6­
347
6.8
Region
8
Nonattainment
Areas
6.8.1
EPA
9­
Factor
Analyses
for
Montana
for
the
Designation
of
PM2.5
Nonattainment
Areas
Based
on
air
quality
data
for
2001­
2003,
the
PM2.5
monitor
at
the
Libby
Courthouse
Annex
is
violating
the
annual
PM2.5
standard.
EPA
utilized
the
9
factors
identified
in
the
April
1,
2003
"
Designations
for
the
Fine
Particle
National
Ambient
Air
Quality
Standards"
guidance
to
evaluate
whether
the
surrounding
rural
counties
around
Lincoln,
MT
should
be
included
as
part
of
the
nonattainment
area.
However,
due
to
the
topographical
features
and
local
meteorology
within
Lincoln
County
and
more
specifically
around
the
Libby,
Montana
vicinity,
several
of
the
9
factors
were
not
significant
for
this
particular
nonattainment
area
when
looking
at
adjacent
counties
to
Lincoln
County,
MT.
Lincoln
County
is
considered
a
rural
county,
according
to
EPA's
April
1,
2003
"
Designations
for
the
Fine
Particle
National
Ambient
Air
Quality
Standards"
which
defines
a
rural
area
as
counties
or
areas
not
included
in
or
adjacent
to
urban
areas
(
metropolitan
statistical
areas
(
MSA).
The
adjacent
areas
to
Lincoln
County
are
the
Canadian
border
to
the
North,
Boundary
and
Bonner
County,
Idaho
to
the
West,
Sanders
County,
MT
to
the
South,
and
Flathead
County,
MT
to
the
East.
Lincoln
County
contains
a
violating
monitor
located
in
the
town
of
Libby.
The
Lincoln
County
PM2.5
nonattainment
issue
is
unique
in
that
the
area
of
impact
is
localized
within
and
around
the
vicinity
of
the
town
of
Libby
due
to
topographical
features
and
meteorology
in
the
area
impacted
by
emissions.

Montana's
recommendation
identifying
the
PM2.5
nonattainment
area
included
part
of
Lincoln
County
(
the
town
of
Libby
and
vicinity).
EPA
initially
responded
to
Montana's
recommendation
stating
that
EPA
agreed
with
Montana's
recommended
nonattainment
designation
for
Lincoln
County
but
that
EPA
intended
to
modify
Montana's
recommended
boundary
for
the
nonattainment
area
to
cover
all
of
Lincoln
County.
However,
based
upon
supplemental
information
provided
by
Montana,
EPA
is
identifying
the
boundary
of
this
PM2.5
nonattainment
area
to
include
a
part
of
Lincoln
County
as
described
further
below.

The
following
is
a
brief
summary
of
the
9
factor
criteria
for
the
Lincoln
County,
MT
area
and
surrounding
counties.
These
analyses
were
based
on
existing
available
data.
The
counties
recommended
as
nonattainment
are
in
bold.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
For
this
factor,
EPA
looked
at
SO2,
NOx,
carbon
and
crustal
PM2.5
emissions.
A
weighted
emissions
score
was
applied
to
Lincoln
County
and
the
adjacent
counties
reflecting
the
speciation
profile
of
Lincoln
County
versus
the
adjacent
counties.
Counties
adjacent
to
the
Lincoln
County
were
assigned
an
emission
score
as
a
way
to
compare
the
emissions
from
those
counties
against
Lincoln
County
emissions.
The
following
table
has
the
SO2,
NOx,
carbon,
and
crustal
PM2.5
emissions
and
composite
emission
scores.
6­
348
This
information
is
from
the
2001
NEI.
(
The
recommended
nonattainment
area
is
in
bold.)

County
SO2
(
tons)
NOx
(
tons)
Carbon
(
tons)
Crustal
PM2.5
(
tons)
Composite
Emission
Score
Lincoln
257
3286
862
275
100
Flathead
1919
6651
1788
1904
257
Bonner
313
5324
1411
730
159.5
Boundary
114
1886
1431
760
134.4
Sanders
328
4543
605
151
88.2
Since
Lincoln
County
is
considered
to
be
a
rural
county
as
defined
in
EPA's
April
1,
2003
PM2.5
Designations
Guidance
and
not
a
metropolitan
statistical
area,
this
factor
did
not
play
a
significant
role
in
the
decision
making
process.
Also,
due
to
the
topographical
features
and
meteorology
in
Lincoln
County
(
see
factors
6
and
7
below)
and
more
specifically
surrounding
Libby,
MT
where
the
PM2.5
problem
is,
EPA
feels
the
surrounding
counties
emissions
are
not
impacting
the
PM2.5
monitor
located
at
the
Libby
Courthouse
Annex.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
County
PM2.5
2001­
2003
design
value
Lincoln
16.2*

Flathead
9.1
Bonner
8.0
Boundary
8.2
Sanders
6.2
*
Lincoln
County
PM2.5
monitor
is
located
at
the
Libby
Courthouse
Annex,
Libby,
MT.

All
adjacent
counties
to
Lincoln,
MT
are
attaining
the
PM2.5
standard.
This
factor
played
a
significant
role
in
the
decision
making
process.
6­
349
Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
following
table
has
the
population
and
population
density
for
Lincoln
County
and
the
adjacent
counties.

County
2002
Population
2002
Population
Density
(
pop.
per
square
mile)
Lincoln
18,665*
5**

Flathead
77,240
15
Bonner
38,205
22
Boundary
10,085
8
Sanders
10,367
4
*
Town
of
Libby,
MT
population:
2,626;
**
Town
of
Libby,
MT
population
density:
2,020
persons/
square
mile
The
town
of
Libby,
where
the
PM2.5
problem
is
located
has
a
much
higher
population
density
than
the
remainder
of
Lincoln
County
or
any
of
the
surrounding
counties.
Also,
due
to
the
commuting
patterns,
topographical
features
and
meteorology
in
Lincoln
County
(
see
factors
4,
6
and
7
below),
EPA
feels
the
adjacent
county
populations
do
not
impact
the
PM2.5
monitor
located
at
the
Libby
Courthouse
Annex.
This
factor
played
a
significant
role
in
the
decision
making
process.

Factor
4:
Traffic
and
commuting
patterns
Commuting
Information:

Lincoln
County,
the
design
value
county,
has
a
total
of
6,721
commuters.
­
Commuters
who
remain
in
Lincoln
County:
6,177
Flathead
County,
an
adjacent
county,
has
a
total
of
34,035
commuters.
­
Commuters
from
Flathead
County
to
Lincoln
County:
85
­
Commuters
that
remain
in
Flathead
County:
32,956
Bonner
County,
an
adjacent
county,
has
a
total
of
15,570
commuters.
­
Commuters
from
Bonner
County
to
Lincoln
County:
0
­
Commuters
that
remain
in
Bonner
County:
12,968
Boundary
County,
an
adjacent
county,
has
a
total
of
3,830
commuters.
­
Commuters
from
Boundary
County
to
Lincoln
County:
10
­
Commuters
that
remain
in
Boundary
County:
3,310
Sanders
County,
an
adjacent
county,
has
a
total
of
3,903
commuters.
­
Commuters
from
Sanders
County
to
Lincoln
County:
12
6­
350
­
Commuters
that
remain
in
Sanders
County:
3,337
The
following
table
has
the
vehicle
miles
traveled
(
thousand
miles)
for
Lincoln
County
and
the
adjacent
counties.

County
VMT
Lincoln
231
Flathead
756
Bonner
442
Boundary
139
Sanders
93
Based
on
the
analysis
for
this
factor
there
are
no
adjacent
counties
impacting
the
PM2.5
monitor
located
at
the
Libby
Courthouse
Annex.
This
factor
played
a
significant
role
in
the
decision
making
process.

Factor
5:
Expected
growth
The
following
table
has
the
population
and
population
growth
figures
for
Lincoln
County
and
the
adjacent
counties.
(
Nonattainment
counties
are
in
bold.)

County
2002
Population
Population
Density
Area
(
sq.
mile)
Growth
(
90­
00)
%
Change
(
90­
00)

Lincoln
18665
5
3613
1356
8
Flathead
77240
15
5099
15253
26
Bonner
38205
22
1738
10213
38
Boundary
10085
8
1269
1539
18
Sanders
10367
4
2762
1558
18
Based
on
the
analysis
for
this
factor,
there
is
no
significant
growth,
on
either
an
absolute
or
a
percentage
basis,
to
indicate
a
contribution
to
the
air
quality
in
Lincoln
County.
This
factor
did
not
play
a
significant
role
in
the
decision
making
process.

Factor
6:
Meteorology
Libby
Montana
is
located
in
the
northwestern
part
of
the
state
in
a
narrow
north­
south
oriented
valley.
The
ridgetops
surrounding
Libby
are
approximately
4,000
feet
higher
6­
351
than
the
town.
There
are
no
other
towns
or
large
emissions
sources
immediately
upwind,
so
transport
of
high
background
concentrations
into
Libby
is
considered
unlikely.
The
highest
PM2.5
concentrations
in
Libby
generally
occur
during
the
months
of
November
through
February.
During
the
summer
months
concentrations
typically
average
less
than
half
the
level
of
the
annual
PM2.5
NAAQS,
while
winter
concentrations
may
double
the
NAAQS.
The
much
higher
concentrations
in
winter
are
related
to
stagnant
weather
conditions
dominated
by
light
winds
and
strong
temperature
inversions.
These
meteorological
conditions
may
trap
emissions
within
the
valley
for
many
days.
No
recent
meteorological
data
is
available
for
Libby,
however,
data
from
Kalispell,
MT
show
calm
wind
conditions
occur
35
percent
of
the
time
in
the
winter
months
and
only
15
percent
of
the
time
in
the
spring
and
summer.
Vertical
temperature
soundings
at
Great
Falls
in
Western
MT
also
show
a
very
high
frequency
of
surface
temperature
inversions
in
the
winter.

Due
to
the
meteorology
conditions
in
the
town
and
surrounding
vicinity
of
Libby
and
due
to
the
topographical
features
within
Lincoln
County
and
more
specifically
around
Libby
(
see
factor
7
below),
that
create
stagnant
weather
conditions,
EPA
feels
the
adjacent
counties
do
not
impact
the
PM2.5
monitor
located
at
the
Libby
Courthouse
Annex
and
that
the
nonattainment
problem
is
a
localized
PM2.5
problem.

Prevailing
Wind
Directions
(%)

County
NW
SW
SE
NE
Lincoln
14
37
22
26
Flathead
21
34
22
24
Bonner
14
42
20
24
Boundary
12
40
22
27
Sanders
26
28
24
22
This
factor
played
a
significant
role
in
the
decision
making
process.

Factor
7:
Geography/
topography
Lincoln
County,
MT
Lincoln
County
has
a
land
area
of
3,675
square
miles.
The
area
of
concern
showing
high
PM2.5
concentrations
is
located
within
and
around
the
Libby,
Montana
vicinity.
Lincoln
County
has
numerous
geographical
or
topographical
boundaries
limiting
its
airshed
to
a
very
narrow
valley
including
the
surrounding
vicinity
of
Libby.
The
town
of
Libby
has
a
total
area
of
1.3
miles.
As
of
the
2000
census,
there
are
2,626
people,
1,132
households,
and
669
families
residing
in
the
city.
The
elevation
for
the
town
of
Libby
is
2,601
feet.
The
ridgetops
surrounding
Libby
are
approximately
4,000
feet
higher
than
the
town.
The
town
sits
in
a
narrow
valley
that
runs
in
a
north­
south
direction
(
48
°
23'
17"
North,
6­
352
115
°
33'
13"
West).
The
Kootenai
River
runs
adjacent
to
the
town
in
an
east­
west
direction.
The
Kootenai
Basin
is
largely
mountainous
and
dominated
by
three
major
ranges.
The
Rocky
Mountain
Range
and
the
Flathead
Range
constitute
the
eastern
boundary;
the
Purcell
Range
roughly
bisects
it
from
north
to
south.
The
Selkirk
and
Cabinet
Ranges
mark
the
western
boundary.
Elevations
reach
a
maximum
of
about
12,000
feet
with
most
summit
elevations
between
6,000
and
7,500
feet.
Except
for
a
few
areas,
the
entire
watershed
is
heavily
forested
(
practically
all
of
Lincoln
County
and
a
large
portion
of
the
surrounding
counties
consists
of
National
Forest
land).
The
Kootenai
River
has
its
origins
in
British
Columbia's
Kootenay
National
Park
in
Canada.
From
there
it
flows
485
miles
into
northwest
Montana
and
through
the
towns
of
Libby
and
Troy.
From
there
it
flows
into
northern
Idaho,
then
back
into
Canada
and
Kootenay
Lake.
Ultimately
it
joins
with
the
Columbia
River.
Sixteen
miles
north
of
Libby,
the
river
is
held
back
by
Libby
Dam,
creating
a
90­
mile
long
reservoir
that
reaches
into
Canada.
The
river
drops
less
than
1,000
feet
(
305
meters)
in
elevation
from
Canal
Flats
to
Kootenay
Lake,
a
distance
of
over
300
miles
(
480
km).
However,
even
along
the
river's
slow
meandering
course,
valley­
bottom
widths
are
generally
less
than
two
miles
and
are
characterized
by
tree­
covered
rolling
hills
with
few
grassland
openings.

Due
to
the
topographical
features
and
meteorological
data
(
see
factor
6
above)
within
and
surrounding
the
vicinity
of
Libby
resulting
in
stagnant
weather
conditions
trapping
emissions
in
the
valley,
EPA
feels
the
adjacent
counties
do
not
impact
the
PM2.5
monitor
located
at
the
Libby
Courthouse
Annex.
Emissions
from
adjacent
counties
would
have
to
traverse
one
or
more
major
mountain
ranges,
in
some
cases
against
the
prevailing
wind
direction,
in
order
to
impact
the
town
of
Libby.

This
factor
played
a
significant
role
in
the
decision
making
process.

Factor
8:
Jurisdictional
boundaries
No
areas
in
Montana
or
Idaho
were
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004.

The
town
of
Libby
and
vicinity
within
Lincoln
County
are
designated
nonattainment
for
PM10.

Due
to
the
fact
that
the
town
and
surrounding
vicinity
of
Libby,
Montana
was
designated
nonattainment
for
PM10
and
did
not
include
the
surrounding
counties
around
Lincoln,
MT,
EPA
believes
this
factor
plays
a
significant
role
in
the
decision
making
process.

Factor
9:
Level
of
control
of
emission
sources
The
following
are
sources
located
in
Lincoln
County,
MT
but
are
not
considered
major
PSD
sources.

­
Plum
Creek
Northwest
Lumber,
Inc.
(
Ksandka
Sawmill),
Fortine,
MT
­
Eureka
Pellet
Mills,
Eureka,
MT
6­
353
­
Genesis
Inc.
(
Troy
Mine),
Troy,
MT
­
Lone
Pine
Timber
Industries,
Eureka,
MT
­
Stimson
Lumber
Mill,
Libby,
MT
(
closed
­
Spring,
2003)

Due
to
the
topographical
features
and
meteorology
in
Lincoln
County
(
see
factors
6
and
7
below)
and
more
specifically
surrounding
Libby,
MT
where
the
PM2.5
problem
is
located,
EPA
believes
this
factor
does
not
play
a
significant
role
in
the
decision
making
process.

6.8.2
Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
Background:
In
a
letter
dated
February
25,
2004,
the
Governor
of
Montana
submitted
to
EPA
a
letter
recommending
that
the
PM2.5
nonattainment
boundary
for
Lincoln
County,
MT
be
designated
as
a
partial
county.
The
Governor's
letter
did
not
provide
a
specific
justification
for
a
partial
county
recommendation
or
identify
what
the
partial
county
boundaries
would
be
for
Lincoln
County.
On
June
29,
2004,
EPA
responded
to
Montana's
recommendation
stating
that
EPA
agreed
with
Montana's
recommended
nonattainment
designation
for
Lincoln
County
but
that
EPA
intended
to
modify
Montana's
recommended
boundary
for
the
nonattainment
area
and
designate
the
entire
Lincoln
County
area
as
nonattainment
for
the
PM2.5
national
ambient
air
quality
standards.
1
In
two
follow­
up
letters
from
Montana
dated
June
25,
2004
and
September
7,
2004,
Montana
identified
specific
PM2.5
nonattainment
boundaries
for
Libby,
MT
along
with
a
technical
justification
for
the
less­
than­
county
request.

EPA's
Recommended
Change:
Based
upon
EPA's
review
of
Montana's
letters
dated
June
25,
2004
and
September
7,
2004
and
subsequent
discussions
EPA
has
had
with
the
Montana
Department
of
Environmental
Quality
(
MT
DEQ),
EPA
is
modifying
our
original
recommendation
and
identifying
the
PM2.5
nonattainment
boundary
area
as
follows:
600,000mE,
5,370,000mN
east
to
620,000mE,
5,370,000mN
south
to
620,000mE,
5,340,000mN
west
to
600,000mE,
5,340,000mN
north
to
600,000mE,
5,370,000mN
as
identified
in
Montana's
September
7,
2004
letter.
EPA
believes
these
boundaries
are
reasonable
for
the
following
reasons:

1
EPA's
April
1,
2003
"
Designations
for
the
Fine
Particle
National
Ambient
Air
Quality
Standards"
which
states:
"
When
a
rural
monitor
violates
the
standard,
EPA
intends
to
apply
a
presumption
that
the
nonattainment
area
shall
include
the
full
county
in
which
the
monitor
is
located.
EPA
will
consider
recommendations
to
adjust
rural
area
nonattainment
boundaries
based
on
the
same
factors
as
it
applies
to
urban
areas,
as
discussed
in
question
5
above.
Using
these
factors,
a
State
or
Tribe
that
recommends
that
a
smaller
area
should
be
designated
nonattainment
should
provide
convincing
evidence
that
the
monitor
is
not
representative
of
the
full
county,
that
the
excluded
portions
of
the
county
are
not
source
areas
contributing
to
the
nonattainment,
and
that
the
excluded
portions
of
the
county
are
meeting
the
standard.
Similarly,
a
State
or
Tribe
may
recommend
that
a
larger
area
be
designated
nonattainment
based
on
technical
information
relevant
to
these
factors.
Nevertheless,
as
discussed
above,
if
nonattainment
is
demonstrably
very
localized
and
is
attributable
to
localized
sources,
EPA
intends
to
establish
nonattainment
area
boundaries
based
on
a
case­
specific
evaluation
of
the
nature
and
extent
of
the
problem."
6­
354
1.
As
stated
under
factors
6
and
7
of
EPA's
factor
analysis
for
Lincoln
County,
meteorology
and
geographical/
topographical
features
within
and
surrounding
the
town
of
Libby
played
a
significant
role
in
the
decision
making
process
and
in
EPA's
consideration
to
modify
the
nonattainment
boundary
to
only
include
the
town
of
Libby
and
surrounding
vicinity.
(
See
Factors
6
and
7
for
more
details.)

2.
The
MT
DEQ
conducted
a
winter
monitoring
study
in
the
Libby,
Montana
area
from
November
2003
through
March
2004.
This
information
was
submitted
to
EPA
in
MT
DEQ's
June
25,
2004
PM2.5
nonattainment
boundary
area
recommendation
for
the
town
of
Libby.
The
monitoring
study
showed
that
within
the
"
T"
shape
basin
where
Libby
Creek
flows
into
the
Kootenai
River,
significant
drops
in
PM2.5
occur
along
the
northwestern
edge
of
the
Libby
valley
as
well
as
the
northeastern
edge
of
the
valley.
Wind
speed
results
showed
that
there
is
very
little
wind
in
the
Libby
area
during
winter
confirming
that
much
higher
concentrations
in
winter
are
related
to
stagnant
weather
conditions
dominated
by
light
winds
and
strong
temperature
inversions.
As
a
result,
meteorological
conditions
may
trap
emissions
within
the
valley
for
many
days.
In
MT
DEQ's
June
25,
2004
recommendation,
MT
DEQ
acknowledged
in
the
boundary
analysis
that
while
monitoring
was
not
conducted
further
south
than
3
miles
from
the
town's
center,
MT
DEQ
was
confident
that
the
boundary
that
they
recommended
in
their
June
25
letter
adequately
surrounds
the
source
area
for
the
Libby
PM2.5
nonattainment
area.
EPA
disagreed
with
MT
DEQ's
southern
boundary
recommendation
and
in
further
discussions
with
MT
DEQ,
came
to
an
agreement
to
extend
the
southern
boundary
area
to
include
an
additional
20,000
meter
UTM
Grids
beyond
what
was
recommended
in
MT
DEQ's
June
25,
2004
recommendation.
This
new
boundary
agreement
is
reflected
in
MT
DEQ's
letter
dated
September
7,
2004.

Due
to
the
geographical/
topographical
features
and
meteorological
data
within
and
surrounding
the
vicinity
of
Libby
and
the
study
performed
by
MT
DEQ,
EPA
feels
the
surrounding
Lincoln
County
area
outside
the
recommended
boundary
area
does
not
impact
the
PM2.5
monitor
located
at
the
Libby
Courthouse
Annex.
Emissions
from
the
surrounding
area
within
Lincoln
County
would
have
to
traverse
one
or
more
major
mountain
ranges,
in
some
cases
against
the
prevailing
wind
direction,
in
order
to
impact
the
town
of
Libby.
