3­
1
3.
Responses
to
Comments
EPA
Region
3
(
Delaware,
District
of
Columbia,
Maryland,
Pennsylvania,
Virginia,
and
West
Virginia)
3­
2
Comment:
1013a­
8
Region:
3
State:
DC
|
MD
|
VA
Area:
Baltimore,
MD
|
Washington,
DC­
MD­
VA|
Martinsburg,
WV­
Hagerstown,
MD
Comment:
The
EPA
has
failed
to
recommend
that
the
Washington­
Baltimore
CMSA
be
designated
as
one
nonattainment
area;
this
area
must
be
designated
as
one
nonattainment
area.

EPA
Response:
Although
large
metropolitan
areas
such
as
the
Washington
DC
CMSA
may
be
considered
as
one
large
area
in
the
designation
process,
EPA
agreed
with
Maryland's
recommendations
to
split
them
into
the
smaller
MSAs.
The
smaller
areas
have
separate
air
quality
planning
processes
that
EPA
believes
would
be
more
practical
and
productive
than
having
one
large
area.
EPA
also
seeks
to
maximize
consistency
between
the
PM2.5
and
the
8­
hour
ozone
designations.
Keeping
these
areas
separate
under
PM2.5
would
be
consistent
with
the
designations
under
8­
hour
ozone.

Comment:
1013a­
8
Region:
3
State:
DC
|
MD
|
VA
Area:
Washington,
DC­
MD­
VA|
Baltimore,
MD|
Martinsburg,
WV­
Hagerstown,
MD
Comment:
The
EPA
has
failed
to
recommend
that
the
Washington­
Baltimore
CMSA
be
designated
as
one
nonattainment
area;
this
area
must
be
designated
as
one
nonattainment
area.

EPA
Response:
Although
large
metropolitan
areas
such
as
the
Washington
DC
CMSA
may
be
considered
as
one
large
area
in
the
designation
process,
EPA
agreed
with
Maryland's
recommendations
to
split
them
into
the
smaller
MSAs.
The
smaller
areas
have
separate
air
quality
planning
processes
that
EPA
believes
would
be
more
practical
and
productive
than
having
one
large
area.
EPA
also
seeks
to
maximize
consistency
between
the
PM2.5
and
the
8­
hour
ozone
designations.
Keeping
these
areas
separate
under
PM2.5
would
be
consistent
with
the
designations
under
8­
hour
ozone.

Comment:
1090­
1
Region:
3
State:
DE
Area:
Philadelphia­
Wilmington,
PA­
NJ­
DE
Comment:
The
commenter
does
not
agree
with
EPA's
modification
to
the
State
of
Delaware's
PM2.5
nonattainment
designation
recommendation.
The
commenter
requests
EPA
to
establish
the
boundaries
of
New
Castle,
Delaware
as
the
boundaries
of
a
standalone
annual
PM2.5
nonattainment
area
and
that
New
Castle
County
not
be
included
as
part
of
the
Philadelphia
CMSA.
The
commenter
notes
that
unlike
ozone,
Delaware's
3­
3
PM2.5
nonattainment
problem
is
caused
by
local
emissions,
exacerbated
by
intra­
and
inter­
state
PM2.5
and
PM2.5
precursor
transport.
The
commenter
believes
that,
in
the
case
of
New
Castle
County,
Delaware,
it
is
appropriate
to
address
PM2.5
nonattainment
as
a
local
problem.
The
commenter
does
not
minimize
the
significance
of
PM2.5
related
transport,
rather
he
indicates
that
there
is
not
a
relationship
between
transport
and
nonattainment
boundaries,
and
PM2.5
and
PM2.5
precursor
transport
must
be
addressed
at
a
larger
regional
level
similar
to
what
has
been
identified
in
EPA's
proposed
CAIR.
Supporting
information
is
attached.

EPA
Response:
The
CAA
requires
EPA
to
designate
as
nonattainment
any
area
that
is
monitoring
a
violation
of
the
standard
or
that
is
contributing
to
a
violation
of
the
standard
in
a
nearby
area.
Thus,
our
designations
include
both
areas
monitoring
violations
of
the
PM2.5
standard
as
well
as
those
nearby
areas
that
are
determined
to
be
contributing
to
violations
at
the
affected
monitors.
The
issue
of
regional
transport
primarily
concerns
long
range
transport
­
i.
e.,
transport
from
areas
that
are
not
"
nearby".
EPA
agrees
that
this
is
an
important
issue
and
is
currently
addressing
the
issue
of
regionally
transported
emissions
via
the
Clean
Air
Interstate
Rule
(
CAIR).

New
Castle
County
is
an
integral
part
of
the
Philadelphia
metropolitan
area.
Population,
growth
and
commuting
into
the
Philadelphia
area
contribute
to
nonattainment
in
the
Philadelphia
area.

Comment:
1013a­
28
Region:
3
State:
MD
Area:
Baltimore,
MD
|
Washington,
DC­
MD­
VA
Comment:
Washington­
Baltimore
CMSA:

EPA
has
failed
to
recommend
that
this
CMSA
be
designated
as
one
nonattainment
area;
this
area
must
be
designated
as
one
nonattainment
area.
EPA
also
failed
to
include
St.
Mary's,
Calvert
and
Queen
Anne's
Counties,
all
part
of
the
CMSA,
in
the
nonattainment
area.
Queen
Anne's
County
has
no
monitor,
but
between
1990
and
2000
the
county
experienced
19%
population
growth
and
between
1996
and
2002
they
experienced
a
25%
increase
in
VMT.
EPA
does
not
appear
to
have
conducted
an
analysis
for
St.
Mary's
County.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
3­
4
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.
Based
on
weighted
emissions
screening
and
the
combined
factor
analysis,
Calvert,
and
Queen
Anne's
Counties
are
considered
to
have
low
contribution
to
the
nonattainment
area
and
were
excluded
from
the
presumptive
boundaries
of
the
nonattainment
area.
St.
Mary's
County
is
an
adjacent
county
that
was
determined
to
have
low
contribution
based
on
the
initial
screening
for
this
area.

Also,
although
large
metropolitan
areas
such
as
the
Washington
DC
CMSA
may
be
considered
as
one
large
area
in
the
designation
process,
EPA
agreed
with
Maryland's
recommendations
to
split
them
into
the
smaller
MSAs.
The
smaller
areas
have
separate
air
quality
planning
processes
that
EPA
believes
would
be
more
practical
and
productive
than
having
one
large
area.
EPA
also
seeks
to
maximize
consistency
between
the
PM2.5
and
the
8­
hour
ozone
designations.
Keeping
these
areas
separate
under
PM2.5
would
be
consistent
with
the
designations
under
8­
hour
ozone.

Comment:
1033­
1
Region:
3
State:
MD
Area:
Baltimore,
MD|
Washington,
DC­
MD­
VA
|
Martinsburg,
WV­
Hagerstown,
MD
Comment:
Commenter
urges
EPA
to
reconsider
the
Maryland
Department
of
the
Environment's
(
MDE)
suggested
option
of
designating
as
nonattainment
only
the
counties
that
are
monitoring
nonattainment
while
requiring
the
remaining
counties
in
the
MSA
to
control
their
emission
sources
at
the
same
level
as
the
counties
designated
nonattainment.
MDE
comments
they
have
worked
closely
with
the
county
governments.
These
governments
would
develop
and
sign
a
MOU
to
commit
to
the
reductions,
which
would
make
the
controls
federally
enforceable.
MDE
notes
that
a
hysplit
model
analysis
for
Washington
County
shows
how
transported
emissions
are
the
primary
reason
for
their
designation
and
MDE
has
looked
into
the
role
county
demographics
played
in
the
EPA
analysis.

EPA
Response:
EPA
appreciates
the
collaboration
between
the
counties
and
MDE,
as
well
as
Maryland's
commitment
to
apply
control
emissions
throughout
the
state
at
the
same
levels.
However,
the
CAA
requires
EPA
to
designate
as
nonattainment
any
area
that
is
monitoring
a
violation
of
the
standard
or
that
is
contributing
to
a
violation
of
the
standard
in
a
nearby
area.
Thus,
our
designations
include
both
areas
monitoring
violations
3­
5
of
the
PM2.5
standard
as
well
as
those
nearby
areas
that
are
determined
to
be
contributing
to
violations
at
the
affected
monitors.
The
issue
of
regional
transport
primarily
concerns
long
range
transport
­
i.
e.,
transport
from
areas
that
are
not
"
nearby".
EPA
agrees
that
this
is
an
important
issue
and
is
currently
addressing
the
issue
of
regionally
transported
emissions
via
the
Clean
Air
Interstate
Rule
(
CAIR).

Please
see
TSD
for
additional
information
on
EPA's
designations.

Comment:
1030­
1
Region:
3
State:
MD
Area:
Baltimore,
MD|
Washington,
DC­
MD­
VA|
Martinsburg,
WV­
Hagerstown,
MD
Comment:
The
commenter,
speaking
for
Maryland
Department
of
the
Environment
(
MDE),
requests
a
dialogue
between
MDE
and
EPA
regarding
differences
in
Maryland's
and
EPA's
recommendations
on
the
proposed
PM2.5
nonattainment
boundaries,
specifically
with
regard
to
Carroll,
Charles,
Frederick,
Harford,
Howard,
Montgomery
and
Washington
Counties.
The
MDE
requests
that
EPA
consider
the
second
option
recommended
earlier
by
MDE.
In
this
option,
only
the
counties
that
have
monitors
showing
nonattainment
would
be
designated
as
nonattainment
but
the
remaining
counties
in
the
MSA
would
be
required
to
control
their
emission
sources
at
the
same
level
as
the
connected
nonattainment
areas.
MDE
has
worked
with
stakeholders
and
explored
the
possibility
of
establishing
a
MOU
or
some
other
federal
enforceable
mechanism
to
ensure
that
all
counties
within
the
MSA
are
part
of
the
regional
solution.

In
addition
the
commenter
requests
that
EPA
complete
and
publish
the
guidance
on
how
the
PM2.5
standard
will
be
implemented.
Without
the
guidance
it
is
difficult
to
discuss
the
recommended
nonattainment
area
boundaries
with
various
stakeholders.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
3­
6
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
areaspecific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

Air
quality
monitoring
information
in
three
of
these
counties
do
not
show
a
violation
of
the
standard,
however,
population,
growth,
and
commuting
in
these
six
counties
contribute
to
the
monitored
nonattainment.
Please
see
the
TSD
for
the
justification
for
the
changes
in
the
State's
recommendations.

To
be
consistent
in
applying
EPA
guidance
across
all
states,
the
(
alternate)
secondary
control
regions
as
suggested
by
the
state
and
its
stakeholders
is
not
endorsed.

Comment:
1013a­
26
Region:
3
State:
MD
Area:
Martinsburg,
WV
­
Hagerstown,
MD
Comment:
EPA
has
recommended
that
the
Maryland
portion
of
the
MSA
(
Washington
County)
be
designated
nonattainment.
Berkeley
and
Morgan
Counties
should
also
be
included
as
nonattainment.
As
described
in
our
previous
letter
to
EPA,
Allegany
County
may
also
be
a
significant
source
of
emissions
impacting
the
nonattainment
problem
and
should
be
considered
for
inclusion
in
the
nonattainment
area.
In
2001,
the
county
emitted
over
3,000
tons
of
PM,
over
20,000
tons
of
SO2
and
over
12,000
tons
of
NOX.
It
does
not
appear
that
an
analysis
of
this
county's
emissions
has
been
done.

EPA
Response:
Once
we
determine
that
an
area
is
violating
the
standard,
we
looked
at
nearby
areas
to
determine
if
they
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
Our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
(
1)
air
quality
monitoring
information,
(
2)
pollutant
emissions,
(
3)
population
and
growth
in
the
area,
(
4)
commuting,
(
5)
vehicle
miles
traveled,
(
6)
meteorology,
(
7)
terrain,
(
8)
jurisdictional
boundaries,
and
(
9)
the
existing
level
of
control
of
emissions
sources.

Berkeley,
Morgan,
and
Washington
Counties
are
part
of
the
Hagerstown­
Martinsburg
CBSA.
Berkeley
and
Washington
Counties
are
designated
as
nonattainment.
However,
our
analysis
of
Morgan
County
shows
that
it
is
low
in
all
areas
of
the
combined
factor
analysis.

Allegany
County
is
an
adjacent
area
that
has
low
population,
negative
growth,
and
negligible
commuting
into
the
CBSA,
and
was
therefore
excluded.
3­
7
Comment:
1013a­
27
Region:
3
State:
MD
Area:
Philadelphia­
Wilmington,
PA­
NJ­
DE
Comment:
EPA
failed
to
recommend
that
Cecil
County
be
designated
nonattainment
as
part
of
the
Philadelphia
nonattainment
area.
This
county
is
part
of
the
CMSA
and
must
be
included
in
the
nonattainment
area.
EPA's
documentation
shows
that
Cecil
County's
2001­
2003
design
value
was
13.0
µ
g/
m3,
which
is
attaining,
but
close
to
the
annual
standard.
Because
the
county's
1990
through
2000
growth
rate
was
20%
and
the
percent
VMT
growth
between
1996
and
2002
was
29%,
emissions
in
this
area
will
briskly
increase
in
future
years.

EPA
Response:
The
EPA's
April
1,
2003,
boundary
guidance
for
designations
provided
9
factors
for
a
state
to
consider
in
their
February
2004
recommendations.
Maryland's
revised
recommendation
of
May
28,
2004
recommended
Cecil
County
as
attainment.
The
monitored
attainment
and
the
combined
factor
analysis
indicate
low
contribution
to
the
monitored
nonattainment
in
the
Philadelphia
area.
Please
see
the
TSD
for
additional
information
on
the
combined
factor
analysis.

Comment:
1013a­
8
Region:
3
State:
MD
|
VA
|
DC
Area:
Washington,
DC­
MD­
VA|
Baltimore,
MD
|
Martinsburg,
WV­
Hagerstown,
MD
Comment:
The
EPA
has
failed
to
recommend
that
the
Washington­
Baltimore
CMSA
be
designated
as
one
nonattainment
area;
this
area
must
be
designated
as
one
nonattainment
area.

EPA
Response:
Although
large
metropolitan
areas
such
as
the
Washington
DC
CMSA
may
be
considered
as
one
large
area
in
the
designation
process,
EPA
agreed
with
Maryland's
recommendations
to
split
them
into
the
smaller
MSAs.
The
smaller
areas
have
separate
air
quality
planning
processes
that
EPA
believes
would
be
more
practical
and
productive
than
having
one
large
area.
EPA
also
seeks
to
maximize
consistency
between
the
PM2.5
and
the
8­
hour
ozone
designations.
Keeping
these
areas
separate
under
PM2.5
would
be
consistent
with
the
designations
under
8­
hour
ozone.

Comment:
1028­
1
Region:
3
State:
PA
Area:

Comment:
Pennsylvania
DEP
urges
EPA
to
reconsider
its
proposed
designations
for
the
PM2.5
standard.
3­
8
1.
Commenter
is
concerned
with
EPA's
overall
approach
for
the
PM2.5
designations.
The
weighted
emissions
approach
expands
nonattainment
areas
to
include
counties
monitoring
attainment
solely
because
of
the
emissions
from
certain
major
sources
like
coal­
fired
power
plants.
Pennsylvania
strongly
opposes
this
approach.
Emissions
from
large
point
sources
should
be
addressed
by
national
or
regional
legislation
or
regulation.

EPA
Response:
As
a
part
of
the
process
to
determine
what
areas
should
be
designated
as
nonattainment,
EPA
first
uses
the
Federal
Reference
Method
(
FRM)
monitors
to
determine
violations
of
the
NAAQS.
The
FRM
monitors
measure
the
total
mass
of
PM2.5
in
the
ambient
air.
These
monitors
are
used
to
calculate
the
values
that
are
compared
to
the
NAAQS
(
15
µ
g/
m3)
in
deciding
if
the
ambient
air
in
an
area
exceeds
the
NAAQS.

Second,
once
an
area
has
a
monitor
violating
the
NAAQS,
EPA
uses
the
speciated
PM2.5
air
quality
data,
along
with
other
data,
to
help
determine
which
counties
in
the
area
are
contributing
to
the
violation.
In
identifying
counties
that
contribute
to
an
area's
violating
air
quality,
it
is
important
give
more
weight
to
emissions
(
sources)
that
contribute
to
the
excess
PM2.5
in
the
urban
area.
For
example,
a
ton
of
nitrogen
oxide
emitted
within
an
area
contributes
less
to
the
PM2.5
in
that
area
than
a
ton
of
organic
carbon
emissions.
Nitrogen
oxide
takes
time
to
form
into
PM2.5
in
the
atmosphere
and
therefore
is
more
of
a
regional
pollutant.
In
addition,
it
will
be
important
to
understand
which
emissions
are
mostly
contributing
to
an
area's
PM2.5
level
in
determining
what
sources
could
be
effectively
controlled
within
the
area.

To
give
each
county
in
an
urban
area
the
proper
"
weight"
for
their
"
contributing"
emissions,
the
emissions
in
the
county
must
be
adjusted
in
two
steps.
In
step
1,
we
must
determine
the
county's
percentage
of
the
violating
area's
total
emissions.
In
step
2,
we
adjust
this
percentage
by
the
violating
area's
excess
urban
emissions
for
the
pertinent
speciated
PM2.5
component.
In
doing
this,
we
calculate
the
excess
levels
associated
with
sulfates,
nitrates,
carbonaceous
matter
and
crustal
material.
These
components
represent
the
vast
majority
of
chemicals
that
make
up
PM2.5
in
urban
areas.

The
calculated
urban
excess
for
each
of
the
four
components
is
the
difference
between
the
speciated
PM2.5
components
for
an
urban
area
and
speciated
components
from
a
near­
by
rural
area.
While
it
may
seem
best
to
choose
a
"
rural"
FRM
(
total
mass)
monitor
and
an
"
urban"
FRM
monitor
for
purposes
of
estimating
the
mass
of
the
urban
excess,
this
would
not
allow
us
to
relate
the
air
quality
levels
to
the
area's
emissions.
This
situation
is
one
of
the
main
reasons
for
a
monitoring
network
for
speciated
PM2.5.
Accordingly,
we
are
using
the
speciated
PM2.5
data
from
rural
and
urban
monitors,
along
with
estimates
of
emissions
within
the
area,
to
identify
the
urban
sources
with
the
greatest
contribution
to
the
urban
excess
PM2.5.

It
is
also
important
to
note
that
the
PM2.5
(
air
quality)
weighted
emissions
(
and
scores)
are
considered
in
the
context
of
all
the
relevant
factors
in
determining
the
boundary
of
a
nonattainment
area.
We
consider
the
other
factors,
in
addition
to
air
quality
and
emissions,
in
identifying
the
counties
that
should
comprise
the
nonattainment
area.
As
3­
9
described
above,
the
speciated
PM2.5
weighted
emissions
are
used
in
developing
a
ranking
score
(
weight)
for
each
county
in
a
potential
nonattainment
area.
In
developing
these
scores,
we
do
not
intend
that
they
be
used
in
"
bright­
line"
manner.
Rather,
they
offer
a
basis
for
looking
closest
at
the
counties
in
an
area
that
may
contribute
to
the
most
to
the
elevated
PM2.5
in
the
area.
For
the
counties
with
the
highest
score,
we
look
at
the
other
information
as
we
determine
the
collection
of
counties
in
a
nonattainment
area.
Please
see
TSD
for
additional
information
on
EPA's
designations.

Comment:
1013a­
42
Region:
3
State:
PA
Area:
Harrisburg­
Lebanon­
Carlisle,
PA
Comment:
Both
Perry
County
(
inside
the
Harrisburg
CMSA)
and
Snyder
County
(
adjacent
to
the
Harrisburg
CMSA)
were
not
included
in
EPA's
recommended
nonattainment
area.
The
Sunbury
coal­
fired
power
plant,
located
in
Snyder
County,
emitted
over
25,000
tons
of
SO2
and
over
5,000
tons
of
NOX
in
2002.
Both
of
these
counties
must
be
included
in
the
nonattainment
area.

EPA
Response:
The
review
of
the
nine
factors
did
not
support
inclusion
of
Snyder
and
Perry
in
the
Harrisburg
nonattainment
area.
Please
see
the
TSD
for
the
justification
for
the
changes
in
the
State's
recommendations.

Comment:
1028­
4
Region:
3
State:
PA
Area:
Harrisburg­
Lebanon­
Carlisle,
PA
Comment:
Lebanon
County
should
not
be
included
in
the
Harrisburg
nonattainment
area.
It
has
low
emissions
and
will
have
little
or
no
effect
on
design
values
in
the
nonattainment
area
since
Lebanon
County
is
generally
downwind
of
Cumberland
and
Dauphin
Counties.
The
proposed
inclusion
of
Lebanon
County
solely
to
establish
a
contiguous
nonattainment
area
seems
more
of
an
aesthetic
exercise
rather
than
assisting
the
nonattainment
area
to
attain
the
annual
PM2.5
standard.

EPA
Response:
EPA
has
reviewed
the
information
provided
by
the
Commonwealth.
EPA
disagrees.
Lebanon
County
is
part
of
the
core
metropolitan
area.
The
population
density
is
similar
to
that
of
Dauphin
and
Cumberland
Counties.
Twenty
four
percent
of
the
population
commutes
within
the
nonattainment
area.
In
addition,
the
juxtaposition
of
two
nonattainment
areas
suggests
Lebanon
County
is
not
only
contributing
to,
but
is
estimated
to
have
elevated
air
quality
similar
to
the
nonattainment
counties
in
Eastern
Pennsylvania.
3­
10
Comment:
1007­
1
Region:
3
State:
PA
Area:
Johnstown,
PA
|
Pittsburgh­
Beaver
Valley,
PA
Comment:
Commenter
disagrees
with
the
addition
of
5
counties
as
nonattainment
beyond
those
proposed
by
Pennsylvania
DEP.
He
believes
that
this
addition,
essentially
doubling
the
size
of
the
proposed
nonattainment
area,
represents
one
of
the
worst
threats
to
economic
competitiveness
of
southwestern
Pennsylvania
in
more
than
a
decade,
while
having
little
or
no
air
quality
benefit.
He
notes
that
most
of
the
monitors
in
southwestern
Pennsylvania
exceed
the
PM2.5
NAAQS
by
only
a
small
amount.
He
comments
that
this
pollution
is
likely
due
to
pollution
from
other
states.
He
points
to
a
study
at
Carnegie
Mellon
University
that
shows
that
80%
of
the
PM2.5
in
southwestern
PA
comes
from
sources
outside
the
region.

EPA
Response:
Thank
you
for
your
July
15,
2004
letter
to
the
U.
S.
Environmental
Protection
Agency
(
EPA)
regarding
the
proposed
designation
of
areas
from
the
fine
particulate
matter
(
PM2.5)
national
ambient
air
quality
standard
in
Pennsylvania.

As
required
by
statute
and
EPA
guidance,
the
Agency
must
designate
areas
that
include
counties
violating
the
standards,
as
well
as
nearby
counties
that
may
contribute
to
a
violation
of
the
standard
as
nonattainment.
Thus,
many
of
the
counties
you
reference
in
your
letter
may
not
have
monitored
a
problem
in
an
adjacent
area.
Our
analysis
included
many
factors
such
as
population,
traffic,
growth,
meteorology,
geography,
and
jurisdictional
boundaries.

In
EPA's
letter
dated
June
29,
2004,
we
informed
Governor
Edward
Rendell
of
our
modification
to
his
original
nonattainment
boundaries
recommendations.
The
next
step
in
the
designation
process
is
for
Pennsylvania
DEP
to
assess
the
available
data
and
to
provide
additional
information.
We
will
consider
any
additional
information
provided
by
PADEP
in
our
decision­
making.
This
information
is
requested
by
September
1,
2004,
but
we
encourage
the
Commonwealth
to
have
an
ongoing
dialogue
with
EPA
during
the
entire
designation
process.
It
is
my
understanding
that
supplemental
information
on
many
of
the
counties
you
mentioned,
including
the
Liberty
area
of
Allegheny
County,
will
be
provided.
We
will
evaluate
your
suggestions
as
well
as
any
additional
information
provided
by
PADEP
as
we
finalize
our
decision
on
nonattainment
boundaries.

It
is
important
to
note
that
EPA
is
also
currently
addressing
fine
particulate
pollution
with
a
comprehensive
national
clean
air
strategy.
This
strategy
includes
EPA's
recent
rule
to
reduce
pollution
from
nonroad
diesel
engines
and
the
proposed
rule
to
reduce
pollution
from
power
plants
in
the
eastern
United
States.
These
regulations
will
produce
significant
reductions
in
the
area
of
transported
pollution.
3­
11
Comment:
1013a­
43
Region:
3
State:
PA
Area:
New
York­
N.
New
Jersey­
Long
Island,
NY­
NJ­
CT
Comment:
EPA
failed
to
include
Pike
County
in
the
recommended
New
York
nonattainment
area.
This
county
is
part
of
the
CMSA
and
must
be
included.

EPA
Response:
The
EPA's
April
1,
2003,
boundary
guidance
for
designations
provided
9
factors
for
a
state
to
consider
in
their
February
2004
recommendations.
The
combined
factor
analysis
indicates
low
contribution
to
the
monitored
nonattainment
in
the
New
York
nonattainment
area.
Please
see
the
TSD
for
additional
information
on
the
combined
factor
analysis.

Comment:
1013a­
44
Region:
3
State:
PA
Area:
Philadelphia
­
Wilmington,
PA­
NJ­
DE
Comment:
Lehigh
and
Northampton
Counties
should
be
designated
nonattainment
due
to
their
likely
contributions
to
nonattaining
C/
MSAs.
Lehigh
County,
adjacent
to
both
the
Philadelphia
CMSA
and
the
Reading
MSA
(
also
recommended
for
nonattainment)
has
high
emissions
of
SO2,
NOx
and
VOC,
according
to
EPA's
June
29,
2004
letter
to
the
State.
Northampton
County
is
home
to
both
the
Martins
Creek
and
Portland
electric
generating
facilities,
which
are
significant
sources
of
SO2
and
NOx
pollution,
emitting
over
46,000
tons
of
SO2
and
over
8,000
tons
of
NOx
in
2002.
This
county
is
adjacent
to
both
the
New
York
CMSA
and
the
Philadelphia
CMSA.
EPA
and
the
State
should
determine
which
nonattainment
area
these
counties
contribute
to
in
order
to
add
them
to
the
appropriate
nonattainment
area.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
3­
12
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

Please
see
TSD
for
additional
information
on
EPA's
designations.

Comment:
1028­
5
Region:
3
State:
PA
Area:
Philadelphia
­
Wilmington,
PA­
NJ­
DE
Comment:
Pennsylvania
DEP
disagrees
with
EPA's
recommendation
to
expand
the
Philadelphia
nonattainment
area
to
include
Montgomery
and
Bucks
Counties.
These
counties
are
monitoring
attainment
and
are
thought
to
be
generally
downwind
and/
or
not
significantly
contributing
to
monitors
exceeding
the
annual
standard.
It
appears
EPA
did
not
take
into
consideration
the
level
of
controls
implemented
in
the
five­
county
Philadelphia
region.
Commenter's
analysis
indicates
that
the
Philadelphia
problem
is
more
local
in
scope
and
expanding
the
area
to
include
Bucks
and
Montgomery
Counties
will
not
help
the
region
to
attain
the
PM2.5
standard.

Additionally,
EPA's
methodology
does
not
establish
a
definitive
relationship
between
countywide
emissions
and
the
region's
design
value
monitor.

EPA
Response:
As
a
part
of
the
process
to
determine
what
areas
should
be
designated
as
nonattainment,
EPA
first
uses
the
Federal
Reference
Method
(
FRM)
monitors
to
determine
violations
of
the
NAAQS.
The
FRM
monitors
measure
the
total
mass
of
PM2.5
in
the
ambient
air.
These
monitors
are
used
to
calculate
the
values
that
are
compared
to
the
NAAQS
(
15
µ
g/
m3)
in
deciding
if
the
ambient
air
in
an
area
exceeds
the
NAAQS.

Second,
once
an
area
has
a
monitor
violating
the
NAAQS,
EPA
uses
the
speciated
PM2.5
air
quality
data,
along
with
other
data,
to
help
determine
which
counties
in
the
area
are
contributing
to
the
violation.
In
identifying
counties
that
contribute
to
an
area's
violating
air
quality,
it
is
important
give
more
weight
to
emissions
(
sources)
that
contribute
to
the
excess
PM2.5
in
the
urban
area.
For
example,
a
ton
of
nitrogen
oxide
emitted
within
an
area
contributes
less
to
the
PM2.5
in
that
area
than
a
ton
of
organic
carbon
emissions.
Nitrogen
oxide
takes
time
to
form
into
PM2.5
in
the
atmosphere
and
therefore
is
more
of
a
regional
pollutant.
In
addition,
it
will
be
important
to
understand
which
emissions
are
mostly
contributing
to
an
area's
PM2.5
level
in
determining
what
sources
could
be
effectively
controlled
within
the
area.

To
give
each
county
in
an
urban
area
the
proper
"
weight"
for
their
"
contributing"
emissions,
the
emissions
in
the
county
must
be
adjusted
in
two
steps.
In
step
1,
we
must
determine
the
county's
percentage
of
the
violating
area's
total
emissions.
In
step
2,
we
adjust
this
percentage
by
the
violating
area's
excess
urban
emissions
for
the
pertinent
3­
13
speciated
PM2.5
component.
In
doing
this,
we
calculate
the
excess
levels
associated
with
sulfates,
nitrates,
carbonaceous
matter
and
crustal
material.
These
components
represent
the
vast
majority
of
chemicals
that
make
up
PM2.5
in
urban
areas.

The
calculated
urban
excess
for
each
of
the
four
components
is
the
difference
between
the
speciated
PM2.5
components
for
an
urban
area
and
speciated
components
from
a
near­
by
rural
area.
While
it
may
seem
best
to
choose
a
"
rural"
FRM
(
total
mass)
monitor
and
an
"
urban"
FRM
monitor
for
purposes
of
estimating
the
mass
of
the
urban
excess,
this
would
not
allow
us
to
relate
the
air
quality
levels
to
the
area's
emissions.
This
situation
is
one
of
the
main
reasons
for
a
monitoring
network
for
speciated
PM2.5.
Accordingly,
we
are
using
the
speciated
PM2.5
data
from
rural
and
urban
monitors,
along
with
estimates
of
emissions
within
the
area,
to
identify
the
urban
sources
with
the
greatest
contribution
to
the
urban
excess
PM2.5.

It
is
also
important
to
note
that
the
PM2.5
(
air
quality)
weighted
emissions
(
and
scores)
are
considered
in
the
context
of
all
the
relevant
factors
in
determining
the
boundary
of
a
nonattainment
area.
We
consider
the
other
factors,
in
addition
to
air
quality
and
emissions,
in
identifying
the
counties
that
should
comprise
the
nonattainment
area.
As
described
above,
the
speciated
PM2.5
weighted
emissions
are
used
in
developing
a
ranking
score
(
weight)
for
each
county
in
a
potential
nonattainment
area.
In
developing
these
scores,
we
do
not
intend
that
they
be
used
in
"
bight­
line"
manner.
Rather,
they
offer
a
basis
for
looking
closest
at
the
counties
in
an
area
that
may
contribute
to
the
most
to
the
elevated
PM2.5
in
the
area.
For
the
counties
with
the
highest
score,
we
look
at
the
other
information
as
we
determine
the
collection
of
counties
in
a
nonattainment
area.

Bucks
and
Montgomery
Counties
are
part
of
the
core
metropolitan
area.
Both
counties
are
among
the
highest
population
and
commuting
in
the
Philadelphia
area.
Bucks
County
has
experienced
a
10
percent
growth
rate.
For
these
reasons,
EPA
has
determined
that
Bucks
and
Montgomery
do
contribute
to
the
nonattainment
in
Philadelphia
and
should
be
included
in
the
nonattainment
boundaries.

Comment:
1028­
3
Region:
3
State:
PA
Area:
Pittsburgh­
Beaver
Valley,
PA|
Liberty­
Clairton,
PA
Comment:
With
regards
to
the
Pittsburgh
area,
Pennsylvania
DEP
offers
the
following
comments:

1.
Based
on
further
analysis,
Pennsylvania
DEP
recommends
designation
of
two
additional
nonattainment
areas
within
the
Pittsburgh
nonattainment
area.
Additional
analysis
of
monitoring
and
meteorology
data
supports
designating
two
partial
county
nonattainment
areas.
The
analysis
shows
that
unique
local
PM2.5
problems
exist
in
the
vicinities
of
the
Liberty
Borough,
Clairton,
and
North
Braddock
monitors.
Bringing
these
areas
into
attainment
will
take
longer
than
bringing
the
rest
of
the
Pittsburgh
area
into
attainment.
The
commenter
believes
it
would
be
illogical
to
tie
the
attainment
status
of
3­
14
the
remainder
of
an
extensive
nonattainment
area
to
this
problem.
The
addition
of
two
additional
nonattainment
areas
within
the
Pittsburgh
nonattainment
area
is
necessary
to
address
the
attainment
timing
issues
and
unique
needs
of
these
two
local
areas.

2.
Butler
County
has
low
emissions,
low
population
density,
low
VMT,
and
scores
low
in
EPA's
weighted
emissions
analysis.
There
is
no
reason
to
conclude
that
this
county
should
be
nonattainment.

3.
Lawrence
County
has
historically
not
been
a
part
of
the
Pittsburgh
planning
area
for
ozone,
has
relatively
low
emissions
and
a
relatively
low
and
declining
population
density.
Furthermore,
the
bulk
of
SO2
emissions
are
from
the
New
Castle
power
plant
and
would
be
addressed
by
EPA's
proposed
CAIR.
Attainment
is
the
correct
designation
for
Lawrence
County.

4.
Pennsylvania
strongly
disagrees
with
EPA's
proposal
to
designate
Indiana,
Armstrong
and
Greene
Counties
as
nonattainment
solely
because
they
have
coal­
fired
power
plants.
These
are
rural,
non­
industrial
counties.
It
is
DEP's
position
that
emissions
from
large
point
sources
must
be
addressed
by
regional
or
national
legislation.

EPA
Response:
EPA
has
reviewed
the
information
provided
by
the
Commonwealth.
However,
EPA
has
determined
that
Butler
and
part
of
Lawrence
counties
are
contributors
to
the
nonattainment
in
the
Pittsburgh
area.

Butler
County
as
part
of
the
MSA
has
experienced
the
largest
growth
in
the
Pittsburgh
area.

EPA
has
worked
with
the
Commonwealth
to
determine
the
portions
of
Indiana,
Armstrong,
Lawrence
and
Greene
counties
with
the
predominance
of
emissions
contribution.
EPA
has
determined
that
portions
of
these
counties
will
be
designated
nonattainment.

The
Commonwealth
of
Pennsylvania
provided
extensive
documentation
to
support
a
recommendation
that
a
separate,
distinctively
local­
source
impacted,
nonattainment
area
be
designated
within
the
Pittsburgh
nonattainment
area.
The
recommended
Liberty
Borough
area
is
specified
as
the
five
municipalities
which
comprise
the
area
in
the
vicinity
of
the
Clairton
Coke
Works
which
were
previously
designated
nonattainment
for
PM­
10.
EPA
agrees
with
the
Commonwealth's
recommendation
is
designating
Glassport,
Liberty,
Lincoln
and
Port
Vue
Boroughs
and
the
City
of
Clairton
as
the
separate
Liberty/
Clairton
nonattainment
area.
The
remainder
of
Allegheny
County
is
in
the
Pittsburgh
nonattainment
area.
Please
see
TSD
for
additional
information.
3­
15
Comment:
1053­
1
Region:
3
State:
PA
Area:
Pittsburgh­
Beaver
Valley,
PA
Comment:
Governor
Rendell
urges
EPA
to
reconsider
its
proposed
PM2.5
designation
modifications,
as
they
do
not
address
the
unique,
local
PM2.5
problem
that
exists
in
the
Pittsburgh
area.
Commenter
disagrees
with
EPA's
designation
of
adjacent
counties.
EPA's
modifications
will
result
in
more
counties
needlessly
designated
nonattainment
and
more
complicated
planning
requirements,
taking
more
time
to
achieve
the
PM2.5
standard,
not
less
time.

EPA
Response:
Thank
you
for
your
letter
of
September
15,
2004,
concerning
the
process
for
designating
nonattainment
areas
for
the
fine
particulate
matter
PM2.5
air
quality
standards
in
Pennsylvania.
In
your
letter,
you
indicated
that
you
have
concerns
about
the
modifications
that
we
have
proposed
to
make
to
your
state's
initial
recommendations,
detailed
in
our
letter
of
June
29,
2004.
You
indicated
that
you
are
concerned
over
the
number
of
areas
that
are
currently
monitoring
attainment
or
lacking
monitors
that
we
have
proposed
to
add
to
the
designated
PM2.5
nonattainment
areas.
In
particular,
you
indicated
that
EPA's
modifications
to
the
Pittsburgh,
Pennsylvania
nonattainment
area,
do
not
take
account
of
the
unique,
local
PM­
2.5,
problem
that
exists
in
the
area.

A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
that
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
Thus,
even
areas
that
may
be
monitoring
even
areas
that
may
be
monitoring
attainment
or
that
lack
monitors
can
be
part
of
a
nonattainment
area,
if
appropriate.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

As
you
stated
in
your
letter,
EPA
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas
on
April
1,
2003
and
February
13,
2004.
The
guidance
states
that
EPA
intends
to
use
the
metropolitan
area
boundary
(
e.
g.
Consolidated
Metropolitan
Statistical
Area
or
Metropolitan
Statistical
Area)
as
the
presumptive
boundary
for
an
area
having
at
least
one
monitor
violating
the
PM2.5
standards.
We
believe
that
violations
in
urban
areas
commonly
are
the
result
of
contributions
from
counties
across
the
broader
metropolitan
area.

However,
the
guidance
also
states
that
in
conducting
an
overall
case­
by­
case
assessment
of
each
nonattainment
area,
EPA
will
consider
currently
available
information
related
to
nine
technical
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
density
and
degree
of
urbanization,
growth
in
the
area,
commuting
and
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

EPA
received
recommendations
from
the
State
of
Pennsylvania
for
PM2.5
designations
in
February
2004,
and
we
responded
to
these
recommendations
on
June
29,
2004.
EPA
is
3­
16
required
to
notify
States
and
Tribes
of
any
intended
modifications
to
their
recommendations
at
least
120
days
prior
to
promulgating
the
designations.
The
120­
day
period
is
signed
for
consultation
between
EPA
and
the
States
and
Tribes.
We
asked
States
to
provide
additional
information
that
they
would
like
to
be
considered
in
the
designations
process
by
September
1.
EPA
intends
to
promulgate
final
designations
in
November
2004.

Our
June
29
letter
and
the
related
technical
attachment
provided
to
the
State
of
Pennsylvania's
Department
of
Environmental
Protection
contain
a
detailed
discussion
of
the
range
of
county
contributions
to
violations
of
the
PM2.5
standards.
The
attachment
provides
our
rationale
for
the
inclusion
of
additional
counties
that
we
believe
contribute
to
violations
of
the
standards.
When
EPA
examined
available
technical
formation,
we
identified
a
number
of
counties
with
relatively
high
pollutant
emissions
adjacent
to
urban
areas
with
violations
of
the
PM2.5
standards.
We
have
included
a
number
of
these
counties
in
our
proposed
modifications
to
PM2.5
nonattainment
areas,
in
Pennsylvania
and
elsewhere,
because
of
their
contributions
to
the
nearby
air
quality
problems.

Additional
information
regarding
PM2.5
designations,
along
with
links
to
the
technical
support
documentation,
is
available
on
the
web
at
the
following
location:
http://
www.
epa.
gov/
pmdesignations/.

Comment:
1049­
1
Region:
3
State:
PA
Area:
Pittsburgh­
Beaver
Valley,
PA|
Liberty­
Clairton,
PA
Comment:
Senator
Santorum
asks
EPA
to
reconsider
the
counties
it
intends
to
designate
as
nonattainment
in
southwestern
Pennsylvania.
He
believes
doubling
the
size
of
the
nonattainment
area
will
have
a
negative
impact
on
economic
competitiveness.
He
notes
that
studies
done
at
Carnegie
Mellon
University
show
that
80%
of
the
PM2.5
in
southwestern
Pennsylvania
comes
from
other
states.
Further,
the
Monongahela
Valley
is
the
only
area
in
southwestern
Pennsylvania
that
generates
enough
emissions
to
exceed
the
standard
on
its
own.
He
suggests
a
more
concentrated
effort
in
cleaning
the
Monongahela
Valley
would
help
reduce
surrounding
counties'
PM2.5
levels.

EPA
Response:
EPA
has
reviewed
the
information
provided
by
the
Commonwealth.
However,
EPA
has
determined
that
Butler
and
part
of
Lawrence
counties
are
contributors
to
the
nonattainment
in
the
Pittsburgh
area.

Butler
County,
part
of
the
MSA,
has
experienced
the
largest
growth
in
the
Pittsburgh
area,
therefore
is
being
designated
as
nonattainment.

EPA
has
worked
with
the
Commonwealth
to
determine
the
portions
of
Indiana,
Armstrong,
Lawrence
and
Greene
counties
with
the
predominance
of
emissions
contribution.
EPA
has
determined
that
portions
of
these
counties
will
be
designated
nonattainment.
3­
17
The
Commonwealth
of
Pennsylvania
provided
extensive
documentation
to
support
a
recommendation
that
a
separate,
distinctively
local­
source
impacted,
nonattainment
area
be
designated
within
the
Pittsburgh
nonattainment
area.
The
recommended
Liberty
Borough
area
is
specified
as
the
five
municipalities
which
comprise
the
area
in
the
vicinity
of
the
Clairton
Coke
Works
which
were
previously
designated
nonattainment
for
PM10.
EPA
agrees
with
the
Commonwealth's
recommendation
and
is
designating
Glassport,
Liberty,
Lincoln
and
Port
Vue
Boroughs
and
the
City
of
Clairton
as
the
separate
Liberty/
Clairton
nonattainment
area.
The
remainder
of
Allegheny
County
is
in
the
Pittsburgh
nonattainment
area.
Please
see
TSD
for
additional
information.

Comment:
1051­
1
Region:
3
State:
PA
Area:
Pittsburgh­
Beaver
Valley,
PA
|
Johnstown,
PA|
Liberty­
Clairton,
PA
Comment:
Commenters
urge
EPA
to
rescind
the
proposed
designation
of
nine
southwestern
Pennsylvania
counties
as
nonattainment.
They
believe
EPA
must
first
develop
and
implement
regulations
to
address
transport
before
imposing
regulations
based
on
political
boundaries.
The
commenters
believe
that
EPA's
designation
of
these
counties
represents
one
of
the
worst
economic
threats
to
the
competitiveness
of
southwestern
Pennsylvania
in
more
than
a
decade.

Commenters
point
to
a
recent
report
from
Pennsylvania
DEP
that
says
that
Butler
County
does
not
contain
significant
sources
of
emissions
and
does
not
contribute
to
nonattainment
in
the
Pittsburgh
MSA.
The
commenters
propose
the
following
recommendations:

1.
EPA
should
create
a
separate
nonattainment
area
for
the
southern
Allegheny
County
where
the
region's
very
high
PM2.5
levels
are
monitored.
This
should
include
the
communities
surrounding
Liberty
Borough
and
Clairton
monitors
and
possibly
the
North
Braddock
monitor.

2.
The
counties
of
Armstrong,
Butler,
Greene,
Indiana
and
Lawrence
should
not
be
designated
as
nonattainment
since
they
do
not
have
a
violating
monitor.

3.
The
counties
of
Beaver,
Washington,
and
Westmoreland,
and
the
portion
of
Allegheny
County
outside
of
the
Monongahela
Valley
should
not
be
designated
as
nonattainment
but
should
be
designated
as
overwhelming
transport
or
transitional
areas.

4.
EPA
should
move
aggressively
to
adopt
and
implement
national
regulations
to
address
transport.

5.
All
monitors
with
the
exception
of
those
in
local
areas
in
southern
Allegheny
County
are
expected
to
reach
attainment
when
the
Interstate
Air
Rule
is
implemented,
thereby
3­
18
eliminating
the
need
to
designate
them
as
nonattainment,
while
providing
EPA
with
a
mechanism
to
track
progress
toward
attainment.

EPA
Response:
EPA
has
reviewed
the
information
provided
by
the
Commonwealth.
However,
EPA
has
determined
that
Butler
and
part
of
Lawrence
counties
are
contributors
to
the
nonattainment
in
the
Pittsburgh
area.

Butler
County,
part
of
the
MSA,
has
experienced
the
largest
growth
in
the
Pittsburgh
area,
therefore
is
being
designated
as
nonattainment.

EPA
has
worked
with
the
Commonwealth
to
determine
the
portions
of
Indiana,
Armstrong,
Lawrence
and
Greene
counties
with
the
predominance
of
emissions
contribution.
EPA
has
determined
that
portions
of
these
counties
will
be
designated
nonattainment.

The
Commonwealth
of
Pennsylvania
provided
extensive
documentation
to
support
a
recommendation
that
a
separate,
distinctively
local­
source
impacted,
nonattainment
area
be
designated
within
the
Pittsburgh
nonattainment
area.
The
recommended
Liberty
Borough
area
is
specified
as
the
five
municipalities
which
comprise
the
area
in
the
vicinity
of
the
Clairton
Coke
Works
which
were
previously
designated
nonattainment
for
PM­
10.
EPA
agrees
with
the
Commonwealth's
recommendation
is
designating
Glassport,
Liberty,
Lincoln
and
Port
Vue
Boroughs
and
the
City
of
Clairton
as
the
separate
Liberty/
Clairton
nonattainment
area.
The
remainder
of
Allegheny
County
is
in
the
Pittsburgh
nonattainment
area.
Please
see
TSD
for
additional
information.
3­
19
Comment:
1057­
1
Region:
3
State:
PA
Area:
Pittsburgh­
Beaver
Valley,
PA
|
Johnstown,
PA|
Liberty­
Clairton,
PA
Comment:
Representative
Adolph
expresses
concern
about
EPA's
proposed
designation
of
nine
counties
in
southwestern
Pennsylvania
as
nonattainment.
He
is
concerned
that
this
designation
will
affect
the
economic
development
of
southwestern
Pennsylvania
while
demonstrating
little
or
no
benefit.
Recent
studies
at
Carnegie
Mellon
University
show
that
80%
of
PM2.5
in
southwestern
Pennsylvania
is
coming
from
sources
outside
the
region.
In
fact,
EPA
data
showed
that
only
one
area
in
southwestern
Pennsylvania
is
significantly
exceeding
the
PM2.5
standard.
This
is
a
portion
of
the
Monongahela
Valley
and
is
a
result
of
a
unique
combination
of
local
emissions,
conditions,
and
monitor
placement.
Rep.
Adolph
urges
EPA
to:

1.
Create
a
separate
nonattainment
area
in
southern
Allegheny
County
where
very
high
PM2.5
levels
have
been
monitored.

2.
Consideration
should
be
given
to
not
designating
Armstrong,
Butler,
Greene
and
Indiana
Counties
as
nonattainment
given
the
fact
there
have
been
no
monitored
levels
of
PM2.5
in
these
area.

3.
Beaver,
Washington
and
Westmoreland
Counties
and
a
portion
of
Allegheny
County
outside
of
the
Monongahela
Valley
should
be
designated
as
overwhelming
transport
area.

4.
EPA
should
adopt
and
implement
national
regulations
to
address
pollutant
transport.

EPA
Response:
Thank
you
for
your
August
12,
2004
letter
to
the
U.
S.
Environmental
Protection
Agency
(
EPA)
regarding
the
intended
designations
for
the
fine
particulate
matter
(
PM2.5)
National
Ambient
Air
Quality
Standard.

As
required
by
statute
and
EPA
guidance,
the
Agency
must
designate
areas
that
include
counties
violating
the
standard,
as
well
as
nearby
counties
that
may
contribute
to
a
violation
of
the
standard,
as
nonattainment.
EPA
has
reviewed
potential
nonattainment
areas
based
on
many
factors
including
population,
traffic,
growth,
meteorology,
geography
and
jurisdictional
boundaries.
Our
analysis
indicated
that
many
of
the
counties
mentioned
in
your
letter
may
have
monitored
attainment
but
contribute
to
the
nonattainment
problem
in
an
adjacent
area.

In
EPA's
letter
dated
June
29,
2004,
we
informed
Governor
Edward
Rendell
of
our
modification
to
his
original
nonattainment
boundaries
recommendations.
The
Pennsylvania
Department
of
Environmental
Protection
(
PADEP)
is
currently
assessing
the
available
data.
As
a
result
of
this
assessment,
we
expect
PADEP
to
provide
additional
information
which
will
be
considered
in
our
decision
making.
We
will
continue
to
encourage
the
Commonwealth
to
have
an
ongoing
dialogue
with
EPA
during
the
entire
designation
process.
We
will
evaluate
your
suggestions
as
well
as
any
additional
3­
20
information
provided
by
PADEP
as
we
finalize
our
decision
on
nonattainment
boundaries.

Please
note,
EPA
is
addressing
power
plant
emissions
through
a
comprehensive
national
clean
air
strategy.
This
strategy
includes
EPA's
proposed
rule
to
reduce
nitrogen
oxides,
sulfur
dioxide
and
mercury
pollution
from
power
plants
in
the
eastern
United
States.
These
regulations
will
produce
significant
reductions
in
the
area
of
transported
pollution.

Please
see
TSD
for
additional
information
on
EPA's
designations.

Comment:
1064­
1
Region:
3
State:
PA
Area:
Pittsburgh­
Beaver
Valley,
PA
|
Johnstown,
PA|
Liberty­
Clairton,
PA
Comment:
Representative
Murtha
expresses
concern
over
EPA's
designation
of
five
additional
counties
as
nonattainment
in
southwestern
Pennsylvania.
Following
are
specific
issues
raised:

1.
Armstrong,
Butler,
Greene,
Indiana
and
Lawrence
Counties
have
no
monitor
showing
nonattainment
but
were
designated
using
a
weighted
emissions
scoring
process.
Pennsylvania
DEP
has
called
this
process
arbitrary
and
noted
that
this
scoring
process
was
never
published
for
review
and
comment.
He
urges
EPA
to
refrain
from
designating
these
counties
until
there
is
monitored
evidence
or
the
methodology
has
been
validated.

2.
Beaver,
Cambria,
Washington,
and
Westmoreland
counties
are
within
5
to
10%
of
the
PM2.5
standard
even
though
most
of
the
PM2.5
is
coming
from
out
of
state
sources.
Recent
studies
at
Carnegie
Mellon
show
that
80%
of
PM2.5
in
southwestern
Pennsylvania
comes
from
outside
the
region.
He
urges
EPA
to
create
a
provisional
category
for
these
counties
and
designate
them
as
transitional
or
overwhelming
transport.

3.
Allegheny
County
is
the
only
county
in
western
Pennsylvania
with
monitored
violations.
It
appears
that
a
small
portion
of
the
county
around
Liberty
and
Clairton
has
a
localized
problem
attributed
to
local
industrial
sources.
He
urges
EPA
to
designate
a
subcounty
or
localized
area
rather
than
listing
the
entire
county
as
nonattainment.

4.
Commenter
urges
EPA
to
move
aggressively
to
adopt
and
implement
transport
regulations
and
to
allow
marginal
or
transitional
areas
of
nonattainment
additional
time­
after
the
transport
issue
has
been
addressed­
to
assess
whether
they
remain
in
nonattainment
and
if
so,
develop
strategies
for
reaching
attainment.

EPA
Response:
Thank
you
for
your
August
13,
2004
letter
to
the
U.
S.
Environmental
Protection
Agency
(
EPA)
regarding
the
intended
designations
for
the
fine
particulate
matter
(
PM2.5)
National
Ambient
Air
Quality
Standard.
3­
21
As
required
by
statute
and
EPA
guidance,
the
Agency
must
designate
areas
that
include
counties
violating
the
standard,
as
well
as
nearby
counties
that
may
contribute
to
a
violation
of
the
standard,
as
nonattainment.
EPA
has
reviewed
potential
nonattainment
areas
based
on
many
factors
including
population,
traffic,
growth,
meteorology,
geography
and
jurisdictional
boundaries.
Our
analysis
indicated
that
many
of
the
counties
mentioned
in
your
letter
may
have
monitored
attainment
but
contribute
to
the
nonattainment
problem
in
an
adjacent
area.

In
EPA's
letter
dated
June
29,
2004,
we
informed
Governor
Edward
Rendell
of
our
modification
to
his
original
nonattainment
boundaries
recommendations.
The
Pennsylvania
Department
of
Environmental
Protection
(
PADEP)
is
currently
assessing
the
available
data.
As
a
result
of
this
assessment,
we
expect
PADEP
to
provide
additional
information
which
will
be
considered
in
our
decision
making.
We
will
continue
to
encourage
the
Commonwealth
to
have
an
ongoing
dialogue
with
EPA
during
the
entire
designation
process.
We
will
evaluate
your
suggestions
as
well
as
any
additional
information
provided
by
PADEP
as
we
finalize
our
decision
on
nonattainment
boundaries.

Please
note,
EPA
is
addressing
power
plant
emissions
through
a
comprehensive
national
clean
air
strategy.
This
strategy
includes
EPA's
proposed
rule
to
reduce
nitrogen
oxides,
sulfur
dioxide
and
mercury
pollution
from
power
plants
in
the
eastern
United
States.
These
regulations
will
produce
significant
reductions
in
the
area
of
transported
pollution.

Please
see
TSD
for
additional
information
on
EPA's
designations.

Comment:
1058­
1
Region:
3
State:
PA
Area:
Pittsburgh­
Beaver
Valley,
PA
|
Johnstown,
PA|
Liberty­
Clairton,
PA
Comment:
Representative
Hart
disagrees
with
EPA's
designation
of
nine
counties
as
nonattainment
in
southwestern
Pennsylvania
and
expresses
concern
raised
by
local
economic
development
policy
experts
and
constituents
about
the
impact
of
these
designations
on
the
economic
competitiveness
of
the
area.
Following
are
suggested
changes
to
the
PM
2.5
designations:

1.
A
separate
nonattainment
area
should
be
created
for
the
area
of
southern
Allegheny
County
where
the
region's
very
high
PM2.5
levels
are
monitored.

2.
Armstrong,
Butler,
Greene,
Indiana,
and
Lawrence
should
not
be
designated
as
nonattainment
since
they
do
not
include
a
monitor
showing
nonattainment
levels.
Too
little
is
known
about
the
causes
and
solutions
of
PM2.5
to
classify
counties
merely
because
they
are
close
to
counties
with
nonattaining
monitors.

3.
Beaver,
Washington,
and
Westmoreland
and
the
portion
of
Allegheny
County
outside
of
the
Monongahela
Valley
should
be
designated
as
overwhelming
transport.
3­
22
4.
EPA
should
move
more
aggressively
to
adopt
and
implement
national
regulations
to
address
transport.

EPA
Response:
Thank
you
for
your
August12,
2004
letter
to
the
U.
S.
Environmental
Protection
Agency
(
EPA)
regarding
the
intended
designations
for
the
fine
particulate
matter
(
PM2.5)
National
Ambient
Air
Quality
Standard.

As
required
by
statute
and
EPA
guidance,
the
Agency
must
designate
areas
that
include
counties
violating
the
standard,
as
well
as
nearby
counties
that
may
contribute
to
a
violation
of
the
standard,
as
nonattainment.
EPA
has
reviewed
potential
nonattainment
areas
based
on
many
factors
including
population,
traffic,
growth,
meteorology,
geography
and
jurisdictional
boundaries.
Our
analysis
indicated
that
many
of
the
counties
mentioned
in
your
letter
may
have
monitored
attainment
but
contribute
to
the
nonattainment
problem
in
an
adjacent
area.

In
EPA's
letter
dated
June
29,
2004,
we
informed
Governor
Edward
Rendell
of
our
modification
to
his
original
nonattainment
boundaries
recommendations.
The
Pennsylvania
Department
of
Environmental
Protection
(
PADEP)
is
currently
assessing
the
available
data.
As
a
result
of
this
assessment,
we
expect
PADEP
to
provide
additional
information
which
will
be
considered
in
our
decision
making.
We
will
continue
to
encourage
the
Commonwealth
to
have
an
ongoing
dialogue
with
EPA
during
the
entire
designation
process.
We
will
evaluate
your
suggestions
as
well
as
any
additional
information
provided
by
PADEP
as
we
finalize
our
decision
on
nonattainment
boundaries.

Please
note,
EPA
is
addressing
power
plant
emissions
through
a
comprehensive
national
clean
air
strategy.
This
strategy
includes
EPA's
proposed
rule
to
reduce
nitrogen
oxides,
sulfur
dioxide
and
mercury
pollution
from
power
plants
in
the
eastern
United
States.
These
regulations
will
produce
significant
reductions
in
the
area
of
transported
pollution.

Please
see
TSD
for
additional
information
on
EPA's
designations.

Comment:
1066­
1
Region:
3
State:
PA
Area:
Pittsburgh­
Beaver
Valley,
PA
|
Johnstown,
PA|
Liberty­
Clairton,
PA
Comment:
Commenters
urge
EPA
to
rescind
the
proposed
designations
of
nine
southwestern
Pennsylvania
counties
as
nonattainment.
They
believe
that
EPA
must
develop
and
implement
regulations
to
address
transport
of
PM2.5
across
state
boundaries
before
imposing
regulations
based
arbitrarily
on
political
boundaries.
They
believe
EPA's
designations
will
represent
one
of
the
worst
threats
to
the
economic
competitiveness
of
southwestern
Pennsylvania
in
more
than
a
decade,
while
having
little
or
no
benefit.
The
commenters
propose
the
following:
3­
23
1.
A
separate
nonattainment
area
should
be
created
for
the
area
of
southern
Allegheny
County
where
the
region's
very
high
PM2.5
levels
are
monitored.

2.
Armstrong,
Butler,
Greene,
Indiana,
and
Lawrence
counties
should
not
be
designated
as
nonattainment
since
they
do
not
include
a
monitor
showing
nonattainment
levels.
Too
little
is
known
about
the
causes
and
solutions
of
PM2.5
to
classify
counties
merely
because
they
are
close
to
counties
with
nonattaining
monitors.

3.
Beaver,
Washington,
and
Westmoreland
and
the
portion
of
Allegheny
County
outside
of
the
Monongahela
Valley
should
be
designated
as
overwhelming
transport.

4.
EPA
should
move
more
aggressively
to
adopt
and
implement
national
regulations
to
address
transport.

5.
All
monitors
in
southwestern
Pennsylvania
are
expected
to
reach
attainment
when
the
Interstate
Air
Rule
is
implemented
thereby
eliminating
the
need
for
designating
these
areas
as
nonattainment,
while
providing
EPA
with
a
mechanism
to
track
further
progress.

EPA
Response:
EPA
has
reviewed
the
information
provided
by
the
Commonwealth.
However,
EPA
has
determined
that
Butler
and
part
of
Lawrence
counties
are
contributors
to
the
nonattainment
in
the
Pittsburgh
area.

Butler
County,
part
of
the
MSA,
has
experienced
the
largest
growth
in
the
Pittsburgh
area,
therefore
is
being
designated
as
nonattainment.

EPA
has
worked
with
the
Commonwealth
to
determine
the
portions
of
Indiana,
Armstrong,
Lawrence
and
Greene
counties
with
the
predominance
of
emissions
contribution.
EPA
has
determined
that
portions
of
these
counties
will
be
designated
nonattainment.

The
Commonwealth
of
Pennsylvania
provided
extensive
documentation
to
support
a
recommendation
that
a
separate,
distinctively
local­
source
impacted,
nonattainment
area
be
designated
within
the
Pittsburgh
nonattainment
area.
The
recommended
Liberty
Borough
area
is
specified
as
the
five
municipalities
which
comprise
the
area
in
the
vicinity
of
the
Clairton
Coke
Works
which
were
previously
designated
nonattainment
for
PM­
10.
EPA
agrees
with
the
Commonwealth's
recommendation
is
designating
Glassport,
Liberty,
Lincoln
and
Port
Vue
Boroughs
and
the
City
of
Clairton
as
the
separate
Liberty/
Clairton
nonattainment
area.
The
remainder
of
Allegheny
County
is
in
the
Pittsburgh
nonattainment
area.
Please
see
TSD
for
additional
information.
3­
24
Comment:
1082­
1
Region:
3
State:
PA
Area:
Pittsburgh­
Beaver
Valley,
PA
|
Johnstown,
PA|
Liberty­
Clairton,
PA
Comment:
Sen.
Santorum
forwards
a
letter
to
EPA
and
asks
EPA
to
provide
information
regarding
comments
made
by
Mr.
Dozzi
of
Pittsburgh.

Mr.
Dozzi
urges
Sen.
Santorum
to
aggressively
oppose
EPA's
proposed
designations
of
nine
southwestern
Pennsylvania
counties
as
nonattainment.
He
believes
that
the
designations
will
threaten
the
economy
of
southwestern
Pennsylvania
with
little
air
quality
benefit.
His
organization
supports
efforts
to
clean
up
the
air
but
notes
that
the
monitors
in
southwestern
Pennsylvania
are
exceeding
the
standard
by
only
a
small
amount.
Further,
recent
studies
at
Carnegie
Mellon
show
that
as
much
as
80%
of
the
pollution
in
southwestern
Pennsylvania
comes
from
sources
outside
the
region.
He
suggests
that
efforts
to
improve
air
quality
be
concentrated
in
Monongahela
Valley,
the
only
area
exceeding
the
standard.
He
urges
Sen.
Santorum
to
contact
EPA
and
demand
the
following:

1.
A
separate
nonattainment
area
should
be
created
for
the
area
of
southern
Allegheny
County
where
the
region's
very
high
PM2.5
levels
are
monitored.

2.
Armstrong,
Butler,
Greene,
Indiana,
and
Lawrence
should
not
be
designated
as
nonattainment
since
they
do
not
contribute
significantly
to
downwind
exceedances
nor
do
they
include
a
monitor
showing
nonattainment
levels.

3.
Beaver,
Washington,
and
Westmoreland
and
the
portion
of
Allegheny
County
outside
of
the
Monongahela
Valley
should
be
designated
as
overwhelming
transport
or
transitional
areas.

4.
EPA
should
move
more
aggressively
to
adopt
and
implement
national
regulations
to
address
transport.

EPA
Response:
The
CAA
requires
EPA
to
designate
as
nonattainment
any
area
that
is
monitoring
a
violation
of
the
standard
or
that
is
contributing
to
a
violation
of
the
standard
in
a
nearby
area.
Thus,
our
designations
include
both
areas
monitoring
violations
of
the
PM2.5
standard
as
well
as
those
nearby
areas
that
are
determined
to
be
contributing
to
violations
at
the
affected
monitors.
The
issue
of
regional
transport
primarily
concerns
long
range
transport
­
i.
e.,
transport
from
areas
that
are
not
"
nearby".
EPA
agrees
that
this
is
an
important
issue
and
is
currently
addressing
the
issue
of
regionally
transported
emissions
via
the
Clean
Air
Interstate
Rule
(
CAIR).

EPA
has
reviewed
the
information
provided
by
the
Commonwealth.
However,
EPA
has
determined
that
Butler
and
part
of
Lawrence
counties
are
contributors
to
the
nonattainment
in
the
Pittsburgh
area.
3­
25
Butler
County,
part
of
the
MSA,
has
experienced
the
largest
growth
in
the
Pittsburgh
area,
therefore
is
being
designated
as
nonattainment.

EPA
has
worked
with
the
Commonwealth
to
determine
the
portions
of
Indiana,
Armstrong,
Lawrence
and
Greene
counties
with
the
predominance
of
emissions
contribution.
EPA
has
determined
that
portions
of
these
counties
will
be
designated
nonattainment.

The
Commonwealth
of
Pennsylvania
provided
extensive
documentation
to
support
a
recommendation
that
a
separate,
distinctively
local­
source
impacted,
nonattainment
area
be
designated
within
the
Pittsburgh
nonattainment
area.
The
recommended
Liberty
Borough
area
is
specified
as
the
five
municipalities
which
comprise
the
area
in
the
vicinity
of
the
Clairton
Coke
Works
which
were
previously
designated
nonattainment
for
PM10.
EPA
agrees
with
the
Commonwealth's
recommendation
is
designating
Glassport,
Liberty,
Lincoln
and
Port
Vue
Boroughs
and
the
City
of
Clairton
as
the
separate
Liberty/
Clairton
nonattainment
area.
The
remainder
of
Allegheny
County
is
in
the
Pittsburgh
nonattainment
area.
Please
see
TSD
for
additional
information.

Comment:
1028­
2
Region:
3
State:
PA
Area:
Youngstown­
Warren­
Sharon,
OH­
PA
Comment:
Pennsylvania
DEP
believes
Mercer
County
should
be
attainment
because
Mercer
County:

1.
Is
monitoring
attainment
2.
Has
low
population
density
3.
Has
low
VMT
4.
Has
low
emissions
which
are
predominantly
downwind
of
the
violating
monitors
and
would
contribute
very
little
to
nonattainment
in
the
Youngstown
area.

PA
DEP
also
contends
that
EPA
has
been
inconsistent
in
applying
MSA
boundaries
for
nonattainment
designations.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
EPA's
decisions
on
the
State's
recommendations
are
contained
in
the
TSD.
3­
26
Comment:
1001­
1
Region:
3
State:
VA
Area:
Washington,
DC­
MD­
VA
Comment:
Commenter
writes
on
behalf
of
Governor
Warner
regarding
EPA's
proposed
designations
for
PM2.5.
He
states
the
Commonwealth
of
Virginia
is
disappointed
that
EPA
chose
to
designate
9
Virginia
localities
as
nonattainment.
For
the
period
from
2001­
2003
the
three­
year
averages
of
air
quality
monitoring
data
in
Northern
Virginia
all
show
attainment
of
the
PM2.5
standards.
The
commenter
notes
Virginia
is
meeting
with
Region
3
to
resolve
the
issues
but
believes
that
the
talks
would
be
more
productive
if
EPA
releases
the
implementation
guidance
for
PM2.5
by
September
1,
2004.

EPA
Response:
Thank
you
for
your
letter
of
July
19,
2004
responding
to
the
U.
S.
Environmental
Protection
Agency
(
EPA)
proposed
designations
of
areas
for
the
fine
particulate
matter
(
PM2.5)
national
ambient
air
quality
standard
in
Virginia.

As
required
by
statute
and
EPA
guidance,
the
Agency
must
designate
areas
that
include
counties
violating
the
standard,
as
well
as
nearby
counties
that
may
contribute
to
a
violation
of
the
standard,
as
nonattainment.
Thus,
while
no
counties
in
Virginia
have
monitored
a
violation,
our
analysis
indicated
that
the
counties
and
cities
we
have
proposed
for
designation
as
nonattainment
contribute
to
the
nonattainment
problem
in
Washington,
D.
C.
area.
This
analysis
included
factors
such
as
population,
traffic,
growth,
meteorology,
geography
and
jurisdictional
boundaries.
During
our
meeting
on
July
29,
2004
with
Mr.
John
Daniel,
Director
of
Virginia's
Air
Division,
we
provided
a
detailed
explanation
of
the
factors
that
led
up
to
our
proposed
designations.

As
noted
in
our
letter
of
June
29,
2004
to
Governor
Mark
Warner,
we
are
interested
in
and
will
consider
any
additional
information
that
you
can
provide
to
support
your
position.
This
information
is
requested
by
September
1,
2004,
but
we
encourage
the
Commonwealth
to
have
a
continuing
dialogue
with
EPA
during
the
entire
designation
process.

EPA
is
currently
working
on
the
Implementation
Guidance
for
PM2.5
and
we
will
keep
you
informed
of
its
status.
Please
see
TSD
for
additional
information
on
EPA's
designations.

Comment:
1013a­
46
Region:
3
State:
VA
Area:
Washington,
DC­
MD­
VA
Comment:
EPA
has
failed
to
recommend
that
eight
Virginia
counties
and
cities
(
Clarke,
Fauquier,
Frederick,
Spotsylvania,
Stafford,
and
Warren
Counties;
Fredericksburg
and
Winchester
Cities)
in
this
CMSA
be
designated
as
nonattainment
area;
the
entire
Washington
CMSA
must
be
designated
nonattainment.
None
of
these
areas
appear
to
3­
27
have
monitors
in
order
to
prove
that
they
are
indeed
attaining
the
PM2.5
standard.
According
to
EPA's
letter
to
the
state,
the
Stafford,
Spotsylvania,
Fauquier,
and
Fredericksburg
areas
all
have
a
majority
of
people
commuting
to
another
county.
In
addition,
emissions
in
Fauquier,
Spotsylvania,
Stafford,
and
Warren
Counties
are
not
low
and
need
to
be
taken
into
consideration
in
the
SIP
planning
process.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

Based
on
weighted
emissions
screening
and
the
combined
factor
analysis,
these
counties
are
considered
to
have
low
contribution
to
the
nonattainment
area
and
were
excluded
from
the
presumptive
boundaries
of
the
nonattainment
area.
Please
see
the
TSD
for
additional
information
on
the
combined
factor
analysis.

Comment:
1052­
1
Region:
3
State:
VA
Area:
Washington,
DC­
MD­
VA
Comment:
Commenter
believes
that
actual
monitoring
should
be
the
basis
for
designations
but
supports
the
idea
of
calling
certain
areas
"
control
areas"
where
EPA
can
demonstrate
a
real
contribution
to
adjacent
counties
that
exceed
the
PM2.5
NAAQS.

Commenter
believes
that
EPA
can
make
a
reasonable
case
that
Alexandria,
Arlington,
and
Fairfax
counties
contribute
pollutants
but
does
not
believe
Prince
William
and
Loudoun
Counties
contribute.
3­
28
EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

To
be
consistent
with
our
guidance
and
to
ensure
national
consistency,
EPA
can
not
endorse
the
control
areas
suggested
by
Virginia.

Adequate
technical
information
was
not
provided
to
demonstrate
that
these
two
counties
(
Prince
William
and
Loudon)
did
not
contribute
to
violations
in
the
CMSA/
MSA.
See
EPA
analysis
in
the
TSD
to
this
document
for
our
analysis
concerning
this
area.

Comment:
1013a­
8
Region:
3
State:
VA
|
DC
|
MD
Area:
Baltimore,
MD|
Washington,
DC­
MD­
VA|
Martinsburg,
WV­
Hagerstown,
MD
Comment:
The
EPA
has
failed
to
recommend
that
the
Washington­
Baltimore
CMSA
be
designated
as
one
nonattainment
area;
this
area
must
be
designated
as
one
nonattainment
area.

EPA
Response:
Although
large
metropolitan
areas
such
as
the
Washington
DC
CMSA
may
be
considered
as
one
large
area
in
the
designation
process,
EPA
agreed
with
Maryland's
recommendations
to
split
them
into
the
smaller
MSAs.
The
smaller
areas
have
separate
air
quality
planning
processes
that
EPA
believes
would
be
more
practical
and
productive
than
having
one
large
area.
EPA
also
seeks
to
maximize
consistency
between
the
PM2.5
and
the
8­
hour
ozone
designations.
Keeping
these
areas
separate
under
PM2.5
would
be
consistent
with
the
designations
under
8­
hour
ozone.
3­
29
Comment:
1013a­
8
Region:
3
State:
VA
|
DC
|
MD
Area:
Washington,
DC­
MD­
VA
|
Baltimore,
MD|
Martinsburg,
WV­
Hagerstown,
MD
Comment:
The
EPA
has
failed
to
recommend
that
the
Washington­
Baltimore
CMSA
be
designated
as
one
nonattainment
area;
this
area
must
be
designated
as
one
nonattainment
area.

EPA
Response:
Although
large
metropolitan
areas
such
as
the
Washington
DC
CMSA
may
be
considered
as
one
large
area
in
the
designation
process,
EPA
agreed
with
Maryland's
recommendations
to
split
them
into
the
smaller
MSAs.
The
smaller
areas
have
separate
air
quality
planning
processes
that
EPA
believes
would
be
more
practical
and
productive
than
having
one
large
area.
EPA
also
seeks
to
maximize
consistency
between
the
PM2.5
and
the
8­
hour
ozone
designations.
Keeping
these
areas
separate
under
PM2.5
would
be
consistent
with
the
designations
under
8­
hour
ozone.

Comment:
1013a­
48
Region:
3
State:
WV
Area:
|
Martinsburg,
WV­
Hagerstown,
MD
Comment:
EPA
failed
to
include
Morgan
County
in
the
recommended
nonattainment
area;
this
county
is
part
of
the
Hagerstown
MSA
and
must
be
included
in
the
nonattainment
area.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
3­
30
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

Evaluating
the
Hagerstown­
Martinsburg
CBSA,
Morgan
County
has
low
contribution
to
the
area
based
on
emissions,
population
and
commuting
and
therefore
has
not
been
designated
as
a
nonattainment
county.

Comment:
1013a­
49
Region:
3
State:
WV
Area:
Marion
County,
WV
Comment:
Fairmont
CMSA
counties,
Doddridge
and
Taylor
must
be
included
in
the
nonattainment
area.
In
addition,
Preston
County,
home
to
the
Albright
coal­
fired
power
plant
that
emitted
over
20,000
tons
of
SO2
and
over
4,000
tons
of
NOX
in
2002,
should
also
be
included
in
the
nonattainment
area.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

Based
on
low
emissions,
population
and
commuting,
geography
and
meteorology,
EPA
believes
there
is
minimal
contribution
to
the
nonattainment
area
from
Doddridge
and
Taylor
counties.
In
addition,
EPA
reviewed
the
potential
contribution
from
Preston
County
with
moderate
emissions
contribution
and
however,
based
on
the
geography
and
meteorology,
EPA
feels
this
county
does
not
significantly
contribute
to
the
nonattainment
in
Marion
County.
3­
31
Comment:
1046­
1
Region:
3
State:
WV
Area:
Marion
County,
WV
Comment:
Commenter
requests
EPA
to
finalize
the
PM2.5
nonattainment
area
designation
for
Monongalia
County,
WV
on
the
basis
of
the
following:

1.
The
PM
monitor
at
the
Morgantown
airport
has
recently
measured
just
below,
and
in
past
years,
above
the
PM2.5
standard.

2.
A
monitor
is
needed
down
in
the
valley
where
the
power
plants
and
their
pollution
are
located.
There
are
frequent
temperature
inversions
in
the
valley
and
a
monitor
on
the
rim
is
a
disservice.

3.
The
county
north
of
Monongalia
and
the
county
south
are
both
nonattainment
and
have
been
for
a
while.

4.
The
results
of
monitoring
in
Marion
County
(
south
of
Monongalia)
indicate
nonattainment
even
though
Marion
County
emissions
are
five
times
lower
than
in
Monongalia.
The
CAA
requires
violating
areas
and
nearby
contributing
areas
to
be
designated
nonattainment.

5.
There
are
large
uncontrolled
sources
located
in
Monongalia
County
and
near
the
county
border.

6.
Monongalia
has
two
coal
burning
power
plants
and
has
permitted
a
third.
The
population
is
being
asked
to
bear
too
high
of
a
pollution
burden.

EPA
Response:
In
the
June
2004
letters
from
EPA
to
the
States
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
extend
to
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.

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.
3­
32
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
freestanding
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.

EPA
has
determined
that
a
portion
of
Monongalia
County
does
contribute
to
the
Marion
nonattainment
area.
Therefore,
we
are
designating
that
portion
of
the
county
as
nonattainment.

Comment:
1045­
1
Region:
3
State:
WV
Area:
Marion
County,
WV
Comment:
Commenters
express
concern
that
EPA
intends
to
designate
Monongalia
County
as
nonattainment.
They
do
not
believe
the
designation
is
imperative,
nor
in
the
best
interest
of
the
future
development
in
the
county.

They
do
not
believe
they
have
had
sufficient
time
to
digest
the
consequences
of
the
designation
in
order
to
give
a
proper
response.
They
note
that
no
other
counties
in
WV
have
faced
this
issue
until
now
and
that
WV
law
does
not
allow
commissions
to
legislate
corrective
measures.
The
commenters
would
like
the
opportunity
to
discuss
with
EPA
other
ways
to
improve
air
quality
without
being
forced
into
a
nonattainment
area.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
3­
33
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

In
the
June
2004
letters
from
EPA
to
the
States
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
extend
to
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.

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.

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
freestanding
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.
EPA
as
determined
that
a
portion
of
Monongalia
County
does
contribute
to
the
Marion
nonattainment
area.
Therefore,
we
are
designating
that
portion
of
the
county
as
nonattainment.

Comment:
1050­
1
Region:
3
State:
WV
Area:
Marion
County,
WV
Comment:
The
commenter
supports
West
Virginia's
proposed
recommendation
of
Monongalia
County
as
attainment
for
PM2.5.
The
air
quality
in
Monongalia
County
meets
the
EPA's
standards
and
was
only
designated
because
of
the
power
plants
located
in
the
county.
West
Virginia
DEP
researched
the
issue
and
found
that
Monongalia
did
not
contribute
to
nonattainment
in
Marion
County
when
the
air
readings
were
at
their
worst.
EPA's
decision
to
designate
the
county
as
nonattainment
is
a
clear
departure
from
past
methods
and
will
be
a
setback
to
the
area.

EPA
Response:
As
a
part
of
the
process
to
determine
what
areas
should
be
designated
as
nonattainment,
EPA
first
uses
the
Federal
Reference
Method
(
FRM)
monitors
to
3­
34
determine
violations
of
the
NAAQS.
The
FRM
monitors
measure
the
total
mass
of
PM2.5
in
the
ambient
air.
These
monitors
are
used
to
calculate
the
values
that
are
compared
to
the
NAAQS
(
15
µ
g/
m3)
in
deciding
if
the
ambient
air
in
an
area
exceeds
the
NAAQS.

Second,
once
an
area
has
a
monitor
violating
the
NAAQS,
EPA
uses
the
speciated
PM2.5
air
quality
data,
along
with
other
data,
to
help
determine
which
counties
in
the
area
are
contributing
to
the
violation.
In
identifying
counties
that
contribute
to
an
area's
violating
air
quality,
it
is
important
to
give
more
weight
to
emissions
(
sources)
that
contribute
to
the
excess
PM2.5
in
the
urban
area.
For
example,
a
ton
of
nitrogen
oxide
emitted
within
an
area
contributes
less
to
the
PM2.5
in
that
area
than
a
ton
of
organic
carbon
emissions.
Nitrogen
oxide
takes
time
to
form
into
PM2.5
in
the
atmosphere
and
therefore
is
more
of
a
regional
pollutant.
In
addition,
it
will
be
important
to
understand
which
emissions
are
mostly
contributing
to
an
area's
PM2.5
level
in
determining
what
sources
could
be
effectively
controlled
within
the
area.

To
give
each
county
in
an
urban
area
the
proper
"
weight"
for
their
"
contributing"
emissions,
the
emissions
in
the
county
must
be
adjusted
in
two
steps.
In
step
1,
we
must
determine
the
county's
percentage
of
the
violating
area's
total
emissions.
In
step
2,
we
adjust
this
percentage
by
the
violating
area's
excess
urban
emissions
for
the
pertinent
speciated
PM2.5
component.
In
doing
this,
we
calculate
the
excess
levels
associated
with
sulfates,
nitrates,
carbonaceous
matter
and
crustal
material.
These
components
represent
the
vast
majority
of
chemicals
that
make
up
PM2.5
in
urban
areas.

The
calculated
urban
excess
for
each
of
the
four
components
is
the
difference
between
the
speciated
PM2.5
components
for
an
urban
area
and
speciated
components
from
a
near­
by
rural
area.
While
it
may
seem
best
to
choose
a
"
rural"
FRM
(
total
mass)
monitor
and
an
"
urban"
FRM
monitor
for
purposes
of
estimating
the
mass
of
the
urban
excess,
this
would
not
allow
us
to
relate
the
air
quality
levels
to
the
area's
emissions.
This
situation
is
one
of
the
main
reasons
for
a
monitoring
network
for
speciated
PM2.5.
Accordingly,
we
are
using
the
speciated
PM2.5
data
from
rural
and
urban
monitors,
along
with
estimates
of
emissions
within
the
area,
to
identify
the
urban
sources
with
the
greatest
contribution
to
the
urban
excess
PM2.5.

It
is
also
important
to
note
that
the
PM2.5
(
air
quality)
weighted
emissions
(
and
scores)
are
considered
in
the
context
of
all
the
relevant
factors
in
determining
the
boundary
of
a
nonattainment
area.
We
consider
the
other
factors,
in
addition
to
air
quality
and
emissions,
in
identifying
the
counties
that
should
comprise
the
nonattainment
area.
As
described
above,
the
speciated
PM2.5
weighted
emissions
are
used
in
developing
a
ranking
score
(
weight)
for
each
county
in
a
potential
nonattainment
area.
In
developing
these
scores,
we
do
not
intend
that
they
be
used
in
"
bright­
line"
manner.
Rather,
they
offer
a
basis
for
looking
closest
at
the
counties
in
an
area
that
may
contribute
to
the
most
to
the
elevated
PM2.5
in
the
area.
For
the
counties
with
the
highest
score,
we
look
at
the
other
information
as
we
determine
the
collection
of
counties
in
a
nonattainment
area.
3­
35
In
the
June
2004
letters
from
EPA
to
the
States
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
extend
to
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.

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.

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
freestanding
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.
EPA
has
determined
that
a
portion
of
Monongalia
County
does
contribute
to
the
Marion
nonattainment
area.
Therefore,
we
are
designating
that
portion
of
the
county
as
nonattainment.

Comment:
1061­
1
Region:
3
State:
WV
Area:
Marion
County,
WV
Comment:
Commenter
requests
that
EPA
ignore
the
campaign
of
the
West
Virginia
Association
of
Counties
and
designate
Monongalia
County
nonattainment.
Commenter
notes
the
following:

1.
Monitored
values
in
Monongalia
County
are
only
slightly
below
the
limits
and
this
is
without
the
emissions
from
an
already
permitted
power
plant.

2.
Emissions
from
Monongalia
County
not
only
impact
Marion
County
but
also
impact
Greene
and
Fayette
Counties
in
Pennsylvania.

3.
The
greatest
source
of
pollution
in
Monongalia
County
is
the
grandfathered
Fort
Martin
power
plant.
A
nonattainment
designation
might
force
this
plant
to
clean
up
its
emissions.
3­
36
EPA
Response:
In
the
June
2004
letters
from
EPA
to
the
States
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
extend
to
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.

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.

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.
EPA
has
determined
that
a
portion
of
Monongalia
County
does
contribute
to
the
Marion
nonattainment
area.
Therefore,
we
are
designating
that
portion
of
the
county
as
nonattainment.

Comment:
1063­
1
Region:
3
State:
WV
Area:
Marion
County,
WV
Comment:
Commenter
expresses
strong
support
for
the
designation
of
Monongalia
County
as
nonattainment.
He
notes
that
this
county
is
home
to
one
of
the
most
polluting
power
plants
in
the
state
and
yet
another
plant
has
been
permitted
for
the
area.
He
believes
designating
the
county
nonattainment
will
ensure
that
the
county
starts
planning
now
for
cleaner
air.

EPA
Response:
In
the
June
2004
letters
from
EPA
to
the
States
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
extend
to
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.
3­
37
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.

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
freestanding
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.
EPA
as
determined
that
a
portion
of
Monongalia
County
does
contribute
to
the
Marion
nonattainment
area.
Therefore,
we
are
designating
that
portion
of
the
county
as
nonattainment.

Comment:
1056­
1
Region:
3
State:
WV
Area:
Martinsburg,
WV­
Hagerstown,
MD
|
Charleston,
WV
Comment:
1.
The
commenters
are
concerned
about
EPA's
proposed
PM2.5
designations
in
West
Virginia.
They
note
EPA's
actions
will
have
a
significant
adverse
impact
on
existing
business
and
on
the
prospects
for
economic
expansion
in
West
Virginia.

2.
The
commenters
believe
the
CAIR
Rule
and
the
NOx
SIP
call
are
the
only
controls
needed
to
achieve
the
attainment
of
the
PM2.5
standard
in
West
Virginia.

3.
EPA's
inclusion
of
adjacent
counties
within
the
nonattainment
area
is
without
justification
and
undermines
the
Agency's
emission
trading
programs.

a.
The
inclusion
of
adjacent
counties
not
supported
by
modeling
data.
To
the
contrary,
EPA
has
computer
modeling
data
that
demonstrates
that
all
nonattainment
areas
in
West
Virginia
will
be
in
attainment
as
a
result
of
the
CAIR
rule.

b.
EPA
lacks
the
authority
to
base
PM2.5
designations
on
any
considerations
other
than
air
quality
monitoring
data.

c.
Because
EPA
ignores
reasonable
alternatives
to
nonattainment
designations,
its
position
on
PM2.5
designations
in
West
Virginia
is
arbitrary.
3­
38
d.
EPA's
reliance
on
the
level
of
control
of
emission
sources
in
a
county
when
determining
whether
to
designate
that
county
is
inconsistent
with
the
EPA
trading
programs.

EPA
Response:
Thank
you
for
your
letter
of
August
31,
2004
to
Regional
Administrator
Welsh
regarding
the
intended
designations
for
the
fine
particulate
matter
National
Ambient
Air
Quality
Standard.

As
required
by
statute
and
the
U.
S.
Environmental
Protection
Agency
(
EPA)
guidance,
the
Agency
must
designate
areas
that
include
counties
violating
the
standard,
as
well
as
nearby
counties
that
may
contribute
to
a
violation
of
the
standard,
as
nonattainment.
EPA
has
reviewed
potential
nonattainment
areas
based
on
many
factors
such
as
population,
traffic,
growth,
meteorology,
geography
and
jurisdictional
boundaries.

In
EPA's
letter
dated
June
29,
2004,
we
informed
Governor
Bob
Wise
of
our
modification
to
his
original
nonattainment
boundaries
recommendations
as
well
as
provided
information.
The
West
Virginia
Department
of
Environmental
Protection
(
WVDEP)
provided
additional
information
for
our
review
on
August
31,
2004.
We
will
evaluate
your
suggestions
and
the
additional
information
provided
by
WVDEP
as
we
finalize
our
decision
on
nonattainment
boundaries.

Please
note,
EPA
is
addressing
power
plant
emissions
through
a
comprehensive
national
clean
air
strategy.
This
strategy
includes
EPA's
proposed
rule
to
reduce
nitrogen
oxides,
sulfur
dioxide
and
mercury
pollution
from
power
plants
in
the
eastern
United
States.
These
regulations
will
produce
significant
reductions
in
the
area
of
transported
pollution.

Please
see
TSD
for
additional
information
on
EPA's
designations.

Comment:
1013a­
47
Region:
3
State:
WV
Area:
Huntington­
Ashland,
WV­
KY­
OH
Comment:
Boone,
Clay
and
Lincoln
Counties
are
all
part
of
the
Charleston
MSA
and
must
be
included
in
the
nonattainment
area;
EPA
has
failed
to
include
these
counties
in
its
recommendation.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
3­
39
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

Based
on
low
emissions,
population
and
commuting,
as
well
as
a
review
of
monitored
data
measured
in
Raleigh
County,
EPA
believes
there
is
minimal
contribution
to
the
nonattainment
area
from
Boone,
Clay
and
Lincoln
counties.

Comment:
1044­
1
Region:
3
State:
WV
Area:
Charleston,
WV
Comment:
Commenters,
representing
an
economic
development
organization,
believe
that
EPA's
position
with
regards
to
Mason
County
is
flawed
both
scientifically
and
in
regards
to
EPA's
own
policies.
Any
nonattainment
designation
has
serious
impacts
on
economic
development.
This
makes
recruiting
new
businesses
all
but
impossible.

1.
EPA
needs
to
reevaluate
the
designation
of
Mason
County
as
nonattainment
using
facts,
data,
and
modeling
before
it
is
adversely
affects
economic
development
for
no
environmental
benefit.

2.
EPA
did
not
take
into
account
the
reductions
that
programs
like
the
NOx
SIP
call
and
the
proposed
CAIR
will
produce.

3.
Modeling
demonstrates
that
all
of
West
Virginia
will
be
in
attainment
due
to
the
CAIR
Rule.
EPA
should
rely
on
reliable
tools
like
modeling
instead
of
relying
on
the
size
of
an
emission
in
an
adjacent
county,
weighed
by
meteorology,
as
its
major
factor
in
reaching
its
conclusion.

EPA
Response:
EPA
cannot
base
an
area's
designation
on
projected
air
quality
or
on
proposed
legislation.
EPA
agrees
that
it
is
important
to
have
programs
that
address
emissions
on
a
national
and
regional
scale.
EPA
is
addressing
power
plant
emissions
through
a
comprehensive
national
clean
air
strategy.
This
strategy
includes
EPA's
proposed
rule
to
reduce
nitrogen
oxides,
sulfur
dioxide
and
mercury
pollution
from
power
plants
in
the
eastern
United
States.
These
regulations
will
produce
significant
reductions
in
the
area
of
transported
pollution.
3­
40
Comment:
1048a­
1
Region:
3
State:
WV
Area:
Charleston,
WV
|
Parkersburg­
Marietta,
WV­
OH
|
Huntington­
Ashland,
WV­
KY­
OH|
Marion
County,
WV
Comment:
Senator
Byrd
requested
EPA
to
comment
on
a
letter
he
received
from
West
Virginia
DEP.
The
letter
from
West
Virginia
is
summarized
below:

1.
West
Virginia
DEP
concurs
with
EPA's
recommendations
for
12
counties
but
by
designating
four
additional
counties
as
nonattainment,
EPA
has
made
a
radical
departure
from
the
approach
used
in
the
recent
8­
hour
ozone
designations.
Two
of
the
four
counties
EPA
added
are
monitoring
attainment.

2.
EPA
changed
its
policy
for
the
designation
of
nonattainment
boundaries
from
federally
defined
MSAs
and
CMSAs
to
counties
adjacent
to
MSAs
and
CMSAs
with
air
pollutant
emissions
from
power
plants.
This
policy
is
arbitrary
and
will
unnecessarily
subject
these
counties
to
two
overlapping
regulatory
programs­
the
nonattainment
program
and
the
CAIR.

3.
EPA's
policy
is
a
very
strong
disincentive
for
economic
development
and
because
of
transportation
conformity,
may
delay
the
development
and
construction
of
the
highway
infrastructure.

EPA
Response:
Pleasants,
Mason,
Monongalia
and
Harrison
do
not
have
a
monitor
that
is
violating
the
PM2.5
standard
although
it
is
adjacent
to
several
counties
in
nonattainment
areas
that
are
monitoring
unhealthful
air
quality
in
excess
of
the
national
standard.
The
CAA
defines
nonattainment
as
an
area
that
is
violating
the
standard
or
contributing
to
a
violation
of
the
standard
in
a
nearby
area.
The
state
provided
technical
information
pertaining
to
the
county
and
satisfactorily
demonstrated
to
EPA
that
part
of
the
county
can
be
designated
as
attainment.
Therefore
large
portions
of
the
above
referenced
counties
will
be
designated
as
attainment
while
small
tax
districts
containing
significant
emission
sources
will
be
designated
as
nonattainment.

In
the
June
2004
letters
from
EPA
to
the
States
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
extend
to
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.

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
3­
41
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
freestanding
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.

Comment:
1048b­
1
Region:
3
State:
WV
Area:
Charleston,
WV
|
Parkersburg­
Marietta,
WV­
OH|
Huntington­
Ashland,
WVKY
OH|
Marion
County,
WV
Comment:
Representative
Alan
Mollohan
asked
Gov.
Leavitt
to
address
the
concerns
of
Stephanie
Timmermeyer
of
West
Virginia
DEP.
The
letter
from
Ms.
Timmermeyer
is
summarized
below:

1.
West
Virginia
DEP
concurs
with
EPA's
recommendations
for
12
counties
but
by
designating
four
additional
counties
as
nonattainment,
EPA
has
made
a
radical
departure
from
the
approach
used
in
the
recent
8­
hour
ozone
designations.
Two
of
the
four
counties
EPA
added
are
monitoring
attainment.

2.
EPA
changed
its
policy
for
the
designation
of
nonattainment
boundaries
from
federally
defined
MSAs
and
CMSAs
to
counties
adjacent
to
MSAs
and
CMSAs
with
air
pollutant
emissions
from
power
plants.
This
policy
is
arbitrary
and
will
unnecessarily
subject
these
counties
to
two
overlapping
regulatory
programs­
the
nonattainment
program
and
the
CAIR.

3.
EPA's
policy
is
a
very
strong
disincentive
for
economic
development
and
because
of
transportation
conformity,
may
delay
the
development
and
construction
of
the
highway
infrastructure.

EPA
Response:
In
the
June
2004
letters
from
EPA
to
the
States
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
extend
to
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.
3­
42
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.

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
freestanding
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.

Comment:
1062­
1
Region:
3
State:
WV
Area:
Charleston,
WV
|
Parkersburg­
Marietta,
WV­
OH
|
Huntington­
Ashland,
WVKY
OH|
Marion
County,
WV
Comment:
1.
Commenter
supports
EPA's
decision
to
designate
Harrison,
Mason,
Monongalia,
and
Pleasants
Counties
in
West
Virginia
as
nonattainment.
This
status
should
be
retained
until
such
time
as
large
pollution
sources
install
and
operate
best
available
pollution
controls
and
all
citizens
enjoy
the
benefits
of
cleaner
air.

2.
EPA
should
require
West
Virginia
DEP
to
offer
a
clear
and
convincing
demonstration
that
counties
that
are
currently
monitoring
nonattainment
(
such
as
Cabell,
Kanawha,
Marion,
Putnam,
or
Wood)
will
be
able
to
come
into
attainment
without
requiring
cleanup
of
upwind
sources
in
adjacent
counties,
before
deleting
any
of
the
four
adjacent
counties
(
Harrison,
Mason,
Monongalia
or
Pleasants)
from
the
nonattainment
designation.

3.
EPA
should
work
with
all
local
stakeholders
to
develop
flexible
mechanisms
to
encourage
the
fastest
practical
clean
up
of
our
air.

4.
EPA
should
also
finalize
its
fine
particle
implementation
guidance
as
soon
as
possible,
so
that
all
parties
are
aware
of
the
requirements
to
achieve
attainment.

5.
Finally,
EPA's
final
implementation
guidance
should
include
provisions
for
early
removal
from
the
nonattainment
status
for
counties
that
attain
the
health
standards
and
implement
controls
on
all
significant
pollution
sources
contributing
to
nonattainment
in
adjacent
areas.
3­
43
EPA
Response:
In
the
June
2004
letters
from
EPA
to
the
States
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
extend
to
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.

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.

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
freestanding
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.

Comment:
1018­
1
Region:
3
State:
WV
Area:
Charleston,
WV
|
Parkersburg­
Marietta,
WV­
OH
|
Huntington­
Ashland,
WV­
KY­
OH|
Marion
County,
WV
Comment:
West
Virginia
DEP
maintains
that
its
original
recommendations
establish
the
appropriate
PM2.5
nonattainment
areas
and
boundaries.
The
commenter
considers
EPA's
addition
of
four
counties
(
Harrison,
Mason,
Monongalia,
and
Pleasants)
unwarranted
and
inconsistent
with
previous
federal
guidance
and
the
approach
taken
under
the
8­
hour
ozone
designations.
The
West
Virginia
DEP
followed
the
federal
boundary
guidance
and
recommended
entire
MSAs
as
the
presumptive
nonattainment
area.
These
four
counties
should
be
withdrawn
from
the
final
nonattainment
designations.

EPA
disregards
monitoring
data
in
Monongalia
and
Harrison
Counties
that
show
attainment.
EPA
cites
that
the
additional
counties
contain
large
emitting
facilities
that
allegedly
contribute
to
violations
in
nonattainment
areas.
West
Virginia
observes
that
these
sources
which
are
adjacent
to
or
near
the
primary
PM2.5
nonattainment
areas
would
be
assessed
as
to
their
impact
in
any
nonattainment
evaluations
such
as
modeling,
3­
44
attainment
demonstrations,
or
control
strategy
development.
That
analysis
would
be
regional
in
scope
and
include
the
large
emitters,
which
would
eliminate
the
need
to
expand
the
boundaries
to
include
an
adjacent
county.
West
Virginia
DEP
possesses
the
authority
to
regulate
any
source
within
the
state
that
may
require
emission
controls
to
achieve
and
maintain
the
NAAQS.

Regarding
the
weighted
emissions
score,
the
commenter
has
serious
concerns
about
the
data
used
to
calculate
the
score.
EPA
has
paired
a
rural
monitor
with
an
urban
STN
monitor.
The
principles
of
collection
and
analysis
for
these
two
monitor
types
and
programs
are
distinctly
different.
It
is
impossible
to
reach
valid
conclusions
about
the
representativeness
of
the
data.

In
an
effort
to
further
evaluate
EPA's
position,
West
Virginia
DEP
analyzed
certain
elevated
PM2.5
days
using
back
trajectory
analyses.
(
The
back
trajectory
analyses
are
attached)
These
analyses
indicated
that
during
high
PM2.5
days,
the
adjacent
counties
were
not
likely
contributors.
Only
Mason
County
may
be
an
exception.
As
it
is
subjected
to
the
meteorological
influence
of
the
Ohio
River
Valley,
it
appears
to
be
upwind
and
within
the
trajectory
vector
during
some
of
the
high
days
evaluated
in
the
analysis.
However,
culpability
should
not
be
considered
conclusive.
That
entire
sub
region
of
the
Ohio
River
Valley
contains
many
large
emitting
sources,
which
could
just
as
easily
impact
the
violating
monitor.
These
facilities
are
almost
certainly
going
to
be
regulated
through
other
programs
including
CAIR.
Based
upon
these
considerations,
West
Virginia
DEP
strongly
encourages
EPA
to
remove
all
four
additional
counties
from
the
PM2.5
nonattainment
areas.
If
EPA
inappropriately
acts
contrarily
to
the
State's
recommendations,
then
West
Virginia
DEP
believes
that
EPA
should
designate
only
portions
of
those
counties
that
EPA
wants
to
add.

Additionally,
EPA
continues
to
place
the
states
in
the
untenable
position
of
recommending
designations
in
the
absence
of
a
final
implementation
rule
or
proposal.
States
can
have
little
certainty
about
the
consequences
of
nonattainment
until
the
implementation
rule
is
finalized.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
3­
45
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.
Please
see
TSD
for
additional
information
on
EPA's
designations.

Comment:
1016­
1
Region:
3
State:
WV
Area:
Parkersburg­
Marietta,
WV­
OH
Comment:
The
Commenter,
on
behalf
of
the
Pleasants
County
Development
Authority
(
PCDA),
objects
to
EPA's
proposed
designation
of
Pleasants
County
as
nonattainment.
PCDA
disagrees
with
EPA's
plans
to
designate
the
area
simply
because
there
is
an
electric­
generating
power
plant
in
the
county.
There
are
no
data
indicating
nonattainment
and
PCDA
notes
that
there
is
no
evidence
that
Pleasants
County
has
ever
been
modeled.
PCDA
comments
that
EPA's
decision
will
stagnate
economic
development
in
the
community
and
unfairly
punish
the
county.

EPA
Response:
Thank
you
for
your
letter
of
August
20,
2004
expressing
your
concern
about
the
U.
S.
Environmental
Protection
Agency's
(
EPA)
intended
designation
of
areas
for
the
fine
particulate
(
PM
2.5)
National
Ambient
Air
Quality
Standards.

As
required
by
statute
and
EPA
guidance,
the
Agency
must
designate
areas
that
include
counties
violating
the
standard,
as
well
as
nearby
counties
that
may
contribute
to
a
violation
of
the
standard,
as
nonattainment.
As
you
stated
in
your
correspondence,
there
is
no
monitor
for
PM2.5
in
Pleasants
County.
However,
our
analysis
indicates
that
Pleasants
County
may
contribute
to
the
nonattainment
problem
in
the
Parkersburg
metropolitan
area.

In
EPA's
letter
dated
June
29,
2004,
we
informed
Governor
Bob
Wise
of
our
modification
to
his
original
nonattainment
boundaries
recommendations.
We
will
consider
any
additional
information
provided
by
West
Virginia
Department
of
Environmental
Protection
(
WVDEP),
including
data
on
recent
emission
reductions
from
power
plants
in
Pleasants
County,
in
our
decision
making.
This
information
is
requested
by
September
1,
2004,
but
we
encourage
the
state
to
have
an
ongoing
dialogue
with
EPA
during
the
entire
designation
process.
We
will
evaluate
your
suggestions
as
well
as
any
additional
information
provided
by
WVDEP
as
we
finalize
our
decision
on
nonattainment
boundaries.

Please
note,
EPA
is
addressing
power
plant
emissions
through
a
comprehensive
national
clean
air
strategy.
This
strategy
includes
EPA's
proposed
rule
to
reduce
nitrogen
oxides,
sulfur
dioxide
and
mercury
pollution
from
power
plants
in
the
eastern
United
States.

Please
see
TSD
for
additional
information
on
EPA's
designations.
3­
46
3­
47
Comment:
1013a­
50
Region:
3
State:
WV
Area:
Parkersburg­
Marietta,
WV­
OH
Comment:
EPA
failed
to
include
Wirt
County,
part
of
the
Parkersburg
MSA,
in
the
recommended
nonattainment
area.
This
county
should
be
included
in
the
nonattainment
area.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
well.
Therefore,
our
guidance
establishes
a
presumption
that
the
full
metropolitan
area
contributes
to
observed
violations
in
urban
areas.
Nevertheless,
our
final
set
of
boundaries
of
nonattainment
areas
will
reflect
an
area­
specific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

Wirt
County
has
low
estimated
emissions
contribution
to
the
nonattainment
area.
It
is
also
the
lowest
population
and
commuting
county
in
the
surrounding
area.
For
these
reasons,
EPA
determined
it
should
not
be
included
in
the
nonattainment
area.

Comment:
1078­
1
Region:
3
State:
WV
Area:
Parkersburg­
Marietta,
WV­
OH
Comment:
The
commenter
presents
the
following
resolution
of
the
Mid­
Ohio
Valley
Regional
Planning
and
Development
Council
(
MOVRC).

1.
The
Pleasants
County
Development
Authority
has
been
officially
notified
by
EPA
that
a
proposed
revision
to
EPA
rules
would
establish
Pleasants
County
as
a
nonattainment
area.
3­
48
2.
It
is
the
understanding
of
the
MOVRC
Board
that
EPA
has
not
performed
monitoring
or
has
any
scientific
basis
or
justification
for
the
reclassification.

3.
If
the
area
were
designated
nonattainment
it
would
impose
severe
restrains
on
the
ability
of
Pleasants
County
to
attract
or
retain
industries.

4.
The
MOVRC
Board
strenuously
objects
to
what
appears
to
be
an
arbitrary
decision
by
EPA
in
the
reclassification
of
Pleasants
County
from
attainment
to
nonattainment.
The
Board
would
like
to
dialogue
with
EPA
with
the
goal
being
either
a
scientific
basis
for
the
designation
or
retaining
the
attainment
status
of
Pleasants
County.

EPA
Response:
In
the
June
2004
letters
from
EPA
to
the
States
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
extend
to
the
relevant
power
plant
to
include
it
in
the
nonattainment
area.

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.

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
freestanding
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.
