction
(
SCR)
Gaston
Units
1
­
4
overfire
air
Gaston
Unit
5
advanced
low
NOx
burners
The
following
controls
are
being
or
have
been
placed
on
Gorgas
and
Miller
power
plants
to
meet
the
requirements
of
the
Birmingham
attainment
SIP:

Gorgas
Unit
10
SCR
Gorgas
Units
6,
7,
and
8
low
NOx
burners
Miller
Units
3&
4
SCR
There
is
only
one
significant
NOX
source
in
St.
Clair
County,
a
cement
kiln
(
National
Cement
Co.
1,851
tpy),
which
is
implementing
significant
controls
which
have
been
determined
to
be
reasonable
and
highly
cost
effective
to
meet
the
Alabama's
NOX
SIP
requirements.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
Walker
County,
AL:

In
the
June
29,
2004,
letters
from
EPA
to
the
States
responding
to
their
designation
recommendations,
EPA
recommended
the
designation
of
a
number
of
counties
primarily
because
of
high
pollutant
emissions
from
power
plants.
Most
of
these
plants
were
located
in
nearby
counties
adjacent
to
the
metropolitan
area
(
as
defined
either
by
the
1999
or
2003
OMB
metropolitan
area
definitions).
EPA
suggested
that
a
State
could
provide
a
partial
county
boundary
that
would
encompass
the
relevant
power
plant
in
the
nonattainment
area.
Walker
County,
AL
is
one
of
those
counties.
Walker
County
has
low
population
(
70,655
compared
to
661,153
in
Jefferson
County
where
the
city
of
Birmingham
is
located),
low
population
density
(
89
people
per
square
mile
compared
to
594
in
Jefferson
County),
low
VMT
(
851,000
compared
to
8,242,000
in
Jefferson
County
),
and
the
only
large
point
source
is
the
Gorgas
Steam
Plant.

A
number
of
states
responded
to
this
suggestion
with
a
series
of
connected
townships
or
other
unique
boundaries.
Some
states
also
suggested
an
alternative
approach
in
which
partial
county
areas
for
power
plants
in
some
cases
could
be
small
"
free­
standing"
boundaries
that
are
considered
part
of
the
nearby
nonattainment
area.
In
this
way,
it
would
not
be
necessary
to
include
additional
townships
or
other
minor
civil
divisions
comprising
an
odd­
shaped
"
land
connector"
extending
from
the
main
part
of
the
nonattainment
area
to
the
power
plant.
The
State
of
Alabama
subsequently
submitted
two
partial
county
recommendations,
one
included
the
Gorgas
Steam
Plant
boundary
as
a
noncontiguous
area
and
the
other
was
contiguous
to
the
Birmingham
area.
6­
144
After
considering
these
comments
from
the
States,
EPA
agrees
that
such
an
approach
is
preferable
in
cases
where
a
partial
county
nonattainment
boundary
has
not
already
been
established
for
that
source
(
e.
g.
partial
county
boundaries
recently
established
for
8­
hour
ozone
nonattainment
areas).
For
purposes
of
consistency,
EPA
has
decided
that
free­
standing
portions
of
nonattainment
areas
should
be
based
on
a
pre­
existing
boundary
for
a
minor
civil
division
(
such
as
a
township
or
tax
district)
or
other
boundary
defined
for
governmental
use
(
such
as
a
census
block
group
or
census
tract).
Accordingly,
this
kind
of
partial
county
boundary
should
not
be
defined
simply
as
the
boundary
of
the
facility.
Therefore,
EPA
is
designating
the
census
block
group
identifiers
(
StateFIPs­
CoFIPs­
Tract#­
Block
Group#)
01­
127­
214­
5,
01­
127­
0215­
4,
and
01­
127­
0216­
2
portion
of
Walker
County
as
part
of
the
Birmingham
nonattainment
area.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Birmingham,
AL
area:
Jefferson,
Shelby,
and
Walker
(
Partial).

6.4.1.2
Columbus
Area
MSA
The
following
is
the
9
factor
analysis
for
Columbus
MSA
and
surrounding
Counties.
Alabama's
submittal
in
February
2004,
recommended
that
Russell
County
be
designated
nonattainment
for
the
fine
particulate
matter
(
PM2.5),
based
on
2001
­
2003
monitoring
data.
Georgia's
submittal
in
June
2004,
recommended
that
Harris,
Muscogee
and
Chattahoochee
Counties
be
designated
attainment
for
PM2.5.
Based
on
the
following
analysis
EPA
recommends
that
Lee
and
Russell
counties
in
Alabama,
and
Harris,
and
Muscogee
Counties
in
Georgia,
should
be
included
in
the
PM2.5
nonattainment
area.
Lee
County
is
adjacent
to
the
MSA,
has
high
VMT
and
a
large
population.
Russell
County
has
a
violating
monitor
and
the
State
recommended
it
as
nonattainment.
Harris
County
has
relatively
high
NOx
and
VOC
emissions
and
relatively
high
VMT.
Muscogee
County
has
high
NOx
and
VOC
emissions,
high
VMT
and
a
large
population.
Based
on
the
following
analysis,
EPA
agrees
with
the
recommendation
that
Barbour,
Chambers,
Montgomery,
Elmore
and
Tallapoosa
Counties
in
Alabama,
and
Chattahoochee,
Troup,
Stewart,
Meriwether,
Sumter
Counties
in
Georgia,
should
be
attainment/
unclassifiable
for
PM2.5
based
on
low
emissions,
low
VMT
and
low
population.

Area
EPA
Recommendation
State
Recommendation
Columbus,
GA
Lee
and
Russell
Counties
in
Alabama
and
Harris
and
Muscogee
Counties
in
Georgia
Russell
County,
Alabama
6­
145
The
following
is
a
brief
summary
of
the
9
criteria
for
the
Columbus
MSA
and
surrounding
Counties
.
These
analyses
were
based
on
existing
available
data.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
2001
PM2.5,
SO2,
NOx,
VOC,
and
NH3
emissions
in
tons,
and
weighted
emissions
scores
for
the
Columbus
Area
and
surrounding
counties.
The
MSA
counties
are
in
bold.

Columbus
MSA
and
Surrounding
Counties
Emissions
County
PM
SO2
NOX
VOC
NH3
Weighted
Emissions
Score
Cumulative
Weighted
Emissions
Score
Russell,
AL
1,344
2,550
5,718
4,434
179
35.1
35.1
Harris,
GA
590
104
2,856
1,748
128
26.8
61.9
Muscogee,
GA
513
803
5,965
9,476
323
25.4
87.3
Chattahoochee,
GA
208
43
387
482
15
12.7
100
Troup,
GA
1,194
422
12,277
8,223
382
48.7
Montgomery,
AL
1,421
6,292
10,454
14,966
973
43.3
Lee,
AL
1,043
1,425
5,125
7,474
333
42.8
Barbour,
AL
874
419
2,208
2,529
497
41.6
Sumter,
GA
2,578
1,725
1,726
2,262
847
40.5
Meriwether,
GA
844
190
1,866
3,006
167
33.7
Elmore,
AL
1,014
517
4,443
4,368
326
30.8
Tallapoosa,
AL
679
655
1,993
3,230
263
26.5
Chambers,
AL
579
527
2,350
2,882
124
23.9
Stewart,
GA
429
32
360
464
189
23.3
Taylor,
GA
398
76
966
622
833
18.3
Macon,
AL
412
223
2,242
1,871
133
17.1
Talbot,
GA
288
70
903
520
74
15.9
Marion,
GA
314
32
328
517
470
15.4
Bullock,
AL
273
93
407
570
214
12.7
Webster,
GA
303
128
358
201
114
12.6
Schley,
GA
192
14
195
290
163
8.4
Based
on
the
analysis
for
this
factor,
there
appear
to
be
emissions
in
Lee
County,
Alabama,
that
contribute
to
the
violation
in
Russell
County.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas.

Columbus
MSA
and
Surrounding
Counties
Design
Value
(
DV)

County
2001­
2003
DV
Russell,
AL
15.3
Muscogee,
GA
14.7
Montgomery,
AL
14.2
6­
146
Muscogee
and
Montgomery
Counties
have
monitors
that
show
attainment
of
the
PM2.5
standard
while
Russell
County
is
violating
the
standard.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
Counties
in
the
Columbus
MSA
and
adjacent
Counties.

Columbus
MSA
and
Surrounding
Counties
Population
&
Area
County
Population20
02
Percent
in
MSA
Population
Density
2002
Russell,
AL
49,415
18
77
Harris,
GA
25,092
9
54
Muscogee,
GA
185,948
67
861
Chattahoochee,
GA
15,440
6
62
Troup,
GA
59,767
144
Montgomery,
AL
223,346
283
Lee,
AL
118,123
194
Barbour,
AL
28,826
33
Sumter,
GA
33,247
69
Meriwether,
GA
22,623
45
Elmore,
AL
68,771
111
Tallapoosa,
AL
40,946
57
Chambers,
AL
36,251
61
Stewart,
GA
5,040
11
Lee
County
is
adjacent
to
Russell
County
and
its
population
(
118,123)
is
about
two
and
half
times
that
of
Russell
County
(
49,415).

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
­
Following
is
an
analysis
of
the
commuting
in
the
Columbus
MSA
and
adjacent
Counties.

Russell
County,
AL
has
a
total
of
19,859
commuters.
­
Commuters
who
remain
in
Russell
County
7,051
(
36%)

Harris
County,
GA
has
a
total
of
11,811
commuters.
­
Commuters
from
Lee
County
to
Russell
County
214
(
2%)
­
Commuters
who
remain
in
Harris
County
2,867
(
24%)

Muscogee
County,
GA
has
a
total
of
82,977
commuters.
­
Commuters
from
Muscogee
County
to
Russell
County
2,479
(
3%)
­
Commuters
who
remain
in
Muscogee
County
71,862
(
87%)

Chattahoochee
County,
GA
has
a
total
of
8,538
commuters.
­
Commuters
who
remain
in
Chattahoochee
County
5,482
(
64%)
6­
147
Troup
County,
GA
has
a
total
of
26,339
commuters.
­
Commuters
who
remain
in
Troup
County
22,074
(
84%)
Montgomery
County,
AL
has
a
total
of
96,943
commuters.
­
Commuters
who
remain
in
Montgomery
County
90,943
(
94%)

Lee
County,
AL
has
a
total
of
52,119
commuters.
­
Commuters
who
remain
in
Lee
County
35,549
(
68%)
­
Commuters
from
Lee
County
to
Russell
County
2,682
(
5%)

Barbour
County,
AL
has
a
total
of
10,023
commuters.
­
Commuters
who
remain
in
Barbour
County:
8,370
(
84%)
­
Commuters
from
Lee
County
to
Russell
County
335
(
3%)

Sumter
County,
GA
has
a
total
of
13,963
commuters.
­
Commuters
who
remain
in
Sumter
County
11,652
(
83%)

Meriwether
County,
GA
has
a
total
of
8,893
commuters.
­
Commuters
who
remain
in
Meriwether
County
4,114
(
46%)

Elmore
County,
AL
has
a
total
of
28,143
commuters.
­
Commuters
who
remain
in
Elmore
County
9,415
(
33%)

Tallapoosa
County,
AL
has
a
total
of
17,009
commuters.
­
Commuters
who
remain
in
Tallapoosa
County
12,125
(
71%)

Chambers
County,
AL
has
a
total
of
15,480
commuters.
­
Commuters
who
remain
in
Chambers
County
9,281
(
60%)

Stewart
County,
GA
has
a
total
of
1,
892
commuters.
­
Commuters
who
remain
in
Stewart
County
965
(
51%)

There
are
no
Counties
that
have
significant
commuters
commuting
to
Russell
County.

Columbus
MSA
and
Surrounding
Counties
VMT
County
VMT
2002
VMT
Growth
02­
10
Russell,
AL
671
276
Harris,
GA
547
­
207
Muscogee,
GA
1,594
534
Chattahoochee,
GA
56
160
Troup,
GA
1,454
­
839
Montgomery,
AL
2,565
642
Lee,
AL
1,119
457
Barbour,
AL
431
­
129
Sumter,
GA
405
­
62
Meriwether,
GA
271
138
6­
148
Elmore,
AL
615
168
Tallapoosa,
AL
502
­
56
Chambers,
AL
378
­
44
Stewart,
GA
75
47
Over
50%
of
the
VMT
in
the
MSA
is
in
Muscogee
County,
Georgia.
As
noted
above,
none
of
the
adjacent
Counties
have
appreciable
commuting
into
the
MSA.

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Columbus
MSA
and
surrounding
Counties.

Columbus
MSA
and
Surrounding
Counties
Population/
Growth
County
Population
2002
Growth
90­
00
Percent
Growth
Russell,
AL
49,415
2,896
6
Harris,
GA
25,092
5,907
33
Muscogee,
GA
185,948
7,013
4
Chattahoochee,
GA
15,440
­
2,052
­
12
Troup,
GA
59,767
3,243
6
Montgomery,
AL
223,346
14,425
7
Lee,
AL
118,123
27,946
32
Barbour,
AL
28,826
3,621
14
Sumter,
GA
33,247
2,972
10
Meriwether,
GA
22,623
123
1
Elmore,
AL
68,771
16,664
34
Tallapoosa,
AL
40,946
2,649
7
Chambers,
AL
36,251
­
293
­
1
Stewart,
GA
5,040
­
402
­
7
Harris
County,
Georgia
has
large
growth
on
a
percentage
basis.

Factor
6:
Meteorology
A
wind
analysis
using
wind
data
from
the
Columbus,
Georgia
Airport
was
completed
to
evaluate
the
predominant
wind
direction(
s)
in
Phenix
City
over
the
3­
year
period
on
all
days.
There
is
a
large
easterly
component
to
the
winds
during
the
3­
year
time
period.,
but
there
is
not
sufficient
information
to
use
meteorology
as
a
deciding
factor
for
an
annual
average..

Factor
7:
Geography/
topography
Not
a
significant
factor
in
the
analyses.

Factor
8:
Jurisdictional
boundaries
Not
a
significant
factor
in
the
analyses.
6­
149
Factor
9:
Level
of
control
of
emission
sources
Reasonable
Available
Control
Technology
for
VOC
has
been
in
place
since
1979
Stage
1
Vapor
Recovery
has
been
in
place
since
1990
NOx
SIP
Call
requires
large
reductions
in
NOx
emissions
from
major
utilities,
large
industrial
boilers,
gas
turbines
and
cement
kilns
(
seasonal
for
Macon,
Tallapoosa,
Chambers,
Elmore
and
Lee
Counties).
Tier
II
National
Fuel
Standard
(
starting
2004)

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
EPA's
initial
nonattainment
recommendations
on
June
29,
2004,
included
the
Lee
County,
Alabama,
and
Harris
County,
Georgia,
as
part
of
the
Columbus,
GA
nonattainment
area.
Upon
further
review
of
additional
information
provided
by
the
states,
EPA
is
revising
its
recommendation
and
is
designating
Lee
County,
AL
and
Harris
County,
GA
as
attainment/
unclassifiable.

Lee
County,
AL:

Lee
County,
Alabama,
is
being
designated
attainment/
unclassifiable
because
it
has
no
major
point
sources
of
precursor
emissions
with
40%
(
7,474
tons)
of
its
total
VOC
and
87%
(
5,125
tons)
of
its
total
NOx
emissions
coming
from
mobile
sources.
Lee
County
is
adjacent
to
the
MSA.
The
majority
of
the
commuting
population
remains
inside
Lee
County,
with
only
5
percent
commuting
to
Russell
County
where
the
violating
monitor
is
located.

We
considered
the
data
in
the
request
for
spatial
averaging
for
the
Columbus
area,
which
was
denied,
while
evaluating
the
other
factors
and
determined
that
Lee
County
is
not
contributing
to
the
violations.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
nonattainment
for
the
Columbus,
GA­
AL
area:
Russell.

6.4.1.3
Chattanooga
Area
The
Chattanooga
MSA
contains
the
following
Tennessee
counties:
Marion
and
Hamilton;
and
the
following
Georgia
Counties:
Dade,
Walker,
and
Catoosa.
Based
on
air
quality
data
for
2001­
2003,
the
monitor
with
the
highest
design
value
in
Hamilton
County
has
a
design
value
of
16.1
and
the
monitor
in
Walker
County
has
a
design
value
of
15.6.
No
other
counties
in
the
MSA
contain
ambient
air
monitors.
The
State
of
Tennessee
recommended
as
nonattainment
the
county
of
Hamilton
and
the
State
of
Georgia
recommended
as
nonattainment
the
county
of
Walker.
The
States
have
recommended
that
all
other
counties
be
designated
attainment.
The
State
of
Tennessee
submitted
some
justification
for
this
recommendation,
however,
they
indicated
that
the
detailed
emission
information
would
be
provided
at
a
later
date.
EPA
is
modifying
the
State
6­
150
of
Tennessee's
recommendation
and
will
review
the
additional
information
during
the
120
day
period
following
the
notification
letter.

EPA
has
received
some
information
from
the
State
of
Tennessee
that
Marion
(
MSA)
County
should
be
designated
attainment
for
the
PM2.5
standard
and
no
justification
from
the
State
of
Georgia
indicating
that
any
other
counties
should
be
included
or
excluded
from
the
Chattanooga
PM2.5
nonattainment
area.
Adjacent
counties
with
significant
emissions
include
McMinn
and
Roane
Counties
which
are
attached
to
the
Knoxville
nonattainment
area
and
Floyd
County
which
is
a
separate
nonattainment
area.

Additionally
we
have
included
in
our
recommended
nonattainment
area
Jackson
County,
AL,
that
is
adjacent
to
the
Chattanooga
MSA,
that
is
generally
rural
in
character,
and
that
contains
an
identifiable
large
emitting
facility
or
facilities
(
e.
g.,
power
plants)
which
we
believe
contribute
to
the
nearby
nonattainment
problem.
We
have
included
this
county
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
county,
including
such
large
facilities,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invite
you
to
submit
to
us
a
recommendation
as
to
what
portion
of
this
adjacent
county,
encompassing
the
large
facility
or
facilities,
should
be
designated
nonattainment.
Therefore
EPA
is
modifying
the
States'
recommendations
to
include
all
of
the
counties
in
the
MSA
and
the
adjacent
county
of
Jackson,
Alabama.

Area
EPA
Recommendation
State
Recommendation
Chattanooga
TN­
GA
Full
counties:
Marion,
Hamilton,
TN;
Dade,
Walker,
Catoosa,
GA;
Jackson,
AL
Full
counties:
Hamilton
and
Walker
Drop:
Marion
6­
151
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
contains
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
and
weighted
emissions
scores
for
the
counties
in
the
Chattanooga
MSA
and
some
adjacent
counties.
(
MSA
counties
are
in
bold.)

County
PM
SOx
NOx
VOC
Amm
Weighted
Emissions
Score
Cumulative
Weighted
Emissions
Score
Hamilton
1,498
5,300
20,048
27,150
1,022
49.5
49.5
Walker
856
632
2,798
4,516
958
17.9
67.4
Marion
679
477
3,156
2,640
501
14.1
81.5
Catoosa
617
167
3,085
3,601
680
11.9
93.4
Dade
302
107
2,415
1,574
285
6.5
99.9
Roane
4967
92331
30865
4300
285
296.9
Jackson,
AL
4389
44333
31502
4742
1494
176.1
Floyd,
GA
10057
31821
22736
7139
976
154.0
McMinn
3348
10216
10829
5546
1268
73.3
Whitfield,
GA
2732
1747
7283
7386
991
54.2
Rhea
1405
302
2625
3643
149
31.2
Loudon
804
4035
5899
5338
360
24.3
DeKalb,
AL
1193
741
4776
5867
5765
21.3
Bradley
1233
419
4230
7551
1916
21.1
Warren
1164
1189
1869
3675
446
20.7
Monroe
743
154
2387
3420
554
16.4
Gordon,
GA
872
200
3645
4019
2630
15.8
Fannin,
GA
614
65
887
1266
283
14.2
Franklin
644
482
2100
2929
1512
13.4
Chattooga,
GA
450
1228
1834
1634
197
11.7
Murray,
GA
576
130
2067
1700
910
11.4
Polk
295
2066
900
949
553
11.3
Cherokee,
NC
428
143
921
1753
111
10.6
Grundy
202
164
1000
1150
1170
4.8
Bledsoe
203
31
475
528
335
4.5
Meigs
198
112
885
871
118
4.3
Sequatchie
140
22
304
591
173
3.4
Van
Buren
118
178
291
320
74
3.3
Based
on
the
analysis
for
this
factor
there
appears
to
be
emissions
in
all
MSA
counties
and
the
adjacent
county
of
Jackson,
AL,
which
show
a
potential
to
contribute.
Other
adjacent
counties
with
large
emissions
(
McMinn
and
Roane,
TN
and
Floyd,
GA)
are
included
in
other
nonattainment
areas.
6­
152
Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
The
following
table
contains
the
2001­
2003
PM2.5
Design
Values
for
all
Chattanooga
MSA
Counties
and
adjacent
counties.
(
MSA
counties
are
in
bold.)

County
2001­
2003
design
value
Hamilton
16.1
Walker
15.6
Roane
14.2
Floyd,
GA
15.7
McMinn
14.6
Loudon
15.4
*
DeKalb,
AL
14.7
*
Incomplete
data
that
is
not
sufficient
to
determine
attainment/
nonattainment.
Data
substitution
does
not
apply.

Based
on
this
factor,
Hamilton
County,
TN
and
Walker
and
Floyd
Counties
in
GA
are
violating
the
PM
2.5
standard.
Catoosa
County,
GA
is
located
between
violating
monitors
in
Hamilton
and
Walker
Counties.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
contains
the
populations
for
the
counties
in
the
Chattanooga
MSA
and
some
adjacent
counties.
Urban
population
figures
were
not
available.
(
MSA
counties
are
in
bold.)

County
2002
Population
Percent
of
MSA
Population
(
2002)
2002
Population
Density
(
people/
sq.
mile)
Hamilton
309,321
65.7
570
Walker
61,949
13.2
139
Marion
27,654
5.9
55
Catoosa
56,341
12.0
348
Dade
15,615
3.3
90
Roane
52,316
145
Jackson,
AL
54,035
50
Floyd,
GA
92,606
181
McMinn
50,051
116
Whitfield,
GA
87,037
300
Based
on
the
analysis
for
this
factor,
there
appears
to
be
population
sufficient
to
indicate
a
contribution
by
the
following
MSA
counties:
Hamilton,
Walker,
and
Catoosa.
The
five
adjacent
counties
also
have
population
with
a
potential
to
contribute.
6­
153
Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
Hamilton
has
a
working
population
of
146,
824
 
Commuters
who
remain
in
Hamilton:
133,644
(
91%)

Marion
has
a
working
population
11766.
 
Commuters
who
remain
in
Marion:
5596
(
48%)
 
Commuters
from
Marion
to
Hamilton:
4271
Dade
has
a
working
population
of
6983.
 
Commuters
who
remain
in
Dade:
2363
 
Commuters
from
Dade
to
Hamilton:
3091
(
44%)
 
Commuters
from
Dade
to
Walker:
747
Catoosa
has
a
working
population
of
26710.
 
Commuters
who
remain
in
Catoosa:
7167
 
Commuters
from
Catoosa
to
Hamilton:
12320
(
46%)
 
Commuters
from
Catoosa
to
Walker:
1937
Walker
has
a
working
population
of
27223.
 
Commuters
who
remain
in
Walker:
11244
(
41%)
 
Commuters
from
Walker
to
Hamilton:
9098
Whitfield,
GA
has
a
working
population
of
38,909
 
Commuters
who
remain
in
Whitfield:
33,796
(
87%)
 
Remaining
commuters
do
not
commute
to
the
Chattanooga
MSA
DeKalb,
AL
has
a
working
population
of
7798
 
Commuters
who
remain
in
DeKalb:
5179
(
66%)
 
Remaining
commuters
do
not
commute
to
the
Chattanooga
MSA
The
following
table
contains
the
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Chattanooga
MSA
and
some
adjacent
counties
with
significant
weighted
emissions
scores.
(
MSA
counties
are
in
bold.)
6­
154
County
2002
VMT
(
thousand
miles/
year)
Hamilton
3,743
Walker
742
Marion
654
Catoosa
810
Dade
512
Roane
784
Jackson,
AL
786
Floyd,
GA
948
McMinn
787
Whitfield,
GA
1423
Based
on
the
analysis
for
this
factor
the
VMT
for
all
MSA
counties
indicate
a
potential
to
contribute.
Although
Whitfield
County
has
a
relatively
high
VMT,
none
of
the
commuters
go
to
the
Chattanooga
MSA.

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Chattanooga
MSA
and
some
adjacent
counties
with
significant
weighted
emissions
scores.
(
MSA
counties
are
in
bold.)

County
2002
Population
Growth
(
90­
00)
%
Growth
(
90­
00)
Hamilton
309,321
22360
8
Walker
61,949
2713
5
Marion
27,654
2916
12
Catoosa
56,341
10818
25
Dade
15,615
2007
15
Roane
52,316
4683
10
Jackson,
AL
54,035
6130
13
Floyd,
GA
92,606
9314
11
McMinn
50,051
6632
16
Whitfield,
GA
87,037
11063
15
Based
on
the
analysis
for
this
factor,
there
appears
to
be
significant
growth
on
a
percentage
basis
in
Catoosa
County
that
indicates
a
contribution
to
the
air
quality
in
the
Chattanooga
MSA.

Factor
6:
Meteorology
This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
7:
Geography/
topography
The
Chattanooga
area
does
not
have
any
geographical
or
topographical
boundaries
limiting
its
airshed.
6­
155
Factor
8:
Jurisdictional
boundaries
Hamilton
and
Meigs
Counties,
TN
and
Catoosa
County,
GA
were
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004.

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
9:
Level
of
control
of
emission
sources
Sources
in
the
Chattanooga
area
are
subject
to
Prevention
of
Significant
Deterioration
(
PSD)
requirements,
Control
Technology
Guidelines
Reasonable
Available
Control
Technology
(
CTG
RACT)
­
(
Hamilton
County
only},
Maximum
Achievable
Control
Technology
(
MACT)
for
Hazardous
Air
Pollutants
(
HAP),
New
Source
Performance
Standards
(
NSPS),
and
the
NOx
SIP
call.

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
Jackson
County,
AL:

In
the
June
29,
2004,
letters
from
EPA
to
the
States
responding
to
their
designation
recommendations,
EPA
recommended
the
designation
of
a
number
of
counties
primarily
because
of
high
pollutant
emissions
from
power
plants.
Most
of
these
plants
were
located
in
nearby
counties
adjacent
to
the
metropolitan
area
(
as
defined
either
by
the
1999
or
2003
OMB
metropolitan
area
definitions).
EPA
suggested
that
a
State
could
provide
a
partial
county
boundary
that
would
encompass
the
relevant
power
plant
in
the
nonattainment
area.
Jackson
County,
AL
is
one
of
those
counties.
Jackson
County
has
4,389
tons
of
PM,
4,333
tons
of
SO2
and
31,502
of
NOx
emissions,
with
the
majority
of
emissions
coming
from
the
Widows
Creek
Power
Plant.
The
commuting
patterns
show
that
68%
(
16,642)
of
the
working
population
in
the
county
actually
works
in
Jackson
County
with
8%
(
1,853)
working
in
Madison
County
and
another
8%
(
1,695)
working
in
Dekalb
County.
The
available
data
indicate
that
there
are
no
identifiable
commuting
patterns
between
Jackson
County
and
Chattanooga.

A
number
of
states
responded
to
this
suggestion
with
a
series
of
connected
townships
or
other
unique
boundaries.
Some
states
also
suggested
an
alternative
approach
in
which
partial
county
areas
for
power
plants
in
some
cases
could
be
small
"
free­
standing"
boundaries
that
are
considered
part
of
the
nearby
nonattainment
area.
In
this
way,
it
would
not
be
necessary
to
include
additional
townships
or
other
minor
civil
divisions
comprising
an
odd­
shaped
"
land
connector"
extending
from
the
main
part
of
the
nonattainment
area
to
the
power
plant.
The
State
of
Alabama
subsequently
submitted
two
partial
county
recommendations,
one
included
the
Widows
Creek
Plant
boundary
as
a
contiguous
area
and
the
other
was
contiguous
to
the
nearest
county
recommended
as
nonattainment.
6­
156
After
considering
these
comments
from
the
States,
EPA
agrees
that
such
an
approach
is
preferable
in
cases
where
a
partial
county
nonattainment
boundary
has
not
already
been
established
for
that
source
(
e.
g.
partial
county
boundaries
recently
established
for
8­
hour
ozone
nonattainment
areas).
For
purposes
of
consistency,
EPA
has
decided
that
free­
standing
portions
of
nonattainment
areas
should
be
based
on
a
pre­
existing
boundary
for
a
minor
civil
division
(
such
as
a
township
or
tax
district)
or
other
boundary
defined
for
governmental
use
(
such
as
a
census
block
group
or
census
tract).
Accordingly,
this
kind
of
partial
county
boundary
should
not
be
defined
simply
as
the
boundary
of
the
facility.
Therefore,
EPA
is
designating
the
census
block
group
identifier
(
StateFIPs­
CoFIPs­
Tract#­
Block
Group#)
01­
071­
9503­
1
portion
of
Jackson
County
as
part
of
the
Chattanooga
nonattainment
area.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
nonattainment
for
the
Chattanooga,
TN­
GA
area:
Jackson
(
Partial).

6.4.1.4
DeKalb
and
Etowah
Counties
Based
on
incomplete
monitoring
data
and
data
substitution
not
being
a
viable
alternative,
it
is
EPA's
position
that
DeKalb
and
Etowah
Counties
be
designated
as
unclassifiable.
These
two
counties
had
monitoring
data
for
2000­
2002
that
was
violating
and
have
incomplete
data
for
2001­
2003.
Applying
the
data
substitution
policy
will
not
confirm
attainment.
There
is
no
distinction,
regulatorily
between
attainment
and
unclassifiable.

Area
EPA
Recommendation
State
Recommendation
De
Kalb
County
Etowah
County
De
Kalb
County
Etowah
County
Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
unclassifiable
for
the
Dekalb
County,
AL
area:
Dekalb.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
unclassifiable
for
the
Gadsden,
AL
area:
Etowah.

6.4.2
EPA
9­
Factor
Analyses
for
Georgia
for
the
Designation
of
PM2.5
Nonattainment
Areas
6.4.2.1
Atlanta
Area
MSA
The
Atlanta
MSA
contains
the
counties
of:
Barrow,
Bartow,
Caroll,
Cherokee,
Clayton,
Cobb,
Coweta,
DeKalb,
Douglas,
Fayette,
Forsyth,
Fulton,
Gwinnett,
Henry,
Newton,
Paulding,
Pickens,
Rockdale,
Spalding,
and
Walton.
6­
157
On
February
13,
2004,
the
State
of
Georgia
submitted
to
EPA
their
PM
2.5
nonattainment
recommendations.
Georgia
recommended
only
counties
which
contained
a
monitored
violation
and
provided
no
further
justification
at
that
time.
On
June
17,
2004,
the
State
submitted
additional
information
and
revised
recommendations.
The
revision
recommended
the
20
county
ozone
nonattainment
area,
which
includes
the
adjacent
county
of
Hall,
plus
a
partial
county
recommendation
for
Heard
County
adjacent
to
the
Atlanta
MSA
which
contains
no
monitor,
but
a
power
plant
with
large
SO2
and
NOx
emissions.
The
State
also
recommended
that
Floyd
County
which
is
adjacent
to
the
Atlanta
MSA
and
has
a
violating
monitor
be
designated
as
a
separate
nonattainment
area.
The
adjacent
counties
of
Hall,
Jasper
and
Putnam
have
significant
emissions
with
a
potential
to
contribute
to
the
violations
in
the
Atlanta
area.
Putnam
county
contains
a
power
plant
with
large
SO2
and
NOx
emissions.
We
have
included
in
our
recommended
nonattainment
area
Putnam
County
in
your
state
that
is
contiguous
to
this
CMSA
with
a
violating
monitor,
that
is
generally
rural
in
character,
and
that
contains
an
identifiable
large
emitting
facility
or
facilities
(
e.
g.,
power
plants)
which
we
believe
contributes
to
the
nearby
nonattainment
problem.
We
have
included
this
county
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
county,
including
such
large
facilities,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invite
you
to
submit
to
us
a
recommendation
as
to
what
portion
of
such
contiguous
county,
encompassing
the
large
facility
or
facilities,
should
be
designated
nonattainment.
Based
on
emission
levels
and
the
other
nine
factors,
EPA
is
modifying
the
Georgia
submittal
to
a
include
Jasper
and
Putnam
counties.
EPA
agrees
with
the
partial
county
recommendation
for
Heard
County,
and
Floyd
County
as
a
separate
nonattainment
area.

Area
EPA
Recommendation
State
Recommendation
Atlanta,
GA
Full
counties:
Barrow,
Bartow,
Caroll,
Cherokee,
Clayton,
Cobb,
Coweta,
DeKalb,
Douglas,
Fayette,
Forsyth,
Fulton,
Gwinnett,
Henry,
Newton,
Paulding,
Rockdale,
Spalding,
and
Walton
Adjacent:
Floyd
as
a
separate
area;
Hall,
Heard
as
a
partial,
Jasper,
Putnam
Full
counties:
Barrow,
Bartow,
Caroll,
Cherokee,
Clayton,
Cobb,
Coweta,
DeKalb,
Douglas,
Fayette,
Forsyth,
Fulton,
Gwinnett,
Henry,
Newton,
Paulding,
Rockdale,
Spalding,
and
Walton
Adjacent:
Floyd
as
a
separate
area;
Hall,
Heard
as
a
partial
The
following
is
a
brief
summary
of
the
9
criteria
for
the
Atlanta
MSA
and
surrounding
counties.
These
analyses
were
based
on
existing
available
data.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
and
weighted
scores
for
the
counties
in
the
Atlanta
MSA
and
some
adjacent
counties.
(
MSA
counties
are
in
bold.)
6­
158
County
PM
SOx
NOx
VOC
Amm
Weighted
score
Cumulative
Weighted
score
Fulton
16,041
11,819
48,166
44,184
1,948
18.7
18.7
Bartow
9,181
154,447
43,326
5,725
1,309
12.5
31.2
Cobb
3,767
26,411
27,948
27,219
969
9.6
40.8
Coweta
3,795
44,839
15,822
5,048
241
9.4
50.2
De
Kalb
3,557
1,734
27,204
36,184
1,175
8.6
58.8
Cherokee
3,761
400
6,769
7,334
1,450
7.4
66.2
Clayton
2,727
612
9,808
10,776
437
6.1
72.3
Gwinnett
2,514
1,446
23,075
27,071
992
5.7
78.0
Henry
2,090
392
14,577
6,349
269
3.6
81.6
Forsyth
1,917
288
5,267
5,763
1,990
2.7
84.3
Carroll
1,629
293
5,536
7,224
2,808
2.6
86.9
Paulding
1,415
236
4,393
3,593
449
2.5
89.4
Douglas
822
239
4,565
4,342
163
1.8
91.2
Newton
1,147
226
4,109
5,047
240
1.8
93.0
Fayette
1,122
252
4,531
4,499
173
1.6
94.6
Walton
919
176
2,759
3,952
755
1.4
96.0
Spalding
795
180
3,251
3,839
212
1.1
97.1
Barrow
706
128
2,340
2,738
1,632
1.0
98.1
Rockdale
774
222
3,678
3,820
166
1.0
99.1
Pickens
463
83
1,116
1,769
1,204
0.9
100.0
Jasper
2,835
210
28,144
2,453
360
6.3
Putnam
3,726
65,560
34,202
1,175
399
6.3
Floyd
10,057
31,821
22,736
7,139
976
6.1
Monroe
3,403
75,571
34,069
2,189
644
6.1
Heard
4,090
75,745
21,714
1,170
634
5.6
Hall
2,347
1,045
7,714
11,062
3,709
3.0
Troup
1,194
422
12,277
8,223
382
2.5
Lee
1,043
1,425
5,125
7,474
333
2.2
Meriwether
844
190
1,866
3,006
167
1.6
Gilmer
646
69
1,148
1,273
2,663
1.5
Walker
856
632
2,798
4,516
958
1.5
Tallapoosa
679
655
1,993
3,230
263
1.3
Gordon
872
200
3,645
4,019
2,630
1.3
Harris
590
104
2,856
1,748
128
1.3
Jackson
817
151
3,639
2,935
3,584
1.3
Chambers
579
527
2,350
2,882
124
1.2
Habersham
651
103
1,757
2,201
3,031
1.1
Polk
660
142
2,345
3,485
575
1.1
Jones
455
105
1,537
1,506
230
1.0
Cherokee
633
222
1,184
2,036
778
0.9
Randolph
404
223
9,276
1,891
1,294
0.9
Lumpkin
403
60
905
1,067
1,090
0.9
Taylor
398
76
966
622
833
0.9
Upson
476
84
1,568
1,926
286
0.9
White
449
58
1,000
1,190
1,462
0.9
Cleburne
331
130
2,057
1,091
1,227
0.8
Chattooga
450
1,228
1,834
1,634
197
0.8
Clarke
395
215
3,362
5,223
390
0.8
Haralson
410
96
1,768
3,071
371
0.8
6­
159
Morgan
390
121
2,422
3,176
1,129
0.8
Talbot
288
70
903
520
74
0.8
Butts
357
112
1,609
1,438
88
0.7
Crawford
346
38
645
570
242
0.7
Dawson
324
58
915
1,246
1,142
0.7
Oconee
507
111
1,599
2,047
1,050
0.7
Banks
325
65
1,178
1,127
3,407
0.6
Pike
314
42
607
823
148
0.5
Lamar
257
59
812
1,090
491
0.4
Based
on
the
emissions
analysis
the
adjacent
counties
of
Floyd,
Hall,
Heard,
Jasper,
and
Putnam
have
significant
emissions
indicating
potential
contribution
to
the
violations
in
the
area.
The
Agency
agrees
that
Floyd
can
be
designated
as
a
separate
PM2.5
nonattainment
area
and
with
the
partial
county
recommendation
for
Heard.
The
Agency
also
agrees
with
the
State
that
Pickens
is
not
contributing
based
on
the
low
emissions
levels.
It
was
not
included
in
the
ozone
nonattainment
area
based
on
noncontribution.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
County
2001­
2003
Design
Value
Fulton
18.0
Cobb
16.1
De
Kalb
16.1
Clayton
16.1
Gwinnett
15.6
Paulding
14.1
Floyd
15.7
Hall
14.9
Walker
15.6
Clarke
15.6
There
are
five
counties
containing
violating
monitors
in
the
area
recommended
by
the
State
and
one
violating
in
the
adjacent
county
of
Floyd
recommended
as
a
separate
nonattainment
area.
Hall
County
contains
an
attaining
monitor
but
was
recommended
by
the
State
as
contributing.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
counties
in
the
Atlanta
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

County
2002
Population
Percent
Population
of
MSA
Population
Density
Fulton
825,431
18.8
1,560
Bartow
82,607
1.9
180
Cobb
651,485
14.9
1,916
Coweta
97,771
2.2
221
De
Kalb
676,996
15.4
2,526
Cherokee
159,295
3.6
376
6­
160
Clayton
252,733
5.8
1,767
Gwinnett
650,771
14.8
1,503
Henry
139,699
3.2
433
Forsyth
116,924
2.7
517
Carroll
94,907
2.2
190
Paulding
94,184
2.1
300
Douglas
98,650
2.2
496
Newton
71,594
1.6
259
Fayette
96,611
2.2
490
Walton
67,069
1.5
204
Spalding
59,410
1.4
300
Barrow
51,016
1.2
315
Rockdale
73,558
1.7
562
Pickens
25,619
0.6
110
Jasper
12,283
33
Putnam
19,390
56
Floyd
92,606
181
Monroe
22,675
57
Heard
11,340
38
Hall
152,235
386
Pickens
County
has
the
lowest
population
of
any
of
the
MSA
counties
supporting
the
noncontributing
determination.
Although,
Heard,
Jasper
and
Putnam
counties
have
small
population,
they
contain
sources
with
large
emissions.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information:

Fulton
County
has
a
total
of
385,442
commuters.
­
Commuters
that
remain
in
Fulton
County:
265,870
­
Commuters
from
Fulton
County
to
Cobb
County:
24,991
­
Commuters
from
Fulton
County
to
Dekalb
County:
41,232
­
Commuters
from
Fulton
County
to
Clayton
County:
9,722
­
Commuters
from
Fulton
County
to
Gwinnett
County:
21,211
Bartow
County
has
a
total
of
35,953
commuters.
­
Commuters
that
remain
in
Bartow
County:
20,692
­
Commuters
from
Bartow
County
to
Fulton
County:
1,882
­
Commuters
from
Bartow
County
to
Cobb
County:
6,936
­
Commuters
from
Bartow
County
to
Dekalb
County:
678
­
Commuters
from
Bartow
County
to
Gwinnett
County:
392
­
Commuters
from
Bartow
County
to
Floyd
County:
986
Cobb
County
has
a
total
of
325,412
commuters.
­
Commuters
that
remain
in
Cobb
County:
179,750
­
Commuters
from
Cobb
County
to
Fulton
County:
92,014
­
Commuters
from
Cobb
County
to
Dekalb
County:
18,098
­
Commuters
from
Cobb
County
to
Gwinnett
County:
8,723
6­
161
Coweta
County
has
a
total
of
43,506
commuters.
­
Commuters
that
remain
in
Coweta
County:
20,735
­
Commuters
from
Coweta
County
to
Fulton
County:
8,855
­
Commuters
from
Coweta
County
to
Cobb
County:
1,136
­
Commuters
from
Coweta
County
to
Dekalb
County:
1,014
­
Commuters
from
Coweta
County
to
Clayton
County:
3,097
Dekalb
County
has
a
total
of
341,110
commuters.
­
Commuters
that
remain
in
Dekalb
County:
149,919
­
Commuters
from
Dekalb
County
to
Fulton
County:
121,921
­
Commuters
from
Dekalb
County
to
Cobb
County:
13,448
­
Commuters
from
Dekalb
County
to
Clayton
County:
5,644
­
Commuters
from
Dekalb
County
to
Gwinnett
County:
34,747
Cherokee
County
has
a
total
of
74,075
commuters.
­
Commuters
that
remain
in
Cherokee
County:
26,239
­
Commuters
from
Cherokee
County
to
Fulton
County:
17,494
­
Commuters
from
Cherokee
County
to
Cobb
County:
18,911
­
Commuters
from
Cherokee
County
to
Dekalb
County:
2,898
­
Commuters
from
Cherokee
County
to
Gwinnett
County:
2,037
Clayton
County
has
a
total
of
112,580
commuters.
­
Commuters
that
remain
in
Clayton
County:
42,924
­
Commuters
from
Clayton
County
to
Fulton
County:
40,271
­
Commuters
from
Clayton
County
to
Cobb
County:
4,053
­
Commuters
from
Clayton
County
to
Dekalb
County:
9,024
­
Commuters
from
Clayton
County
to
Gwinnett
County:
2,785
Gwinnett
County
has
a
total
of
309,797
commuters.
­
Commuters
that
remain
in
Gwinnett
County:
169,000
­
Commuters
from
Gwinnett
County
to
Fulton
County:
57,737
­
Commuters
from
Gwinnett
County
to
Cobb
County:
8,648
­
Commuters
from
Gwinnett
County
to
Dekalb
County:
51,481
Henry
County
has
a
total
of
60,381
commuters.
­
Commuters
that
remain
in
Henry
County:
18,751
­
Commuters
from
Henry
County
to
Fulton
County:
14,157
­
Commuters
from
Henry
County
to
Cobb
County:
1,365
­
Commuters
from
Henry
County
to
Dekalb
County:
5,597
­
Commuters
from
Henry
County
to
Clayton
County:
13,541
­
Commuters
from
Henry
County
to
Gwinnett
County:
1,531
Forsyth
County
has
a
total
of
51,224
commuters.
­
Commuters
that
remain
in
Forsyth
County:
21,039
­
Commuters
from
Forsyth
County
to
Fulton
County:
15,251
6­
162
­
Commuters
from
Forsyth
County
to
Cobb
County:
1,790
­
Commuters
from
Forsyth
County
to
Dekalb
County:
3,067
­
Commuters
from
Forsyth
County
to
Gwinnett
County:
5,663
Carroll
County
has
a
total
of
39,730
commuters.
­
Commuters
that
remain
in
Carroll
County:
24,611
­
Commuters
from
Carroll
County
to
Fulton
County:
3,570
­
Commuters
from
Carroll
County
to
Cobb
County:
2,044
­
Commuters
from
Carroll
County
to
Dekalb
County:
700
­
Commuters
from
Carroll
County
to
Paulding
County:
493
Paulding
County
has
a
total
of
40,830
commuters.
­
Commuters
that
remain
in
Paulding
County:
10,094
­
Commuters
from
Paulding
County
to
Fulton
County:
7,432
­
Commuters
from
Paulding
County
to
Cobb
County:
14,850
­
Commuters
from
Paulding
County
to
Dekalb
County:
1,288
­
Commuters
from
Paulding
County
to
Clayton
County:
440
­
Commuters
from
Paulding
County
to
Gwinnett
County:
655
Douglas
County
has
a
total
of
46,176
commuters.
­
Commuters
that
remain
in
Douglas
County:
16,924
­
Commuters
from
Douglas
County
to
Fulton
County:
14,253
­
Commuters
from
Douglas
County
to
Cobb
County:
7,450
­
Commuters
from
Douglas
County
to
Dekalb
County:
2,211
­
Commuters
from
Douglas
County
to
Clayton
County:
1,196
­
Commuters
from
Douglas
County
to
Gwinnett
County:
747
­
Commuters
from
Douglas
County
to
Paulding
County:
596
Newton
County
has
a
total
of
28,560
commuters.
­
Commuters
that
remain
in
Newton
County:
11,545
­
Commuters
from
Newton
County
to
Fulton
County:
2,399
­
Commuters
from
Newton
County
to
Cobb
County:
411
­
Commuters
from
Newton
County
to
Dekalb
County:
3,567
­
Commuters
from
Newton
County
to
Clayton
County:
480
­
Commuters
from
Newton
County
to
Gwinnett
County:
1,320
Fayette
County
has
a
total
of
45,231
commuters.
­
Commuters
that
remain
in
Fayette
County:
16,977
­
Commuters
from
Fayette
County
to
Fulton
County:
14,745
­
Commuters
from
Fayette
County
to
Cobb
County:
1,124
­
Commuters
from
Fayette
County
to
Dekalb
County:
1,683
­
Commuters
from
Fayette
County
to
Clayton
County:
6,048
Walton
County
has
a
total
of
29,031
commuters.
­
Commuters
that
remain
in
Walton
County:
11,204
­
Commuters
from
Walton
County
to
Fulton
County:
1,666
6­
163
­
Commuters
from
Walton
County
to
Dekalb
County:
2,978
­
Commuters
from
Walton
County
to
Gwinnett
County:
7,037
Spalding
County
has
a
total
of
24,931
commuters.
­
Commuters
that
remain
in
Spalding
County:
13,715
­
Commuters
from
Spalding
County
to
Fulton
County:
1,917
­
Commuters
from
Spalding
County
to
Cobb
County:
273
­
Commuters
from
Spalding
County
to
Dekalb
County:
583
­
Commuters
from
Spalding
County
to
Clayton
County:
2,113
Barrow
County
has
a
total
of
22,616
commuters.
­
Commuters
that
remain
in
Barrow
County:
7,751
­
Commuters
from
Barrow
County
to
Fulton
County:
959
­
Commuters
from
Barrow
County
to
Dekalb
County:
1,177
­
Commuters
from
Barrow
County
to
Gwinnett
County:
8,229
Rockdale
County
has
a
total
of
32,931
commuters.
­
Commuters
that
remain
in
Rockdale
County:
14,378
­
Commuters
from
Rockdale
County
to
Fulton
County:
4,792
­
Commuters
from
Rockdale
County
to
Cobb
County:
570
­
Commuters
from
Rockdale
County
to
Dekalb
County:
6,187
­
Commuters
from
Rockdale
County
to
Clayton
County:
804
­
Commuters
from
Rockdale
County
to
Gwinnett
County:
1,985
Pickens
County
has
a
total
of
11,116
commuters.
­
Commuters
that
remain
in
Pickens
County:
5,318
­
Commuters
from
Pickens
County
to
Fulton
County:
741
­
Commuters
from
Pickens
County
to
Cobb
County:
938
­
Commuters
from
Pickens
County
to
Dekalb
County:
250
­
Commuters
from
Pickens
County
to
Gwinnett
County:
218
Jasper
County
has
a
total
of
5,123
commuters.
­
Commuters
that
remain
in
Jasper
County:
1,910
­
Commuters
from
Jasper
County
to
Fulton
County:
267
­
Commuters
from
Jasper
County
to
Dekalb
County:
238
­
Commuters
from
Jasper
County
to
Clayton
County:
105
­
Commuters
from
Jasper
County
to
Gwinnett
County:
57
Putnam
County
has
a
total
of
8,055
commuters.
­
Commuters
that
remain
in
Putnam
County:
4,478
­
Commuters
from
Putnam
County
to
Fulton
County:
177
­
Commuters
from
Putnam
County
to
Dekalb
County:
129
­
Commuters
from
Putnam
County
to
Gwinnett
County:
82
Floyd
County
has
a
total
of
39,622
commuters.
­
Commuters
that
remain
in
Floyd
County:
32,440
6­
164
­
Commuters
from
Floyd
County
to
Fulton
County:
528
­
Commuters
from
Floyd
County
to
Cobb
County:
662
Monroe
County
has
a
total
of
10,316
commuters.
­
Commuters
that
remain
in
Monroe
County:
4,116
­
Commuters
from
Monroe
County
to
Fulton
County:
318
­
Commuters
from
Monroe
County
to
Dekalb
County:
140
­
Commuters
from
Monroe
County
to
Clayton
County:
233
Heard
County
has
a
total
of
4,488
commuters.
­
Commuters
that
remain
in
Heard
County:
1,413
­
Commuters
from
Heard
County
to
Fulton
County:
308
­
Commuters
from
Heard
County
to
Cobb
County:
70
Hall
County
has
a
total
of
65,402
commuters.
­
Commuters
that
remain
in
Hall
County:
46,680
­
Commuters
from
Hall
County
to
Fulton
County:
2,244
­
Commuters
from
Hall
County
to
Dekalb
County:
1,716
­
Commuters
from
Hall
County
to
Gwinnett
County:
7,189
6­
165
The
following
table
contains
the
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Atlanta
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

County
2002
VMT
2002­
2010
VMT
Growth
Fulton
11,358
4,592
Bartow
1,322
­
285
Cobb
7,015
4,008
Coweta
1,562
­
596
De
Kalb
9,356
4,119
Cherokee
1,795
222
Clayton
3,148
1,341
Gwinnett
6,736
1,600
Henry
1,744
­
508
Forsyth
1,271
­
328
Carroll
1,431
­
255
Paulding
1,047
­
157
Douglas
1,251
465
Newton
1,049
­
300
Fayette
1,197
­
324
Walton
684
­
104
Spalding
796
­
59
Barrow
590
­
123
Rockdale
924
345
Pickens
237
90
Jasper
112
70
Putnam
179
37
Floyd
948
732
Monroe
572
­
283
Heard
146
40
Hall
1,897
­
181
Pickens
County
has
a
very
low
VMT
and
VMT
growth
thus
supporting
the
attainment/
unclassifiable
recommendation.
Approximately
82
percent
of
Floyd
County
commuters
stay
within
the
county.
This
commuting
pattern
supports
Floyd
County
as
a
separate
nonattainment
area.
Although
Jasper
and
Putnam
have
low
VMT,
they
have
large
emission
sources.
6­
166
Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Atlanta
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

County
2002
Population
Growth
90­
00
Percent
Growth
Fulton
825,431
167,055
26
Bartow
82,607
20,108
36
Cobb
651,485
160,006
36
Coweta
97,771
35,362
66
De
Kalb
676,996
120,028
22
Cherokee
159,295
51,699
57
Clayton
252,733
54,465
30
Gwinnett
650,771
235,538
67
Henry
139,699
60,600
103
Forsyth
116,924
54,324
123
Carroll
94,907
15,846
22
Paulding
94,184
40,067
96
Douglas
98,650
21,054
30
Newton
71,594
20,193
48
Fayette
96,611
28,848
46
Walton
67,069
22,101
57
Spalding
59,410
3,960
7
Barrow
51,016
16,423
55
Rockdale
73,558
16,020
30
Pickens
25,619
8,551
59
Jasper
12,283
2,973
35
Putnam
19,390
4,675
33
Floyd
92,606
9,314
11
Monroe
22,675
4,644
27
Heard
11,340
2,384
28
Hall
152,235
43,849
46
Pickens
County
has
a
high
percent
growth
rate.
However,
the
actual
numbers
of
population
growth
are
low
which
support
it's
recommendation
as
attainment.

Factor
6:
Meteorology
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
7:
Geography/
topography
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
8:
Jurisdictional
boundaries
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
9:
Level
of
control
of
emission
sources
6­
167
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
EPA's
initial
nonattainment
recommendations
on
June
29,2004,
included
Jasper
County
as
part
of
the
Atlanta
nonattainment
area.
Upon
further
review
of
additional
information
provided
by
the
State,
EPA
is
revising
its
recommendation
and
is
designating
Jasper
County
as
attainment/
unclassifiable,
and
a
portion
of
Putnam
County
as
nonattainment.
The
remainder
of
Putnam
County
will
be
designated
attainment/
unclassifiable.

Jasper
County:

Jasper
County
emissions
in
tons
per
year
are:
PM
(
2,835),
NOx
(
28,144),
SO2
(
210),
VOC
(
2,453).
Jasper
County
was
added
to
the
Altanta
metropolitan
area
in
the
2003
OMB
definition,
has
no
monitor,
a
low
population
(
12,283),
and
a
low
population
density
(
33
people/
square
mile),
when
compared
to
the
Atlanta
MSA.
For
example,
Fulton
County,
which
contains
the
design
value
monitor,
has
a
population
of
(
825,431),
and
a
population
density
of
(
1,560
people/
square
mile).
The
county
has
low
emissions
when
compared
to
the
Atlanta
MSA.
The
majority
of
the
emissions
in
Jasper
County
come
from
a
Georgia
Pacific
facility
which
is
45
miles
from
the
nearest
violating
monitor.
Additionally,
Jasper
County
has
a
low
number
of
commuters
(
5,123)
and
only
667
of
those
commuters
commute
to
the
Atlanta
MSA.
The
2002
VMT
(
112,000)
for
Jasper
county
is
lower
than
any
county
in
the
Atlanta
MSA.

Putnam
County:

In
the
June
29,2004,
letters
from
EPA
to
the
State
responding
to
their
designation
recommendations,
EPA
proposed
the
designation
of
a
number
of
counties
primarily
because
of
high
pollutant
emissions
from
power
plants.
Most
of
these
plants
were
located
in
nearby
counties
adjacent
to
the
metropolitan
area
(
as
defined
either
by
the
1999
or
2003
OMB
metropolitan
area
definitions).
EPA
suggested
that
a
State
could
provide
a
partial
county
boundary
that
would
encompass
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.
Putnam
County,
GA
is
one
of
those
counties.

Putnam
County
is
adjacent
to
Jasper
County
which
was
added
to
the
Altanta
metropolitan
area
in
the
2003
OMB
definition,
and
has
no
monitor.
Putnam
County
emissions
in
tons
per
year
and
percent
of
MSA
are:
PM
(
3,726),
SO2
(
65,560),
NOx
(
34,202),
and
VOC
(
1,175).
The
NOx
and
SO2
emissions
are
primarily
from
the
Harlee
Branch
power
plant
which
is
approximately
67
miles
from,
and
downwind
of,
the
nearest
violating
monitor.
Putnam
County
has
a
total
of
(
8,055)
commuters
of
which
only
(
388)
commute
to
the
Atlanta
MSA.
The
2002
VMT
(
179,000)
for
Putnam
County
is
lower
than
any
county
in
the
Atlanta
MSA.

A
number
of
states
responded
to
this
suggestion
with
a
series
of
connected
townships
or
other
unique
boundaries.
Some
states
also
suggested
an
alternative
approach
in
which
partial
county
areas
for
power
plants
in
some
cases
could
be
small
"
free­
standing"
boundaries
that
are
6­
168
considered
part
of
the
nearby
nonattainment
area.
In
this
way,
it
would
not
be
necessary
to
include
additional
townships
or
other
minor
civil
divisions
comprising
an
odd­
shaped
"
land
connector"
extending
from
the
main
part
of
the
nonattainment
area
to
the
power
plant.

After
considering
these
comments
from
the
States,
EPA
agrees
that
such
an
approach
is
preferable
in
cases
where
a
partial
county
nonattainment
boundary
has
not
already
been
established
for
that
source
(
e.
g.
partial
county
boundaries
recently
established
for
8­
hour
ozone
nonattainment
areas).
For
purposes
of
consistency,
EPA
has
decided
that
free­
standing
portions
of
nonattainment
areas
should
be
based
on
a
pre­
existing
boundary
for
a
minor
civil
division
(
such
as
a
township
or
tax
district)
or
other
boundary
defined
for
governmental
use
(
such
as
a
census
block
group
or
census
tract).
Accordingly,
this
kind
of
partial
county
boundary
should
not
be
defined
simply
as
the
boundary
of
the
facility.
Therefore,
EPA
is
designating
the
census
block
group
identifier
(
StateFIPs­
CoFIPs­
Tract#­
Block
Group#)
13­
237­
9603­
1
portion
of
Putnam
County
as
part
of
the
Atlanta
nonattainment
area.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Atlanta,
GA
area:
Barrow,
Bartow,
Carroll,
Cherokee,
Clayton,
Cobb,
Coweta,
DeKalb,
Douglas,
Fayette,
Forsyth,
Fulton,
Gwinnett,
Hall,
Heard
(
Partial),
Henry,
Newton,
Paulding,
Putnam
(
Partial),
Rockdale,
Spalding,
and
Walton.
6­
169
6.4.2.2
Macon
Area
MSA
The
Macon
MSA
contains
the
counties
of:
Bibb,
Houston,
Jones,
Peach,
and
Twiggs.

On
February
13,
2004,
the
State
of
Georgia
submitted
to
EPA
their
PM
2.5
nonattainment
recommendations.
Georgia
recommended
only
counties
which
contained
a
monitored
violation
and
provided
no
further
justification.
On
June
17,
2004,
the
State
submitted
additional
information
and
revised
recommendations.
The
revision
recommended
that
Bibb
County
be
nonattainment
and
Monroe
County
as
a
partial
county
nonattainment
area.
EPA
agrees
with
the
State's
recommendation.

Area
EPA
Recommendation
State
Recommendation
Macon,
GA
Full
counties:
Bibb,
Monroe
as
partial
Full
counties:
Bibb,
Monroe
as
partial
The
following
is
a
brief
summary
of
the
9
criteria
for
the
Macon
MSA
and
surrounding
counties.
These
analyses
were
based
on
existing
available
data.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
and
weighted
scores
for
the
counties
in
the
Macon
MSA
and
some
adjacent
counties.
(
MSA
counties
are
in
bold.)

County
PM
SOx
NOx
VOC
AMM
Weighted
score
Cumulative
Weighted
score
Bibb
2,723
8,521
11,353
10,061
370
46.9
46.9
Houston
1,243
1,666
6,285
5,627
629
18.3
65.2
Twiggs
1,203
198
2,263
1,141
92
18.2
83.4
Jones
455
105
1,537
1,506
230
10.5
93.9
Peach
478
89
2,025
2,261
202
6.1
100.0
Monroe
3,403
75,571
34,069
2,189
644
104.3
Putnam
3,726
65,560
34,202
1,175
399
100.8
Jasper
2,835
210
28,144
2,453
360
69.0
Wilkinson
4,397
170
1,368
821
55
48.3
Laurens
1,222
2,674
4,717
3,688
444
28.6
Dooly
1,130
140
2,115
1,442
676
19.8
Macon
1,124
1,395
2,539
1,248
1,349
15.7
Upson
476
84
1,568
1,926
286
10.3
Taylor
398
76
966
622
833
9.7
Baldwin
451
122
2,007
2,949
203
8.9
Crawford
346
38
645
570
242
8.1
Butts
357
112
1,609
1,438
88
7.6
Pulaski
434
37
452
503
263
6.9
Bleckley
341
31
505
642
146
6.2
Lamar
257
59
812
1,090
491
4.9
6­
170
Based
on
this
analysis,
Monroe
County
has
significant
emissions
which
contribute
to
the
violations
at
the
Bibb
County
monitor.
Although
Jasper
and
Putnam
counties
also
have
significant
emissions,
EPA
believes
those
counties
should
be
included
in
the
Atlanta
nonattainment
area,
rather
than
the
Macon
nonattainment
area.
For
the
counties
in
the
Macon
MSA,
there
is
a
natural
break
in
the
weighted
emission
score
between
Bibb
and
the
remaining
counties.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
County
2001­
2003
Design
Value
Bibb
15.2
Houston
12.8
Wilkinson
14.9
There
are
two
counties
containing
monitors
in
the
Macon
area.
Bibb
County
contains
a
violating
monitor
while
Houston
County
contains
an
attaining
monitor.
An
adjacent
county,
Wilkinson,
also
contains
an
attaining
monitor.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
counties
in
the
Macon
MSA
and
some
adjacent
counties.
Urban
population
figures
were
not
available.
(
MSA
counties
are
in
bold.)

County
2002
Population
Percent
Population
of
MSA
Population
Density
Bibb
154,824
47
619
Houston
116,768
35
310
Twiggs
10,545
3
29
Jones
24,492
7
62
Peach
24,224
7
160
Monroe
22,675
57
Putnam
19,390
56
Jasper
12,283
33
Wilkinson
10,357
23
Laurens
45,890
56
Dooly
11,505
29
Twiggs,
Jones,
and
Peach
counties
all
have
low
populations
with
low
populations
densities
which
support
their
attainment
recommendations.
Houston
County's
population
density
is
approximately
half
that
of
Bibb
County's
which
supports
it's
attainment
recommendation.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information:

Bibb
County,
the
design
value
county,
has
a
total
of
63,229
commuters.
­
Commuters
who
remain
in
Bibb
County:
54,
125
6­
171
Houston
County
has
a
total
of
53,089
commuters.
­
Commuters
that
remain
in
Houston
County:
39,
954
­
Commuters
from
Houston
County
to
Bibb
County:
8,570
Twiggs
County
has
a
total
of
4,086
commuters.
­
Commuters
who
remain
in
Twiggs
County:
1,019
­
Commuters
from
Twiggs
County
to
Bibb
County:
1,929
Jones
County
has
a
total
of
10,543
commuters.
­
Commuters
who
remain
in
Jones
County:
2,472
­
Commuters
from
Jones
County
to
Bibb
County:
5,988
Peach
County
has
a
total
of
9,731
commuters.
­
Commuters
that
remain
in
Peach
County:
4,137
­
Commuters
from
Peach
County
to
Bibb
County:
2,361
Monroe
County,
an
adjacent
county,
has
a
total
of
10,316
commuters.
­
Commuters
that
remain
in
Monroe
County:
4,116
­
Commuters
from
Monroe
County
to
Bibb
County:
3,262
Putnam
County
has
a
total
of
8,055
commuters.
­
Commuters
that
remain
in
Putnam
County:
4,479
­
Commuters
from
Putnam
County
to
Bibb
County:
329
Jasper
County
has
a
total
of
5,123
commuters.
­
Commuters
that
remain
in
Jasper
County:
1,910
­
Commuters
from
Jasper
County
to
Bibb
County:
112
Wilkinson
County
has
a
total
of
4,060
commuters.
­
Commuters
that
remain
in
Wilkinson
County:
1,933
­
Commuters
from
Wilkinson
County
to
Bibb
County:
538
Laurens
County
has
a
total
of
18,986
commuters.
­
Commuters
that
remain
in
Laurens
County:
16,046
­
Commuters
from
Laurens
County
to
Bibb
County:
501
Dooly
County
has
a
total
of
4,160
commuters.
­
Commuters
that
remain
in
Dooly
County:
2,399
­
Commuters
from
Dooly
County
to
Bibb
County:
75
The
commuting
patterns
support
Bibb
County
as
the
only
MSA
county
in
the
nonattainment
area.
6­
172
The
following
table
contains
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Macon
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

County
2002
VMT
VMT
Growth
02­
10
Bibb
1,653
1,096
Houston
1,068
130
Twiggs
469
­
270
Jones
283
129
Peach
496
­
210
Monroe
572
­
283
Putnam
179
37
Jasper
112
70
Wilkinson
152
68
Laurens
1,037
­
527
Dooly
348
­
185
Twiggs,
Jones,
and
Peach
counties
have
low
VMTs
with
low
VMT
growth,
or
negative
growth.
Houston
County
has
a
low
VMT
growth.
This
information
supports
the
attainment
recommendations
for
these
counties.

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Macon
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

County
2002
Population
Growth
90­
00
Percent
Growth
Bibb
154,824
3,920
3
Houston
116,768
21,557
24
Twiggs
10,545
784
8
Jones
24,492
2,900
14
Peach
24,224
2,479
12
Monroe
22,675
4,644
27
Putnam
19,390
4,675
33
Jasper
12,283
2,973
35
Wilkinson
10,357
­
8
­
0
Laurens
45,890
4,886
12
Dooly
11,505
1,624
16
Twiggs,
Jones,
and
Peach
counties
all
have
low
populations
with
low
growth
rates.
This
supports
their
recommendations
as
attainment/
unclassifiable.

Factor
6:
Meteorology
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
7:
Geography/
topography
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.
6­
173
Factor
8:
Jurisdictional
boundaries
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
9:
Level
of
control
of
emission
sources
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Macon,
GA
area:
Bibb
and
Monroe
(
Partial).

6.4.2.3
Athens
Area
MSA
The
Athens
MSA
contains
the
counties
of:
Clarke,
Madison,
and
Oconee.

On
February
13,
2004,
the
State
of
Georgia
submitted
to
EPA
their
PM
2.5
nonattainment
recommendations.
Georgia
recommended
only
counties
which
contained
a
monitored
violation
and
provided
no
further
justification.
On
June
17,
2004,
the
State
submitted
additional
information
and
revised
recommendations.
The
revision
recommended
that
Clarke
County
be
designated
as
nonattainment
and
that
Oconee
and
Madison
counties
be
designated
as
attainment.

Area
EPA
Recommendation
State
Recommendation
Athens,
GA
Full
counties:
Clarke,
Oconee,
and
Madison
Full
counties:
Clarke
The
following
is
a
brief
summary
of
the
9
criteria
for
the
Athens
MSA
and
surrounding
Counties.
These
analyses
were
based
on
existing
available
data.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
and
weighted
scores
for
the
counties
in
the
Athens
MSA
and
some
adjacent
counties.
(
MSA
counties
are
in
bold.)
6­
174
County
PM
SO2
NOx
VOC
AMM
Weighted
score
Cumulative
Weighted
score
Clarke
395
215
3,362
5,223
390
41.2
41.2
Oconee
507
111
1,599
2,047
1,050
30.5
71.7
Madison
543
70
1,449
1,219
3,013
28.3
100
Walton
919
176
2,759
3,952
755
57.1
Jackson
817
151
3,639
2,935
3,584
52.2
Greene
437
161
2,137
1,582
468
42.3
Barrow
706
128
2,340
2,738
1,632
40.2
Morgan
390
121
2,422
3,176
1,129
33.1
Franklin
449
84
2,068
1,813
4,128
27.6
Elbert
410
71
1,357
1,280
343
27.5
Wilkes
340
46
507
756
491
26.9
Oglethorpe
343
40
639
730
1,664
24.7
Hart
505
63
1,321
1,595
1,516
24.2
Banks
325
65
1,178
1,127
3,407
22.3
Taliaferro
131
32
718
355
89
13.1
Analysis
of
this
factor
indicates
that
Clarke,
Oconee,
and
Madison
counties
have
emissions
with
potential
to
contribute
to
the
violation
in
Clarke
County.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
County
2001­
2003
Design
Value
Clarke
15.6
There
is
one
violating
monitor
in
Clarke
County.
Therefore,
Clarke
County
is
nonattainment.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
counties
in
the
Athens
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

County
2002
Population
Percent
Population
of
MSA
Population
Density
Clarke
103,881
66
859
Oconee
27,264
17
147
Madison
26,717
17
94
Walton
67,069
204
Jackson
45,374
133
Greene
15,101
39
Barrow
51,016
315
Morgan
16,301
47
Franklin
20,778
79
Elbert
20,667
56
Wilkes
10,734
23
Ogelthorpe
13,176
30
Hart
23,249
100
Banks
15,123
65
Taliafero
1,977
10
6­
175
Walton
County
has
appreciable
population,
but
is
population
that
is
included
in
the
Atlanta
nonattainment
area.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information:

Jackson
County
has
total
of
19,132
commuters.
­
Commuters
that
stay
in
Jackson
County:
7,960
­
Commuters
that
commute
to
Clarke
County:
3,022
Clarke
County,
the
design
value
county,
has
a
total
of
48,241
commuters.
­
Commuters
that
stay
in
Clarke
County:
39,009
Oconee
County
has
a
total
of
12,903
commuters.
­
Commuters
that
stay
in
Oconee
County:
3,630
­
Commuters
that
commute
to
Clarke
County:
6,696
Madison
County
has
a
total
of
12,257
commuters.
­
Commuters
that
stay
in
Madison
County:
3,432
­
Commuters
that
commute
to
Clarke
County:
6,048
Greene
County
has
a
total
of
5,609
commuters.
­
Commuters
that
stay
in
Greene
County:
3,856
­
Commuters
that
commute
to
Clarke
County:
266
Morgan
County
has
a
total
of
7,278
commuters.
­
Commuters
that
stay
in
Morgan
County:
4,570
­
Commuters
that
commute
to
Clarke
County:
417
Franklin
County
has
a
total
of
8,844
commuters
­
Commuters
that
stay
in
Franklin
County:
4,766
­
Commuters
that
commute
to
Clarke
County:
461
Elbert
County
has
a
total
of
8,576
commuters.
­
Commuters
that
stay
in
Elbert
County:
6,238
­
Commuters
that
commute
to
Clarke
County:
417
Hart
County
has
a
total
of
10,275
commuters.
­
Commuters
that
stay
in
Hart
County:
6,768
­
Commuters
that
commute
to
Clarke
County:
272
Wilkes
County
has
a
total
of
4,457
commuters.
­
Commuters
that
stay
in
Wilkes
County:
3,464
­
Commuters
that
commute
to
Clarke
County:
181
6­
176
More
than
50
percent
of
the
commuters
in
Oconee
County
and
almost
50
percent
of
the
commuters
in
Madison
County
commute
to
Clarke
County.

The
following
table
contains
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Athens
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

County
2002
VMT
VMT
Growth
02­
10
Clarke
820
929
Oconee
330
43
Madison
351
96
Jackson
748
­
226
Greene
354
­
153
Morgan
514
­
302
Madison
351
96
Franklin
546
­
228
Elbert
259
43
Hart
269
59
Wilkes
95
53
Analysis
of
this
factor
indicates
that
Oconee
and
Madison
counties
have
commuting
patterns
and
VMT
which
contribute
to
the
violation
in
Clarke
County.

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Athens
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

County
2002
Population
Growth
90­
00
Percent
Growth
Clarke
103,881
13,895
16
Oconee
27,264
8,607
49
Madison
26,717
4,680
22
Jackson
45,374
11,584
39
Greene
15,101
2,613
22
Morgan
16,301
2,574
20
Franklin
20,778
3,635
22
Elbert
20,667
1,562
8
Hart
23,249
3,285
17
Wilkes
10,734
90
1
Analysis
of
this
factor
indicates
that
Oconee
and
Madison
counties
contain
growth
patterns
which
potentially
contribute
to
the
violation
in
Clarke
County.

Factor
6:
Meteorology
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.
6­
177
Factor
7:
Geography/
topography
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
8:
Jurisdictional
boundaries
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
9:
Level
of
control
of
emission
sources
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
EPA's
initial
nonattainment
recommendations
on
June
29,2004,
included
the
counties
of
Oconee
and
Madison
as
part
of
the
Athens
nonattainment
area.
Upon
further
review
of
additional
information
provided
by
the
State,
EPA
is
revising
its
recommendation
and
is
designating
Oconee
and
Madison
as
attainment/
unclassifiable.

Oconee
County:

Oconee
County
emissions
in
tons
per
year
and
percent
of
MSA
emissions
are:
SO2
(
111
/
28%),
NOx
(
1,599/
25%),
PM
(
507/
35%)
and
VOC
(
2,047/
24%).
These
emissions
are
low
when
compared
to
Clarke
County
which
has
over
half
of
the
SO2,
NOx,
and
VOC
emissions
for
the
MSA.
Oconee
County
also
has
a
low
population
(
27,264/
17%
of
MSA),
and
a
low
population
density
(
147
people/
square
mile)
when
compared
to
Clarke
County
which
has
a
population
of
(
103,881/
66%)
and
a
high
population
density
(
859
people/
square
mile).

Oconee
County
has
a
low
total
number
of
commuters
(
12,903)
of
which
6,696
commute
to
Clarke
County.
This
is
a
low
number
of
commuters
compared
to
Clarke
County's
(
48,241)
of
which
80
percent
(
39,009)
remain
in
Clarke
County.
Of
the
daily
VMT
in
the
MSA,
55
percent
occurs
in
Clarke
County.
Oconee
County
does
not
contain
a
monitor.

Madison
County:

Madison
County
emissions
in
tons
per
year
and
percent
of
MSA
are:
SO2
(
70/
18%),
NOx
(
1,449/
23%),
PM
(
543/
38%),
and
VOC
(
1,219/
14%).
These
emissions
are
low
when
compared
to
Clarke
County
which
has
over
half
of
the
SO2,
NOx,
and
VOC
emissions
for
the
MSA.
Madison
County
also
has
a
low
population
(
26,717/
17%
of
MSA),
and
a
low
population
density
(
94
people/
square
mile)
when
compared
to
Clarke
County
which
has
a
population
of
(
103,881/
66%)
and
a
high
population
density
(
859
people/
square
mile).

Madison
County
has
a
low
total
number
of
commuters
(
12,257)
of
which
6,048
commute
to
Clarke
County.
This
is
a
low
number
of
commuters
compared
to
Clarke
County's
(
48,241)
of
6­
178
which
80
percent
(
39,009)
remain
in
Clarke
County.
Of
the
daily
VMT
in
the
MSA,
55
percent
occurs
in
Clarke
County.
Madison
County
does
not
contain
a
monitor.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
nonattainment
for
the
Athens,
GA
area:
Clarke
6.4.2.4
Chattanooga
Area
The
Chattanooga
MSA
contains
the
following
Tennessee
counties:
Marion
and
Hamilton;
and
the
following
Georgia
Counties:
Dade,
Walker,
and
Catoosa.
Based
on
air
quality
data
for
2001­
2003,
the
monitor
with
the
highest
design
value
in
Hamilton
County
has
a
design
value
of
16.1
and
the
monitor
in
Walker
County
has
a
design
value
of
15.6.
No
other
counties
in
the
MSA
contain
ambient
air
monitors.
The
State
of
Tennessee
recommended
as
nonattainment
the
county
of
Hamilton
and
the
State
of
Georgia
recommended
as
nonattainment
the
county
of
Walker.
The
States
have
recommended
that
all
other
counties
be
designated
attainment.
The
State
of
Tennessee
submitted
some
justification
for
this
recommendation,
however,
they
indicated
that
the
detailed
emission
information
would
be
provided
at
a
later
date.
EPA
is
modifying
the
State
of
Tennessee's
recommendation
and
will
review
the
additional
information
during
the
120
day
period
following
the
notification
letter.

EPA
has
received
some
information
from
the
State
of
Tennessee
that
Marion
(
MSA)
County
should
be
designated
attainment
for
the
PM2.5
standard
and
no
justification
from
the
State
of
Georgia
indicating
that
any
other
counties
should
be
included
or
excluded
from
the
Chattanooga
PM2.5
nonattainment
area.
Adjacent
counties
with
significant
emissions
include
McMinn
and
Roane
Counties
which
are
attached
to
the
Knoxville
nonattainment
area
and
Floyd
County
which
is
a
separate
nonattainment
area.

Additionally
we
have
included
in
our
recommended
nonattainment
area
Jackson
County,
AL,
that
is
adjacent
to
the
Chattanooga
MSA,
that
is
generally
rural
in
character,
and
that
contains
an
identifiable
large
emitting
facility
or
facilities
(
e.
g.,
power
plants)
which
we
believe
contribute
to
the
nearby
nonattainment
problem.
We
have
included
this
county
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
county,
including
such
large
facilities,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invite
you
to
submit
to
us
a
recommendation
as
to
what
portion
of
this
adjacent
county,
encompassing
the
large
facility
or
facilities,
should
be
designated
nonattainment.
Therefore
EPA
is
modifying
the
States'
recommendations
to
include
all
of
the
counties
in
the
MSA
and
the
adjacent
county
of
Jackson,
Alabama.

Area
EPA
Recommendation
States
Recommendations
Chattanooga
Full
counties:
Marion,
Hamilton,
TN;
Dade,
Walker,
Catoosa,
GA;
Jackson,
AL
Full
counties:
Hamilton
and
Walker
6­
179
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
contains
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
and
weighted
emissions
scores
for
the
counties
in
the
Chattanooga
MSA
and
some
adjacent
counties.
(
MSA
counties
are
in
bold.)

County
PM
SOx
NOx
VOC
Amm
Weighted
Emissions
Score
Cumulative
Weighted
Emissions
Score
Hamilton
1,498
5,300
20,048
27,150
1,022
49.5
49.5
Walker
856
632
2,798
4,516
958
17.9
67.4
Marion
679
477
3,156
2,640
501
14.1
81.5
Catoosa
617
167
3,085
3,601
680
11.9
93.4
Dade
302
107
2,415
1,574
285
6.5
99.9
Roane
4967
92331
30865
4300
285
296.9
Jackson,
AL
4389
44333
31502
4742
1494
176.1
Floyd,
GA
10057
31821
22736
7139
976
154.0
McMinn
3348
10216
10829
5546
1268
73.3
Whitfield,
GA
2732
1747
7283
7386
991
54.2
Rhea
1405
302
2625
3643
149
31.2
Loudon
804
4035
5899
5338
360
24.3
DeKalb,
AL
1193
741
4776
5867
5765
21.3
Bradley
1233
419
4230
7551
1916
21.1
Warren
1164
1189
1869
3675
446
20.7
Monroe
743
154
2387
3420
554
16.4
Gordon,
GA
872
200
3645
4019
2630
15.8
Fannin,
GA
614
65
887
1266
283
14.2
Franklin
644
482
2100
2929
1512
13.4
Chattooga,
GA
450
1228
1834
1634
197
11.7
Murray,
GA
576
130
2067
1700
910
11.4
Polk
295
2066
900
949
553
11.3
Cherokee,
NC
428
143
921
1753
111
10.6
Grundy
202
164
1000
1150
1170
4.8
Bledsoe
203
31
475
528
335
4.5
Meigs
198
112
885
871
118
4.3
Sequatchie
140
22
304
591
173
3.4
Van
Buren
118
178
291
320
74
3.3
Based
on
the
analysis
for
this
factor
there
appears
to
be
emissions
in
all
MSA
counties
and
the
adjacent
county
of
Jackson,
AL,
which
show
a
potential
to
contribute.
Other
adjacent
counties
with
large
emissions
(
McMinn
and
Roane,
TN
and
Floyd,
GA)
are
included
in
other
nonattainment
areas.
6­
180
Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
The
following
table
contains
the
2001­
2003
PM2.5
Design
Values
for
all
Chattanooga
MSA
Counties
and
adjacent
counties.
(
MSA
counties
are
in
bold.)

County
2001­
2003
design
value
Hamilton
16.1
Walker
15.6
Roane
14.2
Floyd,
GA
15.7
McMinn
14.6
Loudon
15.4
*
DeKalb,
AL
14.7
*
Incomplete
data
that
is
not
sufficient
to
determine
attainment/
nonattainment.
Data
substitution
does
not
apply.

Based
on
this
factor,
Hamilton
County,
TN
and
Walker
and
Floyd
Counties
in
GA
are
violating
the
PM
2.5
standard.
Catoosa
County,
GA
is
located
between
violating
monitors
in
Hamilton
and
Walker
Counties.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
contains
the
populations
for
the
counties
in
the
Chattanooga
MSA
and
some
adjacent
counties.
Urban
population
figures
were
not
available.
(
MSA
counties
are
in
bold.)

County
2002
Population
Percent
of
MSA
Population
(
2002)
2002
Population
Density
(
people/
mile^
2)
Hamilton
309,321
65.7
570
Walker
61,949
13.2
139
Marion
27,654
5.9
55
Catoosa
56,341
12.0
348
Dade
15,615
3.3
90
Roane
52,316
145
Jackson,
AL
54,035
50
Floyd,
GA
92,606
181
McMinn
50,051
116
Whitfield,
GA
87,037
300
Based
on
the
analysis
for
this
factor,
there
appears
to
be
population
sufficient
to
indicate
a
contribution
by
the
following
MSA
counties:
Hamilton,
Walker,
and
Catoosa.
The
five
adjacent
counties
also
have
population
with
a
potential
to
contribute.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information:
6­
181
Hamilton
has
a
working
population
of
146,
824
 
Commuters
who
remain
in
Hamilton:
133,644
(
91%)

Marion
has
a
working
population
11766.
 
Commuters
who
remain
in
Marion:
5596
(
48%)
 
Commuters
from
Marion
to
Hamilton:
4271
Dade
has
a
working
population
of
6983.
 
Commuters
who
remain
in
Dade:
2363
 
Commuters
from
Dade
to
Hamilton:
3091
(
44%)
 
Commuters
from
Dade
to
Walker:
747
Catoosa
has
a
working
population
of
26710.
 
Commuters
who
remain
in
Catoosa:
7167
 
Commuters
from
Catoosa
to
Hamilton:
12320
(
46%)
 
Commuters
from
Catoosa
to
Walker:
1937
Walker
has
a
working
population
of
27223.
 
Commuters
who
remain
in
Walker:
11244
(
41%)
 
Commuters
from
Walker
to
Hamilton:
9098
Whitfield,
GA
has
a
working
population
of
38,909
 
Commuters
who
remain
in
Whitfield:
33,796
(
87%)
 
Remaining
commuters
do
not
commute
to
the
Chattanooga
MSA
DeKalb,
AL
has
a
working
population
of
7798
 
Commuters
who
remain
in
DeKalb:
5179
(
66%)
 
Remaining
commuters
do
not
commute
to
the
Chattanooga
MSA
The
following
table
contains
the
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Chattanooga
MSA
and
some
adjacent
counties
with
significant
weighted
emissions
scores.
(
MSA
counties
are
in
bold.)

County
2002
VMT
(
thousand
miles/
year)
Hamilton
3,743
Walker
742
Marion
654
Catoosa
810
Dade
512
Roane
784
Jackson,
AL
786
Floyd,
GA
948
McMinn
787
Whitfield,
GA
1423
6­
182
Based
on
the
analysis
for
this
factor
the
VMT
for
all
MSA
counties
indicate
a
potential
to
contribute.
Although
Whitfield
County
has
a
relatively
high
VMT,
none
of
the
commuters
go
to
the
Chattanooga
MSA.

Factor
5:
Population
Growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Chattanooga
MSA
and
some
adjacent
counties
with
significant
weighted
emissions
scores.
(
MSA
counties
are
in
bold.)

County
2002
Population
Growth
(
90­
00)
%
Growth
(
90­
00)
Hamilton
309,321
22360
8
Walker
61,949
2713
5
Marion
27,654
2916
12
Catoosa
56,341
10818
25
Dade
15,615
2007
15
Roane
52,316
4683
10
Jackson,
AL
54,035
6130
13
Floyd,
GA
92,606
9314
11
McMinn
50,051
6632
16
Whitfield,
GA
87,037
11063
15
Based
on
the
analysis
for
this
factor,
there
appears
to
be
significant
growth
on
a
percentage
basis
in
Catoosa
County
that
indicates
a
contribution
to
the
air
quality
in
the
Chattanooga
MSA.

Factor
6:
Meteorology
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
7:
Geography/
topography
The
Chattanooga
area
does
not
have
any
geographical
or
topographical
boundaries
limiting
its
airshed.

This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
8:
Jurisdictional
boundaries
Hamilton
and
Meigs
Counties,
TN
and
Catoosa
County,
GA
were
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004.

This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
9:
Level
of
control
of
emission
sources
Sources
in
the
Chattanooga
area
are
subject
to
Prevention
of
Significant
Deterioration
(
PSD)
requirements,
Control
Technology
Guidelines
Reasonable
Available
Control
Technology
(
CTG
6­
183
RACT)
­
(
Hamilton
County
only),
Maximum
Achievable
Control
Technology
(
MACT)
for
Hazardous
Air
Pollutants
(
HAP),
New
Source
Performance
Standards
(
NSPS),
and
the
NOx
SIP
call.

This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
EPA's
initial
nonattainment
recommendations
on
June
29,2004,
included
Dade
County
as
part
of
the
Chattanooga
nonattainment
area.
Upon
further
review
of
additional
information
provided
by
the
State,
EPA
is
revising
its
recommendation
and
designating
Dade
County
as
attainment/
unclassifiable.

Dade
County:

Dade
County
emissions
in
tons
per
year
and
percent
of
MSA
are:
PM
(
302/
8%),
SO2
(
107/
1.6%),
NOx
(
2,415/
7.7%),
and
VOC
(
1,574/
4%).
These
are
the
lowest
emissions
of
any
county
in
the
MSA.
Dade
County
contains
no
major
point
sources
of
precursor
emissions,
has
the
lowest
population
in
the
MSA
(
15,615),
and
low
population
density
90
people/
square
mile.
Dade
County
constitutes
approximately
3
percent
of
the
total
MSA
commuters.
Dade
County
contains
no
monitor.

In
addition,
the
State's
topography
analysis
indicates
that
the
Lookout
Mountain
Ridge
(
2,100
feet)
separates
the
low
level
emissions
in
Dade
County
from
the
violating
monitors.
The
County
is
located
to
the
west
of
the
ridge,
while
the
violating
monitors
reside
to
the
east
of
the
ridge.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Chattanooga,
TN­
GA
area:
Catoosa
and
Walker.

6.4.2.5
Columbus
Area
MSA
The
following
is
the
9
factor
analysis
for
Columbus
MSA
and
surrounding
Counties.
Alabama's
submittal
in
February
2004,
recommended
that
Russell
County
be
designated
nonattainment
for
the
fine
particulate
matter
(
PM2.5),
based
on
2001
­
2003
monitoring
data.
Georgia's
submittal
in
June
2004,
recommended
that
Harris,
Muscogee
and
Chattahoochee
Counties
be
designated
attainment
for
PM2.5.
Based
on
the
following
analysis
EPA
recommends
that
Lee
and
Russell
counties
in
Alabama,
and
Harris,
and
Muscogee
Counties
in
Georgia,
should
be
included
in
the
PM2.5
nonattainment
area.
Lee
County
is
adjacent
to
the
MSA,
has
high
VMT
and
a
large
population.
Russell
County
has
a
violating
monitor
and
the
State
recommended
it
as
nonattainment.
Harris
County
has
relatively
high
NOx
and
VOC
emissions
and
relatively
high
VMT.
Muscogee
County
has
high
NOx
and
VOC
emissions,
high
VMT
and
a
large
population.
Based
on
the
following
analysis,
EPA
agrees
with
the
recommendation
that
Barbour,
Chambers,
Montgomery,
Elmore
and
Tallapoosa
Counties
in
Alabama,
and
Chattahoochee,
Troup,
Stewart,
6­
184
Meriwether,
Sumter
Counties
in
Georgia,
should
be
attainment/
unclassifiable
for
PM2.5
based
on
low
emissions,
low
VMT
and
low
population.

Area
EPA
Recommendation
State
Recommendation
Columbus,
GA
Full
counties:
Lee
and
Russell
Counties
in
Alabama
and
Harris
and
Muscogee
Counties
in
Georgia
Full
counties:
Russell
County,
Alabama
9
Factor
Analysis
for
the
Columbus,
Georgia
MSA
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
2001
PM2.5,
SO2,
NOx,
VOC,
and
NH3
emissions
in
tons,
and
weighted
emissions
scores
for
the
Columbus
Area
and
surrounding
counties.
The
MSA
counties
are
in
bold.

Columbus
MSA
and
Surrounding
Counties
Emissions
County
PM
SO2
NOX
VOC
NH3
Weighted
Emissions
Score
Cumulative
Weighted
Emissions
Score
Russell,
AL
1,344
2,550
5,718
4,434
179
35.1
35.1
Harris,
GA
590
104
2,856
1,748
128
26.8
61.9
Muscogee,
GA
513
803
5,965
9,476
323
25.4
87.3
Chattahoochee,
GA
208
43
387
482
15
12.7
100
Troup,
GA
1,194
422
12,277
8,223
382
48.7
Montgomery,
AL
1,421
6,292
10,454
14,966
973
43.3
Lee,
AL
1,043
1,425
5,125
7,474
333
42.8
Barbour,
AL
874
419
2,208
2,529
497
41.6
Sumter,
GA
2,578
1,725
1,726
2,262
847
40.5
Meriwether,
GA
844
190
1,866
3,006
167
33.7
Elmore,
AL
1,014
517
4,443
4,368
326
30.8
Tallapoosa,
AL
679
655
1,993
3,230
263
26.5
Chambers,
AL
579
527
2,350
2,882
124
23.9
Stewart,
GA
429
32
360
464
189
23.3
Taylor,
GA
398
76
966
622
833
18.3
Macon,
AL
412
223
2,242
1,871
133
17.1
Talbot,
GA
288
70
903
520
74
15.9
Marion,
GA
314
32
328
517
470
15.4
Bullock,
AL
273
93
407
570
214
12.7
Webster,
GA
303
128
358
201
114
12.6
Schley,
GA
192
14
195
290
163
8.4
Based
on
the
analysis
for
this
factor,
there
appear
to
be
emissions
in
Lee
County,
Alabama,
that
contribute
to
the
violation
in
Russell
County.
6­
185
Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas.

Columbus
MSA
and
Surrounding
Counties
Design
Value
(
DV)

County
2001­
2003
DV
Russell,
AL
15.3
Muscogee,
GA
14.7
Montgomery,
AL
14.2
Muscogee
and
Montgomery
Counties
have
monitors
that
show
attainment
of
the
PM2.5
standard
while
Russell
County
is
violating
the
standard.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas.

The
following
table
has
the
populations
for
the
Counties
in
the
Columbus
MSA
and
adjacent
Counties.

Columbus
MSA
and
Surrounding
Counties
Population
&
Area
County
Population20
02
Percent
in
MSA
Population
Density
2002
Russell,
AL
49,415
18
77
Harris,
GA
25,092
9
54
Muscogee,
GA
185,948
67
861
Chattahoochee,
GA
15,440
6
62
Troup,
GA
59,767
144
Montgomery,
AL
223,346
283
Lee,
AL
118,123
194
Barbour,
AL
28,826
33
Sumter,
GA
33,247
69
Meriwether,
GA
22,623
45
Elmore,
AL
68,771
111
Tallapoosa,
AL
40,946
57
Chambers,
AL
36,251
61
Stewart,
GA
5,040
11
Lee
County
is
adjacent
to
Russell
County
and
its
population
(
118,123)
is
about
two
and
half
times
that
of
Russell
County
(
49,415).

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information:

Russell
County,
AL
has
a
total
of
19,859
commuters.
­
Commuters
who
remain
in
Russell
County
7,051
(
36%)

Harris
County,
GA
has
a
total
of
11,811
commuters.
­
Commuters
from
Lee
County
to
Russell
County
214
(
2%)
6­
186
­
Commuters
who
remain
in
Harris
County
2,867
(
24%)

Muscogee
County,
GA
has
a
total
of
82,977
commuters.
­
Commuters
from
Muscogee
County
to
Russell
County
2,479
(
3%)
­
Commuters
who
remain
in
Muscogee
County
71,862
(
87%)

Chattahoochee
County,
GA
has
a
total
of
8,538
commuters.
­
Commuters
who
remain
in
Chattahoochee
County
5,482
(
64%)

Troup
County,
GA
has
a
total
of
26,339
commuters.
­
Commuters
who
remain
in
Troup
County
22,074
(
84%)

Montgomery
County,
AL
has
a
total
of
96,943
commuters.
­
Commuters
who
remain
in
Montgomery
County
90,943
(
94%)

Lee
County,
AL
has
a
total
of
52,119
commuters.
­
Commuters
who
remain
in
Lee
County
35,549
(
68%)
­
Commuters
from
Lee
County
to
Russell
County
2,682
(
5%)

Barbour
County,
AL
has
a
total
of
10,023
commuters.
­
Commuters
who
remain
in
Barbour
County:
8,370
(
84%)
­
Commuters
from
Lee
County
to
Russell
County
335
(
3%)

Sumter
County,
GA
has
a
total
of
13,963
commuters.
­
Commuters
who
remain
in
Sumter
County
11,652
(
83%)

Meriwether
County,
GA
has
a
total
of
8,893
commuters.
­
Commuters
who
remain
in
Meriwether
County
4,114
(
46%)

Elmore
County,
AL
has
a
total
of
28,143
commuters.
­
Commuters
who
remain
in
Elmore
County
9,415
(
33%)

Tallapoosa
County,
AL
has
a
total
of
17,009
commuters.
­
Commuters
who
remain
in
Tallapoosa
County
12,125
(
71%)
Chambers
County,
AL
has
a
total
of
15,480
commuters.
­
Commuters
who
remain
in
Chambers
County
9,281
(
60%)

Stewart
County,
GA
has
a
total
of
1,
892
commuters.
­
Commuters
who
remain
in
Stewart
County
965
(
51%)

There
are
no
Counties
that
have
significant
commuters
commuting
to
Russell
County.
6­
187
Columbus
MSA
and
Surrounding
Counties
VMT
County
VMT
2002
VMT
Growth
02­
10
Russell,
AL
671
276
Harris,
GA
547
­
207
Muscogee,
GA
1,594
534
Chattahoochee,
GA
56
160
Troup,
GA
1,454
­
839
Montgomery,
AL
2,565
642
Lee,
AL
1,119
457
Barbour,
AL
431
­
129
Sumter,
GA
405
­
62
Meriwether,
GA
271
138
Elmore,
AL
615
168
Tallapoosa,
AL
502
­
56
Chambers,
AL
378
­
44
Stewart,
GA
75
47
Over
50%
of
the
VMT
in
the
MSA
is
in
Muscogee
County,
Georgia.
As
noted
above,
none
of
the
adjacent
Counties
have
appreciable
commuting
into
the
MSA.

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Columbus
MSA
and
surrounding
Counties.

Columbus
MSA
and
Surrounding
Counties
Population/
Growth
County
Population
2002
Growth
90­
00
Percent
Growth
Russell,
AL
49,415
2,896
6
Harris,
GA
25,092
5,907
33
Muscogee,
GA
185,948
7,013
4
Chattahoochee,
GA
15,440
­
2,052
­
12
Troup,
GA
59,767
3,243
6
Montgomery,
AL
223,346
14,425
7
Lee,
AL
118,123
27,946
32
Barbour,
AL
28,826
3,621
14
Sumter,
GA
33,247
2,972
10
Meriwether,
GA
22,623
123
1
Elmore,
AL
68,771
16,664
34
Tallapoosa,
AL
40,946
2,649
7
Chambers,
AL
36,251
­
293
­
1
Stewart,
GA
5,040
­
402
­
7
Harris
County,
Georgia
has
large
growth
on
a
percentage
basis.

Factor
6:
Meteorology.
6­
188
A
wind
analysis
using
wind
data
from
the
Columbus,
Georgia
Airport
was
completed
to
evaluate
the
predominant
wind
direction(
s)
in
Phenix
City
over
the
3­
year
period
on
all
days.
There
is
a
large
easterly
component
to
the
winds
during
the
3­
year
time
period.,
but
there
is
not
sufficient
information
to
use
meteorology
as
a
deciding
factor
for
an
annual
average..

Factor
7:
Geography/
topography
This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
8
Jurisdictional
boundaries.

This
factor
did
not
constitute
a
significant
role
in
the
decision
making
process.

Factor
9
Level
of
control
of
emission
sources.

Reasonable
Available
Control
Technology
for
VOC
has
been
in
place
since
1979
Stage
1
Vapor
Recovery
has
been
in
place
since
1990
NOx
SIP
Call
requires
large
reductions
in
NOx
emissions
from
major
utilities,
large
industrial
boilers,
gas
turbines
and
cement
kilns
(
seasonal
for
Macon,
Tallapoosa,
Chambers,
Elmore
and
Lee
Counties).
Tier
II
National
Fuel
Standard
(
starting
2004)

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
EPA's
initial
nonattainment
recommendations
on
June
29,
2004,
included
the
Counties
of
Lee
in
Alabama
and
Harris
in
Georgia
as
part
of
the
Columbus,
GA
nonattainment
area.
Upon
further
review
of
additional
information
provided
by
the
states,
EPA
is
revising
its
recommendation
and
is
designating
Lee
County,
AL
and
Harris
County,
GA
as
attainment/
unclassifiable.

Harris
County:

Harris
County,
Georgia,
is
being
designated
attainment/
unclassifiable
because
it
has
low
population
in
the
MSA
which
is
only
9%
(
25,092)
as
compared
to
185,948
in
Muscogee
County,
the
most
populated
County.
Only
214
of
Harris
County
commuters
commute
into
Russell
County,
where
the
violating
monitor
is
located,
and
it
has
low
VMT
(
547,000)
as
compared
to
1,594,000
in
Muscogee.
Harris
County
has
no
major
point
sources
of
precursor
emissions
and
comparatively
low
emissions
of
590
tons
of
PM,
104
tons
of
SO2,
and
2,856
tons
of
NOx.

We
considered
the
data
in
the
request
for
spatial
averaging
for
the
Columbus
area,
which
was
denied,
while
evaluating
the
other
factors
and
determined
that
Harris
County
is
not
contributing
to
the
violations.
6­
189
Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
nonattainment
for
the
Columbus,
GA­
AL
area:
Muscogee.

6.4.2.6
Augusta
Area
On
February
13,
2004,
the
State
of
Georgia
submitted
to
EPA
their
PM
2.5
nonattainment
recommendations.
Georgia
recommended
only
counties
which
contained
a
monitored
violation
and
provided
no
further
justification.
On
June
15,
2004,
the
State
submitted
additional
information
and
revised
recommendations
for
the
Augusta
area.
The
revision
recommended
that
Richmond
County
be
unclassifiable.

Richmond
County
has
two
PM2.5
monitors
with
air
quality
data
for
2001­
2003.
The
data
for
one
monitor
demonstrates
attainment
and
the
other
monitor
has
incomplete
data
for
2001­
2003
that
was
violating.
EPA's
analysis
of
all
the
available
monitoring
data
indicates
that
the
area
should
be
designated
as
attainment/
unclassifiable.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
attainment/
unclassifiable
for
the
Augusta,
GA
area:
Richmond.

6.4.3
EPA
9­
Factor
Analyses
for
Kentucky
for
the
Designation
of
PM2.5
Nonattainment
Areas
6.4.3.1
Cincinnati­
Hamilton
Area
The
MSA
contains
the
Kentucky
Counties
of
Boone,
Campbell,
Kenton,
Grant,
Pendleton,
Gallatin;
the
Ohio
Counties
of
Hamilton,
Clermont,
Butler,
Warren,
Brown;
and
the
Indiana
Counties
of
Dearborn
and
Ohio.

The
following
counties
are
violating
the
PM2.5
standard:
Hamilton
County,
Ohio;
Butler
County,
Ohio;
and
Montgomery
County,
Ohio.

In
February
2004,
Kentucky
recommended
that
all
Kentucky
counties
in
the
Cincinnati­
Hamilton
MSA
be
designated
attainment
for
the
PM2.5
standard.
EPA
is
modifying
Kentucky's
recommendation
to
include
Boone,
Campbell
and
Kenton
Counties
in
the
Cincinnati­
Hamilton
nonattainment
area.
Boone
County
has
significant
emissions,
relatively
high
population
growth,
and
a
large
(>
10,000
tons
per
year
SO2)
power
plant
located
in
the
County.
Campbell
and
Kenton
Counties
have
significant
VMT,
significant
numbers
of
commuters
into
violating
Hamilton
County,
and
both
counties
part
of
the
Cincinnati
1­
hour
ozone
nonattainment
area
due
to
violating
monitors.
Kenton
County
also
has
monitoring
data
close
to
the
standard.
EPA
agrees
that
the
remaining
KY
MSA
counties
of
Gallatin,
Grant,
and
Pendleton
should
be
designated
as
attainment/
unclassifiable
due
to
low
emissions,
very
low
population
relative
to
the
area,
and
very
low
numbers
of
commuters
into
the
violating
counties.
6­
190
EPA
agrees
that
the
adjacent
counties
of
Carroll
and
Mason
should
be
designated
attainment/
classifiable
for
the
PM2.5
standard,
although
they
have
significant
emissions
due
to
power
plants.
These
counties
have
relatively
low
populations,
low
population
growth,
and
low
VMT
.
Further,
their
commuting
patterns
and
distance
from
the
violating
monitors
indicate
that
these
counties
do
not
contribute
to
the
violations
in
the
area.
The
other
adjacent
counties
do
not
contribute
and
therefore,
will
be
designated
as
attainment/
unclassifiable.

Area
EPA
Recommendation
State
Recommendation
Cincinnati­
Hamilton,
OH­
KY­
IN
Full
counties:
Boone
County
Campbell
County
Kenton
County
Full
counties:
none
The
following
is
a
brief
summary
of
the
nine
criteria
for
the
Cincinnati­
Hamilton,
OH­
KY­
IN
area.
These
analyses
were
based
on
existing
available
data.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
and
weighted
emissions
scores
for
the
counties
in
the
Cincinnati­
Hamilton
MSA
and
surrounding
counties.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
in
bold
italics.)

County
PM
SOx
NOx
VOC
Amm
Score
Cum.
Score
Hamilton,
OH
7,601
88,053
58,398
47,014
2,422
30.3
30.3
Clermont,
OH
6,443
84,599
45,618
7,638
326
20.0
50.3
Dearborn,
IN
3581
56,773
31,138
3,732
246
11.4
61.7
Butler,
OH
3,153
13,204
19,735
14,228
1,363
9.9
71.6
Boone,
KY
1,946
14,717
15,794
6,644
256
7.7
79.3
Warren,
OH
1,844
895
7,565
7,003
417
6.9
86.2
Kenton,
KY
741
1,573
8,365
7,392
285
4.2
90.4
Campbell,
KY
590
860
5,294
4,421
267
2.8
93.2
Brown,
OH
748
395
2,927
1,995
294
2.0
95.2
Grant,
KY
381
210
2,664
1,364
257
1.8
97.0
Pendleton,
KY
363
597
3,396
900
186
1.5
98.5
Gallatin,
KY
367
350
2,365
904
192
1.0
99.5
Ohio,
IN
142
113
682
380
238
0.5
100.0
Adams,
OH
6,417
125,136
52,992
1,508
431
19.4
N/
A
Montgomery,
OH
2,542
11,214
24,177
28,598
1,170
12.2
N/
A
Carroll,
KY
3,547
53,086
26,269
3,249
159
10.3
N/
A
Mason,
KY
2,316
38,142
16,071
1,640
520
7.0
N/
A
Greene,
OH
1,516
1,895
8,841
5,827
538
4.0
N/
A
Preble,
OH
963
428
2,765
2,638
762
2.2
N/
A
Ripley,
IN
743
140
2,081
3,519
796
2.0
N/
A
Scott,
KY
627
260
3,629
6,041
481
2.0
N/
A
Fayette,
OH
883
309
2,136
2,100
310
1.9
N/
A
Decatur,
IN
922
154
2,525
3,876
1,538
1.8
N/
A
Clinton,
OH
788
375
2,490
2,572
329
1.8
N/
A
Rush,
IN
1,003
140
1,274
1,839
1,227
1.6
N/
A
6­
191
Highland,
OH
687
242
1,756
2,089
373
1.6
N/
A
Fayette,
IN
561
150
1,426
2,609
387
1.4
N/
A
Franklin,
IN
491
92
1,335
1,634
664
1.3
N/
A
Harrison,
KY
354
290
1,786
1,158
303
1.1
N/
A
Owen,
KY
236
57
572
566
245
1.1
N/
A
Switzerland,
IN
257
251
1,554
776
364
1.0
N/
A
Bracken,
IN
174
52
570
479
134
0.7
N/
A
Union,
IN
343
58
548
705
266
0.6
N/
A
Robertson,
KY
74
12
112
107
65
0.3
N/
A
Based
on
the
analysis
for
this
factor
for
Kentucky
only,
Boone,
Carroll,
and
Mason
Counties
have
significant
emissions
which
could
indicate
a
potential
emissions
contribution
to
the
PM2.5
violations
in
the
area.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
in
this
table.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
The
following
table
contains
the
design
value
for
the
MSA
and
adjacent
counties
that
contain
PM2.5
monitors.
Design
values
followed
by
"
a"
indicate
that
the
value
is
based
on
incomplete
monitoring
data.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
in
bold
italics.)

County
2001­
2003
design
value
Hamilton,
OH
17.8
Butler,
OH
16.2
Kenton,
KY
15.0
Campbell,
KY
14.5
Montgomery,
OH
15.2
Greene,
OH
9.5a
Preble,
OH
13.5a
Based
on
an
analysis
of
this
factor
for
Kentucky
only,
the
Campbell
and
Kenton
County
monitors
are
attaining.
The
Kenton
County
monitor
reading
of
15.0
indicates
that
there
may
be
a
potential
emissions
contribution
from
the
County
to
the
area.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
counties
in
the
Cincinnati­
Hamilton
MSA
and
some
adjacent
counties
with
violating
monitors
and
those
with
significant
emissions.
The
total
MSA
2002
population
is
2,009,679.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
in
bold
italics.)

County
2002
Population
Percent
of
Population
of
MSA
2002
Population
Density
Hamilton,
OH
833,721
41.49
2,048
Clermont,
OH
183,352
9.12
406
Dearborn,
IN
47,333
2.36
155
6­
192
Butler,
OH
340,543
16.95
729
Boone,
KY
93,290
4.64
379
Warren,
OH
175,133
8.71
438
Kenton,
KY
152,164
7.57
934
Campbell,
KY
88,604
4.41
583
Brown,
OH
43,464
2.16
88
Grant,
KY
23,620
1.18
91
Pendleton,
KY
14,815
0.74
53
Gallatin,
KY
7,836
0.39
79
Ohio,
IN
5,804
0.29
67
Adams,
OH
27,804
48
Montgomery,
OH
554,470
1,200
Carroll,
KY
10,223
79
Mason,
KY
16,916
70
Based
on
the
analysis
for
this
factor,
the
populations
for
the
Kentucky
counties
are
much
smaller
than
those
in
the
Ohio
Counties
of
Hamilton,
Butler,
and
Montgomery.
The
Kentucky
Counties
of
Boone,
Kenton,
and
Campbell
have
population
values
of
some
significance
as
compared
to
the
much
smaller
MSA
Kentucky
Counties
of
Grant,
Gallatin,
and
Pendleton.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties
in
this
table.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
Total
number
of
workers
in
Boone
County,
KY:
44,507
Commuters
in
Boone
County,
KY
who
work
in
Boone
County,
KY:
23,589
(
53%)
Commuters
from
Boone
County,
KY
to
Hamilton
County,
OH:
8,351
(
19%)
Commuters
from
Boone
County,
KY
to
Butler
County,
OH:
641
(
1%)

Total
number
of
workers
in
Kenton
County,
KY:
76,169
Commuters
in
Kenton
County,
KY
who
work
in
Kenton
County,
KY:
30,771
(
40%)
Commuters
from
Kenton
County,
KY
to
Boone
County,
KY:
17,053
(
22%)
Commuters
from
Kenton
County,
KY
to
Hamilton
County,
OH:
20,200
(
27%)
Commuters
from
Kenton
County,
KY
to
Butler
County,
OH:
908
(
1%)

Total
number
of
workers
in
Campbell
County,
KY:
42,820
Commuters
in
Campbell
County,
KY
who
work
in
Campbell
County,
KY:
15,474
(
36%)
Commuters
from
Campbell
County,
KY
to
Boone
County,
KY:
4,062
(
9%)
Commuters
from
Campbell
County,
KY
to
Hamilton
County,
OH:
14,946
(
35%)
Commuters
from
Campbell
County,
KY
to
Butler
County,
OH:
652
(
2%)

Total
number
of
workers
in
Gallatin
County,
KY:
3,589
Commuters
in
Gallatin
County,
KY
who
work
in
Gallatin
County,
KY:
1,317
(
37%)
Commuters
from
Gallatin
County,
KY
to
Boone
County,
KY:
1,038
(
29%)
Commuters
from
Gallatin
County,
KY
to
Hamilton
County,
OH:
196
(
5%)

Total
number
of
workers
in
Grant
County,
KY:
10,262
6­
193
Commuters
in
Grant
County,
KY
who
work
in
Grant
County,
KY:
4,181
(
41%)
Commuters
from
Grant
County,
KY
to
Boone
County,
KY:
2,852
(
28%)
Commuters
from
Grant
County,
KY
to
Hamilton
County,
OH:
716
(
7%)

Total
number
of
workers
in
Pendleton
County,
KY:
6,467
Commuters
in
Pendleton
County,
KY
who
work
in
Pendleton
County,
KY:
2,482
(
38%)
Commuters
from
Pendleton
County,
KY
to
Boone
County,
KY:
789
(
12%)
Commuters
from
Pendleton
County,
KY
to
Hamilton
County,
OH:
785
(
12%)
Commuters
from
Pendleton
County,
KY
to
Butler
County,
OH:
101
(
2%)

Total
number
of
workers
in
Carroll
County,
KY:
4,466
Commuters
in
Carroll
County,
KY
who
work
in
Carroll
County,
KY:
3,475
(
78%)
Commuters
from
Carroll
County,
KY
to
Boone
County,
KY:
54
(
1%)
Commuters
from
Carroll
County,
KY
to
Hamilton
County,
OH:
48
(
1%)

Total
number
of
workers
in
Mason
County,
KY:
7,560
Commuters
in
Boone
County,
KY
who
work
in
Boone
County,
KY:
5,978
(
79%)
Commuters
from
Mason
County,
KY
to
Hamilton
County,
OH:
95
(
1%)

A
notable
number
of
commuters
from
Kenton
and
Campbell
Counties
commute
into
violating
Hamilton
County.
Although
these
numbers
are
far
less
than
the
number
of
commuters
in
Hamilton
County,
in
conjunction
with
VMT
data
analyzed
below,
they
indicate
some
potential
for
contributing
to
the
mobile
source
emissions
in
the
area.

Although
47%
of
Boone's
44,507
workers
commute
into
other
counties
in
the
MSA,
a
relatively
small
number
commute
into
the
violating
counties.
In
Carroll
County,
78%
of
the
4,466
workers
commute
within
the
County.
Similarly,
in
Mason
County,
79%
of
the
7,560
workers
commute
within
the
County.
Thus,
onroad
mobile
source
emissions
from
commuting
patterns
for
Boone,
Carroll,
and
Mason
Counties
do
not
appear
to
be
contributing
to
violations
in
the
area.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
above.

Vehicle
Miles
Traveled:

The
following
table
has
the
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Cincinnati­
Hamilton
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
in
bold
italics.)

County
2002
VMT
(
thousand
miles/
year)
Hamilton,
OH
8,420
Clermont,
OH
1,649
Dearborn,
IN
607
Butler,
OH
2,610
Boone,
KY
842
Warren,
OH
1,354
Kenton,
KY
1,816
Campbell,
KY
1,097
6­
194
Brown,
OH
417
Grant,
KY
379
Pendleton,
KY
169
Gallatin,
KY
254
Ohio,
IN
56
Adams,
OH
283
Montgomery,
OH
5,668
Carroll,
KY
213
Mason,
KY
178
Based
on
an
analysis
of
this
factor
for
Kentucky
only,
the
VMT
for
Boone,
Kenton,
and
Campbell
Counties
are
in
the
relatively
moderate
to
high
range
as
compared
to
the
counties
listed
above,
with
the
exception
of
the
the
violating
Ohio
counties
of
Hamilton,
Butler,
and
Montgomery.
Boone,
Kenton,
and
Campbell
VMT
data
indicate
some
potential
to
contribute
to
the
PM2.5
violations
in
the
area.
VMT
values
for
Carroll
and
Mason
are
very
low
and
do
not
indicate
a
potential
contribution.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
in
this
table.

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Cincinnati­
Hamilton
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
in
bold
italics.)

County
2002
Population
growth
(
90­
00)
%
growth
(
90­
00)
Hamilton,
OH
833,721
­
20,925
­
2
Clermont,
OH
183,352
27,790
19
Dearborn,
IN
47,333
7,274
19
Butler,
OH
340,543
41,328
14
Boone,
KY
93,290
28,402
49
Warren,
OH
175,133
44,474
39
Kenton,
KY
152,164
9,433
7
Campbell,
KY
88,604
4,750
6
Brown,
OH
43,464
7,319
21
Grant,
KY
23,620
6,647
42
Pendleton,
KY
14,815
2,354
20
Gallatin,
KY
7,836
2,477
46
Ohio,
IN
5,804
308
6
Adams,
OH
27,804
1,959
8
Montgomery,
OH
554,470
­
14,747
­
3
Carroll,
KY
10,223
863
9
Mason,
KY
16,916
134
1
While
the
Kentucky
Counties
of
Boone,
Grant,
and
Gallatin
have
the
highest
population
growth
rates
from
1990­
2000
than
all
of
the
counties
in
the
MSA,
only
Boone
County's
resulting
population
increase
of
28,402,
(
third
highest
increase
in
the
MSA),
is
significant
enough
to
indicate
a
potential
to
contribute
to
violations
in
the
area.
The
population
growth
rates
of
Carroll
and
Mason
Counties
are
relatively
very
low
and
thus,
do
not
indicate
a
potential
to
contribute
to
6­
195
the
area's
violations.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
in
this
table.

Factor
6:
Meteorology
The
following
meteorological
information
was
provided
by
Kentucky
for
the
MSA
Kentucky
Counties
of
Boone,
Campbell,
Kenton,
Gallatin,
Pendleton,
and
Grant.
(
The
figure
referenced
is
a
wind
rose
for
April
1­
October
31
for
the
1988­
1992
period
that
is
provided
in
Kentucky's
PM2.5
recommendations
submittal.)

Meteorological
Information
"
Due
to
the
close
proximity
of
Cincinnati,
Ohio,
meteorological
data
from
Cincinnati
was
used
for
this
Kentucky
area.
Wind
speed/
wind
direction
information
shows
that
the
majority
of
the
time
for
the
period
1988
 
1992,
the
wind
in
the...
County
area
came
from
the
southwest
and
typically
from
7­
10
knots.
(
See
figure
1­
A)
The
mean
high
temperature
for
July
for
the
area
from
1961
through
1990
was
86

F,
the
mean
low
was
66

F.
The
mean
precipitation
for
the
same
period
was
3.8
inches."
(
Source:
Kentucky
PM2.5
submittal)

Based
on
an
analysis
of
this
factor,
the
information
provided
is
not
sufficient
to
provide
a
compelling
argument
to
exclude
counties
based
on
prevailing
winds.
This
information
was
provided
only
for
the
summertime
winds.

Factor
7:
Geography/
topography
Based
on
an
analysis
of
this
factor,
there
are
no
significant
topographical
issues
associated
with
this
MSA.
For
the
adjacent
Carroll
and
Mason
Counties
in
Kentucky
with
significant
emissions,
both
counties
are
two
counties
removed
from
the
nearest
county
with
a
violating
monitor
(
Hamilton,
Ohio),
with
attaining
monitors
in
between
in
Kenton
and
Campbell
Counties
in
Kentucky.

Factor
8:
Jurisdictional
boundaries
The
following
MSA
counties
were
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004:
the
Kentucky
Counties
of
Boone,
Campbell,
and
Kenton;
the
Indiana
County
of
Dearborn;
and
the
Ohio
Counties
of
Hamilton,
Clermont,
Butler,
Warren,
Montgomery,
Greene,
Clinton.
This
factor
did
not
play
a
significant
role
in
the
decision­
making
process.

Factor
9:
Level
of
control
of
emission
sources
The
following
information
was
provided
by
Kentucky
for
Boone,
Campbell,
Kenton,
Grant,
Gallatin
and
Pendleton
Counties.
"
Point
sources
located
within...
County
are
subject
to
PSD
requirements,
CTG
RACT
requirements,
Maximum
Achievable
Control
Technology
(
MACT)
requirements
for
sources
of
Hazardous
Air
Pollutants,
and
New
Source
Performance
Standards
(
NSPS).
Any
controls
imposed
as
a
result
of
previous
nonattainment
designations
are
required
to
remain
in...
County."
6­
196
For
Boone
County
only:
"
Additionally,
substantial
NOx
reductions
have
occurred
during
the
last
year
from
East
Bend
Power
Plant
which
would
further
lower
the
contribution
of
NOx
emissions
from
Boone
County."

This
factor
did
not
play
a
significant
role
in
the
decision­
making
process.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
No
Changes
Made
to
June
29,
2004,
Recommendations.

Boone
County,
KY:

Boone
County
contains
one
major
point
source,
the
Cinergy
East
Bend
(
Cincinnati
Gas
&
Electric)
power
plant.
Kentucky
provided
the
following
information
on
controls
at
this
facility:
scrubber
with
85%
control
efficiency;
ESP
with
>
99%
control
efficiency;
and
low
NOx
burners
and
SCR
with
annual
efficiency
69%.
NOx
controls
have
been
in
place
since
2002.
The
NOx
SCR
controls
are
seasonal.
The
installation
of
SCR
in
2002
gained
2,534
tpy
of
NOx
reductions.

Corrections
to
TSD
for
Cincinnati­
Hamilton
MSA:

6.4.3.1­
Factor
1:
The
following
corrections
are
made
to
the
third
paragraph
in
this
section
as
follows:

Insert
redlined
phrase:
"...
and
both
counties
were
previously
designated
part
of
the
Cincinnati
1­
hour
ozone
nonattainment
area..."

Add
an
"
s"
to:
"...
very
low
populations
relative
to
the
area..."

6.4.3.1
­
Factor
2:
The
2001­
2003
design
values
in
the
Factor
2
table
for
Campbell
and
Kenton
Counties
are
corrected
to
read
as
follows:

County
2001­
2003
design
value
Kenton,
KY
14.9
Campbell,
KY
13.9
6.4.3.1­
Factor
4:

The
following
correction
is
made
to
the
section,
"
Commuting
Information,"
for
Mason
County:
6­
197
Replace
"
Boone"
with
"
Mason"
as
noted:
"
Commuters
in
MasonBoone
County,
KY
who
work
in
MasonBoone
County,
KY..."

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Cincinnati
 
Hamilton,
OH­
KY­
IN
area:
Boone,
Campbell,
and
Kenton.

6.4.3.2
Louisville
Area
The
Louisville
MSA
contains
the
Kentucky
Counties
of
Jefferson,
Bullitt,
and
Oldham;
and
the
Indiana
Counties
of
Floyd,
Clark,
Harrison,
and
Scott.
Jefferson
County,
Kentucky
and
Clark
County,
Indiana
are
violating
the
PM2.5
standard.
The
adjacent
Kentucky
County
of
Carroll
has
relatively
high
emissions
for
the
area,
however,
it
was
evaluated
as
part
of
the
Cincinnati
area.

In
February
2004,
Kentucky
recommended
that
Jefferson
County
be
designated
nonattainment
and
that
Bullitt
and
Oldham
Counties
be
designated
attainment
for
the
PM2.5
standard
for
the
Louisville
MSA.

EPA
agrees
that
the
Kentucky
MSA
County
of
Oldham
be
designated
attainment/
unclassifiable
due
to
low
emissions
and
relatively
low
population.
EPA
agrees
that
Jefferson
County
be
designated
nonattainment
due
to
four
violating
monitors
in
the
County
and
is
modifying
Kentucky's
recommendation
to
include
Bullitt
County
in
the
Louisville
nonattainment
area
due
to
a
relatively
high
number
of
commuters
into
violating
Jefferson
County,
a
monitored
PM2.5
value
of
15.0
that
is
very
close
to
the
standard,
and
relatively
high
population
growth.

EPA
agrees
that
the
adjacent
counties
should
be
designated
as
attainment/
unclassifiable
due
to
low
population
growth,
a
low
percentage
of
workers
commuting
into
the
Louisville
MSA,
relatively
low
emissions,
and
large
distance
from
the
violating
monitors
in
the
area.

Area
EPA
Recommendation
for
KY
State
Recommendation
Louisville,
KY
Full
counties:
Jefferson
County
Bullitt
County
Full
counties:
Jefferson
The
following
is
a
brief
summary
of
the
nine
criteria
for
the
Louisville,
KY
area.
These
analyses
were
based
on
existing
available
data.
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
and
weighted
emissions
scores
for
the
counties
in
the
Louisville
MSA
and
surrounding
counties.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
in
bold
italics.)

County
PM
SOx
NOx
VOC
Amm
Score
Cum.
Score
6­
198
Jefferson,
KY
7,385
62,526
81,398
55,376
1,539
51.5
51.5
Floyd,
IN
3,826
47,796
10,282
4,789
346
16.4
67.9
Clark,
IN
1,612
484
4,960
7,125
498
12.2
80.1
Bullitt,
KY
829
343
3,463
5,817
210
7.3
87.4
Harrison,
IN
794
419
3,677
2,702
2,632
5.3
92.7
Oldham,
KY
770
529
3,707
2,168
224
4.7
97.4
Scott,
IN
397
100
1,515
2,426
318
2.6
100.0
Carroll,
KY
3,547
53,086
26,269
3,249
159
15.2
Jefferson,
IN
2,247
39,599
33,990
2,921
302
11.2
Hardin,
KY
1,207
1,774
7,695
6,713
1,114
9.1
Lawrence,
IN
1,544
4,330
5,707
3,330
543
6.5
Jackson,
IN
919
260
3,427
4,721
898
5.8
Nelson,
KY
781
497
2,134
7,923
1,147
5.0
Trimble,
KY
869
7,998
8,458
520
182
4.6
Breckinridge,
KY
566
321
2,592
1,273
757
4.4
Grayson,
KY
593
412
1,532
1,796
1,166
4.0
Meade,
KY
692
661
4,551
2,272
556
4.0
Shelby,
KY
699
397
2,906
2,778
842
4.0
Franklin,
KY
506
601
3,059
4,396
217
3.8
Jennings,
IN
640
233
1,589
2,274
256
3.5
Perry,
IN
518
789
3,102
2,018
403
3.4
Hart,
KY
391
162
1,839
1,499
662
3.2
Washington,
IN
580
136
1,452
2,448
3,468
3.1
Taylor,
KY
408
632
3,642
1,609
461
3.1
Crawford,
IN
319
536
3,842
1,237
192
2.9
Orange,
IN
475
86
2,017
2,599
313
2.9
Anderson,
KY
335
443
1,535
2,648
164
2.5
Marion,
KY
381
143
801
1,400
775
2.5
Henry,
KY
424
156
1,465
1,246
420
2.1
Owen,
KY
236
57
572
566
245
2.1
Larue,
KY
294
186
768
646
573
1.8
Washington,
KY
273
115
618
1,051
584
1.8
Green,
KY
261
104
507
586
331
1.7
Spencer,
KY
281
31
393
574
221
1.7
Based
on
the
analysis
for
this
factor
for
Kentucky
only,
the
Kentucky
Counties
of
Jefferson
and
Carroll
have
significant
emissions.
Bullitt
County
has
emissions
with
a
potential
to
contribute
to
the
PM2.5
violations
in
the
area.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
in
this
table.
6­
199
Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
County
2001­
2003
design
value
Jefferson,
KY
16.9
Floyd,
IN
14.9
Clark,
IN
16.2
Bullitt,
KY
15.0
Franklin,
KY
13.6
Hardin,
KY
14.1
There
are
four
counties
in
the
MSA
with
PM2.5
monitors,
two
of
which
have
violating
design
values
(
Jefferson
County,
Kentucky
and
Clark,
Indiana).
Bullitt
County,
Kentucky
has
an
attaining
monitor
whose
design
value
is
close
to
the
standard
(
15.0),
which
indicates
that
there
is
a
potential
to
contribute
to
the
PM2.5
violations
in
area.
The
adjacent
Kentucky
Counties
of
Hardin
and
Franklin
are
monitoring
attainment
and
thus,
do
not
indicate
emissions
contributions.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
in
this
table.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
counties
in
the
Louisville
MSA
and
adjacent
counties
with
significant
emissions.
The
total
MSA
2002
population
is
1,039,599.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
are
in
bold
italics.)

County
2002
Population
%
of
MSA
Population
(%)
Population
Density
Jefferson,
KY
698,080
67.15
1,813
Floyd,
IN
71,633
6.89
484
Clark,
IN
98,198
9.45
262
Bullitt,
KY
63,800
6.14
213
Harrison,
IN
35,244
3.39
73
Oldham,
KY
49,310
4.74
261
Scott,
IN
23,334
2.24
123
Hardin,
KY
95,724
N/
A
152
Based
on
the
analysis
for
this
factor
for
Kentucky
only,
Jefferson
County's
population
of
698,080
is
approximately
6­
30
times
higher
than
all
the
other
MSA
counties.
Hardin
County's
population
is
the
third
largest
of
the
counties
analyzed,
however,
it
is
still
relatively
insignificant
in
comparison
to
Jefferson
County's
population.
Thus,
this
factor
is
not
significant
for
the
Kentucky
counties
listed
in
this
table
with
the
exception
of
Jefferson
County.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information:

Total
number
of
workers
in
Jefferson
County,
KY:
329,091
Commuters
in
Jefferson
County,
KY
who
work
in
Jefferson
County,
KY:
303,624
(
92%)
Commuters
from
Jefferson
County,
KY
to
Clark
County,
IN:
7,047
(
2%)
6­
200
Total
number
of
workers
in
Bullitt
County,
KY:
30,648
Commuters
in
Bullitt
County,
KY
who
work
in
Bullitt
County,
KY:
8,419
(
27%)
Commuters
from
Bullitt
County,
KY
to
Jefferson
County,
KY:
19,730
(
64%)
Commuters
from
Bullitt
County,
KY
to
Clark
County,
IN:
418
(
1%)

Total
number
of
workers
in
Oldham
County,
KY:
27,716
Commuters
in
Oldham
County,
KY
who
work
in
Oldham
County,
KY:
7,207
(
33%)
Commuters
from
Oldham
County,
KY
to
Jefferson
County,
KY:
12,684
(
58%)
Commuters
from
Oldham
County,
KY
to
Clark
County,
IN:
326
(
1%)

Total
number
of
workers
in
Hardin
County,
KY:
44,815
Commuters
in
Hardin
County,
KY
who
work
in
Hardin
County,
KY:
36,030
(
80%)
Commuters
from
Hardin
County,
KY
to
Jefferson
County,
KY:
5,347
(
12%)

Based
on
the
commuting
data
for
the
Kentucky
counties
listed
above,
there
appears
to
be
potentially
significant
on­
road
mobile
source
emissions
contributions
from
Bullitt
and
Oldham
to
Jefferson
County,
which
has
over
300,000
resident
commuters.
A
large
percent
(
78%­
80%)
of
the
workers
in
Carroll
and
Hardin
Counties,
respectively,
commute
within
their
resident
counties.
Thus,
with
the
exception
of
Bullitt,
Jefferson,
and
Oldham
Counties,
this
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
above.

Vehicle
Miles
Traveled
(
VMT):

The
following
table
has
the
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Louisville
MSA
and
the
adjacent
county
of
Hardin
due
to
its
relatively
high
VMT
and
population.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
are
in
bold
italics.)

County
2002
VMT
(
thousand
miles/
year)
Jefferson,
KY
7,149
Floyd,
IN
843
Clark,
IN
1,262
Bullitt,
KY
849
Harrison,
IN
528
Oldham,
KY
507
Scott,
IN
364
Hardin,
KY
1,333
Based
on
the
analysis
for
this
factor,
the
VMT
for
Jefferson
County
far
exceeds
the
VMT
of
the
MSA
and
surrounding
counties.
Although
Hardin
County
has
a
relatively
high
VMT,
80%
of
its
workers
commute
within
the
County,
with
an
additional
12%
commuting
into
Jefferson
County,
Kentucky.
Based
on
the
analysis
for
this
factor,
Hardin
County
does
not
appear
to
significantly
contribute
on­
road
mobile
source
emissions
to
Jefferson
County.
Thus,
with
the
exception
of
Jefferson
County,
this
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
in
this
table.
6­
201
Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Louisville
MSA
and
the
adjacent
Hardin
County
due
to
its
relatively
high
VMT
and
population.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
are
in
bold
italics.)

County
2002
Population
growth
(
90­
00)
%
growth
(
90­
00)
Jefferson,
KY
698,080
28,667
4
Floyd,
IN
71,633
6,419
10
Clark,
IN
98,198
8,695
10
Bullitt,
KY
63,800
13,669
29
Harrison,
IN
35,244
4,435
15
Oldham,
KY
49,310
12,915
39
Scott,
IN
23,334
1,969
9
Hardin,
KY
95,724
4,934
6
Based
on
the
analysis
for
this
factor
for
Kentucky
only,
the
population
growth
in
Bullitt
and
Oldham
Counties
indicate
that
these
counties
may
contribute
to
the
PM2.5
issues
in
Jefferson
County.
Although
Jefferson
County's
growth
rate
is
fairly
low,
the
magnitude
of
its
population
increase
is
the
highest
in
the
MSA
and
is
approximately
twice
that
of
the
increases
in
Bullitt
and
Oldham.
Although
Hardin
County's
population
is
the
third
largest
of
the
counties
analyzed
above,
its
population
growth
is
relatively
low.
Thus,
with
the
exception
of
Bullitt,
Jefferson,
and
Oldham
Counties,
this
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
in
this
table.

Factor
6:
Meteorology
The
following
meteorological
information
was
provided
by
Kentucky
for
Jefferson,
Bullitt,
and
Oldham.

Wind
speed/
wind
direction
information
shows
that
the
majority
of
the
time
for
the
period
1988
 
1992,
the
wind
in
the...
County
area
came
from
the
south
southwest
and
typically
at
7­
10
knots.
The
mean
high
temperature
for
July
for
the
area
from
1961
through
1990
was
87

F
and
the
mean
low
was
70

F.
The
mean
precipitation
for
the
same
period
was
4.3
inches.

The
information
provided
is
not
sufficient
to
provide
a
compelling
argument
to
exclude
counties
based
on
prevailing
winds.
The
information
provided
was
based
only
on
summertime
winds.

Factor
7:
Geography/
topography
Based
on
an
analysis
of
this
factor,
there
are
no
significant
geographical
or
topographical
issues
associated
with
this
MSA.
boundary.
6­
202
Factor
8:
Jurisdictional
boundaries
The
following
MSA
counties
were
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004:
the
Kentucky
Counties
of
Jefferson,
Bullitt,
and
Oldham;
and
the
Indiana
Counties
of
Floyd,
Clark,
and
Jackson.
This
factor
did
not
play
a
significant
role
in
the
decisionmaking
process
for
these
counties.

Factor
9:
Level
of
control
of
emission
sources
The
following
information
was
provided
by
Kentucky
for
Bullitt,
Oldham,
and
Jefferson
Counties:
"
Point
sources
located
within...
County
are
subject
to
Prevention
of
Significant
Deterioration
(
PSD)
requirements,
Control
Technology
Guidelines
Reasonable
Available
Control
Technology
(
CTG
RACT)
requirements,
Maximum
Achievable
Control
Technology
(
MACT)
requirements
for
sources
of
Hazardous
Air
Pollutants
(
HAP),
and
New
Source
Performance
Standards
(
NSPS)."
This
factor
did
not
play
a
significant
role
in
the
decisionmaking
process
for
these
counties.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
No
Changes
Made
to
June
29,
2004,
Recommendations.

Corrections
to
TSD
for
Louisville
MSA:

6.4.3.1­
Factor
2:
The
2001­
2003
design
value
in
the
Factor
2
table
for
Bullitt
County
is
corrected
to
read
as
follows:

Bullitt,
KY
14.9
Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Louisville,
KY­
IN
area:
Bullitt
and
Jefferson.

6.4.3.3
Lexington
Area
The
Lexington
MSA
contains
the
Counties
of
Fayette,
Bourbon,
Clark,
Jessamine,
Madison,
Scott,
and
Woodford.
Fayette
County
is
violating
the
PM2.5
standard.

In
February
2004,
Kentucky
recommended
that
Fayette
County
be
designated
attainment
for
the
PM2.5
standard
for
the
Lexington,
KY
MSA,
and
the
remaining
MSA
counties
be
designated
attainment.
EPA
agrees
that
Fayette
County
should
be
designated
nonattainment
for
PM2.5
due
to
a
violating
monitor
(
South
Limestone).
EPA
is
modifying
Kentucky's
recommendation
to
6­
203
include
the
MSA
counties
of
Clark,
Madison
and
Woodford
and
the
adjacent
county
of
Mercer
in
the
Lexington
nonattainment
area.
Clark
and
Madison
Counties
are
included
significant
emissions.
Madison
County
also
has
relatively
high
population
and
population
growth,
and
relatively
high
VMT.
Woodford
County
as
nonattainment
due
to
the
level
of
emissions.
We
have
included
in
our
recommended
nonattainment
area
Mercer
County
that
is
adjacent
to
the
Lexington
MSA
with
a
violating
monitor,
that
is
generally
rural
in
character,
and
that
contains
an
identifiable
large
emitting
facility
(
e.
g.,
power
plants)
which
we
believe
contributes
to
the
nearby
nonattainment
problem.
We
have
included
this
county
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
county,
including
such
a
large
facility,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invite
you
to
submit
to
us
a
recommendation
as
to
what
portion
of
this
adjacent
county,
encompassing
the
large
facility,
should
be
designated
nonattainment.
EPA
agrees
that
the
remaining
MSA
Counties
of
Bourbon,
Jessamine,
and
Scott
in
Kentucky
be
designated
attainment/
unclassifiable
due
to
their
relatively
low
emissions,
low
populations,
low
VMT,
low
numbers
of
commuters
into
the
violating
counties,
and
small
point
sources.

EPA
agrees
that
the
adjacent
county
of
Pulaski
should
be
designated
attainment/
classifiable
for
the
PM2.5
standard,
although
it
has
significant
emissions
due
to
a
power
plant.
This
county
has
relatively
low
population,
low
population
growth,
and
low
VMT.
Further,
the
commuting
patterns
and
distance
from
the
violating
monitors
indicate
that
this
county
does
not
contribute
to
the
violations
in
the
area.
The
other
adjacent
counties
do
not
contribute
and
therefore,
will
be
designated
as
attainment/
unclassifiable.

The
recommendations
of
EPA
and
Kentucky
are
summarized
in
the
table
below.

Area
EPA
Recommendation
State
Recommendation
Lexington,
KY
Full
counties:
Fayette
County
Clark
County
Madison
County
Mercer
County
Woodford
County
Full
counties:
Fayette
Drop:
Bourbon,
Clark,
Madison,
Jessamine,
Woodford
and
Scott
Counties
The
following
is
a
brief
summary
of
the
nine
criteria
for
the
Lexington,
KY
area.
These
analyses
were
based
on
existing
available
data.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
and
Weighted
Emissions
Scores
for
the
counties
in
the
Lexington
MSA
and
surrounding
counties.
(
MSA
counties
in
Kentucky
are
in
bold.)

County
PM
SOx
NOx
VOC
Amm
Score
Cum.
Score
Fayette
(
KY)
1703
3925
13620
15720
606
31.4
31.4
Clark
(
KY)
1132
9647
6622
2374
398
25.7
57.1
6­
204
Madison
(
KY)
867
1189
5512
4215
641
13.6
70.7
Woodford
(
KY)
559
2663
3530
2852
427
9.5
80.2
Scott
(
KY)
627
260
3629
6041
481
7.9
88.1
Jessamine
(
KY)
504
323
2189
2436
242
7.6
95.7
Bourbon
(
KY)
444
147
1424
1352
597
4.3
100.0
Mercer
(
KY)
3136
49269
9145
1686
409
83.8
N/
A
Pulaski
(
KY)
2403
25156
10996
3901
877
56.8
N/
A
Laurel
(
KY)
770
1044
4564
3823
439
14.6
N/
A
Nelson
(
KY)
781
497
2134
7923
1147
10.3
N/
A
Based
on
the
analysis
for
this
factor,
the
following
counties
appear
to
have
significant
emissions
(
over
10,000
tons
per
year
of
any
pollutant):
Fayette,
Mercer
and
Pulaski.
Clark,
Madison,
and
Woodford
also
have
significant
level
of
emissions.
Although
Pulaski
County
This
factor
did
not
appear
significant
for
the
remaining
counties
listed
in
this
table.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
County
2001­
2003
design
value
Fayette
(
KY)
15.7
Madison
(
KY)
13.5
Laurel
(
KY)
12.6
Based
on
the
analysis
for
this
factor,
only
Fayette
County's
South
Lomestone
monitoring
data
exceeds
the
standard.
The
Newtown
Pike
monitor,
also
in
Fayette
County,
is
attaining
at
14.9.
Madison
County
and
the
adjacent
county
of
Laurel
have
monitors
with
readings
well
below
the
standard.
This
factor
is
not
significant
for
the
remaining
counties
listed
in
the
area.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
counties
in
the
Lexington
MSA
and
adjacent
counties
with
significant
emissions.
The
total
MSA
2002
population
is
489,717.
(
MSA
counties
are
in
bold.)

County
2002
Population
Percent
of
Total
MSA
Population
Population
Density
Fayette
(
KY)
263,618
53.83
925
Clark
(
KY)
33,726
6.89
133
Madison
(
KY)
73,334
14.97
166
Woodford
(
KY)
23,403
4.78
123
Scott
(
KY)
35,320
7.21
124
Jessamine
(
KY)
40,740
8.32
235
Bourbon
(
KY)
19,576
4.0
67
Mercer
(
KY)
21,047
84
Laurel
(
KY)
54,313
125
Nelson
(
KY)
38,823
92
Fayette
County's
population
is
roughly
3­
11
times
higher
than
the
other
counties
listed.
Madison
County
has
the
second
highest
of
the
MSA
counties
and
surrounding
counties
with
significant
6­
205
weighted
emissions
scores.
Based
on
an
analysis
of
this
factor,
no
other
Kentucky
counties,
with
the
exception
of
Madison
County,
have
populations
significant
to
indicate
a
potential
contribution
to
the
PM2.5
violations
in
Fayette
County.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
Total
number
of
workers
in
Fayette
County,
KY:
136,793
Commuters
in
Fayette
County,
KY
who
work
in
Fayette
County,
KY:
117,584
(
86%)

Total
number
of
workers
in
Bourbon
County,
KY:
9,103
Commuters
in
Bourbon
County,
KY
who
work
in
Bourbon
County,
KY:
4,764
(
52%)
Commuters
from
Bourbon
County,
KY
to
Fayette
County,
KY:
2,600
(
29%)

Total
number
of
workers
in
Clark
County,
KY:
15,487
Commuters
in
Clark
County,
KY
who
work
in
Clark
County,
KY:
8,492
(
55%)
Commuters
from
Clark
County,
KY
to
Fayette
County,
KY:
4,777
(
31%)

Total
number
of
workers
in
Jessamine
County,
KY:
18,885
Commuters
in
Jessamine
County,
KY
who
work
in
Jessamine
County,
KY:
8,721
(
46%)
Commuters
from
Jessamine
County,
KY
to
Fayette
County,
KY:
8,748
(
46%)

Total
number
of
workers
in
Madison
County,
KY:
34,494
Commuters
in
Madison
County,
KY
who
work
in
Madison
County,
KY:
24,061
(
70%)
Commuters
from
Madison
County,
KY
to
Fayette
County,
KY:
6,870
(
20%)

Total
number
of
workers
in
Scott
County,
KY:
16,536
Commuters
in
Scott
County,
KY
who
work
in
Scott
County,
KY:
10,148
(
61%)
Commuters
from
Scott
County,
KY
to
Fayette
County,
KY:
4,287
(
26%)

Total
number
of
workers
in
Woodford
County,
KY:
12,377
Commuters
in
Woodford
County,
KY
who
work
in
Woodford
County,
KY:
5,591
(
45%)
Commuters
from
Woodford
County,
KY
to
Fayette
County,
KY:
4,308
(
35%)

Total
number
of
workers
in
Laurel
County,
KY:
21,180
Commuters
in
Laurel
County,
KY
who
work
in
Laurel
County,
KY:
16,286
(
77%)

Total
number
of
workers
in
Mercer
County,
KY:
9,610
Commuters
in
Mercer
County,
KY
who
work
in
Mercer
County,
KY:
5,235
(
54%)
Commuters
from
Mercer
County,
KY
to
Fayette
County,
KY:
1,319
(
14%)

Total
number
of
workers
in
Nelson
County,
KY:
17,594
Commuters
in
Nelson
County,
KY
who
work
in
Nelson
County,
KY:
11,189
(
64%)
6­
206
Madison
County
has
the
largest
number
of
workers
commuting
into
Fayette
County
(
6,870
commuters),
which
is
relatively
insignificant
for
such
a
large
county
as
Fayette.
Laurel
and
Nelson
County
workers
do
not
commute
into
the
Lexington
MSA
at
all.
Based
on
the
analysis
for
this
factor,
there
are
no
counties
with
commuting
data
showing
a
potential
to
contribute
to
the
PM2.5
violations
in
Fayette
County.

Vehicle
Miles
Traveled:

The
following
table
has
the
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Lexington
MSA
and
adjacent
counties
with
significant
emissions.
(
Kentucky
MSA
counties
are
in
bold.)

County
2002
VMT
Fayette
(
KY)
2764
Clark
(
KY)
523
Madison
(
KY)
944
Woodford
(
KY)
311
Scott
(
KY)
645
Jessamine
(
KY)
362
Bourbon
(
KY)
204
Mercer
(
KY)
224
Laurel
(
KY)
852
Nelson
(
KY)
427
Fayette
County's
VMT
is
substantially
higher
than
the
other
MSA
counties.
Although
Madison
and
Laurel
Counties
have
the
second
and
third
highest
VMT
of
the
counties
analyzed,
commuting
data
do
not
indicate
significant
(
or
any)
contributions
to
Fayette
County.
Further,
Laurel
County
is
a
significant
distance
from
Fayette
County
and
does
not
contribute
to
Fayette
County
through
its
commuting
patterns.
Based
on
the
analysis
for
this
factor,
no
other
Kentucky
counties,
with
the
exception
of
Madison
County,
have
VMT
and
commuting
data
with
a
potential
to
contribute
to
the
PM2.5
violations
in
Fayette
County.

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Lexington
MSA
and
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

County
2002
Population
growth
(
90­
00)
%
growth
(
90­
00)
Fayette
(
KY)
263618
35,146
16
Clark
(
KY)
33726
3,648
12
Madison
(
KY)
73334
13,364
23
Woodford
(
KY)
23403
3,253
16
Scott
(
KY)
35320
9,194
39
Jessamine
(
KY)
40740
8,533
28
Bourbon
(
KY)
19576
124
1
Mercer
(
KY)
21047
1,669
9
6­
207
Laurel
(
KY)
54313
9,277
21
Nelson
(
KY)
38823
7,767
26
Fayette
County's
population
is
substantially
higher
than
the
MSA
counties
and
adjacent
counties
with
significant
weighted
emissions
scores,
and
grew
the
most
during
the
1990­
2000
time
period.
Madison
County
is
the
third
fastest
growing
county
in
the
MSA
based
on
a
percent
growth
rate
with
the
second
largest
population
and
the
second
largest
population
increase.
Thus,
Madison
County's
population
growth
is
significant
enough
to
contribute
to
PM2.5
violations
in
Fayette
County.
None
of
the
other
MSA
and
adjacent
counties
listed
above
have
population
characteristics
which
appear
to
be
contributing
to
the
PM2.5
violations
in
Fayette
County.

Factor
6:
Meteorology
The
following
meteorological
information
was
provided
by
Kentucky.
The
figure
referenced
is
a
wind
rose
for
April
1­
October
31
for
the
1988­
1992
period
that
is
provided
in
Kentucky's
PM2.5
recommendations
submittal.
The
text
below
is
the
same
for
Fayette,
Bourbon,
Clark,
Jessamine,
Scott,
and
Woodford
Counties.

"
Wind
speed/
wind
direction
information
shows
that
the
majority
of
the
time
for
the
period
1988
 
1992,
the
wind
in
the...
County
area
came
from
the
southwest
and
typically
from
7­
10
knots.
(
See
figure
1­
A)
The
mean
high
temperature
for
July
for
the
area
from
1961
through
1990
was
86

F
and
the
mean
low
was
66

F.
The
mean
precipitation
for
the
same
period
was
4.8
inches."
(
Source:
KY
submittal)

For
Madison
County,
the
following
statement
preceded
the
excerpted
paragraph
above:

Due
to
the
close
proximity
of
Lexington,
Kentucky,
meteorological
data
from
Lexington
was
used
for
the
Madison
county
area."

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.
The
submitted
information
was
only
for
the
summertime
winds.

Factor
7:
Geography/
topography
Based
on
an
analysis
of
this
factor,
there
are
no
significant
topographical
issues
associated
with
this
MSA.

Factor
8:
Jurisdictional
boundaries
No
county
in
the
Lexington
MSA
was
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004.
This
factor
did
not
play
a
significant
role
in
the
decision
making
process.
6­
208
Factor
9:
Level
of
control
of
emission
sources
The
following
information
was
provided
by
Kentucky
for
Fayette,
Bourbon,
Clark,
Jessamine,
Madison,
Scott,
Woodford
Counties.

"
Point
sources
located
within...
County
are
subject
to
PSD
requirements,
CTG
RACT
requirements,
Maximum
Achievable
Control
Technology
(
MACT)
requirements
for
sources
of
Hazardous
Air
Pollutants,
and
New
Source
Performance
Standards
(
NSPS)."
(
Source:
KY
PM2.5
submittal)

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
EPA's
initial
nonattainment
recommendations
on
June
29,
2004,
include
the
MSA
counties
of
Clark,
Madison,
and
Woodford
and
the
adjacent
county
of
Mercer.
Upon
further
review
of
additional
information
provided
by
Kentucky,
EPA
is
revising
its
recommendations
and
designating
Clark,
Madison,
and
Woodford
Counties
as
attainment/
unclassifiable.
EPA
is
designating
a
portion
of
Mercer
County
as
nonattainment
and
the
remainder
of
the
county
as
attainment/
unclassifiable.

The
additional
analysis
provided
by
Kentucky
indicated
that
there
is
a
strong
localized
effect
on
the
violating
monitor
in
Fayette
County.
Fayette
County
has
two
monitors
located
in
Lexington,
Kentucky
which
are
1.9
miles
apart,
with
one
violating
at
a
design
value
of
15.6
and
one
attaining
at
a
design
value
of
14.9.
The
supplemental
submittals
from
Kentucky
provided
additional
data
and
analysis
to
demonstrate
that
the
monitor
located
on
the
University
of
Kentucky's
(
UK)
campus
is
violating
due
to
localized
impacts.
These
local
impacts
include:
emissions
from
112
UK
boilers
fueled
by
coal
and
natural
gas;
13
major
construction
projects
on
the
UK
campus
which
began
as
early
as
December
1999
and
have
just
been
completed
or
are
in
process;
and
several,
nearby
downtown
construction
projects
in
Lexington.
All
of
the
construction
projects
in
the
area
are
one
to
six
blocks
from
the
violating
monitor.

Clark
County,
KY:

Clark
County's
population
of
33,726
people
and
VMT
of
523,000
are
very
small
in
comparison
to
those
of
Fayette
County,
whose
population,
commuters,
and
VMT
are
substantially
higher
than
those
of
the
other
MSA
counties.
In
contrast,
Fayette
County,
with
one
violating
monitor,
has
a
population
of
263,618
and
VMT
of
2,764,000.
Clark
County
has
no
monitor.
Clark
County's
population
comprises
only
6.9%
of
the
total
MSA
population.
In
addition,
Clark
County
has
a
low
number
of
workers
(
4,777)
commuting
to
the
violating
MSA
County
of
Fayette
and
whose
15,487
workers
account
for
just
6.4%
of
the
total
number
of
MSA
workers.

Clark
County's
total
emissions
are,
in
tpy
(
and
%
of
the
MSA
emissions):
1,132
PM
(
19.4%),
9,647
SO2
(
53.1%),
6,622
NOx
(
18.1%),
and
2,374
VOC
(
6.8%).
Clark
County
does
contain
a
small
outlying
power
plant,
East
Kentucky
Power,
with
2001
emissions
of
6,846
tpy
of
SO2
and
6­
209
1,910
tpy
of
NOx.
These
factors
in
combination
with
Kentucky's
localized
impact
analysis
indicate
Clark
County's
emissions
are
not
contributing
to
the
PM2.5
violation
at
the
one
monitor
in
Fayette
County.

Madison
County,
KY:

Madison
County
has
no
large
point
sources
and
the
design
value
of
its
attaining
monitor
is
13.4.
The
County
has
a
relatively
small
population
of
73,334
and
a
low
number
of
VMT
of
944,000
in
comparison
to
Fayette,
the
violating
county,
whose
population
is
263,618
and
VMT
is
2,764,000.
Madison
County
workers
account
for
only
14.2%
of
the
total
number
of
commuters
in
the
MSA.
In
addition,
70%
of
the
County's
workers
commute
within
Madison
County.

Woodford
County,
KY:

Woodford
County
has
relatively
low
emissions
and
no
monitor.
Specifically,
County
emission
totals
are,
in
tpy
(
and
%
of
the
MSA
emissions):
559
tpy
PM
(
9.6%),
2,663
tpy
SO2
(
14.7%),
3,530
tpy
NOx
(
9.7%),
and
2,852
tpy
VOC
(
8.2%).
While
there
is
a
small
Kentucky
Utilities
power
plant,
the
highest
emissions
from
this
plant
are
only
1,117
tpy
NOx
and
2,087
tpy
SO2.
In
addition,
the
County
has
a
very
small
population
of
23,403
and
accounts
for
only
5.1%
of
all
the
commuters
in
the
MSA.
Only
5,020
workers
from
Woodford
County
commute
to
other
counties
in
the
MSA.
These
factors
in
combination
with
Kentucky's
localized
impact
analysis
indicate
Woodford
County's
emissions
are
not
contributing
to
the
PM2.5
violation
at
the
one
monitor
in
Fayette
County.

Mercer
County,
KY:

In
the
June
29,
2004,
letters
from
EPA
to
the
States
responding
to
their
designation
recommendations,
EPA
recommended
the
designation
of
a
number
of
counties
primarily
because
of
high
pollutant
emissions
from
power
plants.
Most
of
these
plants
were
located
in
nearby
counties
adjacent
to
the
metropolitan
area
(
as
defined
either
by
the
1999
or
2003
OMB
metropolitan
area
definitions).
EPA
suggested
that
a
State
could
provide
a
partial
county
boundary
that
would
encompass
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.
Mercer
County
is
one
of
those
counties.

Mercer
County
has
low
population
(
21,047
compared
to
263,618
in
Fayette
County
where
the
city
of
Lexington
is
located),
low
population
density
(
84
people
per
square
mile
compared
to
925
in
Fayette
County),
low
VMT
(
224,000
compared
to
2,764,000
in
Fayette
County),
and
the
only
large
point
source
is
Kentucky
Utilities'
E.
W.
Brown
facility.
Mercer
County
has
no
monitor.

A
number
of
states
responded
to
this
suggestion
with
a
series
of
connected
townships
or
other
unique
boundaries.
Some
states
also
suggested
an
alternative
approach
in
which
partial
county
areas
for
power
plants
in
some
cases
could
be
small
"
free­
standing"
boundaries
that
are
considered
part
of
the
nearby
nonattainment
area.
In
this
way,
it
would
not
be
necessary
to
include
additional
townships
or
other
minor
civil
divisions
comprising
an
odd­
shaped
"
land
connector"
extending
from
the
main
part
of
the
nonattainment
area
to
the
power
plant.
The
6­
210
Commonwealth
of
Kentucky
subsequently
submitted
a
partial
county
recommendation
that
included
the
E.
W.
Brown
facility.

After
considering
these
comments
from
the
States,
EPA
agrees
that
such
an
approach
is
preferable
in
cases
where
a
partial
county
nonattainment
boundary
has
not
already
been
established
for
that
source
(
e.
g.
partial
county
boundaries
recently
established
for
8­
hour
ozone
nonattainment
areas).
For
purposes
of
consistency,
EPA
has
decided
that
free­
standing
portions
of
nonattainment
areas
should
be
based
on
a
pre­
existing
boundary
for
a
minor
civil
division
(
such
as
a
township
or
tax
district)
or
other
boundary
defined
for
governmental
use
(
such
as
a
census
block
group
or
census
tract).
Accordingly,
this
kind
of
partial
county
boundary
should
not
be
defined
simply
as
the
boundary
of
the
facility.
Therefore,
EPA
is
designating
the
census
block
group
identifier
(
StateFIPs­
CoFIPs­
Tract#­
Block
Group#)
21­
167­
9605­
1
portion
of
Mercer
County
as
part
of
the
Lexington
nonattainment
area.

Corrections
to
TSD
for
Lexington
MSA:

6.4.3.3
­
Preamble:

The
following
corrections
are
noted
to
the
preamble
to
the
factors
text
above:

"
In
February
2004,
Kentucky
recommended
that
Fayette
County
be
designated
attainment
nonattainment
..."

"
Clark
and
Madison
Counties
are
included
due
to
significant
emissions..."

"
Woodford
County
is
recommended
as
nonattainment..."

6.4.3.3
­
Factor
1
The
following
corrections
are
noted
to
the
text
after
the
emissions
table:

"...
have
significant
levels
of
emissions.
Although
Pulaski
County
This
factor..."

6.4.3.3
­
Factor
2
The
following
correction
is
noted
to
the
text
after
the
design
value
table:

"...
South
LomestoneLimestone
monitoring..."

6.4.3.3
­
Factor
2
The
2001­
2003
design
values
in
the
Factor
2
table
for
Fayette
and
Madison
Counties
are
corrected
to
read
as
follows:
6­
211
County
2001­
2003
design
value
Fayette
(
KY)
15.6
Madison
(
KY)
13.4
Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Lexington,
KY
area:
Fayette
and
Mercer
(
Partial).

6.4.3.4
Huntington­
Ashland
Area
The
Huntington­
Ashland
MSA
contains
the
Kentucky
Counties
of
Boyd,
Carter,
and
Greenup;
the
West
Virginia
Counties
of
Cabell
and
Wayne;
and
Lawrence
County,
Ohio.
The
following
MSA
and
adjacent
counties
are
violating
the
PM2.5
standard:
Cabell
County,
West
Virginia
(
MSA)
and
Lawrence
(
MSA)
and
Scioto
(
adjacent)
Counties,
Ohio.

In
February
2004,
Kentucky
recommended
that
the
PM2.5
designation
for
Boyd
County
be
deferred
and
that
Greenup
and
Carter
Counties
be
designated
attainment
for
the
Huntington­
Ashland
MSA.
EPA
is
modifying
Kentucky's
recommendeation
to
include
Boyd
County
and
Lawrence
Counties
in
Kentucky
in
the
Huntington­
Ashland
nonattainment
area.
The
following
factors
played
a
significant
role
in
this
decision
for
Boyd
County:
attaining
monitor
reading
of
15.0,
at
the
standard;
significant
SOx,
NOx,
and
PM
emissions;
proximity
to
the
violating
MSA
counties;
controls
with
anticipated,
substantial
SOx,
NOx,
and
PM
emission
reductions
will
not
be
implemented
until
the
end
of
2005,
well
after
designations
are
made.
Lawrence
County,
Kentucky
is
included
due
to
significant
emissions
of
SOx
and
NOx
from
a
power
plant
and
its
close
proximity
to
the
violating
counties
in
the
MSA.
We
have
included
in
our
recommended
nonattainment
area
this
County
that
is
adjacent
to
the
Huntington­
Ashland
MSA
with
a
violating
monitor,
that
is
generally
rural
in
character,
and
that
contains
an
identifiable
large
emitting
facility
(
e.
g.,
power
plant)
which
we
believe
contributes
to
the
nearby
nonattainment
problem.
We
have
included
this
county
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
county,
including
such
a
large
facility,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invite
you
to
submit
to
us
a
recommendation
as
to
what
portion
of
this
adjacent
county,
encompassing
the
large
facility,
should
be
designated
nonattainment.

EPA
agrees
that
Greenup
and
Carter
Counties
in
Kentucky
should
be
designated
attainment/
unclassifiable
due
to
their
relatively
low
emissions,
low
populations,
low
VMT,
low
numbers
of
commuters
into
the
violating
counties,
and
small
point
sources.

The
recommendations
of
EPA
and
Kentucky
are
summarized
in
the
table
below.
6­
212
Area
EPA
Recommendation
for
KY
State
Recommendation
Huntington­
Ashland,
WVKY
OH
Full
counties:
Boyd
County
Lawrence
County
(
adjacent)
Full
counties:
Boyd
(
Defer
Designation)

The
following
is
a
brief
summary
of
the
nine
criteria
for
the
Kentucky
portion
of
the
Huntington­
Ashland,
WV­
KY­
OH
area.
These
analyses
were
based
on
existing
available
data.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
per
year
and
weighted
emissions
scores
for
the
counties
in
the
Huntington­
Ashland
MSA
and
surrounding
counties.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
are
in
bold
italics.)

County
PM
SOx
NOx
VOC
Amm
Score
Cum.
Score
Cabell
(
WV)
2,365
5,155
27,903
7,080
181
40.3
40.3
Boyd
(
KY)
2,314
11,740
13,478
8,620
467
25.2
65.5
Wayne
(
WV)
550
1,023
6,485
2,620
56
9.6
75.1
Greenup
(
KY)
477
2,519
4,336
1,795
156
9.5
84.6
Lawrence
(
OH)
770
841
4,399
4,366
207
8.6
93.2
Carter
(
KY)
506
237
2,615
1,996
223
6.8
100.0
Gallia
(
OH)
10,010
164,984
61,079
1,839
300
141.4
Adams
(
OH)
6,417
125,136
52,992
1,508
431
102.4
Putnam
(
WV)
4,395
80,150
39,795
3,752
97
72.7
Mason
(
WV)
3,610
70,053
31,327
2,831
264
60.0
Lawrence
(
KY)
2,903
56,066
21,265
919
56
48.3
Scioto
(
OH)
1,053
2,790
5,566
4,703
350
12.5
Lewis
(
KY)
429
469
2,873
990
222
8.1
Pike
(
OH)
425
4,203
2,081
1,311
149
6.8
Rowan
KY
336
313
1,691
1,535
91
5.7
Mingo
(
WV)
437
281
2,842
1,379
150
5.5
Jackson
(
OH)
404
461
1,320
1,717
165
4.7
Martin
(
KY)
281
661
1,236
706
762
4.0
Lincoln
(
WV)
259
67
1,314
1,128
37
4.0
Elliott
(
KY)
164
115
393
313
42
3.1
Based
on
the
analysis
for
this
factor,
the
following
Kentucky
counties
appear
to
have
significant
emissions
(
over
10,000
tons
per
year
of
any
pollutant):
Boyd
and
Lawrence.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties
listed
in
this
table.
6­
213
Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
County
2001­
2003
design
value
Cabell
(
WV)
16.6
Boyd
(
KY)
15.0
Lawrence
(
OH)
15.8
Carter
(
KY)
12.2
Scioto
(
OH)
17.2
There
are
four
monitors
in
the
MSA,
with
two
of
them
in
the
Kentucky
Counties
of
Boyd
and
Carter.
The
Kentucky
monitors
are
monitoring
attainment.
Three
monitors
in
the
MSA
and
surrounding
counties
are
violating:
Cabell
County,
West
Virginia;
Lawrence
County,
Ohio;
and
the
adjacent
Scioto
County,
Ohio.
Based
on
the
analysis
for
this
factor
for
Kentucky
only,
Boyd
County
has
attaining
monitoring
data
very
close
to
the
standard,
thus
indicating
a
potential
to
contribute
to
the
PM2.5
violations
in
the
area.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
counties
in
the
Huntington­
Ashland
MSA
and
adjacent
counties
with
significant
emissions.
The
total
MSA
2002
population
is
313,239.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
are
in
bold
italics.)

County
2002
Population
Percent
of
Total
MSA
Population
2002
Population
Density
Cabell
(
WV)
95,266
30.41
338
Boyd
(
KY)
49,603
15.84
310
Wayne
(
WV)
42,382
13.53
84
Greenup
(
KY)
36,761
11.74
106
Lawrence
(
OH)
62,172
19.85
137
Carter
(
KY)
27,055
8.64
66
Gallia
(
OH)
31,301
67
Adams
(
OH)
27,804
48
Putnam
(
WV)
52,230
151
Mason
(
WV)
26,004
60
Scioto
(
OH)
78,041
128
Based
on
the
analysis
for
this
factor
for
Kentucky
only,
Boyd
County
has
the
third
largest
population
in
the
MSA
and
the
second
largest
population
density,
indicating
a
potential
to
contribute
to
the
PM2.5
violations
in
the
area.
This
factor
is
not
significant
for
the
remaining
Kentucky
counties.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
Total
number
of
workers
in
Boyd
County,
KY:
19,106
6­
214
Commuters
in
Boyd
County,
KY
who
work
in
Boyd
County,
KY:
13,816
(
72%)
Commuters
from
Boyd
County,
KY
to
Cabell
County,
WV:
1,157
(
6%)
Commuters
from
Boyd
County,
KY
to
Lawrence
County,
OH:
540
(
3%)

Total
number
of
workers
in
Carter
County,
KY:
10,258
Commuters
in
Carter
County,
KY
who
work
in
Carter
County,
KY:
5,641
(
55%)
Commuters
from
Carter
County,
KY
to
Boyd
County,
KY:
1,401
(
14%)
Commuters
from
Carter
County,
KY
to
Cabell
County,
WV:
237
(
2%)

Total
number
of
workers
in
Greenup
County,
KY:
13,798
Commuters
in
Greenup
County,
KY
who
work
in
Greenup
County,
KY:
5,930
(
43%)
Commuters
from
Greenup
County,
KY
to
Boyd
County,
KY:
4,147
(
30%)
Commuters
from
Greenup
County,
KY
to
Cabell
County,
WV:
473
(
3%)
Commuters
from
Greenup
County,
KY
to
Lawrence
County,
OH:
443
(
3%)
Commuters
from
Greenup
County,
KY
to
Scioto
County,
KY:
1,252
(
9%)

Total
number
of
workers
in
Lawrence
County,
KY:
4,899
Commuters
in
Lawrence
County,
KY
who
work
in
Lawrence
County,
KY:
2,483
(
51%)
Commuters
from
Lawrence
County,
KY
to
Boyd
County,
KY:
575
(
12%)
Commuters
from
Lawrence
County,
KY
to
Cabell
County,
WV:
193
(
4%)
Commuters
from
Lawrence
County,
KY
to
Lawrence
and
Scioto
Counties,
OH:
0
(
0%)

Based
on
commuting
data
above,
none
of
the
Kentucky
counties
appear
to
be
contributing
a
significant
level
of
onroad
mobile
source
emissions
to
the
area.

Vehicle
Miles
Traveled:

The
following
table
has
the
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Huntington­
Ashland
MSA
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
are
in
bold
italics.)

County
2002
VMT
(
thousand
miles/
year)
Cabell
(
WV)
1,030
Boyd
(
KY)
411
Wayne
(
WV)
377
Greenup
(
KY)
264
Lawrence
(
OH)
796
Carter
(
KY)
665
Gallia
(
OH)
266
Adams
(
OH)
283
Putnam
(
WV)
578
Mason
(
WV)
270
Scioto
(
OH)
633
Based
on
the
total
VMT
of
the
Kentucky
counties
only,
there
appears
to
be
a
potential
contribution
of
onroad
mobile
source
emissions
to
the
area
from
Boyd
and
Carter
Counties.
6­
215
However,
the
analysis
of
the
commuting
data
above
shows
that
a
low
number
of
workers
commute
from
these
Kentucky
counties
into
the
violating
counties.
Thus,
this
factor
is
not
significant
for
the
Kentucky
counties
listed
above
when
VMT
and
commuting
data
are
analyzed
together.

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Huntington­
Ashland
MSA
and
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold;
Kentucky
MSA
counties
are
in
bold
italics.)

County
2002
Population
growth
(
90­
00)
%
growth
(
90­
00)
Cabell
(
WV)
95,266
­
43
­
0
Boyd
(
KY)
49,603
­
1,398
­
3
Wayne
(
WV)
42,382
1,267
3
Greenup
(
KY)
36,761
149
0
Lawrence
(
OH)
62,172
485
1
Carter
(
KY)
27,055
2,549
10
Gallia
(
OH)
31,301
115
0
Adams
(
OH)
27,804
1,959
8
Putnam
(
WV)
52,230
8,754
20
Mason
(
WV)
26,004
779
3
Scioto
(
OH)
78,041
­
1,132
­
1
Based
on
an
analysis
of
this
factor
for
Kentucky
only,
there
appears
to
be
relatively
significant
population
growth
in
Carter
County
to
indicate
a
potential
air
quality
contribution.
However,
Carter
County's
population
is
low.
Boyd
and
Greenup
Counties
have
a
negative
or
zero
population
growth
rate.
Thus,
this
factor
is
not
significant
for
the
Kentucky
counties.

Factor
6:
Meteorology
The
following
meteorological
information
was
provided
by
Kentucky.
The
text
below
is
the
same
for
Boyd,
Carter,
and
Greenup
Counties
in
Kentucky.
The
figure
referenced
is
a
wind
rose
for
April
1­
October
31
for
the
1988­
1992
period
that
is
provided
in
Kentucky's
PM2.5
recommendations
submittal.

Meteorological
Information
"
Due
to
the
close
proximity
of
Huntington,
West
Virginia,
meteorological
data
from
Huntington
was
used
for
this
Kentucky
area.
Wind
speed/
wind
direction
information
shows
that
the
majority
of
the
time
for
the
period
1988
 
1992,
the
wind
in
the
Huntington­
Ashland
area
came
from
the
southwest
and
typically
from
4­
6
knots.
(
See
figure
1­
A)
The
mean
high
temperature
for
July
for
the
area
from
1961
through
1990
was
85

F
and
the
mean
low
was
65

F.
The
mean
precipitation
for
the
same
period
was
4.5
inches."
(
Source:
Kentucky
PM2.5
submittal)
6­
216
Based
on
an
analysis
of
this
factor,
the
information
provided
is
not
sufficient
to
provide
a
compelling
argument
to
exclude
counties
based
on
prevailing
winds.
The
information
provided
was
for
only
the
summertime
winds.

Factor
7:
Geography/
topography
Based
on
an
analysis
of
this
factor,
there
are
no
significant
topographical
issues
associated
with
this
MSA.

Factor
8:
Jurisdictional
boundaries
The
following
MSA
counties
were
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004:
Boyd
County,
Kentucky;
the
West
Virginia
Counties
of
Cabell,
Wayne,
and
Putnam;
and
no
counties
in
Ohio.
This
factor
did
not
play
a
significant
role
in
the
decisionmaking
process.

Factor
9:
Level
of
control
of
emission
sources
The
following
information
was
provided
by
Kentucky
for
Boyd,
Carter,
and
Greenup
Counties.
"
Point
sources
located
within...
County
are
subject
to
PSD
requirements,
CTG
RACT
requirements,
Maximum
Achievable
Control
Technology
(
MACT)
requirements
for
sources
of
Hazardous
Air
Pollutants,
and
New
Source
Performance
Standards
(
NSPS)."
This
factor
did
not
play
a
significant
role
in
the
decisionmaking
process
for
these
counties
Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
Lawrence
County,
KY:

In
the
June
29,
2004,
letters
from
EPA
to
the
States
responding
to
their
designation
recommendations,
EPA
recommended
the
designation
of
a
number
of
counties
primarily
because
of
high
pollutant
emissions
from
power
plants.
Most
of
these
plants
were
located
in
nearby
counties
adjacent
to
the
metropolitan
area
(
as
defined
either
by
the
1999
or
2003
OMB
metropolitan
area
definitions).
EPA
suggested
that
a
State
could
provide
a
partial
county
boundary
that
would
encompass
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.
Lawrence
County,
Kentucky,
is
one
of
those
counties.

Lawrence
County,
Kentucky,
has
low
population
(
15,784
compared
to
95,266
and
62,172
in
the
violating
MSA
counties
of
Cabell,
West
Virginia
and
Lawrence,
Ohio,
respectively),
low
population
density
(
38
people
per
square
mile
compared
to
338
in
Cabell,
West
Virginia
and
137
in
Lawrence,
Ohio),
low
VMT
(
163,000
compared
to
1,030,000
and
796,000
in
Cabell,
West
Virginia
and
Lawrence,
Ohio),
and
the
only
large
point
source
is
the
Big
Sandy
Power
Plant.
Lawrence
County,
Kentucky,
has
no
monitor.
6­
217
A
number
of
states
responded
to
this
suggestion
with
a
series
of
connected
townships
or
other
unique
boundaries.
Some
states
also
suggested
an
alternative
approach
in
which
partial
county
areas
for
power
plants
in
some
cases
could
be
small
"
free­
standing"
boundaries
that
are
considered
part
of
the
nearby
nonattainment
area.
In
this
way,
it
would
not
be
necessary
to
include
additional
townships
or
other
minor
civil
divisions
comprising
an
odd­
shaped
"
land
connector"
extending
from
the
main
part
of
the
nonattainment
area
to
the
power
plant.
The
Commonwealth
of
Kentucky
subsequently
submitted
a
partial
county
recommendation
that
included
the
Big
Sandy
Power
Plant.

After
considering
these
comments
from
the
States,
EPA
agrees
that
such
an
approach
is
preferable
in
cases
where
a
partial
county
nonattainment
boundary
has
not
already
been
established
for
that
source
(
e.
g.
partial
county
boundaries
recently
established
for
8­
hour
ozone
nonattainment
areas).
For
purposes
of
consistency,
EPA
has
decided
that
free­
standing
portions
of
nonattainment
areas
should
be
based
on
a
pre­
existing
boundary
for
a
minor
civil
division
(
such
as
a
township
or
tax
district)
or
other
boundary
defined
for
governmental
use
(
such
as
a
census
block
group
or
census
tract).
Accordingly,
this
kind
of
partial
county
boundary
should
not
be
defined
simply
as
the
boundary
of
the
facility.
Therefore,
EPA
is
designating
the
census
block
group
identifier
(
StateFIPs­
CoFIPs­
Tract#­
Block
Group#)
21­
127­
9901­
6
portion
of
Lawrence
County,
Kentucky
as
part
of
the
Huntington­
Ashland
nonattainment
area
and
the
remainder
of
the
county
as
attainment/
unclassifiable.

Corrections
to
TSD
to
Huntington­
Ashland
MSA:

6.4.3.4
­
Factor
1:
Deletion:
(
over
10,000
tons
per
year
of
any
pollutant)

6.4.3.4
­
Factor
2:

The
design
value
for
Boyd
County
is
corrected
to
read
as
follows:

County
2001­
2003
design
value
Boyd,
KY
14.9
6.4.3.4
­
Factor
3:
The
following
information
is
inserted
into
the
population
data
table:

County
2002
Population
Percent
of
Total
MSA
Population
2002
Population
Density
Lawrence
(
KY)
15,784
38
6.4.3.4
­
Factor
4:
The
following
information
is
inserted
into
the
VMT
data
table:
6­
218
County
2002
VMT
(
thousand
miles/
year)

Lawrence
(
KY)
163
6.4.3.4
­
Factor
5:
The
following
information
is
inserted
into
the
population
growth
table:

County
2002
Population
growth
(
90­
00)
%
growth
(
90­
00)

Lawrence
(
KY)
15,784
1,571
11
Insert
the
following
statements
regarding
Lawrence
County,
KY
as
follows
(
additions
are
in
italics,
deletions
are
in
strikeout).

Based
on
an
analysis
of
this
factor
for
Kentucky
only,
there
appears
to
be
relatively
significant
population
growth
in
Carter
and
Lawrence
Countyies
in
Kentucky
to
indicate
a
potential
air
quality
contribution.
However,
the
populations
of
Carter
and
Lawrence
Countyies
population
is
are
low.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Huntington
 
Ashland,
WV­
KY­
OH
area:
Boyd
and
Lawrence
(
Partial).

6.4.3.5
Boyd
County
Area
Kentucky
anticipates
that
emissions
of
PM2.5,
SOx,
and
NOx
will
decrease
substantially
within
Boyd
County
over
the
next
two
years.
These
anticipated
emission
decreases
are
due
to
source
modernization
and
new
controls
being
implemented
at
two
major
sources
in
Boyd
County:
the
Marathon­
Ashland
Refinery
and
Calgon
Carbon
Corporation.

For
the
Marathon­
Ashland
Refinery,
the
facility
modifications
are
anticipated
to
be
completed
by
the
end
of
2005.
According
to
Kentucky,
based
on
2002
emissions
data,
this
would
mean
an
approximate
reduction
of
1,571
tons
per
year
of
SO2,
a
761
ton
per
year
reduction
in
NOx,
and
a
32
ton
per
year
reduction
in
particulate
matter.

For
Calgon
Carbon
Corporation,
the
May
2003
shutdown
of
two
of
their
activator
lines
resulted
in
SO2
emissions
being
reduced
from
this
facility
by
approximately
187
tons
in
2003.
Before
these
lines
can
be
reactivated,
scrubbers,
with
SO2
and
PM
control
efficiencies
of
90%
will
be
required
to
be
installed
on
these
units.
If
brought
back
into
operation,
these
units
will
have
controls
in
place
to
reduce
emissions
of
SO2
from
these
two
lines
to
approximately
32
tons
per
year.

Based
on
an
analysis
of
this
factor,
these
controls
will
not
be
implemented
in
a
timeframe
early
enough
to
influence
the
decision
for
Boyd
County
on
PM2.5
designations.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
6­
219
counties
as
nonattainment
for
the
Huntington
 
Ashland,
WV­
KY­
OH
area:
Boyd
and
Lawrence
(
Partial).

6.4.4
EPA
9­
Factor
Analyses
for
North
Carolina
for
the
Designation
of
Nonattainment
Areas
for
PM2.5
6.4.4.1
Greensboro­
Winston­
Salem­
High
Point
Area
In
February
2004,
North
Carolina
recommended
that
the
entire
county
of
Davidson,
be
designated
as
nonattainment
for
the
Fine
Particulate
Matter
Standard.
The
table
below
shows
the
State
recommendations
and
EPA
modifications
for
the
Particulate
Matter(
PM
2.5)
nonattainment
area
in
Greensboro­
Winston­
Salem­
High
Point,
NC.
EPA
is
recommending
Davidson
County
be
designated
nonattainment
because
it
has
a
violating
PM
2.5
monitor.
The
MSA
counties
of
Guilford,
Stokes,
Forsyth
and
Randolph
are
also
being
recommended
as
nonattaiment.
Guilford,
Forsyth
and
Randolph
counties
are
adjacent
to
Davidson
County
and
have
large
populations
and
large
emissions.
Stokes
has
significant
power
plant
emissions.
EPA
agrees
that
Alamance,
Davie,
Yadkin,
Rowan,
Chatham,
Rockingham,
and
Iredell
Counties
be
designated
attainment/
unclassifiable.
Alamance
is
an
MSA
county
with
an
attaining
monitor
of
13.7
micrograms
per
cubic
meter
(
µ
g/
m3),
75
%
of
the
commuters
remain
in
Alamance
County
and
the
county
has
low
emissions.
Davie
and
Yadkin
are
MSA
counties
that
do
not
contain
PM
2.5
monitors,
have
low
populations,
and
low
commuting
into
Davidson.
There
is
significant
distance
between
the
violating
monitor
and
the
counties
of
Iredell
and
Yadkin.
Rowan
and
Iredell
are
adjacent
to
the
MSA,
do
not
contain
PM
2.5
monitors
and
are
a
part
of
the
Charlotte­
Gastonia­
Rock
Hill
nonattainment
area
for
ozone.
Rowan
and
Rockingham
both
have
small
power
plants
and
there
are
attaining
monitors
in
counties
between
the
SO2/
NOx
sources
in
Rowan
and
Rockingham
counties
and
the
violating
monitor.
Chatham
is
an
adjacent
county
to
the
Greensboro­
Winston­
Salem­
High
Point
MSA
with
an
attaining
monitor
of
12.2
µ
g/
m3,
has
low
population,
and
part
of
the
county
is
in
the
Raleigh­
Durham­
Chapel
Hill
nonattainment
area
for
ozone.
The
remaining
adjacent
counties
all
have
low
emissions,
low
population
and
low
VMT,
indicating
they
should
be
attainment/
unclassifiable.

Area
EPA
Recommendation
State
Recommendation
Greensboro­
Winston­
Salem­
High
Point,
NC
Full
Counties:
Stokes,
Guilford,
Davidson,
Forsyth,
and
Randolph
Full
Counties:
Davidson
6­
220
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
2001
PM2.5,
SO2,
NOx,
VOC,
and
Ammonia
(
Amm)
emissions
in
tons,
and
weighted
emissions
scores
for
the
Greensboro­
Winston­
Salem­
High
Point
Area
and
surrounding
counties.
The
MSA
counties
are
in
bold.

PM
2.5
SO2
NOx
VOC
Amm
Weighted
emissions
score
Cumulative
Weighted
emissions
score
NC
Stokes
4,821
83,409
35,936
2,566
357
32.8
32.8
NC
Guilford
2,418
2,833
19,068
34,464
1,178
17.6
50.4
NC
Davidson
1,951
1,398
11,281
14,970
632
12.9
63.3
NC
Forsyth
1,559
5,885
14,552
20,679
722
11.7
75.0
NC
Randolph
1,370
907
5,898
10,307
4,014
9.5
84.5
NC
Alamance
1,181
749
5,618
8,967
730
8.2
92.7
NC
Yadkin
606
318
2,061
2,247
896
4.0
96.7
NC
Davie
508
205
1,959
3,278
448
3.3
100.0
NC
Rowan
2,012
12,465
11,681
11,323
726
13.4
NC
Chatham
1,714
11,605
5,823
4,734
3,012
11.7
NC
Rockingham
1,555
6,263
12,227
8,770
523
11.2
NC
Iredell
1,537
1,365
11,065
10,346
2,090
10.8
NC
Surry
1,224
1,238
5,055
7,478
1,811
8.5
VA
Pittsylvania
980
1,828
7,490
4,149
581
7.2
NC
Moore
956
409
3,197
6,519
2,396
6.9
NC
Wilkes
966
647
2,890
5,097
5,300
6.6
NC
Orange
857
756
6,264
6,751
572
6.4
VA
Henry
818
535
3,811
10,517
197
5.6
NC
Stanly
795
3,129
2,891
4,581
1,460
5.3
NC
Montgomery
516
484
1,631
4,175
1,246
3.6
NC
Caswell
483
199
1,071
1,622
155
3.2
VA
Patrick
408
176
1,039
1,363
214
2.8
VA
Carroll
378
509
2,305
1,986
441
2.7
VA
Grayson
291
95
819
952
405
2.0
NC
Alleghany
217
190
379
590
425
1.4
Based
on
the
analysis
for
this
factor,
there
appears
to
be
emissions
in
Stokes,
Guilford,
Forsyth,
and
Randolph
counties
that
contribute
to
the
air
quality
in
Davidson
County,
resulting
in
a
violating
monitor
there.
This
analysis
shows
that
the
adjacent
counties
of
Rowan,
Chatham,
Rockingham,
and
Iredell
have
emissions
that
may
contribute
to
the
violation
in
Davidson
County.
However,
these
counties
are
more
distant
from
the
violating
monitor.
Chatham
County
has
an
attaining
monitor
and
is
part
of
the
Raleigh
MSA.
Rowan
and
part
of
Iredell
County
are
in
the
Charlotte
ozone
nonattainment
area.
6­
221
Factor
2:
Air
Quality
in
potentially
included
versus
excluded
areas
2001­
2003
Design
Value
NC
Guilford
14.1
NC
Davidson
15.8
NC
Forsyth
14.6
NC
Alamance
13.7
NC
Chatham
12.2
NC
Orange
13.1
NC
Montgomery
12.1
NC
Caswell
13.3
There
are
six
monitors
in
the
MSA
(
two
in
Guilford,
and
two
in
Forsyth
counties
and
one
in
Davidson,
and
Alamance
counties)
and
five
monitors
in
the
adjacent
counties.
The
monitor
in
Davidson
County,
is
violating
the
Particulate
Matter
Standard
of
15.0
micrograms
per
cubic
meter
(
µ
g/
m3).
All
other
monitors
in
this
area
are
attaining
the
Particulate
Matter
Standard.

Factor
3:
Population
Density
and
Degree
of
Urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
populations
for
the
counties
in
the
Greensboro­
Winston­
Salem­
High
Point
area
and
adjacent
counties
with
significant
weighted
emissions
scores.

2002
Population
%
Population
of
MSA
Population
Density
(
pop./
mi2)

NC
Stokes
44,984
3.5
100
NC
Guilford
430,937
33.5
663
NC
Davidson
151,238
11.6
274
NC
Forsyth
314,933
24.5
768
NC
Randolph
134,217
10.4
170
NC
Alamance
135,893
10.6
315
NC
Yadkin
37,329
2.9
111
NC
Davie
36,734
2.9
139
NC
Rowan
133,359
261
NC
Chatham
53,893
79
NC
Rockingham
92,778
164
NC
Iredell
130,178
227
Based
on
the
analysis
for
this
factor,
there
appears
to
be
significant
populations
in
Guilford,
Forsyth,
Davidson,
Rowan,
Iredell,
Randolph
and
Alamance
counties,
indicating
potential
contribution.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
Total
commuters
in
Davidson
County:
72,893
6­
222
Commuters
in
Davidson
County,
NC,
who
work
in
Davidson
County:
40,621
(
56%)

Total
commuters
in
Forsyth
County:
147,838
Commuters
in
Forsyth
County,
NC,
who
work
in
Forsyth
County:
119,233
(
81%)
Commuters
from
Forsyth
County,
NC
to
Davidson
County,
NC:
4,136
(
3%)

Total
commuters
in
Guilford
County:
213,079
Commuters
in
Guilford
County,
NC,
who
work
in
Guilford
County:
187,150
(
88%)
Commuters
from
Guilford
County,
NC
to
Davidson
County,
NC:
2,982
(
1%)

Total
commuters
in
Randolph
County:
65,803
Commuters
in
Randolph
County,
NC,
who
work
in
Randolph
County:
38,637
(
59%)
Commuters
from
Randolph
County,
NC
to
Davidson
County,
NC:
2,607
(
4%)

Total
commuters
in
Stokes
County:
21,709
Commuters
in
Stokes
County,
NC,
who
work
in
Stokes
County:
6,330
(
29%)
Commuters
from
Stokes
County,
NC
to
Davidson
County,
NC:
252
(
1%)

The
counties
of
Davie
and
Rowan
have
a
small
number
of
commuters
and
very
few
of
them
commute
to
Davidson
County.
Chatham,
Yadkin,
Iredell,
and
Rockingham
counties
have
a
low
number
of
commuters
and
most
of
them
stay
within
their
counties.

Based
on
commuting
patterns,
Forsyth
and
Guilford
appear
to
have
the
most
impact
on
the
violating
monitor
in
Davidson
County.
However,
the
impact
on
the
monitor
from
commuting
appears
to
be
small.

The
following
table
contains
the
vehicle
miles
traveled
(
VMT)
for
the
counties
in
the
Greensboro­
Winston­
Salem­
High
Point
area
and
some
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold).

2002
VMT
(
thousands
of
miles)
NC
Stokes
415
NC
Guilford
5,096
NC
Davidson
1,765
NC
Forsyth
3,832
NC
Randolph
1,486
NC
Alamance
1,575
NC
Yadkin
520
NC
Davie
476
NC
Rowan
1,654
NC
Chatham
434
NC
Rockingham
923
NC
Iredell
1,901
Based
on
total
VMT,
there
appears
to
be
contribution
to
air
quality
in
Davidson
County
from
Guilford,
Davidson,
Forysth,
Rowan,
Iredell,
Randolph
and
Alamance
counties.
However,
there
6­
223
is
very
low
or
no
commuting
into
Davidson
County
from
Rowan.
Iredell,
and
Alamance
Counties
Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
on
a
percentage
basis
figures
for
counties
in
the
Greensboro­
Winston­
Salem­
High
Point
MSA
and
some
adjacent
counties
with
significant
emissions.
As
noted
above,
Chatham
County
is
part
of
the
Raleigh
MSA,
and
Iredell
and
Rowan
Counties
are
in
the
Charlotte
rather
than
the
Greensboro
ozone
nonattainment
area.

2002
Population
Growth
'
90­'
00
%
Change
'
90­'
00
NC
Stokes
44,984
7,488
20
NC
Guilford
430,937
73,628
21
NC
Davidson
151,238
20,569
16
NC
Forsyth
314,933
40,189
15
NC
Randolph
134,217
23,908
22
NC
Alamance
135,893
22,587
21
NC
Yadkin
37,329
5,860
19
NC
Davie
36,734
6,976
25
NC
Rowan
133,359
19,735
18
NC
Chatham
53,893
10,570
27
NC
Rockingham
92,778
5,864
7
NC
Iredell
130,178
29,729
32
Based
on
the
analysis
for
this
factor,
there
appears
to
be
significant
growth
in
Davidson,
Guilford,
Forsyth,
Alamance,
Randolph,
Rowan,
Chatham,
and
Iredell
counties
indicating
a
potential
contribution
to
the
air
quality
in
Davidson
County.

Factor
6:
Meteorology
The
following
meteorological
information
was
provided
by
North
Carolina.
This
summarizes
the
wind
directions
for
the
MSA
during
the
time
periods
when
PM2.5
values
are
the
highest.

Summertime:
southwesterly
winds
and
recirculating
patterns
dominate.
Main
urban
areas
of
influence
include
Charlotte,
the
Triad,
and
Hickory.

Wintertime:
More
northerly
and
stronger
northwesterly
winds
observed
that
during
the
summer.
High
PM2.5
is
generally
observed
prior
to
frontal
passages
when
high
pressure
is
in
control
or
during
strong
nocturnal
low­
level
temperature
inversions.
Year­
round
trajectories
indicate
influence
from
nearby
states.

The
information
provided
is
not
sufficient
to
provide
a
compelling
argument
to
exclude
counties
based
on
prevailing
winds.

Factor
7:
Geography/
topography
6­
224
There
are
no
significant
topographical
issues
associated
with
this
MSA.
Chatham,
Iredell,
and
Rockingham
counties
are
one
or
more
counties
away
from
Davidson
county.
Additionally,
there
is
one
or
more
attaining
monitors
between
the
major
emissions
sources
in
these
counties
and
the
violating
monitor,
indicating
no
contribution.

Factor
8:
Jurisdictional
boundaries
The
8­
hour
nonattainment
boundary
designation
for
the
Greensboro­
Winston­
Salem­
High
Point
area
includes
the
entire
counties
of
Davidson,
Davie,
Forsyth,
Guilford,
Alamance,
Caswell,
Randolph,
and
Rockingham.
Davie,
Alamance,
Caswell,
and
Rockingham
were
designated
nonattainment
for
ozone
because
they
contained
violating
monitors
not
because
they
were
found
to
be
contributing.
Rowan
county
and
a
portion
of
Iredell
county
were
designated
nonattainment
for
the
ozone
standard
as
apart
of
the
Charlotte­
Gastonia­
Rock
Hill
MSA
area.
Due
to
significant
NOx
controls,
Stokes
County
was
determined
not
to
contribute
to
the
ozone
violations.

Factor
9:
Level
of
control
of
emission
sources
Belews
Creek
is
the
largest
coal­
burning
station
owned
by
Duke
Power
located
in
Stokes
County,
NC.
Duke
Power
completed
the
first
phase
of
its
massive
Selective
Catalytic
Reduction
(
SCR)
project
at
Belews
Creek
Steam
Station
that
will
reduce
the
power
plant's
nitrogen
oxide
emissions
by
over
90
percent.
No
scrubbers
are
installed
at
this
time,
but
are
scheduled
to
be
installed
in
2009.

The
state
initiatives
are
listed
below:
NOx
SIP
Call
The
Clean
Smokestacks
Act
Clean
Air
Bill
On
Board
Diagnostics
II
Emissions
Inspection
Program
PM2.5
Forecasting
Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
EPA's
initial
recommendations
on
June
29,
included
Forsyth,
Randolph
and
Stokes
Counties
as
part
of
the
Greensboro
nonattainment
area.
Upon
further
review
of
additional
information
provided
by
the
State,
EPA
is
revising
its
recommendation
and
is
designating
Forsyth,
Randolph
and
Stokes
Counties
as
attainment/
unclassifiable.

The
State
of
North
Carolina
has
taken
a
proactive
approach
to
solving
its
air
pollution
problems.
Several
programs
have
been
implemented
and
will
continue
to
be
implemented
to
control
PM2.5
precursors.
The
State
has
a
robust
PM2.5
monitoring
network.
The
Clean
Smokestacks
Act
requires
NOx
SIP
Call
controls
to
be
operated
year
round
and
requires
significant
emission
reductions
of
SO2
from
power
plants.
These
NOx
and
SO2
reductions
must
occur
within
the
boundaries
of
North
Carolina.
As
a
statewide
effort,
several
mobile
source
controls
have
been
implemented.
The
On
Board
Diagnostics
II
Emissions
Inspection
and
Maintenance
(
I/
M)
6­
225
program
has
expanded
to
now
encompass
48
counties,
including
all
MSA
counties
and
covering
82%
of
all
statewide
vehicles.
EPA
and
State
grants
have
been
used
to
support
of
their
efforts
to
reduce
emissions
from
mobile
sources
which
include
Alternate
Fuel
Vehicle
Infrastructure,
Compressed
Natural
Gas
Stations,
bike
racks
on
buses,
and
a
Mobile
Source
Abatement
Program.

The
Greensboro
area
Early
Action
Compact
(
EAC)
includes
the
counties
of
Alamance,
Caswell,
Davidson,
Davie,
Forsyth,
Guilford,
Randolph,
Rockingham,
Stokes,
Surry
and
Yadkin.
As
an
EAC
area,
all
11
counties
are
adopting
policies
to
encourage
and
promote
diesel
retrofits.
Less
polluting
vehicles
area
expected
to
result
in
a
reduction
in
emissions
of
1.1
tpy
of
VOC
and
0.9
tpy
of
NOx.
An
increase
in
ridership
on
regional
bus
services
is
projected
to
decrease
VOC
emissions
by
8.9
tpy
and
NOx
emissions
by
7.3
tpy.
All
diesel
vehicles
will
be
converted
to
biodiesel.
In
addition,
an
increase
in
telecommuting
is
expected
to
lead
to
a
decrease
of
VOC
and
NOx
emissions
by
189
tpy
and
155
tpy,
respectively.
Through
the
use
of
non­
motorized
transportation,
all
Triad
EAC
Counties
are
also
expected
to
decrease
VOC
emissions
by
279
tpy
and
NOx
by
229
tpy.
As
part
of
Duke
Energy's
initiative
to
cleaner
air,
implementation
of
a
Meter
Reading
Optimizing
program
will
reduce
Vehicle
Miles
Traveled
(
VMT)
in
all
11
EAC
Counties.

Stokes
County,
NC:

The
Belews
Creek
Steam
Station
is
the
major
source
of
the
County's
emissions.
However,
Duke
Power,
as
part
of
the
NOx
SIP
Call,
has
completed
the
Selective
Catalytic
Reduction
(
SCR)
project
and
began
operation
on
unit
one
in
2003
and
unit
two
in
2004.
Additionally,
unit
two
had
burner
technology
installed.
NOx
emissions
at
the
Belews
Creek
Steam
Station
were
reduced
by
36,545
tons
per
year
(
tpy)
to
7,022
TPY
by
the
end
of
2004.
Per
the
Clean
Smokestacks
Legislation,
SCR
must
be
operated
year
round
by
2009.
In
addition,
the
Belews
Creek
Power
Plant
will
complete
the
installation
of
state
of
the
art
scrubbers
on
both
units
by
2008,
reducing
sulfur
dioxide
(
SO2)
emissions
by
90%
to
10,805
TPY
and
achieve
an
emission
rate
of
0.15
lb/
mmBTU
emission
rate.
Stokes
County
rates
low
for
other
factors,
such
as
population,
population
density,
commuting
patterns,
and
VMT.

Duke
Power
has
committed
to
work
with
the
State
of
North
Carolina
to
expeditiously
place
the
schedule
for
compliance
with
the
Clean
Smokestacks
requirements
(
SO2
&
NOx)
into
the
title
V
permit.
This
schedule
will
include
installation
of
state
of
the
art
scrubbers
by
2008.

Forsyth
County,
NC:

Forsyth
County
has
two
attaining
monitors
at
14.0
and
14.6
micrograms/
cubic
meter.
Forsyth
emissions
in
tons
per
year
are
as
follows:
PM
emissions
1,559
tpy
(
11%
of
MSA),
SO2
emissions
5,885
tpy
(
6%
of
MSA),
NOx
emissions
14,552
TPY
(
15%
of
MSA).
Even
though
Forsyth
County
has
the
second
highest
MSA
population
with
314,933
people
representing
24.5%
of
the
MSA,
it
is
substantially
less
than
Guilford
County
with
a
population
of
430,937.
Of
147,838
commuters
in
Forsyth
County,
119,233
(
80.7%)
commuters
stay
within
the
county.
The
majority
of
emissions
are
from
mobile
sources.
These
emissions
are
controlled
(
or
addressed)
as
described
above.
6­
226
Wind
direction
and
pollution
roses
for
the
Greensboro
area
were
more
predominant
in
the
direction
of
Guilford
County
than
Forsyth
County.

Randolph
County,
NC:

Randolph
County's
emissions
represent
a
small
percentage
of
the
total
emissions
for
the
MSA.
Randolph
County's
total
emissions
in
tons
per
year
(
tpy)
are:
PM
1,370
(
9.5%
of
the
MSA),
SO2
907
(
0.9%
of
the
MSA),
NOx
5,898
(
6.1%
of
the
MSA).
The
population
of
Randolph
County,
134,217,
is
low
compared
to
Guilford
County
with
a
population
of
430,937
and
Randolph
County's
VMT
of
1,486
is
one
of
the
lowest
in
the
MSA
as
compared
to
5,096
thousands
of
miles.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Greensboro­
Winston
Salem
 
High
Point,
NC
area:
Davidson
and
Guilford
.

6.4.4.2
Hickory­
Morganton­
Lenoir
Area
The
following
is
the
nine
factor
analysis
for
Hickory­
Morganton­
Lenoir,
NC.
The
Hickory­
Morganton­
Lenoir,
NC
Metropolitan
Statistical
Area
(
MSA)
contains
the
counties
of
Catawba,
Caldwell,
Burke,
and
Alexander.

In
February
2004,
North
Carolina
recommended
that
the
Unifour
Metropolitan
Planning
Organization's
(
MPO)
Planning
Boundary
in
Catawba
County,
be
designated
as
nonattainment.
The
table
below
shows
State
Recommendations
and
EPA
recommended
modifications
for
the
Particulate
Matter
2.5
(
PM
2.5)
nonattainment
area
in
the
Hickory­
Morganton­
Lenoir
area.
EPA
is
modifying
the
recommendation
to
include
the
entire
county
of
Catawba
and
partial
county
boundaries
in
Burke
and
Caldwell
Counties.
Catawba
County
has
a
violating
PM
2.5
monitor.
The
partial
county
boundaries
in
Burke
and
Caldwell
Counties
follow
the
MPO
boundary
lines
which
were
the
boundaries
determined
in
the
8­
hour
ozone
designation
in
April
2004
for
the
two
counties.
Over
20
percent
of
the
commuters
from
Burke
and
Caldwell
counties
commute
to
Catawba
County
and
both
counties
contain
population
levels
that
indicate
contribution.
EPA
agrees
that
the
MSA
county
of
Alexander
and
the
adjacent
counties
of
Rutherford,
Iredell,
Cleveland,
and
Wilkes
be
designated
attainment/
unclassifiable.
These
counties
have
low
population,
and
are
low
commuting
into
Catawba
County,
distant
from
the
violating
monitor
in
Catawba
County.
The
remaining
adjacent
counties
all
have
low
emissions
and
low
population,
indicating
they
should
be
attainment/
unclassifiable.

Area
EPA
Recommendation
State
Recommendation
6­
227
Hickory­
Morganton­
Lenoir
Full
Counties:
Catawba
Partial
Counties:
Burke
and
Caldwell
Full
Counties:
None
Partial
Counties:
Catawba
The
following
is
a
brief
summary
of
the
9
criteria
for
the
Hickory­
Morganton­
Lenoir
MSA
and
surrounding
counties.
These
analyses
were
based
on
existing
available
data.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
has
2001
PM2.5,
SO2,
NOx,
VOC,
and
Ammonia
(
Amm)
emissions
in
tons,
and
weighted
emissions
scores
for
the
Hickory­
Morganton­
Lenoir
Area
and
surrounding
counties.
The
Metropolitan
Statistical
Area
(
MSA)
counties
are
in
bold.

PM
2.5
SO2
NOx
VOC
Amm
Weighted
emissions
score
Cumulative
Weighted
emissions
score
Catawba
5,153
78,620
27,968
19,760
886
59.7
59.7
Caldwell
1,104
634
3,530
11,122
391
18.1
77.8
Burke
1,198
877
4,601
7,721
562
17.0
94.8
Alexander
365
349
988
3,312
1,217
5.1
99.9
Rutherford
2,323
30,023
12,135
4,847
254
28.4
Iredell
1,537
1,365
11,065
10,346
2,090
25.3
Cleveland
1,258
1,261
4,975
6,591
1,240
18.4
Wilkes
966
647
2,890
5,097
5,300
15.3
Mc
Dowell
751
373
3,675
4,230
214
13.6
Lincoln
785
513
2,880
4,556
645
10.8
Watauga
541
352
1,523
2,370
341
8.5
Avery
269
163
730
985
77
4.4
Based
on
the
analysis
for
this
factor,
there
appears
to
be
emissions
in
the
MSA
counties
of
Caldwell
and
Burke,
counties
that
contribute
to
the
violation
in
Catawba
County.
Although
there
are
large
SO2
emissions
in
Rutherford
county,
adjacent
to
Burke,
the
source
is
distant
from
the
violating
monitor.
6­
228
Factor
2:
Air
Quality
in
potentially
included
versus
excluded
areas
2001­
2003
Design
Value
Catawba
15.5
Mc
Dowell
14.2
Watauga
10.9
There
is
one
monitor
in
this
area,
in
Catawba
County,
which
is
violating
the
particulate
matter
standard
of
15.0
micrograms
per
cubic
meter
(
µ
g/
m3).
Two
adjacent
counties
contain
monitors
attaining
the
standard.

Factor
3:
Population
Density
and
Degree
of
Urbanization
The
following
table
has
the
populations
for
the
counties
in
the
Hickory­
Morganton­
Lenoir
area
and
adjacent
counties
with
significant
emissions.
(
MSA
counties
are
in
bold.)

2002
Population
%
Population
of
MSA
Population
Density
(
pop./
mi2)

Catawba
146,690
42.0
367
Caldwell
78,513
22.5
166
Burke
89,638
25.7
177
Alexander
34,400
9.8
132
Rutherford
63,287
112
Iredell
130,178
227
Cleveland
97,960
211
Wilkes
66,773
88
Based
on
the
analysis
for
this
factor,
there
appears
to
significant
populations
in
Catawba,
Iredell,
Cleveland,
Caldwell
and
Burke
counties,
indicating
potential
contribution.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
Total
commuters
in
Catawba
County:
73,
984
Commuters
in
Catawba
County,
NC,
who
work
in
Catawba
County:
62,
459
(
84%)
6­
229
Total
commuters
in
Rutherford
County:
27,
673
Commuters
in
Rutherford
County,
NC,
who
work
in
Rutherford
County:
21,
812
(
79%)
Commuters
from
Rutherford
County,
NC
to
Burke
County,
NC:
305
(
1%)

Total
commuters
in
Caldwell
County:
38,
970
Commuters
in
Caldwell
County,
NC,
who
work
in
Caldwell
County:
26,
932
(
69
%)
Commuters
from
Caldwell
County,
NC
to
Catawba
County,
NC:
8,011
(
21
%)

Total
commuters
in
Burke
County:
42,214
Commuters
in
Burke
County,
NC,
who
work
in
Burke
County:
29,
123
(
69%)
Commuters
from
Burke
County,
NC
to
Catawba
County,
NC:
8,366
(
20%)

Total
commuters
in
Alexander
County:
31,
041
Commuters
in
Alexander
County,
NC,
who
work
in
Alexander
County:
24,
270
(
51%)
Commuters
from
Alexander
County,
NC
to
Catawba
County,
NC:
5,679
(
32%)

Most
of
the
commuters
in
Iredell,
Cleveland
and
Wilkes
counties
commute
within
their
counties
and
very
few
of
them
commute
to
Davidson
County.

Based
on
commuting
patterns,
Caldwell,
Alexander
and
Burke
counties
appear
to
have
the
most
potential
impact
on
the
violating
monitor
in
Catawba
county.

The
following
table
contains
the
vehicle
miles
traveled
(
VMT)
for
the
counties
in
the
Hickory­
Morganton­
Lenoir
MSA
and
some
adjacent
counties
with
significant
weighted
emissions
scores.
(
MSA
counties
are
in
bold.)

2002
VMT
(
thousands
of
miles)
Catawba
2,048
Caldwell
738
Burke
1,112
Alexander
229
Rutherford
606
Iredell
1,901
Cleveland
1,125
Wilkes
619
Based
on
the
analysis
for
this
factor,
Burke
County
has
VMT
that
appears
to
contribute
to
the
air
quality
in
Catawba
County.
Although
the
adjacent
counties
of
Iredell
and
Cleveland
have
significant
levels
of
VMT,
there
is
little
commuting
to
Catawba
County
from
these
counties.
6­
230
Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
counties
in
the
Hickory­
Morganton­
Lenoir
MSA
and
some
adjacent
counties
with
significant
emissions.

2002
Population
Growth
'
90­'
00
Pct
change
'
90­'
00
Catawba
146,690
23,273
20
Caldwell
78,513
6,706
9
Burke
89,638
13,404
18
Alexander
34,400
6,059
22
Rutherford
63,287
5,981
11
Iredell
130,178
29,729
32
Cleveland
97,960
11,573
14
Wilkes
66,773
6,239
11
Based
on
the
analysis
for
this
factor,
there
appears
to
be
significant
growth
on
a
percentage
in
Catawba
and
Alexander
Counties
in
the
MSA
and
adjacent
Iredell
County,
indicating
a
potential
contribution
to
the
air
quality
in
Catawba
County.
Although
the
percentage
growth
is
high
for
the
Iredell
County,
it
is
more
closely
associated
with
the
Charlotte
area.

Factor
6:
Meteorology
The
following
meteorological
information
was
provided
by
North
Carolina.
This
summarizes
the
wind
directions
for
the
MSA
during
the
time
periods
when
PM2.5
values
are
the
highest.

Summertime:
southwesterly
winds
and
recirculating
patterns
dominate.
Main
urban
areas
of
influence
include
Charlotte,
the
Triad,
and
Hickory.

Wintertime:
More
northerly
and
stronger
northwesterly
winds
observed
that
during
the
summer.
High
PM2.5
is
generally
observed
prior
to
frontal
passages
when
high
pressure
is
in
control
or
during
strong
nocturnal
low­
level
temperature
inversions.
Year­
round
trajectories
indicate
influence
from
nearby
states.

The
information
provided
is
not
sufficient
to
provide
a
compelling
argument
to
exclude
counties
based
on
prevailing
winds.

Factor
7:
Geography/
topography
6­
231
There
are
no
significant
topographical
issues
associated
with
this
MSA.

Factor
8:
Jurisdictional
boundaries
The
8­
hour
nonattainment
boundary
designation
for
the
Hickory­
Morganton­
Lenoir
area
includes
the
entire
counties
of
Alexander
and
Catawba
and
partial
counties
of
Burke
and
Caldwell.
The
nonattainment
designation
in
Burke
and
Caldwell
counties
are
along
the
Unifour
Metropolitan
Planning
Organization
boundaries.
Catawba
County
is
located
geographically
between
Alexander
and
Lincoln
Counties,
which
both
have
monitors
violating
the
8­
hour
ozone
standard.

In
Catawba
County,
a
second
monitor
was
operated
approximately
10
miles
southwest
of
the
current
violating
Hickory
monitor.
This
monitor
was
further
removed
from
a
major
highway.
The
location
of
this
monitor
at
a
rescue
squad
and
was
not
able
to
continue
at
that
location.
While
in
existence
for
seven
quarters,
this
monitor
showed
an
average
of
1.89
µ
g/
m3
lower
than
the
current
violating
monitor.
Therefore,
the
state
believes
that
this
monitor
would
have
continued
to
show
attainment/
unclassifiable
if
it
remained
in
existence
to
collect
three
years
of
data.

Factor
9:
Level
of
control
of
emission
sources
Duke
Power
­
Marshall
Steam
Station
(
Catawba
County)

No
scrubbers
are
installed
at
this
time.
However,
in
2004,
Duke
Power
began
installation
of
flue
gas
desulfurization
(
scrubber)
equipment.
This
equipment
will
lower
sulfur
dioxide
emissions
by
approximately
90
percent.
The
project
is
scheduled
for
completion
in
2007.

The
state
initiatives
are
listed
below:
NOx
SIP
Call
The
Clean
Smokestacks
Act
Clean
Air
Bill
On
Board
Diagnostics
II
Emissions
Inspection
Program
PM2.5
Forecasting
Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
EPA's
initial
nonattainment
recommendations
on
June
29,
2004,
included
a
portion
of
Burke
and
Caldwell
Counties.
Upon
further
review
of
additional
information
provided
by
the
State,
EPA
is
revising
its
recommendation
and
is
designating
Burke
and
Caldwell
Counties
as
attainment/
unclassifiable.

The
State
of
North
Carolina
has
taken
a
proactive
approach
to
solving
its
air
pollution
problems.
Several
programs
have
been
implemented
and
will
continue
to
be
implemented
to
control
PM2.5
pollution.
The
State
has
a
robust
PM2.5
monitoring
network.
The
Clean
Smokestacks
Act
requires
NOx
controls
to
be
operated
year
round
and
requires
substantial
SO2
reductions
from
6­
232
power
plants.
The
NOx
and
SO2
reductions
must
be
generated
within
the
State.
As
a
statewide
effort,
several
mobile
source
controls
have
been
implemented
including
I/
M
programs
in
Burke
and
Caldwell
Counties
beginning
July
1,
2005.
Burke
County
has
expected
decreases
in
NOx
of
1.29
tpd
and
VOC
of
0.23
tpd
while
Caldwell
County
has
expected
decreases
in
NOx
of
0.20
tpd
and
VOC
of
0.17
tpd.
Additionally,
Burke
and
Caldwell
Counties
are
in
the
Unifour
Early
Action
Compact
and
this
area
shows
attainment
of
the
8­
hour
ozone
NAAQS
with
2004
data.

Burke
County,
NC:

Most
of
the
MSA
emissions
are
generated
in
Catawba
County.
Burke
emissions
in
tons
per
year
are
as
follows:
PM
emissions
1,198
TPY
(
15.3%
of
MSA),
SO2
emissions
877
TPY
(
only
1.1%
of
MSA),
NOx
emissions
4,601
TPY
(
12.4%
of
MSA).
Burke
County
has
a
population
of
89,638
as
compared
to
Catawba
County's
population
of
146,690
people.
In
addition,
Burke
has
a
VMT
of
1,112
thousand
miles
as
compared
to
Catawba
County's
VMT
of
2,048.
Of
42,214
(
24%
of
MSA)
commuters
in
Burke
County,
29,123
(
69.0%)
commuters
stay
within
the
county.
There
are
no
large
point
sources
of
precursor
emissions
and
the
majority
of
emissions
are
due
to
mobile
emissions,
which
are
controlled
as
described
above.

Caldwell
County,
NC:

Most
of
the
MSA
emissions
are
generated
in
Catawba
County.
Caldwell
emissions
in
tons
per
year
are
as
follows:
PM
emissions
1,104
TPY
(
14.1%
of
MSA),
SO2
emissions
634
TPY
(
only
0.8%
of
MSA),
NOx
emissions
3,530
TPY
(
9.5%
of
MSA).
Caldwell
County
has
a
population
of
78,513
as
compared
to
Catawba
County's
population
of
146,690
people.
In
addition,
Caldwell
has
a
VMT
of
738
thousands
of
miles
as
compared
to
Catawba
County's
VMT
of
2,048.
Of
38,970
(
23%
of
MSA)
commuters
in
Caldwell
County,
26,932
(
69.1%)
commuters
stay
within
the
county.
There
are
no
large
point
sources
and
the
majority
of
emissions
are
due
to
mobile
emissions,
which
are
controlled
as
described
above.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
nonattainment
for
the
Hickory
 
Morganton
 
Lenoir,
NC
area:
Catawba.

6.4.5
EPA
9­
Factor
Analyses
for
South
Carolina
for
the
Designation
of
Nonattainment
Areas
for
PM2.5
6.4.5.1
Greenville­
Spartanburg­
Anderson
Area
In
February
2004,
South
Carolina
recommended
that
the
entire
state
be
designated
attainment.
Currently,
all
monitors
with
three
years
of
complete
data
are
attaining
the
Particulate
Matter
standard
of
15.0
micrograms
per
cubic
meter
(
µ
g/
m3).
However,
Greenville
County
has
a
monitor
that
has
not
been
in
operation
for
three
years,
but
is
indicating
potential
to
violate
the
PM
2.5
standard.
Anderson
and
Spartanburg
counties
have
emissions
and
population
levels
that
potentially
contribute
to
the
high
levels
at
the
Greenville
monitor
in
question.
Therefore,
EPA
is
modifying
the
State's
recommendation
to
designate
Anderson,
Greenville
and
Spartanburg
counties
as
unclassifiable.
Once
the
monitor
has
operated
for
three
full
years,
EPA
in
6­
233
conjunction
with
the
State
will
reassess
the
situation
and
revise
the
designation
based
on
three
years
of
data.

Area
EPA
Recommendation
State
Recommendation
Greenville­
Spartanburg­
Anderson,
SC
Full
Counties:
Anderson,
Greenville,
and
Spartanburg
as
unclassifiable
Full
Counties:
None
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
Region
4'
s
analysis
for
factor
1
looks
primarily
at
PM2.5,
SOx,
NOx,
VOC,
ammonia
emissions
and
weighted
emissions
data.
A
score
is
assigned
for
each
county
reflecting
the
speciation
profile
of
the
urban
increment
and
the
corresponding
weighted
emissions
of
the
MSA/
CMSA.
These
scores
add
to
100
for
the
MSA/
CMSA
counties
and
are
referred
to
as
weighted
emissions
scores.
Counties
adjacent
to
the
CSA
can
then
be
assigned
an
weighted
emissions
score
based
on
the
MSA/
CMSA
as
a
way
to
compare
the
emissions
from
those
counties
the
MSA/
CMSA
counties.

The
following
table
has
2001
PM2.5,
SO2,
NOx,
VOC
and
Ammonia
(
Amm)
emissions
in
tons,
and
weighted
emissions
scores
for
the
Greenville­
Spartanburg­
Anderson
Area
and
surrounding
counties.
The
Metropolitan
Statistical
Area
(
MSA)
counties
are
in
bold.

PM
SO2
NOx
VOC
Amm
Weighted
emissions
score
Cumulative
Weighted
emissions
score
SC
Spartanburg
3070
2351
19046
23897
821
29.7
29.7
SC
Greenville
2793
3369
15407
28867
861
27.4
57.1
SC
Anderson
2904
9903
11559
13621
1090
22.9
80.0
SC
Pickens
1428
1239
5153
7489
274
12.5
92.5
SC
Cherokee
834
1270
4121
3538
301
7.4
SC
York
2525
9714
12206
15064
1325
22.5
NC
Rutherford
2323
30023
12135
4847
254
17.0
NC
Cleveland
1258
1261
4975
6591
1240
11.4
SC
Newberry
979
353
3682
3813
1357
11.0
SC
Laurens
1027
597
5262
4846
414
10.2
NC
Henderson
1068
419
4088
7066
358
10.1
SC
Greenwood
1095
624
3680
4353
404
10.0
SC
Oconee
1058
298
3561
4867
1457
9.7
NC
Jackson
588
303
1344
1846
216
6.7
NC
Macon
555
307
1164
1798
262
6.3
SC
Union
549
849
2027
2047
197
5.8
GA
Habersham
651
103
1757
2201
3031
5.6
NC
Transylvania
449
3259
2824
3388
106
5.4
GA
Rabun
455
66
943
1606
341
5.1
SC
Abbeville
474
208
1384
1538
203
4.7
GA
Elbert
410
71
1357
1280
343
3.8
GA
Franklin
449
84
2068
1813
4128
3.7
GA
Stephens
406
277
1480
2075
976
3.5
GA
Hart
505
63
1321
1595
1516
3.2
6­
234
NC
Polk
266
105
1299
1149
256
3.1
Based
on
the
analysis
for
this
factor,
there
appears
to
be
emissions
in
Spartanburg
and
Anderson
counties
that
contribute
to
the
air
quality
in
Greenville
County.
The
emissions
in
Pickens
and
Cherokee
Counties
are
much
less
and
father
from
the
Greenville
monitor
with
potential
violation.

Factor
2:
Air
Quality
in
potentially
included
versus
excluded
areas
2001­
2003
Design
Value
SC
Spartanburg
13.7
SC
Greenville
14.5
SC
York
14.0
SC
Greenwood
13.1
SC
Oconee
10.6
NC
Jackson
13.0
All
of
the
monitors
in
this
area
with
three
years
of
complete
data
are
attaining
the
particulate
matter
standard.
However,
there
is
a
monitor
in
Greenville
County,
SC
with
less
than
three
years
of
data
that
indicates
a
potential
to
violate
the
stardard
of
15.0
µ
g/
m3.

Factor
3:
Population
Density
and
Degree
of
Urbanization
The
following
table
has
the
populations
for
the
counties
in
the
Greenville­
Spartanburg­
Anderson
area
and
adjacent
counties
with
significant
weighted
emissions
scores.

2002
Population
%
Population
of
MSA
Population
Density
(
pop./
mi2)

SC
Spartanburg
259,322
26.3
320
SC
Greenville
391,334
39.6
494
SC
Anderson
170,578
17.3
238
SC
Pickens
113,097
11.4
228
SC
Cherokee
53,524
5.4
136
SC
York
173,755
254
NC
Rutherford
63,287
112
Based
of
the
analysis
for
this
factor,
there
appears
to
be
significant
populations
to
indicate
a
contribution
by
Spartanburg
and
Anderson
counties.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
Total
commuters
in
Greenville
County:
185,461
Commuters
in
Greenville
County,
SC
who
work
in
Greenville
County:
24,270
(
87%)

Total
commuters
in
Spartanburg
County:
117,096
Commuters
in
Spartanburg
County,
SC,
who
work
in
Spartanburg
County:
95,496
(
82%)
6­
235
Commuters
from
Spartanburg
County,
SC
to
Greenville
County,
SC:
14,586
(
12%)

Total
commuters
in
Anderson
County:
76,098
Commuters
in
Anderson
County,
SC,
who
work
in
Anderson
County:
52,133
(
69%)
Commuters
from
Anderson
County,
SC
to
Greenville
County,
SC:
13,766
(
18%)

Total
commuters
in
Pickens
County:
52,130
Commuters
in
Pickens
County,
SC,
who
work
in
Pickens
County:
28,951
(
56%)
Commuters
from
Pickens
County,
SC
to
Greenville
County,
SC:
15,095
(
29%)

Total
commuters
in
Cherokee
County:
22,999
Commuters
in
Cherokee
County,
SC,
who
work
in
Cherokee
County:
16,052
(
70%)
Commuters
from
Cherokee
County,
SC
to
Greenville
County,
SC:
431
(
2%)

Greenville
County
has
the
largest
number
of
commuters
in
Greenville­
Spartanburg­
Anderson
MSA.
There
appears
to
be
significant
commuting
from
Spartanburg,
Anderson,
and
Pickens
Counties
to
indicate
a
contribution
to
the
monitor
in
Greenville
County.

The
following
table
has
the
vehicle
miles
traveled
(
thousands
of
miles)
for
the
counties
in
the
Greenville­
Spartanburg­
Anderson
area
and
some
adjacent
counties
with
significant
weighted
emissions
scores.
(
MSA
counties
are
in
bold).

2002
VMT
SC
Spartanburg
3,509
SC
Greenville
3,664
SC
Anderson
2,163
SC
Pickens
1,180
SC
Cherokee
754
SC
York
1,860
NC
Rutherford
606
Based
on
the
analysis
for
this
factor,
there
is
contribution
to
air
quality
in
Spartanburg,
Greenville,
Anderson,
Pickens,
and
York
counties.

Factor
5:
Expected
Growth
The
following
table
has
the
population
and
population
growth
figures
for
counties
in
the
Greenville­
Spartanburg­
Anderson
area
and
some
adjacent
counties
with
significant
weighted
emissions
scores.

2002
Population
Growth
'
90­`
00
%
Change
'
90­`
00
SC
Spartanburg
259,322
26,991
12
SC
Greenville
391,334
59,449
19
SC
Anderson
170,578
20,544
14
SC
Pickens
113,097
16,863
18
SC
Cherokee
53,524
8,031
18
6­
236
SC
York
173,755
33,117
25
NC
Rutherford
63,287
5,981
11
Based
on
the
analysis
for
this
factor,
there
appears
to
be
significant
growth
in
Greenville,
Spartanburg,
Anderson,
Pickens
and
York
counties
indicating
a
potential
contribution
to
the
air
quality
in
Greenville
County.

Factor
6:
Meteorology
No
meteorological
information
was
provided
by
South
Carolina.
This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
7:
Geography/
topography
The
counties
of
Greenville,
Spartanburg,
Pickens,
and
York
are
located
on
the
northern
border
of
South
Carolina,
which
borders
the
state
of
North
Carolina.

No
geographical
or
topographical
data
was
provided
by
South
Carolina.

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
8:
Jurisdictional
boundaries
This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
9:
Level
of
control
of
emission
sources
South
Carolina
is
subject
to
the
NOx
SIP
Call
and
the
Greenville­
Spartanburg­
Anderson
MSA
is
participating
in
Early
Action
Compacts.

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
unclassifiable
for
the
Greenville­
Spartanburg,
SC
area:
Anderson,
Greenville,
and
Spartanburg.

6.4.6
EPA
9­
Factor
Analyses
for
Tennessee
for
the
Designation
of
Nonattainment
Areas
for
PM2.5
6.4.6.1
Chattanooga
Area
The
Chattanooga
MSA
contains
the
following
Tennessee
counties:
Marion
and
Hamilton;
and
the
following
Georgia
Counties:
Dade,
Walker,
and
Catoosa.
Based
on
air
quality
data
for
2001­
2003,
the
monitor
with
the
highest
design
value
in
Hamilton
County
has
a
design
value
of
16.1
and
the
monitor
in
Walker
County
has
a
design
value
of
15.6.
No
other
counties
in
the
MSA
contain
ambient
air
monitors.
The
State
of
Tennessee
recommended
as
nonattainment
the
county
6­
237
of
Hamilton
and
the
State
of
Georgia
recommended
as
nonattainment
the
county
of
Walker.
The
States
have
recommended
that
all
other
counties
be
designated
attainment.
The
State
of
Tennessee
submitted
some
justification
for
this
recommendation,
however,
they
indicated
that
the
detailed
emission
information
would
be
provided
at
a
later
date.
EPA
is
modifying
the
State
of
Tennessee's
recommendation
and
will
review
the
additional
information
during
the
120
day
period
following
the
notification
letter.

EPA
has
received
some
information
from
the
State
of
Tennessee
that
Marion
(
MSA)
County
should
be
designated
attainment
for
the
PM2.5
standard
and
no
justification
from
the
State
of
Georgia
indicating
that
any
other
counties
should
be
included
or
excluded
from
the
Chattanooga
PM2.5
nonattainment
area.
Adjacent
counties
with
significant
emissions
include
McMinn
and
Roane
Counties
which
are
attached
to
the
Knoxville
nonattainment
area
and
Floyd
County
which
is
a
separate
nonattainment
area.

Additionally
we
have
included
in
our
recommended
nonattainment
area
Jackson
County,
AL,
that
is
adjacent
to
the
Chattanooga
MSA,
that
is
generally
rural
in
character,
and
that
contains
an
identifiable
large
emitting
facility
or
facilities
(
e.
g.,
power
plants)
which
we
believe
contribute
to
the
nearby
nonattainment
problem.
We
have
included
this
county
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
county,
including
such
large
facilities,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invite
you
to
submit
to
us
a
recommendation
as
to
what
portion
of
this
adjacent
county,
encompassing
the
large
facility
or
facilities,
should
be
designated
nonattainment.
Therefore
EPA
is
modifying
the
States'
recommendations
to
include
all
of
the
counties
in
the
MSA
and
the
adjacent
county
of
Jackson,
Alabama.

Area
EPA
Recommendation
States
Recommendations
Chattanooga
Full
counties:
Marion,
Hamilton,
TN;
Dade,
Walker,
Catoosa,
GA;
Jackson,
AL
Full
counties:
Hamilton
and
Walker
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
contains
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
and
weighted
emissions
scores
for
the
counties
in
the
Chattanooga
MSA
and
some
adjacent
counties.
(
MSA
counties
are
in
bold.)
6­
238
County
PM
SOx
NOx
VOC
Amm
Weighted
Emissions
Score
Cumulative
Weighted
Emissions
Score
Hamilton
1,498
5,300
20,048
27,150
1,022
49.5
49.5
Walker
856
632
2,798
4,516
958
17.9
67.4
Marion
679
477
3,156
2,640
501
14.1
81.5
Catoosa
617
167
3,085
3,601
680
11.9
93.4
Dade
302
107
2,415
1,574
285
6.5
99.9
Roane
4967
92331
30865
4300
285
296.9
Jackson,
AL
4389
44333
31502
4742
1494
176.1
Floyd,
GA
10057
31821
22736
7139
976
154.0
McMinn
3348
10216
10829
5546
1268
73.3
Whitfield,
GA
2732
1747
7283
7386
991
54.2
Rhea
1405
302
2625
3643
149
31.2
Loudon
804
4035
5899
5338
360
24.3
DeKalb,
AL
1193
741
4776
5867
5765
21.3
Bradley
1233
419
4230
7551
1916
21.1
Warren
1164
1189
1869
3675
446
20.7
Monroe
743
154
2387
3420
554
16.4
Gordon,
GA
872
200
3645
4019
2630
15.8
Fannin,
GA
614
65
887
1266
283
14.2
Franklin
644
482
2100
2929
1512
13.4
Chattooga,
GA
450
1228
1834
1634
197
11.7
Murray,
GA
576
130
2067
1700
910
11.4
Polk
295
2066
900
949
553
11.3
Cherokee,
NC
428
143
921
1753
111
10.6
Grundy
202
164
1000
1150
1170
4.8
Bledsoe
203
31
475
528
335
4.5
Meigs
198
112
885
871
118
4.3
Sequatchie
140
22
304
591
173
3.4
Van
Buren
118
178
291
320
74
3.3
Based
on
the
analysis
for
this
factor
there
appears
to
be
emissions
in
all
MSA
counties
and
the
adjacent
county
of
Jackson,
AL,
which
show
a
potential
to
contribute.
Other
adjacent
counties
with
large
emissions
(
McMinn
and
Roane,
TN
and
Floyd,
GA)
are
included
in
other
nonattainment
areas.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
The
following
table
contains
the
2001­
2003
PM2.5
Design
Values
for
all
Chattanooga
MSA
Counties
and
adjacent
counties.
(
MSA
counties
are
in
bold.)

County
2001­
2003
design
value
Hamilton
16.1
Walker
15.6
Roane
14.2
Floyd,
GA
15.7
6­
239
McMinn
14.6
Loudon
15.4
*
DeKalb,
AL
14.7
*
Incomplete
data
that
is
not
sufficient
to
determine
attainment/
nonattainment.
Data
substitution
does
not
apply.

Based
on
this
factor,
Hamilton
County,
TN
and
Walker
and
Floyd
Counties
in
GA
are
violating
the
PM
2.5
standard.
Catoosa
County,
GA
is
located
between
violating
monitors
in
Hamilton
and
Walker
Counties.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
contains
the
populations
for
the
counties
in
the
Chattanooga
MSA
and
some
adjacent
counties.
Urban
population
figures
were
not
available.
(
MSA
counties
are
in
bold.)
County
2002
Population
Percent
of
MSA
Population
(
2002)
2002
Population
Density
(
people/
mile^
2)
Hamilton
309,321
65.7
570
Walker
61,949
13.2
139
Marion
27,654
5.9
55
Catoosa
56,341
12.0
348
Dade
15,615
3.3
90
Roane
52,316
145
Jackson,
AL
54,035
50
Floyd,
GA
92,606
181
McMinn
50,051
116
Whitfield,
GA
87,037
300
Based
on
the
analysis
for
this
factor,
there
appears
to
be
population
sufficient
to
indicate
a
contribution
by
the
following
MSA
counties:
Hamilton,
Walker,
and
Catoosa.
The
five
adjacent
counties
also
have
population
with
a
potential
to
contribute.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
Hamilton
has
a
working
population
of
146,
824
 
Commuters
who
remain
in
Hamilton:
133,644
(
91%)

Marion
has
a
working
population
11766.
 
Commuters
who
remain
in
Marion:
5596
(
48%)
 
Commuters
from
Marion
to
Hamilton:
4271
Dade
has
a
working
population
of
6983.
 
Commuters
who
remain
in
Dade:
2363
 
Commuters
from
Dade
to
Hamilton:
3091
(
44%)
 
Commuters
from
Dade
to
Walker:
747
6­
240
Catoosa
has
a
working
population
of
26710.
 
Commuters
who
remain
in
Catoosa:
7167
 
Commuters
from
Catoosa
to
Hamilton:
12320
(
46%)
 
Commuters
from
Catoosa
to
Walker:
1937
Walker
has
a
working
population
of
27223.
 
Commuters
who
remain
in
Walker:
11244
(
41%)
 
Commuters
from
Walker
to
Hamilton:
9098
Whitfield,
GA
has
a
working
population
of
38,909
 
Commuters
who
remain
in
Whitfield:
33,796
(
87%)
 
Remaining
commuters
do
not
commute
to
the
Chattanooga
MSA
DeKalb,
AL
has
a
working
population
of
7798
 
Commuters
who
remain
in
DeKalb:
5179
(
66%)
 
Remaining
commuters
do
not
commute
to
the
Chattanooga
MSA
The
following
table
contains
the
vehicle
miles
traveled
(
thousand
miles)
for
the
counties
in
the
Chattanooga
MSA
and
some
adjacent
counties
with
significant
weighted
emissions
scores.
(
MSA
counties
are
in
bold.)

County
2002
VMT
(
thousand
miles/
year)
Hamilton
3,743
Walker
742
Marion
654
Catoosa
810
Dade
512
Roane
784
Jackson,
AL
786
Floyd,
GA
948
McMinn
787
Whitfield,
GA
1423
Based
on
the
analysis
for
this
factor
the
VMT
for
all
MSA
counties
indicate
a
potential
to
contribute.
Although
Whitfield
County
has
a
relatively
high
VMT,
none
of
the
commuters
go
to
the
Chattanooga
MSA.

Factor
5:
Population
Growth
6­
241
The
following
table
has
the
population
and
population
growth
figures
for
the
Chattanooga
MSA
and
some
adjacent
counties
with
significant
weighted
emissions
scores.
(
MSA
counties
are
in
bold.)

County
2002
Population
Growth
(
90­
00)
%
Growth
(
90­
00)
Hamilton
309,321
22360
8
Walker
61,949
2713
5
Marion
27,654
2916
12
Catoosa
56,341
10818
25
Dade
15,615
2007
15
Roane
52,316
4683
10
Jackson,
AL
54,035
6130
13
Floyd,
GA
92,606
9314
11
McMinn
50,051
6632
16
Whitfield,
GA
87,037
11063
15
Based
on
the
analysis
for
this
factor,
there
appears
to
be
significant
growth
on
a
percentage
basis
in
Catoosa
County
that
indicates
a
contribution
to
the
air
quality
in
the
Chattanooga
MSA.

Factor
6:
Meteorology
This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
7:
Geography/
topography
The
Chattanooga
area
does
not
have
any
geographical
or
topographical
boundaries
limiting
its
airshed.

Factor
8:
Jurisdictional
boundaries
Hamilton
and
Meigs
Counties,
TN
and
Catoosa
County,
GA
were
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004.

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
9:
Level
of
control
of
emission
sources
Sources
in
the
Chattanooga
area
are
subject
to
Prevention
of
Significant
Deterioration
(
PSD)
requirements,
Control
Technology
Guidelines
Reasonable
Available
Control
Technology
(
CTG
RACT)
­
(
Hamilton
County
only),
Maximum
Achievable
Control
Technology
(
MACT)
for
Hazardous
Air
Pollutants
(
HAP),
New
Source
Performance
Standards
(
NSPS),
and
the
NOx
SIP
call.

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
6­
242
EPA's
initial
nonattainment
recommendation
on
June
29,
2004
included
Marion
County,
TN
as
part
of
the
Chattanooga
nonattainment
area.
Upon
further
analysis,
including
the
review
of
additional
material
submitted
by
the
state,
EPA
is
revising
its
recommendation
and
designating
Marion
County
as
attainment/
unclassifiable.

Marion
County,
TN
Marion
County
has
a
small
population
(
27,654)
and
population
density
(
55
people/
mile2).
There
are
no
large
point
sources
and
the
County
only
contributes
17.2
percent
of
the
total
MSA
PM2.5
emissions
(
679
tpy),
7.1
percent
of
the
total
SO2
emissions
(
477
tpy),
and
10.0
percent
of
the
total
NOx
emissions
(
3156
tpy).
In
addition,
the
topography
analysis
indicates
that
the
Lookout
Mountain
Ridge
(
2100
feet)
separates
the
Marion
County
emissions
from
the
violating
monitors.
The
County
is
located
to
the
west
of
the
ridge
while
the
violating
monitors
reside
to
the
east
of
the
ridge.

McMinn
County,
TN
See
the
McMinn
County
Section
in
the
Knoxville,
TN
TSD.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
nonattainment
for
the
Chattanooga,
TN­
GA
area:
Hamilton.

6.4.6.2
Knoxville
Area
The
Knoxville,
TN
MSA
contains
the
counties
of
Anderson,
Blount,
Knox,
Loudon,
Sevier
and
Union.
Based
on
air
quality
data
for
2001­
2003
the
following
MSA
counties
contain
PM2.5
ambient
air
monitors
(
Design
values
are
included
in
parenthesis):
Knox
County
(
16.8),
Blount
County
(
14.4),
and
Loudon
County
(
15.4).
Two
adjacent
Tennessee
counties
also
contain
PM2.5
monitors:
Roane
County
(
14.2),
and
McMinn
County
(
14.6).

In
a
February
12,
2004
letter,
the
State
recommended
that
Knox,
Roane,
and
McMinn
Counties
be
designated
nonattainment
based
on
2000­
2002
monitoring
data.
The
State
revised
its
recommendation
on
May
7,
2004,
to
recommend
that
McMinn
and
Roane
Counties
be
designated
attainment
due
to
2001­
2003
data.
Therefore,
the
State's
current
recommendation
for
the
Knoxville
MSA
PM2.5
nonattainment
area
only
includes
Knox
County
and
recommends
that
all
other
MSA
and
adjacent
counties
be
designated
attainment.
The
State
submitted
some
justification
for
this
recommendation,
however,
they
indicated
that
the
detailed
emission
information
would
be
provided
at
a
later
date.
Union
County
has
very
small
amounts
of
PM2.5
and
precursor
emissions,
indicating
no
contribution.
Therefore,
EPA
agrees
that
Union
County
should
be
designated
attainment/
unclassifiable.
Roane
and
McMinn,
counties
adjacent
to
the
MSA,
currently
contain
attaining
ambient
air
monitors,
however,
Roane
and
McMinn
counties
have
significant
SO2
and
NOx
emissions
which
contribute
to
the
violations.
EPA
is
modifying
the
State's
recommendation
and
will
review
the
additional
information
during
the
120
day
period
following
the
notification
letter.
6­
243
We
have
included
in
our
recommended
nonattainment
area
Roane
County
that
is
adjacent
to
the
Knoxville
MSA
with
a
violating
monitor,
that
is
generally
rural
in
character,
and
that
contains
an
identifiable
large
emitting
facility
or
facilities
(
e.
g.,
power
plants)
which
we
believe
contributes
to
the
nearby
nonattainment
problem.
We
have
included
this
county
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
the
county,
including
such
large
facilities,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invite
you
to
submit
to
us
a
recommendation
as
to
what
portion
of
this
adjacent
county,
encompassing
the
large
facility
or
facilities,
should
be
designated
nonattainment.

Based
on
EPA's
analysis
of
the
available
information,
EPA
is
modifying
the
recommended
nonattainment
area
to
include
all
of
the
MSA
counties,
except
Union,
and
the
adjacent
counties
of
Roane
and
McMinn.

Area
EPA
Recommendation
State
Recommendation
Knoxville,
TN
Full
counties:
Anderson,
Blount,
Knox,
Loudon,
Sevier,
Roane,
and
McMinn
Full
counties:
Knox
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
following
table
contains
the
2001
PM2.5,
SOx,
NOx,
VOC,
and
ammonia
emissions
in
tons
per
year
and
weighted
emissions
scores
for
the
counties
in
the
Knoxville
MSA
and
some
adjacent
counties.
(
MSA
counties
are
in
bold.)

County
PM
SOx
NOx
VOC
Amm
Weighted
Emissions
Score
Cumulative
Weighted
Emissions
Score
6­
244
Knox
1995
3005
23648
29966
1220
28.6
28.6
Anderson
2891
45986
23020
5328
265
27.5
56.1
Blount
3535
2999
5282
8250
606
22.4
78.5
Sevier
711
433
2838
4756
472
9.4
87.9
Loudon
804
4035
5899
5338
360
8.8
96.7
Union
325
156
1057
1067
184
3.2
99.9
Roane
4967
92,331
30865
4300
285
38.0
McMinn
3348
10216
10829
5546
1268
27.0
Rhea
1405
302
2625
3643
149
18.1
Haywood,
NC
1218
8701
8669
4923
547
14.8
Jefferson
1407
183
3220
4194
662
14.4
Scott
1113
122
1338
1813
294
11.1
Monroe
743
154
2387
3420
554
9.6
Cumberland
682
181
3682
3989
532
8.6
Whitley,
KY
521
675
3646
3017
171
8.1
Campbell
527
268
3323
3323
161
7.5
Claiborne
509
165
1420
2554
475
6.0
McCreary,
KY
346
188
1414
904
52
5.8
Cocke
400
247
2507
2361
357
5.5
Swain,
NC
12.93
28
141
567
1210
199
5.3
Morgan
288
98
1252
929
222
4.3
Graham,
NC
209
70
377
981
47
3.2
Grainger
288
80
893
1647
287
3.2
Meigs
198
112
885
871
118
2.4
Based
on
the
analysis
of
emissions,
there
appears
to
be
very
small
emissions
in
Union
County
for
all
the
relevant
pollutants.
The
other
counties
in
the
MSA
and
the
counties
of
McMinn
and
Roane
have
significant
emissions
of
some
or
all
of
the
relevant
pollutants,
indicating
contribution
to
the
violations.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
The
following
table
contains
the
2001­
2003
PM2.5
Design
Values
for
all
Knoxville
MSA
Counties
and
adjacent
counties.
(
MSA
counties
are
in
bold.)
6­
245
County
2001­
2003
design
value
Knox
16.8
Blount
14.4
Loudon
15.4
*

Roane
14.2
McMinn
14.6
Haywood,
NC
13.6
Swain,
NC
12.9
*
Incomplete
data
that
is
not
sufficient
to
determine
attainment/
nonattainment.
Data
substitution
does
not
apply.

There
are
two
monitors
in
the
MSA
that
are
violating
and
one
MSA
monitor
(
Blount
County)
that
is
attaining.
The
four
monitors
in
adjacent
counties
are
attaining.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
contains
the
populations
for
the
counties
in
the
Knoxville
MSA
and
some
adjacent
counties
with
significant
weighted
emissions
scores.
(
MSA
counties
are
in
bold.)

County
2002
Population
Percent
of
MSA
Population
(
2002)
Population
Density
(
People/
mile2)
Knox
389327
55.3
765
Anderson
71627
10.2
212
Blount
109849
15.6
197
Sevier
74456
10.6
126
Loudon
40631
5.8
177
Union
18541
2.6
83
Roane
52316
145
McMinn
50051
116
6­
246
Based
on
the
analysis
for
this
factor,
there
appears
to
be
population
sufficient
to
indicate
a
contribution
by
Knox,
Anderson,
Blount,
and
Sevier
Counties
and
the
adjacent
counties
of
Roane
and
McMinn.
Union
County
has
very
low
population
and
population
density
supporting
an
attainment/
unclassifiable
designation.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information
­
Following
is
an
analysis
of
the
commuting
in
the
Knoxville
MSA.
Knox
County
has
the
most
commuters
of
any
of
the
MSA
counties.
As
described
below,
86
%
of
the
Knox
County
commuters
remain
in
Knox
County,
contributing
79
%
of
the
commuting
in
Knox
County.
People
from
Blount
and
Anderson
Counties
commute
to
Knox
County
contributing
approximately
7%
and
4
%,
respectively,
with
the
remaining
MSA
counties
contributing
3
%
or
less.
Union
County
has
the
smallest
number
of
commuters
and
the
least
contribution
to
the
Knox
County
monitor.

Knox
County,
the
core
MSA
county,
has
a
total
of
184,824
commuters.
­
Commuters
who
remain
in
Knox
County:
158,292
Anderson
County,
an
MSA
county
has
a
total
of
30,688
commuters
­
Commuters
that
remain
in
Anderson
County:
20,029
­
Commuters
from
Anderson
County
to
Knox
County:
8,115
Blount
County,
an
MSA
county,
has
a
total
of
49,250
commuters
­
Commuters
that
remain
in
Blount
County:
31,298
­
Commuters
from
Blount
County
to
Knox
County:
13,611
Loudon
County,
an
MSA
county,
has
a
total
of
17,671
commuters.
­
Commuters
who
remain
in
Loudon
County:
8,951
­
Commuters
from
Loudon
County
to
Knox
County:
4,580
Sevier
County,
an
MSA
county,
has
a
total
of
34,389
commuters
­
Commuters
who
remain
in
Sevier
County:
25,388
­
Commuters
from
Sevier
County
to
Knox
County:
6,522
Union
County,
an
MSA
county,
has
a
total
of
7,302
commuters
­
Commuters
who
remain
in
Union
County:
2,573
­
Commuters
from
Union
County
to
Knox
County:
3,873
The
following
table
contains
the
vehicle
miles
traveled
(
thousands
of
miles)
for
the
counties
in
the
Knoxville
MSA
and
some
adjacent
counties.
6­
247
County
2000
VMT
(
thousand
miles/
year)

Knox
5135
Anderson
875
Blount
1205
Sevier
724
Loudon
728
Union
126
Roane
784
McMinn
787
Knox
and
Blount
counties
contain
58
%
and
14
%
of
the
VMT
of
the
MSA
VMT,
respectively.
The
remaining
counties
contribute
less
than
10
%
each
of
the
MSA
VMT
with
Union
County
contributing
1
%.
The
small
contribution
from
Union
County
supports
an
attainment/
unclassifiable
designation.
The
adjacent
counties
each
contribute
an
amount
equivalent
to
9
%
of
the
total
MSA
VMT.
(
The
VMT
from
the
adjacent
counties
was
not
used
to
calculate
the
total
MSA
VMT.)

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
the
Knoxville
MSA
counties
and
some
adjacent
counties
with
significant
weighted
emissions
scores.

County
2002
Population
Growth
(
90­
00)
%
Change
(
90­
00)
Knox
389327
46283
14
Anderson
71627
3080
5
Blount
109849
19854
23
Sevier
74456
20127
39
Loudon
40631
7831
25
Union
18541
4114
30
Roane
52316
4683
10
McMinn
50051
6632
16
The
population
growth
has
been
relatively
high
for
all
of
the
MSA
counties
on
a
percentage
basis,
except
Anderson,
indicating
potential
contribution
to
the
particulate
matter
levels
in
the
MSA.
Anderson
County
contributed
only
3
%
of
the
MSA
growth.
Although
the
percent
growth
in
Union
County
was
30
%,
its
contribution
to
the
MSA
growth
was
only
4
%.
McMinn
and
Roane
Counties
(
adjacent)
have
a
percent
growth
of
16
%
and
10
%,
respectively.
6­
248
Factor
6:
Meteorology
This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
7:
Geography/
topography
This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
8:
Jurisdictional
boundaries
Knox,
Anderson,
Blount,
Jefferson,
Loudon,
Sevier
Counties
and
a
portion
of
Cocke
County
were
designated
nonattainment
for
the
8­
hour
ozone
standard.

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
9:
Level
of
control
of
emission
sources
Anderson,
Blount,
Jefferson,
Loudon,
Sevier­
Subject
to
Prevention
of
Significant
Deterioration
(
PSD)
requirements,
Control
Technology
Guidelines
Reasonable
Available
Control
Technology
(
CTG
RACT,
Maximum
Achievable
Control
Technology
(
MACT)
for
Hazardous
Air
Pollutants
(
HAP),
New
Source
Performance
Standards
(
NSPS)

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
EPA's
initial
nonattainment
recommendation
on
June
29,
2004
included
McMinn,
Roane,
and
Sevier
Counties,
TN
as
part
of
the
Chattanooga
nonattainment
area.
Upon
further
analysis,
including
the
review
of
additional
material
submitted
by
the
state,
EPA
is
revising
its
recommendation
and
designating
McMinn
County
as
unclassifiable
and
Sevier
County
as
attainment/
unclassifiable.
EPA
is
designating
a
portion
of
Roane
County
that
encompasses
the
TVA
Kingston
power
plant
as
nonattainment.
The
remainder
of
Roane
County
will
be
designated
as
attainment/
unclassifiable.

McMinn
County,
TN
The
McMinn
County
emissions,
represented
in
the
table
below,
indicate
that
the
county
does
not
contribute
to
the
violations
in
Knoxville.
The
county
is
located
outside
of
the
Metropolitan
Statistical
Area,
has
a
small
population
(
50,051),
and
low
population
density
(
116
people/
mile2).
McMinn
County
and
the
State
of
Tennessee
submitted
additional
information,
correcting
the
emissions
for
Bowater
Newsprint
and
for
McMinn
County.
The
corrected
emissions
data
for
McMinn
County
emissions
are
represented
in
tons
per
year
in
the
following
table:

County
PM
2.5
SO2
NOx
VOC
Ammonia
McMinn
1479
5775
10701
5004
1250
6­
249
Based
on
incomplete
monitoring
data
and
data
substitution
not
being
a
viable
alternative,
EPA
has
changed
its
June
2004
recommendation
of
nonattainment
and
is
designating
McMinn
County
unclassifiable.
The
county
had
monitoring
data
for
2000­
2002
that
was
violating
and
has
incomplete
data
for
2001­
2003.
Applying
the
data
substitution
policy
will
not
confirm
attainment.

Sevier
County,
TN
Sevier
County
has
low
emissions.
The
data
indicate
that
the
county
only
contributes
7.0
percent
of
the
total
MSA
PM2.5
emissions
(
711
tpy),
0.8
percent
of
the
total
SO2
emissions
(
433
tpy),
and
4.6
percent
of
the
total
NOx
emissions
(
2838
tpy).
The
County
is
located
within
the
Metropolitan
Statistical
Area,
however
it
has
a
small
population
(
74,456),
10.6
percent
of
the
MSA
population.
Additionally,
the
County
has
a
population
density
of
126
people/
mile2
which
is
low
compared
to
Knox
County
that
has
a
population
density
of
765
people/
mile2.

Roane
County,
TN
In
the
June
29,
2004,
letters
from
EPA
to
the
States
responding
to
their
designation
recommendations,
EPA
recommended
the
designation
of
a
number
of
counties
primarily
because
of
high
pollutant
emissions
from
power
plants.
Most
of
these
plants
were
located
in
nearby
counties
adjacent
to
the
metropolitan
area
(
as
defined
either
by
the
1999
or
2003
OMB
metropolitan
area
definitions).
EPA
suggested
that
a
State
could
provide
a
partial
county
boundary
that
would
encompass
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.
Roane
County,
Tennessee
is
one
of
those
counties.
Roane
County
has
low
population
(
52,316
compared
to
389,327
in
Knox
County,
the
predominant
county
in
the
Knoxville
MSA),
low
population
density
(
145
people
per
square
mile
compared
to
765
in
Knox
County),
low
VMT
(
784,000
miles
compared
to
5,135,000
in
Knox
County
),
and
the
only
large
point
source
is
the
Kingston
Fossil
Plant.
Additionally,
Roane
County
has
a
monitor
that
is
indicating
attainment
with
a
design
value
of
14.2
(
2001­
2003).

A
number
of
states
responded
to
this
suggestion
with
a
series
of
connected
townships
or
other
unique
boundaries.
Some
states
also
suggested
an
alternative
approach
in
which
partial
county
areas
for
power
plants
in
some
cases
could
be
small
"
free­
standing"
boundaries
that
are
considered
part
of
the
nearby
nonattainment
area.
In
this
way,
it
would
not
be
necessary
to
include
additional
townships
or
other
minor
civil
divisions
comprising
an
odd­
shaped
"
land
connector"
extending
from
the
main
part
of
the
nonattainment
area
to
the
power
plant.
The
State
of
Tennessee
subsequently
submitted
a
partial
county
recommendation
that
included
the
Kingston
Fossil
Plant.

After
considering
these
comments
from
the
States,
EPA
agrees
that
such
an
approach
is
preferable
in
cases
where
a
partial
county
nonattainment
boundary
has
not
already
been
established
for
that
source
(
e.
g.
partial
county
boundaries
recently
established
for
8­
hour
ozone
nonattainment
areas).
For
purposes
of
consistency,
EPA
has
decided
that
free­
standing
portions
of
nonattainment
areas
should
be
based
on
a
pre­
existing
boundary
for
a
minor
civil
division
(
such
as
a
township
or
tax
district)
or
other
boundary
defined
for
governmental
use
(
such
as
a
census
block
group
or
census
tract).
Accordingly,
this
kind
of
partial
county
boundary
should
not
6­
250
be
defined
simply
as
the
boundary
of
the
facility.
Therefore,
EPA
is
designating
the
census
block
group
identifier
(
StateFIPs­
CoFIPs­
Tract#­
Block
Group#)
47­
145­
0307­
2
portion
of
Roane
County
as
part
of
the
Knoxville
nonattainment
area.

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
counties
as
nonattainment
for
the
Knoxville,
TN
area:
Anderson,
Blount,
Knox,
Loudon,
and
Roane
(
Partial).

Based
on
the
analysis
EPA
conducted
as
described
in
the
June
29,
2004
letter,
and
review
of
additional
information
received
after
our
initial
analysis,
EPA
is
designating
the
following
county
as
unclassifiable
for
the
McMinn
County,
TN
area:
McMinn.
