4­
1
4.
Responses
to
Comments
EPA
Region
4
(
Alabama,
Florida,
Georgia,
Kentucky,
Mississippi,
North
Carolina,
South
Carolina,
and
Tennessee)
4­
2
Comment:
1013a­
2
Region:
4
State:
AL
Area:
Atlanta,
GA
Comment:
Atlanta
CMSA:

Chambers
County,
Alabama
is
part
of
the
Atlanta
CMSA
but
EPA
did
not
analyze
the
inclusion
of
this
county
in
the
nonattainment
area.
This
county
must
be
included
in
the
Atlanta
nonattainment
area.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

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.

Comment:
1013a­
3
Region:
4
State:
AL
Area:
Birmingham,
AL
Comment:
In
its
June
29,
2004
letter
to
Alabama,
EPA
recommended
the
inclusion
of
Jefferson,
Shelby
and
Walker
Counties
in
the
Birmingham
PM2.5
nonattainment
area;
in
addition
to
these
counties,
we
recommend
that
Bibb,
Blount,
Chilton,
Cullman,
Etowah
and
St.
Clair
Counties
be
added
to
the
nonattainment
area.
With
the
exception
of
Etowah
County,
these
counties
are
all
part
of
the
Birmingham
CMSA.
EPA
mentioned
that
4­
3
Walker
County
"
is
contiguous
to
the
MSA "
and
asked
for
the
state
to
comment
on
which
portion
of
the
county
should
be
designated
nonattainment.
The
2003
OMB
metropolitan
area
list
indicates
that
Walker
County
is
actually
part
of
the
Birmingham
CMSA
and
therefore,
the
entire
county
must
be
included
in
the
nonattainment
area.
According
to
EPA's
letter,
St.
Clair
and
Blount
Counties
both
experienced
around
30%
population
growth
between
1990
and
2000,
suggesting
that
this
high
rate
of
population
growth
may
contribute
to
the
PM2.5
problem
in
the
area.

EPA
did
not
recommend
that
Etowah
County
be
part
of
the
nonattainment
area
despite
its
being
adjacent
to
the
nonattainment
area
and
containing
the
Gadsden
power
plant.
According
to
EPA's
2002
Acid
Rain
Database,
this
plant
has
no
SO2
or
NOx
controls
and
the
2002
SO2
emissions
were
8,741
tons
per
year
while
NOx
emissions
were
1,918
tons
per
year.
And
the
three­
year
PM2.5
design
value
for
Etowah
County
is
very
close
to
violating
the
annual
standard,
at
14.8
µ
g/
m3.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

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.
4­
4
Comment:
1038­
4
Region:
4
State:
AL
Area:
Birmingham,
AL
Comment:
ADEM
disagrees
with
EPA
including
Walker
County
in
the
Birmingham
nonattainment
area
due
to
the
following
reasons:

1.
Monitors
located
between
Walker
County
and
the
non­
attaining
monitors
in
Jefferson
County
measure
PM2.5
concentrations
below
the
NAAQS.
This
is
an
indication
that
Walker
County
is
not
contributing
to
nonattainment
in
Jefferson
County
and
that
nonattainment
in
Jefferson
County
may
be
a
localized
problem.

2.
Limited
data
from
a
PM2.5
monitor
in
Walker
County
indicates
attainment.

3.
Walker
County
has
a
very
low
population
density
and
VMT
compared
to
Jefferson
County.

4.
The
overwhelming
majority
of
NOx
and
SO2
emissions
in
Walker
County
are
due
to
the
Alabama
Power
Company
steam
plant.
There
are
few
other
point
sources
in
the
county.
An
SCR
was
installed
on
the
largest
unit
at
the
power
plant
in
2002.
SO2
scrubbers
are
scheduled
to
be
in
operation
on
this
unit
and
two
smaller
units
in
2008.

5.
The
wind
infrequently
blows
from
the
direction
of
Walker
County
towards
Jefferson
County
on
days
with
high
PM2.5
concentrations.

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

Comment:
1038­
5
Region:
4
State:
AL
Area:
Birmingham,
AL
Comment:
ADEM
disagrees
with
EPA's
intention
to
include
Shelby
County
in
the
Birmingham
nonattainment
area
due
to
the
following
reasons:

1.
The
monitor
in
Shelby
County
measures
attainment
of
the
PM2.5
standard,
along
with
5
of
the
6
Jefferson
County
monitors.
Monitoring
data
collected
from
the
monitors
do
not
suggest
that
Shelby
County
is
contributing
to
nonattainment
in
Jefferson
County.

2.
71%
of
the
MSA
population
resides
in
Jefferson
County.

3.
Jefferson
County's
VMT
is
7.5
times
that
of
Shelby
County.

4.
The
vast
majority
of
NOx
and
SO2
emissions
in
Shelby
County
are
due
to
the
Alabama
Power
Company
Gaston
Steam
Plant.
SCRs
and
scrubbers
are
scheduled
to
be
installed.

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

Comment:
1013a­
5
Region:
4
State:
AL
Area:
Chattanooga,
TN­
GA
Comment:
EPA
recommended
that
all
or
a
portion
of
Jackson
County
be
included
in
the
Chattanooga
nonattainment
area
due
to
large
contributing
facilities.
EPA
asked
the
state
to
recommend
which
portion(
s)
of
this
county
should
be
included
in
the
nonattainment
area.
Our
analysis
found
that
the
Widows
Creek
power
plant
is
located
in
Jackson
County.
This
facility
emits
almost
44,000
tons
per
year
of
SO2
and
over
25,000
tons
per
year
of
NOx.
Jackson
County
in
its
entirety
should
be
included
in
the
nonattainment
area.

EPA
Response:
Even
though
some
rural
counties
are
not
a
part
of
some
CMSAs,
these
counties
are
being
designated
as
nonattainment
areas
because
they
have
violating
monitors
or
because
they
contribute
emissions
to
the
nonattainment
problem
in
the
affected
CMSAs.
The
CAA
requires
EPA
to
designate
as
nonattainment
any
area
that
is
violating
the
standard
and
any
area
that
is
contributing
to
a
violation
in
a
nearby
area.
The
designated
nonattainment
area
will
need
to
determine
what
local
controls
are
appropriate
for
bringing
the
area
into
attainment
in
conjunction
with
national
and
regional
control
requirements.

Jackson
County
has
high
SOx
and
NOx
emissions
from
a
power
plant.
We
have
included
in
our
recommended
nonattainment
area
Jackson
County,
which
is
generally
rural
in
character,
and
contains
an
identifiable
large
emitting
facility
or
facilities
(
e.
g.,
power
plants)
which
we
believe
contributes
to
the
nearby
nonattainment
problem.
We
have
included
this
County
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
County,
including
such
large
facilities,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invited
the
State
to
submit
to
us
a
recommendation
as
to
what
portion
of
Jackson
County,
encompassing
the
large
facility
or
facilities,
should
be
designated
nonattainment.
4­
7
Comment:
1038­
3
Region:
4
State:
AL
Area:
Chattanooga,
TN­
GA
Comment:
ADEM
disagrees
with
the
inclusion
of
Jackson
County
in
the
Chattanooga
nonattainment
area
for
the
following
reasons:

1.
The
wind
blows
infrequently
from
the
direction
of
Jackson
County
towards
Chattanooga
on
days
where
the
PM2.5
concentrations
are
high.

2.
Vehicle
Miles
Traveled
(
VMT)
in
Jackson
County
accounts
for
less
than
11%
of
the
total
VMT
for
the
nonattainment
counties
proposed
by
EPA.

3.
Jackson
County
has
a
small
population
and
population
density
compared
to
Hamilton
County,
Tennessee
(
Chattanooga).

4.
The
vast
majority
of
NOx
and
SO2
emissions
in
Jackson
County
are
due
to
the
TVA
Widows
Creek
Steam
Plant.
ADEM
has
legal
authority
to
require
emission
reductions
form
this
utility
and
other
sources
to
correct
air
quality
problems
regardless
of
the
county's
attainment
designation.

5.
SCR
and
SO2
scrubbers
are
installed
on
the
two
largest
units
at
the
TVA
Widows
Creek
facility.

EPA
Response:
Jackson
County
has
high
SOx
and
NOx
emissions
from
a
power
plant.
We
have
included
in
our
recommended
nonattainment
area
Jackson
County,
which
is
generally
rural
in
character,
and
contains
an
identifiable
large
emitting
facility
or
facilities
(
e.
g.,
power
plants)
which
we
believe
contributes
to
the
nearby
nonattainment
problem.
We
included
this
County
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
County,
including
such
large
facilities,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invited
the
State
to
submit
to
us
a
recommendation
as
to
what
portion
of
Jackson
County,
encompassing
the
large
facility
or
facilities,
should
be
designated
nonattainment.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

Comment:
1038­
2
Region:
4
State:
AL
Area:
Columbus,
GA­
AL
Comment:
ADEM
disagrees
with
the
inclusion
of
Lee
County
in
Phenix/
Columbus
Georgia
nonattainment
area
for
the
following
reasons:

1.
There
are
few
significant
point
sources
in
Lee
County.
4­
8
2.
NOx
and
VOC
emissions
account
for
the
vast
majority
(
78%)
of
total
emissions
in
Lee
County.
The
majority
of
NOx
emissions
come
from
mobile
sources
and
half
of
the
VOC
emissions
are
from
mobile
sources.
About
68%
of
all
Lee
County
commuters
stay
or
work
in
Lee
County.
Only
5%
work
in
Russell
County
where
the
standard
is
exceeded.

3.
The
wind
infrequently
blows
from
the
direction
of
Lee
County
towards
Phenix
City
on
days
with
high
PM2.5
concentrations.

4.
Alabama
counties
are
much
larger
than
Georgia
counties,
which
result
in
higher
"
composite
emission
scores".
Russell
County
alone
is
almost
as
large
as
the
two
Georgia
counties
(
Muscogee
and
Harris)
which
EPA
proposed
for
nonattainment.

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

Comment:
1038­
1
Region:
4
State:
AL
Area:
Columbus,
GA­
AL
|
Chattanooga,
TN­
GA
|
Birmingham,
AL
Comment:
On
behalf
of
the
Alabama
Department
of
Environmental
Management
(
ADEM),
the
commenter
disagrees
with
EPA's
decision
to
designate
four
additional
counties
in
Alabama
as
nonattainment.
Based
on
a
thorough
review
of
EPA's
information,
the
commenter
requests
that
EPA
designate
only
Jefferson
County
as
nonattainment
for
PM2.5.
The
commenter
offers
the
following
on
EPA's
intended
designation.

1.
ADEM
has
the
authority
to
impose
reduction
measures
as
necessary
in
any
county
near
a
nonattainment
county,
regardless
of
the
attainment
status
of
that
nearby
county.
Accordingly,
ADEM's
recommendation
only
included
those
counties
with
monitoring
data
exceeding
the
PM2.5
standard.
High
background
levels
of
PM2.5
present
in
the
eastern
United
States
are
the
major
cause
of
PM2.5
problems,
not
emissions
generated
solely
in
the
local
areas.
4­
9
2.
ADEM's
analysis
of
EPA's
11
factors
supported
the
state's
recommendation
that
only
those
counties
that
violated
the
annual
PM2.5
standard,
Jefferson
and
Russell
should
be
designated
nonattainment.

3.
ADEM
has
several
problems
with
EPA's
composite
emission
score
methodology
including:
there
was
no
public
or
scientific
review
of
the
complex
process
used
to
develop
the
composite
emission
score;
the
inventory
used
to
calculate
the
composite
scores
used
emission
data
not
available
to
ADEM
and
did
not
use
the
more
recent
1999
national
inventory;
and
the
composite
score
did
not
take
into
account
several
important
factors
like
the
distance
of
emissions
sources
from
violating
monitors,
the
size
of
counties,
and
meteorology.

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).

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.

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.
4­
10
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
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.
4­
11
Comment:
1013a­
4
Region:
4
State:
AL
|
GA
Area:
Columbus,
GA­
AL
Comment:
With
regard
to
the
Columbus
CMSA,
EPA
recommended
that
Lee
and
Russell
Counties
be
designated
nonattainment;
Macon
County
should
be
included
in
the
nonattainment
area
as
well
since
it
is
part
of
the
CMSA.
EPA
mentioned
that
Lee
County
is,
"
adjacent
to
the
MSA,
has
high
VMT
and
a
large
population;"
this
county
is
actually
part
of
the
CMSA
and
therefore
must
be
included
in
the
nonattainment
area.
Despite
the
fact
that
Macon
County
is
part
of
the
CMSA,
EPA's
analysis
failed
to
consider
the
county
when
analyzing
several
factors
for
determining
the
nonattainment
boundary,
including
population
data
and
growth
and
traffic
data
and
VMT
growth.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM­
2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

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.

Comment:
1013a­
11
Region:
4
State:
GA
Area:

Comment:
Correspondence
between
the
State
and
EPA
indicates
that
Richmond
County
(
Augusta)
may
be
on
the
verge
of
nonattainment.
Georgia
had
originally
recommended
4­
12
that
this
county
be
designated
nonattainment,
but
both
the
State
and
EPA
since
determined
that
incomplete
data
capture
at
one
of
the
monitoring
sites
should
lead
to
an
attainment/
unclassifiable
determination.
According
to
the
State's
June
15,
2004
letter
to
EPA,
the
monitor
with
complete
data
(
after
data
substitution)
has
a
design
value
of
14.8
µ
g/
m3,
very
near
the
PM2.5
annual
standard.
EPA's
AirData
website
indicates
that
the
2001­
2003
design
value
for
the
monitor
with
incomplete
data
is
15.2
µ
g/
m3.
While
we
recognize
that
an
area
can
not
be
designated
nonattainment
with
incomplete
data,
we
request
that
EPA
and
the
State
be
diligent
in
collecting
complete
data
for
this
area
in
order
to
determine
whether
this
area
is
indeed
attaining
the
standard.
Due
to
the
monitoring
data
showing
that
are
quality
is
most
likely
poor,
this
area
should
receive
an
unclassifiable
designation
at
the
most.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
The
EPA
is
using
the
most
current
data
in
the
decision
making
process.
EPA
and
the
States
continue
to
work
to
improve
data
collection
and
analysis.
On
February
13,
2004,
the
State
of
Georgia
submitted
to
EPA
their
PM
2.5
nonattainment
recommendations.
Georgia
recommended
only
counties
which
contained
a
monitored
violation
and
provided
no
further
justification.
On
September
1,
2004,
the
State
submitted
additional
information
and
revised
recommendations
for
the
Augusta
area.
The
revision
recommended
that
Richmond
County
be
attainment/
unclassifiable.
Richmond
County
has
two
PM2.5
monitors
with
air
quality
data
for
2001­
2003.
The
data
for
one
monitor
demonstrates
attainment
and
the
other
monitor
has
incomplete
data
for
2001­
2003
that
was
violating.
EPA's
analysis
of
all
the
available
monitoring
data
indicates
that
the
area
should
be
designated
as
attainment/
unclassifiable.

Comment:
1036­
6
Region:
4
State:
GA
Area:

Comment:
Georgia
EPD
Recommendations
A
table
indicating
Georgia
EPD's
revised
recommendations
for
all
counties
and
partial
counties
in
the
state
and
a
map
indicating
EPD's
revised
designations
is
attached
to
the
comment
letter.

Please
note
that
during
this
evaluation,
EPD
discovered
that
the
vehicle
miles
traveled
(
VMT)
data
posted
on
EPA's
PM2.5
technical
information
web
site
and
used
by
both
EPA
and
Georgia
EPD
in
attainment
designation
analysis
is
incorrect.
EPD
has
used
correct
VMT
data
for
the
analyses
created
for
this
response.
EPD
will
be
checking
the
VMT
data
utilized
in
the
data
supporting
our
June
17,
2004,
submittal
and
will
notify
EPA
if
the
updated
VMT
data
alters
any
of
those
analysis
results.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.
4­
13
Comment:
1013a­
9
Region:
4
State:
GA
Area:
Athens,
GA
Comment:
EPA
did
not
recommend
the
inclusion
of
Oglethorpe
County
in
the
Athens
nonattainment
area,
but
this
county
is
part
of
the
MSA
and
must
be
included
in
the
nonattainment
boundary.
There
is
no
monitor
in
Oglethorpe
County
to
prove
that
this
county
is
attaining
despite
the
PM2.5
violations
in
Clarke
County.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

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.

Comment:
1036­
4
Region:
4
State:
GA
Area:
Athens,
GA
Comment:
Athens
PM2.5
Nonattainment
Area
U.
S.
EPA's
June
29,
2004
letter
added
Madison
and
Oconee
Counties
to
Georgia
EPD's
recommendation
for
the
Athens
PM2.5
nonattainment
area.
In
our
June
17th
submission,
EPD
did
not
analyze
Oconee
County
for
the
7
"
other
factors,"
since
EPD's
Updated
LScore
analysis
indicated
that
the
urban
excess
from
Oconee
County
did
not
significantly
4­
14
impact
on
the
Athens
area.
Since
U.
S.
EPA
has
included
Oconee
County
in
its
recommendation
for
the
Athens
PM2.5
nonattainment
area,
EPD
has
conducted
additional
analysis
for
Oconee
County.
Also,
EPD
has
conducted
an
analysis
of
meteorological
factors
that
was
not
included
in
our
June
17th
submittal.
Both
of
these
analyses,
together
with
the
information
already
submitted
to
U.
S.
EPA
on
June
17th,
indicate
that
neither
Oconee
nor
Madison
should
be
included
in
the
Athens
PM2.5
nonattainment
area.
Additionally,
should
EPA
accept
EPD's
recommendation
that
Clarke
County
be
designated
as
unclassifiable,
then
Madison
and
Oconee
Counties
should
be
designated
either
as
attainment
or
unclassifiable.
The
additional
analyses
for
Oconee
and
Madison
Counties
are
contained
in
attachment
6.

EPA
Response:
On
February
13,
2004,
the
State
of
Georgia
submitted
to
EPA
their
PM
2.5
nonattainment
recommendations.
Georgia
recommended
only
counties
that
contained
a
monitored
violation
and
provided
no
further
justification.
On
June
17,
2004,
the
State
submitted
additional
information
and
revised
recommendations.
The
revision
recommended
that
Clarke
County
be
designated
as
nonattainment.
EPA
has
reviewed
the
State's
additional
information
and
now
agrees
with
the
State's
recommendation
as
to
Oconee
and
Madison
Counties.

Comment:
1036­
1
Region:
4
State:
GA
Area:
Athens,
GA
|
Macon,
GA
Comment:
Commenter
recommends
that
certain
areas
be
classified
as
"
unclassifiable."
Based
on
PM2.5
monitoring
trends
through
mid­
2004,
it
is
very
possible
that
the
2002­
2004
data
will
indicate
attainment
for
the
Athens
monitor,
the
Macon
Allied
Chemical
monitor
(
the
Macon
Forestry
Office
monitor
already
shows
attainment),
and
the
Rossville
monitor.
Data
indicating
these
trends
is
included
in
attachment
3.
We
will
have
more
complete
data
later
this
Fall,
before
U.
S.
EPA's
expected
November
action.
If
these
monitoring
trends
continue,
EPD
recommends
that
Clarke
County,
Bibb
County,
the
partial
county
area
of
Monroe
County
that
includes
Plant
Scherer,
and
Walker
County
be
designated
as
"
unclassifiable."

EPA
Response:
The
EPA
is
using
the
most
current
data
in
the
decision
making
process.
EPA
and
the
States
continue
to
work
to
improve
data
collection
and
analysis.

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
4­
15
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.

Comment:
1013a­
10
Region:
4
State:
GA
Area:
Atlanta,
GA
Comment:
EPA
did
not
include
all
or
portions
of
Butts,
Dawson,
Haralson,
Heard,
Jasper,
Lamar,
Meriwether,
Pickens,
Pike,
Polk,
Hall,
Troup
and
Upson
Counties
and
Chambers
County,
Alabama
in
the
Atlanta
nonattainment
boundary.
These
counties
are
all
part
of
the
CMSA
and
must
be
included
in
the
nonattainment
area.
Instead,
EPA
listed
Hall,
Heard
and
Jasper
as
being
adjacent
to
the
CMSA
and
recommended
partial
inclusion
in
the
nonattainment
boundary.
We
agree
that
Putnam
County
should
be
included
in
the
nonattainment
area
due
to
the
Harllee
Branch
power
plant
located
in
the
county,
but
for
planning
purposes,
we
believe
that
the
entire
county
should
be
included
in
the
nonattainment
area.

EPA
has
agreed
with
the
state
to
make
Floyd
County
a
separate
nonattainment
area;
this
county
must
be
included
in
the
Atlanta
CMSA
nonattainment
area.
The
Hammond
power
plant,
located
in
Floyd
County
contributes
to
the
nonattainment
problem
in
the
Atlanta
area.
As
for
the
other
counties
that
are
included
in
the
CMSA,
but
not
recommended
to
be
part
of
the
nonattainment
area,
EPA's
letter
to
the
state
does
not
even
address
most
of
these
other
counties.
Thus,
it
appears
that
no
analysis
has
been
done
for
several
counties
that
are
part
of
the
CMSA
and
these
counties
must
be
included
in
the
nonattainment
area.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

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.
4­
16
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.

Comment:
1036­
3
Region:
4
State:
GA
Area:
Atlanta,
GA
Comment:
Atlanta
PM2.5
Nonattainment
Area
U.
S.
EPA's
June
29,
2004
letter
added
Jasper
and
Putnam
Counties
to
Georgia
EPD's
recommendation
for
the
Atlanta
PM2.5
nonattainment
area.
EPA's
letter
also
suggested
that
EPD
submit
partial
county
recommendations
for
those
counties.
EPD
has
determined
that
it
is
not
practical
to
design
partial
county
nonattainment
boundaries
for
Jasper
and
Putnam
County.
We
have
also
conducted
additional
analysis
using
EPA's
wind
direction
frequency
data
that,
together
with
information
submitted
with
our
June
17th
recommendation,
supports
EPD's
earlier
recommendation
that
neither
Jasper
nor
Putnam
County
be
included
in
the
Atlanta
PM2.5
nonattainment
area.
Also,
by
designating
Jasper
and
Putnam
County
"
attainment"
for
PM2.5,
the
Atlanta
PM2.5
nonattainment
boundary
will
be
basically
identical
to
the
Atlanta
8­
hour
ozone
nonattainment
boundary
ensuring
more
efficient
air
quality
and
transportation
planning.
EPD's
additional
analysis
of
Putnam
County
is
included.

EPA
Response:
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

Comment:
1036­
2
Region:
4
State:
GA
Area:
Chattanooga,
TN­
GA
Comment:
Chattanooga
PM2.5
Nonattainment
Area
U.
S.
EPA's
June
29,
2004
letter
included
all
of
the
Georgia
Counties
that
are
part
of
the
Chattanooga
MSA
in
the
Chattanooga
PM2.5
nonattainment
area.
It
is
our
understanding
4­
17
that
this
was
due
in
part
to
the
fact
that
EPD
had
not
submitted
an
analysis
of
this
area
prior
to
EPA's
June
29th
letter.
EPD
has
completed
this
analysis
and
it
is
attached.
EPD
has
recommended
above
that
Walker
County
be
designated
unclassifiable
and
further
recommends
that
Catoosa
County
and
Dade
County
be
classified
as
"
attainment".
Should
additional
data
available
this
fall
not
indicate
that
the
Rossville
monitor
will
attain
the
PM2.5
standard
using
2002­
2004
data
or
should
U.
S.
EPA
reject
EPD's
unclassifiable
recommendation
for
Walker
County,
we
recommend
that
the
portion
of
Walker
County
as
described
below
be
included
in
the
Chattanooga
PM2.5
nonattainment
area.

From
the
west
Walker
County
line
¾
of
a
mile
south
of
Lookout
Mtn.
city
limits,
the
boundary
travels
southeast
to
the
3700
block
of
Lula
Lake
Rd.
Boundary
then
travels
south
intersecting
the
2200
block
of
Nick­
a­
Jack
Rd.
and
continues
south
1
½
miles.
Boundary
then
travels
east
to
7600
block
of
Hwy
193
at
N.
Cedar
Ln.
intersection.
Boundary
then
travels
east
following
southern
right
of
way
of
Walker
Hollow
Rd.
to
1500
block
of
N.
Marbletop
Rd.
Boundary
then
travels
southeast
intersecting
400
block
of
Childress
Hollow
Rd.
and
continuing
east
to
east
right
of
way
of
McCarty
Rd.
Boundary
then
travels
south
½
mile.
Boundary
then
travels
east
to
north
right
of
way
of
Peter
Lewis
Trl.
Boundary
then
travels
southeast
to
1100
block
of
S.
Hwy
341
at
Garretts
Chapel
Rd.
intersection.
Boundary
then
travels
southeast
to
southern
right
of
way
of
Hames
Rd.
and
Driftwood
Dr.
Boundary
then
travels
east
to
intersect
800
block
of
Lofton
Ln.
Boundary
then
travels
northeast
to
100
block
of
Glass
Mill
Rd.
at
Old
Bethel
Rd.
intersection.
Boundary
then
travels
east
along
southern
right
of
way
of
Glass
Mill
Rd.
Boundary
then
intersects
500
block
of
Old
LaFayette
Rd.
at
Glass
Mill
Rd.
intersection.
Boundary
continues
east
intersecting
9900
block
of
N.
Hwy
27,
300
block
of
Arnold
Rd.,
and
500
block
of
Long
Hollow
Rd.
Boundary
continues
east
to
1200
block
of
Peaving
Rd.
at
E.
Long
Hollow
Rd.
intersection.
Boundary
continues
east
along
southern
right
of
way
of
Peavine
Rd.
to
east
Walker
County
line.

Clearly
the
opportunity
for
a
partial
county
designation
is
something
EPA
is
willing
to
consider
(
EPA's
June
29,
2004
suggestion
regarding
both
Putnam
and
Jasper
counties,
for
example).
In
evaluating
this
recommendation,
EPA
should
consider
Walker
County's
geography,
the
location
of
the
emission
sources,
other
factors
we
have
analyzed,
and
the
fact
that
the
northern
urbanized
area
is
not
unlike
the
localized
stationary
sources
EPA
refers
to
in
Jasper
and
Putnam
counties.

A
complete
analysis
and
a
map
of
the
partial
county
area
are
included
in
an
attachment.

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
4­
18
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.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

Comment:
1013a­
12
Region:
4
State:
GA
Area:
Columbus,
GA­
AL
Comment:
EPA
has
not
recommended
the
inclusion
of
the
CMSA
counties
of
Chattahoochee
and
Marion
in
the
Columbus
nonattainment
area.
Our
letter
to
you
indicated
that
Troup
County
should
be
analyzed
for
its
impact
on
the
nonattainment
problem.
According
to
EPA's
June
29,
2004
letter
to
Georgia,
Troup
County's
NOx
emissions
were
over
twice
as
high
as
any
of
the
counties
EPA
has
recommended
for
nonattainment
in
this
area.
Primary
PM
and
VOC
emissions
in
Troup
County
also
appear
to
be
high.

EPA
Response:
Based
on
the
analysis
contained
in
the
TSD,
EPA
agrees
with
the
recommendation
that
Barbour,
Chambers,
Montgomery,
Elmore
and
Tallapoosa
Counties
in
Alabama,
and
Chattahoochee,
Troup,
Stewart,
Meriwether,
Sumter
Counties
in
Georgia,
should
be
attainment/
unclassifiable
for
PM2.5
based
on
low
emissions,
low
VMT
and
low
population.

Comment:
1036­
5
Region:
4
State:
GA
Area:
Columbus,
GA­
AL
Comment:
Columbus/
Phenix
City
Nonattainment
Area
The
commenter
does
not
agree
with
U.
S.
EPA's
recommended
boundary.
However,
On
July
28,
2004,
EPD,
in
cooperation
with
Alabama's
Department
of
Environmental
Management,
submitted
a
request
for
revision
to
the
PM2.5
Monitoring
Plan
for
the
Columbus/
Phenix
City
area.
U.
S.
EPA's
prompt
action
on
this
request
will
result
in
the
attainment
designation
for
the
entire
Columbus/
Phenix
City
area,
including
both
Muscogee
and
Harris
County
in
Georgia.
4­
19
EPA
Response:
Alabama's
submittal
in
February
2004,
recommended
that
Russell
County
be
designated
nonattainment
for
the
fine
particulate
matter
(
PM2.5),
based
on
2001
­
2003
monitoring
data.
Georgia's
submittal
in
June
2004,
recommended
that
Harris,
Muscogee
and
Chattahoochee
Counties
be
designated
attainment
for
PM2.5.
Based
on
the
analysis
in
the
TSD,
EPA
recommends
that
Russell
County
in
Alabama,
and
Muscogee
County
in
Georgia
should
be
included
in
the
PM2.5
nonattainment
area.
Russell
County
has
a
violating
monitor
and
the
State
recommended
it
as
nonattainment.
Muscogee
County
has
high
NOx
and
VOC
emissions,
high
VMT
and
a
large
population.
Based
on
the
analysis
in
the
TSD,
EPA
agrees
with
the
recommendation
that
Barbour,
Chambers,
Lee,
Montgomery,
Elmore
and
Tallapoosa
Counties
in
Alabama,
and
Chattahoochee,
Harris,
Troup,
Stewart,
Meriwether,
and
Sumter
Counties
in
Georgia,
should
be
attainment/
unclassifiable
for
PM2.5
based
on
low
emissions,
low
VMT
and
low
population.

Comment:
1013a­
13
Region:
4
State:
GA
Area:
Macon,
GA
Comment:
EPA
has
not
recommended
that
Crawford,
Jones,
Peach,
Houston,
and
Twiggs
Counties
be
part
of
the
Macon
nonattainment
area
despite
the
fact
that
these
counties
are
all
part
of
the
CMSA.
These
counties
must
be
included
in
the
nonattainment
area.
In
addition,
EPA
has
only
recommended
that
part
of
Monroe
County
be
included
in
the
nonattainment
area;
as
this
county
is
also
part
of
the
CMSA,
the
entire
county
must
be
included
in
the
nonattainment
area.
Although
EPA
has
assumed
that
air
quality
in
the
other
counties
is
clean,
Crawford,
Jones,
Peach
and
Twiggs
Counties
have
no
monitors
in
order
to
determine
whether
those
counties
are
attaining
or
not.
While
Houston
County's
monitor
is
attaining,
at
12.8
µ
g/
m3,
the
county
has
the
second
largest
population
for
the
CMSA,
after
Bibb
County,
at
35%.
In
addition,
Houston
County
is
experiencing
much
faster
growth
than
is
Bibb
County,
with
24%
growth
between
1990
and
2000.

EPA
Response:
The
Macon
MSA
contains
the
counties
of:
Bibb,
Houston,
Jones,
Peach,
and
Twiggs.
EPA
agrees
with
the
State's
recommendation
that
Bibb
County
be
nonattainment
and
Monroe
County
as
a
partial
county
nonattainment
area.

Comment:
1013a­
4
Region:
4
State:
GA
|
AL
Area:
Columbus,
GA­
AL
Comment:
With
regard
to
the
Columbus
CMSA,
EPA
recommended
that
Lee
and
Russell
Counties
be
designated
nonattainment;
Macon
County
should
be
included
in
the
nonattainment
area
as
well
since
it
is
part
of
the
CMSA.
EPA
mentioned
that
Lee
County
is,
"
adjacent
to
the
MSA,
has
high
VMT
and
a
large
population;"
this
county
is
actually
part
of
the
CMSA
and
therefore
must
be
included
in
the
nonattainment
area.
Despite
the
fact
that
Macon
County
is
part
of
the
CMSA,
EPA's
analysis
failed
to
consider
the
4­
20
county
when
analyzing
several
factors
for
determining
the
nonattainment
boundary,
including
population
data
and
growth
and
traffic
data
and
VMT
growth.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

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.

Comment:
1041­
6
Region:
4
State:
KY
Area:

Comment:
Commenter
states
that
EPA
indicated
in
previous
guidance
its
intention
to
consider
2002­
2004
monitoring
when
making
PM2.5
designations.
Kentucky
feels
that
EPA
should
follow
through
with
its
original
intentions.

Commenter
states
that
the
Commonwealth
of
Kentucky
believes
that
the
date
for
official
designation
should
be
extended
until
after
the
beginning
of
2005,
instead
of
mid­
November
2004.
This
would
allow
states
to
utilize
the
2004
data,
and
would
provide
the
use
of
the
most
recent
available
data,
a
requirement
that
EPA
consistently
espouses.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.
4­
21
The
EPA
is
using
the
most
current
data
in
the
decision
making
process.
EPA
and
the
States
continue
to
work
to
improve
data
collection
and
analysis.

Comment:
1041­
7
Region:
4
State:
KY
Area:

Comment:
The
commenter
states
that
the
geographic
location
of
a
county
and
the
historic
prevailing
wind
data
in
an
area
has
an
impact
on
PM2.5
monitored
values.
In
addressing
comments
from
information
presented
in
the
February
2004
recommendations
from
Kentucky,
EPA
claims
that
an
area
may
contribute
to
the
monitored
violation
even
if
it
is
located
downwind
of
another
area,
due
to
this
being
a
"
year­
long"
standard.
EPA
has
previously
made
numerous
references
to
"
upwind
areas
impacting
downwind
areas"
and
"
predominant
wind
patterns."
This
has
been
the
premise
for
several
control
programs
recently
implemented
by
EPA
and
most
recently
set
the
stage
for
the
CAIR
and
BART
proposals.
Therefore,
if
the
geographic
location
and
predominant
wind
patterns
are
an
important
variable
when
determining
when
and
at
what
levels
PM
impacts
are
seen,
including
at
Class
I
areas,
then
the
same
variable
should
be
taken
into
account
when
EPA
makes
final
PM2.5
designations.

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).

Comment:
1041­
2
Region:
4
State:
KY
Area:

Comment:
The
Commonwealth
was
surprised
to
learn
that
EPA
had
employed
the
use
of
a
"
weighted
emissions
scoring"
process
to
evaluate
counties
for
emissions
contributions
to
an
area
attainment
problem.
At
no
time
did
U.
S.
EPA
offer
information
concerning
this
methodology.
Further,
EPA
did
not
afford
the
states
the
opportunity
to
provide
input
on
the
appropriateness
of
or
the
science
behind
this
methodology.
This
approach
was
revealed
in
late
May
2004,
a
full
three
months
after
states
had
been
required
to
submit
boundary
recommendations
to
EPA.
Taking
this
approach,
especially
at
such
a
late
date,
is
not
only
contrary
to
boundary
guidance
provided
to
states
by
U.
S.
EPA,
but
insults
the
established
designation
process
which
allows
states
to
use
their
thorough
knowledge
of
the
monitoring
network
and
local
and
regional
circumstances
to
make
those
designations.
4­
22
A
full
detailed
explanation
of
the
origin
of
the
data
and
how
EPA
has
used
the
scoring
methodology
has
still
not
been
released
for
review.

Given
the
facts
presented
above,
the
Commonwealth
must
go
on
record
as
being
strongly
opposed
to
the
use
of
this
process.

However,
since
EPA
has
utilized
the
weighted
emission
scores
in
its
PM2.5
response
letter
to
the
states,
it
still
remains
important
to
document
the
problems
that
exist
with
the
methodology
used
by
EPA
in
determining
those
weighted
emission
scores:

1.
EPA
did
not
include
adjacent
county
(
i.
e.,
county
outside
the
MSA)
emissions
into
the
total
emissions
for
an
area
when
calculating
the
weighted
emissions
score.
The
weighted
emissions
score,
in
some
instances
for
counties
within
the
MSA,
would
have
been
drastically
different
if
all
counties
emissions
had
been
included
in
calculating
the
weighted
emissions
scores.

2.
EPA's
choice
of
regional
speciation
monitors
must
be
questioned.
EPA,
has
provided
no
explanation
how
it
determined
"
appropriate"
regional
monitoring
sites
to
use
in
the
weighted
emissions
scoring
process.
This
eliminates
states
air
quality
agencies
from
having
any
input
on
the
appropriateness
of
those
sites.
States
have
"
background"
monitors
located
to
determine
background
pollutant
levels.
For
EPA
to
ignore
the
availability
of
area
specific
information,
or
request
input
from
states
on
the
appropriateness
of
using
one
site
versus
another,
is
shortsighted.
It
stands
to
reason
that
an
in­
state
regional
background
monitor
would
have
been
more
representative
of
the
area
than
a
monitor
located
in
another
state.
This
could
have
drastic
impacts
on
the
results
obtained
from
the
analysis.

3.
EPA
used
the
SMOKE
model
information
from
the
Clear
Skies
modeling
that
was
based
on
the
1996
NEI
to
generate
the
total
carbon
and
crustal
components
of
the
emissions
data
used
in
their
analyses.
This
data
was
used
in
an
attempt
to
generate
urban
excess
in
the
weighted
emissions
score
calculation.
This
approach
is
subjective
at
best.

4.
The
use
of
a
cumulative
percentage
roll­
up
of
the
weighted
emissions
scores
is
inherently
flawed
since
it
causes
the
inclusion
of
counties
that
have
scores
that
are
significantly
lower
than
the
top
scoring
counties
in
an
area.
The
cumulative
roll­
up
is
purely
an
arbitrary
mathematical
exercise
that
does
not
take
into
account
important
information
(
e.
g.
geographic
location,
predominant
wind
patterns,
future
national
control
measures,
etc.)
that
should
be
considered
in
making
PM2.5
nonattainment
designations.

5.
EPA
has
still
not
supplied
the
speciation
data
nor
the
timeframes
used
in
their
analysis
for
the
background
monitor
sites
used
in
the
regional
analysis.

6.
Other
national
studies
performed
have
taken
a
different
approach
in
determining
source
apportionment.
Of
particular
note
are
conclusions
contained
in
2003
National
Air
Quality
and
Emissions
Trends
Report
that
compares
the
percent
difference
in
PM
constituency
from
regionally
representative
monitors
and
urban
monitors.
While
this
4­
23
approach
on
the
front
end
is
similar
to
the
methodology
EPA
used,
EPA
went
a
step
further
in
attempting
to
use
that
data
to
correlate
with
actual
emissions
within
a
set
geographic
area.
Of
a
more
specific
concern,
when
reviewing
regional
background
PM
constituency
compared
with
urban
data,
sulfates
appear
to
make
up
a
small
percentage
of
urban
excess.
We
believe
this
shows
that
sulfates
are
a
regional
problem
and
that
the
proposed
regional
controls
of
SO2
should
alleviate
the
problem.
The
second
concern
is
that
carbon
mass
seems
to
make
up
the
largest
percentage
of
the
urban
excess
and
it
appears
that
mobile
sources
are
a
major
contributor
to
PM2.5
levels
in
our
urban
areas.
With
the
proposed
federal
changes
to
fuels
and
engine
requirements,
contributions
from
this
sector
will
also
be
lowered
within
the
next
few
years.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

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.

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
to
give
more
weight
to
emissions
(
sources)
that
contribute
to
4­
24
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.

Comment:
1041­
1
Region:
4
State:
KY
Area:

Comment:
EPA
has
finalized
or
is
in
the
process
of
finalizing
several
new
control
initiatives
that
are
designed
to
lower
emissions
that
contribute
to
PM2.5
levels.
The
implementation
dates
for
many
of
these
initiatives
will
begin
within
the
next
two
years
and
in
many
instances,
will
be
in
place
well
before
control
plan
submittal
deadlines
or
attainment
dates.
This
fact
should
lead
to
the
conclusion
that
greater
caution
should
be
4­
25
exercised
before
saddling
an
area
with
a
nonattainment
designation
when
no
local
control
strategies
will
be
available
or
required.

1.
Clean
Air
Interstate
Rule
(
CAIR)/
BART
In
the
June
29,
2004,
response
to
Kentucky,
EPA
has
proposed
nonattainment
designations
for
several
counties,
either
within
the
MSA
or
adjacent
to
an
MSA,
due
to
the
location
of
a
power
plant
within
their
borders.

The
May
5,
2004,
proposed
BART
rule
states
on
page
25204
that
"
Based
on
our
current
evaluation,
we
believe
the
IAQR
rule,
as
proposed,
is
clearly
better
than
BART
for
those
affected
EGUs
in
the
affected
States
which
we
propose
to
cover
under
the
IAQR.
We
thus
expect
that
the
final
IAQR
would
satisfy
the
BART
requirements
for
affected
EGUs
that
are
covered
pursuant
to
the
final
IAQR".
Per
this
EPA
finding
regarding
PM
and
EGUs
under
the
IAQR/
BART,
EPA
should
not
include
counties
in
PM2.5
nonattainment
areas
because
they
contain
a
power
plant.
EPA
has
determined
that
the
IAQR
(
i.
e.,
CAIR)
will
achieve
the
necessary
PM
air
quality
improvements.

Upon
implementation
of
the
Clean
Air
Interstate
Rule
(
CAIR)
SO2
emissions
from
power
plants
will
be
reduced
nationwide
by
3.6
million
tons
in
2010
(
approximately
40
percent
below
current
levels)
and
by
another
2
million
tons
per
year
when
the
rules
are
fully
implemented
(
approximately
70
percent
below
current
levels).
NOx
emissions
would
be
cut
by
1.5
million
tons
nationwide
in
2010
and
1.8
million
tons
annually
in
2015
(
about
65
percent
below
today's
levels).

To
designate
counties
nonattainment
because
they
have
a
power
plant
in
them
would
place
additional
hardships
on
the
county
and
would
be
counterproductive
since
the
EGUs
in
the
entire
region
will
be
mandated
by
EPA's
CAIR
rule
to
significantly
control
their
PM
precursor
emissions
without
being
designated
nonattainment.
In
addition,
Non­
EGUs
in
Kentucky
will
also
be
required
to
put
on
BART
controls,
which
will
further
achieve
PM
air
quality
improvements.

2.
Mobile
Controls
In
many
areas,
EPA
based
potential
nonattainment
designations
on
the
supposition
that
population,
commuter
traffic,
or
local
VMT
played
an
important
role
in
determining
potential
impacts
on
PM2.5
levels
within
an
MSA.
It
is
not
feasible
to
designate
a
county
as
nonattainment
if
the
only
reason
an
area
has
been
included
was
due
to
these
population­
based
factors.
With
national
controls
being
implemented
that
would
address
this
contribution,
including
these
counties
as
nonattainment
would
place
additional,
burdensome
planning
requirements
on
these
local
areas
for
no
useful
purpose.
Due
to
the
Tier
2
Vehicle
and
Low
Sulfur
Gasoline,
scheduled
to
be
in
place
by
2006,
average
national
gasoline
sulfur
levels
will
be
90%
lower.
The
new
Low
Sulfur
Diesel
Rule,
scheduled
to
be
phased
in
beginning
in
2007,
along
with
new
clean
engines
operating
requirements
will
reduce
NOx
emissions
by
50%,
and
reduce
PM
emissions
by
more
than
90%.
The
implementation
of
these
new
federal
rules
will
significantly
decrease
the
fine
4­
26
particulate
contribution
in
and
from
areas
impacted
by
population
and
transportation
factors.

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
PM­
2.5
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).

Comment:
1004­
1
Region:
4
State:
KY
Area:
Cincinnati­
Hamilton,
OH­
KY­
IN
Comment:
Senator
Mitch
McConnell,
U.
S.
Senate,
requests
EPA
to
consider
the
comments
of
Harold
Tomlinson,
County
Judge/
Executive
of
Carroll
County,
Kentucky.
Mr.
Tomlinson
disagrees
with
EPA's
proposed
decision
to
designate
Carroll
County
as
nonattainment
and
comments
that
this
will
hurt
Carroll
County
economically.
He
notes
that
there
are
no
data
demonstrating
that
Carroll
County
exceeds
the
PM2.5
standard,
Carroll
County
is
not
a
part
of
the
Cincinnati­
Hamilton,
OH­
KY­
IN
MSA,
and
Carroll
County
is
not
within
the
boundaries
of
an
8­
hour
ozone
nonattainment
area.

He
believes
EPA
proposed
the
nonattainment
designation
solely
on
the
fact
that
the
LG&
E
coal­
fired
generating
station
is
in
Carroll
County.
He
believes
that
EPA
has
the
authority
elsewhere
in
the
CAA
to
regulate
point
sources
and
should
not
subject
the
entire
county
to
a
nonattainment
designation
for
the
purpose
of
exerting
regulatory
control
over
one
facility.

EPA
Response:
Thank
you
for
your
letter
of
June
8,
2004,
on
behalf
of
Mr.
Harold
Tomlinson,
the
County
Judge/
Executive
for
Carroll
County,
Kentucky,
concerning
fine
particulate
matter
(
PM2.5)
designations
and
northern
Kentucky.
In
your
letter
you
requested
that
the
Environmental
Protection
Agency
(
EPA)
provide
you
with
an
update
on
the
status
of
PM2.5
designations,
as
well
as
relevant
information
on
EPA's
decisions
regarding
any
region
of
Kentucky.

In
determining
an
area's
designation,
we
rely
on
the
Clean
Air
Act
(
CAA)
definition
of
a
nonattainment
area
in
section
107(
d)(
1)(
A)(
i):
an
area
that
is
violating
an
ambient
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.
In
making
designations,
we
use
the
most
recent
3
years
of
monitoring
data.
Once
we
determine
that
a
monitor
is
recording
a
violation,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
include
them
in
the
designated
nonattainment
area.
In
making
this
determination,
we
review
all
available
technical
data
4­
27
such
as
air
quality,
source
locations
and
emissions,
meteorology,
terrain,
population,
commuting,
and
growth
in
the
area.
PM2.5
is
a
regional
pollutant
and
can
be
transported
by
prevailing
wind.

States
had
until
February
2004
to
recommend
to
EPA
areas
that
should
be
designated
as
attainment
and
nonattainment.
The
Commonwealth
of
Kentucky
recommended
that
Fayette
and
Jefferson
Counties
be
designated
nonattainment
and
deferred
making
a
recommendation
on
Boyd
County
in
their
February
20,
2004,
submittal.
EPA
will
review
and
consider
those
recommendations,
and
intends
to
respond
to
states
and
tribes
by
the
end
of
June
2004.
In
that
response,
the
Agency
will
notify
states
and
tribes
of
any
modifications
EPA
wishes
to
make
to
state
or
tribal
recommendations.
States
will
have
an
opportunity
to
comment
on
any
modifications
EPA
makes
to
their
recommendations.
EPA
expects
to
take
the
2001­
2003
data
into
consideration
when
making
the
final
designations
(
by
November
17,
2004).
Tribes
that
have
their
own
air
quality
programs
may
submit
recommendations
for
designations;
however,
they
are
not
required
to
do
so.
Because
air
quality
data
is
lacking
in
some
tribal
areas,
EPA
will
work
with
tribes
to
determine
the
appropriate
designations.
EPA
will
address
all
state
and
tribal
lands
during
the
designations
process.

SCHEDULE
States/
Tribes
recommend
designations
February
2004
EPA
responds
with
letters
describing
intended
"
modifications"
June
28­
30,
2004
EPA
proposes
implementation
rule
Fall
2004
EPA
finalizes
designations
November
17,
2004
Effective
date
of
PM2.5
designations
February
2005
EPA
finalizes
implementation
rule
Spring
2005
State/
Tribal
plans
due
February
2008
Attainment
dates
2010
­
2015
Additional
information
regarding
PM2.5
designations,
along
with
links
to
the
technical
support
documentation,
is
available
on
the
web
at
the
following
web
site:
http://
www.
epa.
gov/
pmdesignations/.

If
you
have
questions
or
need
additional
information
from
EPA,
please
contact
me
or
the
Region
4
Office
of
Congressional
and
Intergovernmental
Relations
at
(
404)
562­
8327.
4­
28
Comment:
1013a­
21
Region:
4
State:
KY
Area:
Cincinnati­
Hamilton,
OH­
KY­
IN
Comment:
EPA
failed
to
include
Bracken,
Carroll,
Gallatin,
Grant,
Mason
and
Pendleton
Counties
in
its
recommended
nonattainment
area
for
Cincinnati.
Bracken,
Gallatin,
Grant
and
Pendleton
Counties
are
all
part
of
the
nonattainment
area
and
must
be
designated
nonattainment.
Carroll
and
Mason
Counties
are
adjacent
to
the
Cincinnati
CMSA,
but
both
contain
high
emitting
coal­
fired
power
plants
and
therefore
should
be
included
in
the
nonattainment
area
due
to
their
probable
contribution
to
the
poor
air
quality
in
the
Cincinnati
area.
EPA's
June
29,
2004
letter
to
the
State
explains
that
these
counties
should
be
designated
attainment/
unclassifiable
despite
their
power
plants
because
they
have
low
population,
population
growth
and
VMT.
These
factors
do
not
change
the
important
fact
that
the
Ghent
electric
generating
facility
in
Carroll
County
produced
over
46,000
of
SO2
and
over
19,000
tons
of
NOx
while
the
H.
L.
Spurlock
power
plant
in
Mason
County
emitted
over
40,000
tons
of
SO2
and
over
8,000
tons
of
NOx
in
2002.
Regardless
of
population
in
these
counties,
these
high
emitting
plants
must
be
controlled
for
their
impact
on
the
nonattainment
problem
in
the
Cincinnati
area.

EPA
Response:
In
February
2004,
Kentucky
recommended
that
all
Kentucky
counties
in
the
Cincinnati­
Hamilton
MSA
be
designated
attainment
for
the
PM2.5
standard.
EPA
is
modifying
Kentucky's
recommendation
to
include
Boone,
Campbell
and
Kenton
Counties
in
the
Cincinnati­
Hamilton
nonattainment
area.
Boone
County
has
significant
emissions,
relatively
high
population
growth,
and
a
large
(>
10,000
tons
per
year
SO2)
power
plant
located
in
the
County.
Campbell
and
Kenton
Counties
have
significant
VMT,
significant
numbers
of
commuters
into
violating
Hamilton
County,
and
both
counties
part
of
the
Cincinnati
1­
hour
ozone
nonattainment
area
due
to
violating
monitors.
Kenton
County
also
has
monitoring
data
close
to
the
standard.
EPA
agrees
that
the
remaining
KY
MSA
counties
of
Gallatin,
Grant,
and
Pendleton
should
be
designated
as
attainment/
unclassifiable
due
to
low
emissions,
very
low
population
relative
to
the
area,
and
very
low
numbers
of
commuters
into
the
violating
counties.

EPA
agrees
that
the
adjacent
counties
of
Carroll
and
Mason
should
be
designated
attainment/
classifiable
for
the
PM2.5
standard,
although
they
have
significant
emissions
due
to
power
plants.
These
counties
have
relatively
low
populations,
low
population
growth,
and
low
VMT
.
Further,
their
commuting
patterns
and
distance
from
the
violating
monitors
indicate
that
these
counties
do
not
contribute
to
the
violations
in
the
area.
The
other
adjacent
counties
do
not
contribute
and
therefore,
will
be
designated
as
attainment/
unclassifiable.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.
4­
29
Comment:
1041­
5
Region:
4
State:
KY
Area:
Cincinnati­
Hamilton,
OH­
KY­
IN
|
Dayton­
Spriengfield,
OH
|
Lexington,
KY
Comment:
Commenter
states
there
were
many
contradictions
or
inaccuracies
noted
throughout
the
June
29,
2004
letter
from
EPA.
These
include:

1.
On
page
3,
the
letter
states
"
Campbell
and
Kenton
Counties 
and
both
counties
part
[
sic]
of
the
Cincinnati
1­
hour
ozone
nonattainment
area
due
to
violating
monitors."
This
statement
is
incorrect.
On
August
30,
2002,
EPA's
final
rule,
redesignating
the
Kentucky
portion
of
the
Cincinnati­
Hamilton
1­
Hour
Ozone
Nonattainment
Area
to
maintenance,
became
effective.

2.
On
page
4,
the
table
that
EPA
utilizes
in
it's
analysis
of
the
weighted
emissions
factor
for
the
area
includes
Montgomery
County,
Ohio.
However,
Montgomery
County,
Ohio
is
not
in
the
MSA,
it
is
in
the
Dayton­
Springfield
MSA,
so
the
emissions
from
this
county
would
skew
the
analysis.

3.
Comments
on
page
5
and
page
12
indicate
that
even
though
a
monitor
shows
attainment
with
the
standard,
being
close
to
the
standard
is
a
reason
for
nonattainment
designation.

4.
On
page
20,
the
letter
states
"
Although
Pulaski
County
This
factor
did
not
appear
significant
for
the
remaining
counties
listed
in
this
table."
It
appears
that
a
sentence
ending
is
missing.

5.
On
page
22,
the
letter
states
that
Madison
County
" 
has
the
largest
number
of
workers
commuting
into
Fayette
County
(
6,870),
which
is
relatively
insignificant
for
such
a
large
county
as
Fayette.
Based
on
the
analysis
for
this
factor,
there
are
no
counties
with
commuting
data
showing
a
potential
to
contribute
to
the
PM2.5
violations
in
Fayette
County."
On
page
23,
the
letter
states,
" 
no
other
Kentucky
counties,
with
the
exception
of
Madison
County,
have
VMT
and
commuting
data
with
a
potential
to
contribute
to
the
PM2.5
violations
in
Fayette
County."
One
page
indicates
that
commuting
data
indicates
no
potential
impact;
the
next
page
states
that
the
commuting
data
indicates
a
potential
impact.

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
4­
30
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.

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
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.
4­
31
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.

Comment:
1013a­
22
Region:
4
State:
KY
Area:
Evansville,
IN
Comment:
Our
June
16,
2004
letter
to
you
indicated
that
the
Kentucky
portions
of
the
Evansville
MSA
must
be
designated
nonattainment
along
with
the
Indiana
portion
of
this
MSA.
But
EPA
has
failed
to
recommend
that
this
area
be
designated
nonattainment.
Henderson
and
Webster
Counties
must
be
included
in
this
nonattainment
area.
In
addition,
Daviess
County,
adjacent
to
the
MSA,
must
be
included
in
the
nonattainment
area.
There
are
two
coal­
fired
power
plants
in
both
Webster
and
Henderson
Counties
while
the
Elmer
Smith
power
plant
is
located
in
Daviess
County.
Together,
these
facilities
emitted
almost
25,000
tons
of
SO2
and
almost
24,000
tons
of
NOx
in
2002.
These
power
plants
are
most
likely
important
factors
in
the
area's
nonattainment
problem
and
must
be
controlled.

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
is
designating
Henderson
County
as
attainment.
The
following
factors
played
a
role
in
this
decision:
low
emissions,
attaining
monitor
(
14.0),
low
population
growth
(
4%
or
1785
persons),
relatively
low
commuting,
designated
attainment
for
the
8­
hour
ozone
standard,
relatively
low
VMT
(
510,000
miles/
year),
and
no
large
power
plants.
The
adjacent
Kentucky
Counties
of
Daviess
and
Webster
were
included
in
this
analysis.
EPA
is
designating
the
adjacent
counties
of
Daviess
and
Webster
as
attainment.
The
following
reasons
played
a
role
in
this
decision
for
Webster
County:
relatively
low
emissions
as
compared
to
MSA
and
adjacent
counties,
low
population
(
14,079),
low
population
growth
rate,
low
VMT
(
119,000
miles/
year),
and
low
number
of
commuters.
The
following
reasons
played
a
role
in
this
decision
for
Daviess
County:
attaining
monitor
4­
32
(
14.9),
relatively
low
emissions
as
compared
to
MSA
and
adjacent
counties,
adjacent
to
Henderson
(
attaining),
and
low
number
of
commuters.

Comment:
1013a­
23
Region:
4
State:
KY
Area:
Huntington­
Ashland,
WV­
KY­
OH
Comment:
EPA
failed
to
include
Greenup
County,
part
of
the
Huntington
MSA,
in
its
recommended
nonattainment
area.
There
is
no
monitor
in
this
county
in
order
to
determine
that
this
area
is
attaining
despite
the
violation
in
the
adjacent
county.
This
county
must
be
included
in
the
nonattainment
area.

EPA
Response:
In
February
2004,
Kentucky
recommended
that
the
PM2.5
designation
for
Boyd
County
be
deferred
and
that
Greenup
and
Carter
Counties
be
designated
attainment
for
the
Huntington­
Ashland
MSA.
EPA
is
modifying
Kentucky's
recommendation
to
include
Boyd
County
and
Lawrence
Counties
in
Kentucky
in
the
Huntington­
Ashland
nonattainment
area.
The
following
factors
played
a
significant
role
in
this
decision
for
Boyd
County:
attaining
monitor
reading
of
15.0
µ
g/
m3,
at
the
standard;
significant
SOx,
NOx,
and
PM
emissions;
proximity
to
the
violating
MSA
counties;
controls
with
anticipated,
substantial
SOx,
NOx,
and
PM
emission
reductions
will
not
be
implemented
until
the
end
of
2005,
well
after
designations
are
made.
Lawrence
County,
Kentucky
is
included
due
to
significant
emissions
of
SOx
and
NOx
from
a
power
plant
and
its
close
proximity
to
the
violating
counties
in
the
MSA.
We
have
included
in
our
recommended
nonattainment
area
this
County
that
is
adjacent
to
the
Huntington­
Ashland
MSA
with
a
violating
monitor,
that
is
generally
rural
in
character,
and
that
contains
an
identifiable
large
emitting
facility
(
e.
g.,
power
plant)
which
we
believe
contributes
to
the
nearby
nonattainment
problem.
We
have
included
this
county
in
our
initial
recommendations
in
order
to
ensure
that
a
sufficient
portion
of
this
county,
including
such
a
large
facility,
is
included
within
the
boundaries
of
the
nonattainment
area
as
part
of
the
final
designations.
We
invite
you
to
submit
to
us
a
recommendation
as
to
what
portion
of
this
adjacent
county,
encompassing
the
large
facility,
should
be
designated
nonattainment.

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

Comment:
1013a­
24
Region:
4
State:
KY
Area:
Lexington,
KY
Comment:
EPA
failed
to
include
10
counties
in
the
Lexington
nonattainment
area;
those
counties
are:
Anderson,
Bath,
Bourbon,
Franklin,
Jessamine,
Menifee,
Montgomery,
4­
33
Pulaski,
Rock
Castle
and
Scott.
With
the
exception
of
Pulaski
County,
all
of
these
counties
are
part
of
the
CMSA.
The
entire
CMSA
must
be
designated
nonattainment.
The
Cooper
electric
generating
facility
is
located
in
Pulaski
County;
this
facility
emitted
over
22,000
tons
of
SO2
and
almost
5,000
tons
of
NOx
in
2002.
Therefore,
this
county
must
be
included
in
the
nonattainment
area
due
to
its
probable
contribution
to
the
poor
air
quality
in
the
area.

EPA
Response:
In
February
2004,
Kentucky
recommended
that
Fayette
County
be
designated
attainment
for
the
PM2.5
standard
for
the
Lexington,
KY
MSA,
and
the
remaining
MSA
counties
be
designated
attainment.
EPA
agrees
that
Fayette
County
should
be
designated
nonattainment
for
PM2.5
due
to
a
violating
monitor
(
South
Limestone).
EPA
is
modifying
Kentucky's
recommendation
to
include
a
portion
of
the
adjacent
county
of
Mercer
in
the
Lexington
nonattainment
area.
EPA
agrees
that
the
remaining
MSA
Counties
of
Bourbon,
Clark,
Jessamine,
Madison,
Scott,
and
Woodford
in
Kentucky
be
designated
attainment/
unclassifiable
due
to
their
relatively
low
emissions,
low
populations,
low
VMT,
low
numbers
of
commuters
into
the
violating
counties,
and
small
point
sources.

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

Comment:
1013a­
25
Region:
4
State:
KY
Area:
Louisville,
KY­
IN
Comment:
EPA
failed
to
include
9
counties
(
Hardin,
Henry,
Larue,
Meade,
Nelson,
Oldham,
Shelly,
Spencer
and
Trimble)
in
its
recommended
nonattainment
area
for
the
Louisville
CMSA.
EPA's
analysis
only
indicates
that
Bullitt,
Jefferson
and
Oldham
Counties
are
part
of
the
CMSA,
but
there
are
6
other
counties
that
are
part
of
the
CMSA.
All
of
these
counties
must
be
included
in
the
nonattainment
area.
Hardin
County
is
the
only
county
with
a
monitor
besides
Jefferson
and
Bullitt.
The
2001­
2003
design
value
for
Hardin
County
is
14.1
µ
g/
m3,
which
is
very
near
to
a
violation.

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

EPA
agrees
that
the
Kentucky
MSA
County
of
Oldham
be
designated
attainment/
unclassifiable
due
to
low
emissions
and
relatively
low
population.
EPA
agrees
that
Jefferson
County
be
designated
nonattainment
due
to
four
violating
monitors
in
the
4­
34
County
and
is
modifying
Kentucky's
recommendation
to
include
Bullitt
County
in
the
Louisville
nonattainment
area
due
to
a
relatively
high
number
of
commuters
into
violating
Jefferson
County,
a
monitored
PM2.5
value
of
14.9
that
is
very
close
to
the
standard,
and
relatively
high
population
growth.

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

Comment:
1037­
3
Region:
4
State:
NC
Area:

Comment:
Commenter
states
that
the
emissions­
weighted
analysis
fails
to
account
for
prevailing
wind
directions
during
the
periods
when
PM2.5
values
are
higher,
assumes
incorrectly
that
emissions
impact
a
monitor
equally
throughout
the
year,
fails
to
consider
distance
between
emissions
and
the
monitors,
and
fails
to
recognize
any
effects
from
the
significant
reductions
resulting
from
North
Carolina's
Clean
Smokestacks
Act.
The
most
glaring
demonstration
of
the
weakness
of
the
emissions­
weighted
approach
is
that
some
counties
EPA
intends
to
designate
as
nonattainment
under
this
approach
actually
are
in
attainment
according
to
monitors
located
in
those
counties.
Moreover,
this
emissionsweighted
analysis
was
introduced
late
and
so
could
not
be
addressed
by
the
Governors
in
their
initial
recommendations.
This
runs
counter
to
the
state­
federal
interactive
process
prescribed
by
law.
For
these
reasons,
the
State
believes
that
the
use
of
the
emissionsweighted
approach
is
arbitrary
and
should
not
influence
the
final
delineation
of
nonattainment
area
boundaries.

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
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.
4­
35
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.

Comment:
1037­
1
Region:
4
State:
NC
Area:
Greensboro­
Winston­
Salem­
High
Point,
NC
Comment:
Commenter
notes
that
the
non­
attainment
boundary
recommended
by
EPA
include
several
counties
that
North
Carolina
continues
to
believe
should
be
designated
attainment
for
PM2.5.
Commenter
also
attaches
PM2.5
Designation
Response
Technical
Support
Document.

1.
In
the
Greensboro/
Winston­
Salem/
High
Point
area,
EPA
recommends
that
the
entire
counties
of
Stokes,
Guilford,
Davidson,
Forsyth
and
Randolph
be
designated
nonattainment
North
Carolina
originally
recommended
Davidson
County
only
as
the
PM2.5
non­
attainment
boundary.
We
continue
to
believe
that
only
Davidson
County
should
be
designated
as
non­
attainment.
4­
36
2.
North
Carolina
believes
that
Stokes
County
should
be
designated
attainment
for
the
following
reasons.
While
Stokes
County
contains
the
Belews
Creek
power
plant,
an
analysis
of
forward
trajectories
indicates
that
emissions
from
Belews
Creek
do
not
frequently
impact
the
PM2.5
monitor
in
Davidson
County.
There
are
also
PM2.5
monitors
currently
attaining
the
standard
in
Forsyth
County
that
lie
between
Stokes
County
and
the
non­
attaining
monitor
in
Davidson
County.
Even
if
the
Belews
Creek
facility
is
affecting
the
Lexington
area,
significant
NOx
controls
have
already
been
installed
on
the
plant.
Selective
catalytic
reduction
systems
have
already
been
installed
on
units
1
and
2
at
the
Belews
Creek
facility,
and
additional
burner
technology
has
been
added
at
unit
2.
This
NOx
control
technology
began
operation
in
2003
and
2004.
Consequently,
the
NOx
emissions
will
decrease
from
43,567
tons
per
year
to
7,022
tons
per
year
and
new
SO2
controls
will
be
installed
over
the
next
several
years
as
a
result
of
the
Clean
Smokestacks
Act.
SO2
emissions
from
Belews
Creek
will
be
reduced
by
nearly
90%
in
the
next
several
years
as
these
controls
become
fully
operational.

3.
Stokes
County
is
an
extremely
rural
county,
and
therefore
has
very
little
mobile
emissions.
North
Carolina
believes
that
the
current
and
future
controls
on
the
Belews
Creek
facility,
the
apparent
small
impact
of
Belews
Creek
on
Davidson
County,
and
the
rural
nature
of
the
county
support
designating
Stokes
County
in
attainment
for
PM2.5.
If
EPA
continues
to
believe
that
Stokes
County
should
be
designated
non­
attainment
because
of
Belews
Creek,
North
Carolina
recommends
that
only
the
Sauratown
Township
where
the
Belews
Creek
power
plant
is
located
be
designated
non­
attainment.

4.
North
Carolina
believes
that
Randolph
County
should
be
designated
attainment
for
several
reasons.
The
EPA
L­
Factor
ranking
for
Randolph
County
is
the
lowest
of
the
counties
recommended
by
EPA
to
be
designated
non­
attainment.
Randolph
County
is
also
predominately
downwind
of
Davidson
County
during
the
summer
months
when
PM2.5
concentrations
are
the
highest
and
therefore
emissions
from
Randolph
County
would
not
be
expected
to
contribute
significantly
to
PM2.5
concentrations
in
Davidson
County
during
those
months.
The
majority
of
emissions
within
Randolph
County
are
mobile
emissions
and
less
than
5%
of
the
workforce
commutes
into
Davidson
County.
Furthermore,
the
mobile
source
emissions
will
be
addressed
by
federal
rules
such
as
heavy­
duty
engine
standards
and
low
sulfur
diesel.

5.
Guilford
and
Forsyth
counties
each
contain
PM2.5
monitors
that
are
attaining
the
standard
based
on
current
design
values.
The
counties
also
lie
to
the
north
and
northeast
of
Davidson
County,
which
makes
Guilford
and
Forsyth
counties
predominately
downwind
of
Davidson
County
during
the
summer
months
when
PM2.5
is
the
highest.
The
majority
of
emissions
from
these
counties
are
mobile,
and
therefore
these
counties
and
surrounding
counties
will
benefit
from
federal
rules
addressing
mobile
emissions
as
well
as
the
expanded
North
Carolina
motor
vehicle
inspection
program.
They
will
also
benefit
from
local
measures
aimed
at
reducing
mobile
emissions
as
part
of
the
Early
Action
Compact
(
EAC)
effort
in
the
Triad
area.

6.
North
Carolina
has
an
analysis
that
shows
PM2.5
concentration
and
its
relationship
to
population
density
in
the
Triad
area.
The
Lexington
monitor
does
not
behave
the
same
as
4­
37
surrounding
monitors
when
considering
the
population
around
the
monitoring
site.
The
analysis
suggests
that
the
higher
concentrations
of
PM2.5
in
Davidson
County
are
the
result
of
local
factors
rather
than
broader
population­
related
regional
influences
and
therefore
the
addition
of
counties
beyond
just
Davidson
County
will
not
help
the
monitor
attain
the
standard.
Please
see
appendix
for
details.

7.
With
regard
to
the
Lexington
monitor,
there
has
been
a
downward
trend
in
the
PM2.5
concentrations
since
1999.
We
believe
that
this
in
considerable
part
reflects
some
reductions
in
the
emission
of
pollutants
in
certain
upwind
states
over
that
period.
EPA
itself
has
already
concluded
that
these
out­
of­
state
sources
contribute
significantly
to
elevated
PM2.5
in
North
Carolina.
We
expect
that
the
downward
trend
should
continue
at
this
site
as
more
emissions
reductions
are
expected
due
to
implementation
of
the
Clean
Smokestacks
Act,
NOx
SIP
call
rules,
federal
heavy­
duty
engine
standards
and
new
fuel
standards.
We
anticipate
further
improvement
in
Lexington
monitor
air
quality
will
result
from
positive
action
by
EPA
on
North
Carolina's
section
126
petition,
as
well
as
actual
promulgation
of
the
proposed
Clean
Air
Interstate
Rule,
both
of
which
will
further
reduce
the
contribution
from
upwind,
out­
of­
state
sources
to
the
Lexington
area's
non­
attainment
and
maintenance
problems.

For
the
reasons
stated
herein,
North
Carolina
believes
that
only
Davidson
County
should
be
designated
non­
attainment,
while
Stokes,
Randolph,
Guilford
and
Forsyth
counties
should
be
designated
as
attainment
for
PM2.5.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

For
the
Greensboro
area,
EPA
proposed
to
modify
the
State's
recommendation
to
include
Davidson
County
and
the
MSA
counties
of
Guilford,
Stokes,
Forsyth
and
Randolph.
Guilford,
Forsyth
and
Randolph
counties
are
adjacent
to
Davidson
County
and
have
large
populations
and
large
emissions.
Stokes
has
significant
power
plant
emissions.
EPA
did
not
take
into
consideration
participation
in
Early
Action
Compacts
(
EACs)
for
8­
hour
ozone
in
making
modifications
to
recommended
designations
and
boundaries
for
this
area.

Comment:
1013a­
34
Region:
4
State:
NC
Area:
Greensboro­
Winston­
Salem­
High
Point,
NC
Comment:
Davie,
Surry,
Yadkin,
and
Rockingham
Counties
are
all
part
of
the
Greensboro
CMSA,
but
EPA
has
not
recommended
that
these
areas
be
included
in
the
nonattainment
area.
Rockingham
County
in
particular
is
home
to
the
Dan
River
coal­
fired
power
plant,
which
emitted
almost
3,000
tons
of
SO2
and
over
1,000
tons
of
NOx
in
2002.
In
addition,
the
adjacent
counties
of
Chatham
and
Rowan
must
be
included
in
the
nonattainment
area
due
to
the
coal­
fired
power
plants
located
within
these
counties
that
4­
38
contribute
to
the
nonattainment
problem.
The
Cape
Fear
power
plant
emitted
almost
12,000
tons
of
SO2
and
over
2,000
tons
of
NOx
in
2002.
The
Buck
electric
generating
facility
is
located
in
Rowan
and
must
be
included
in
the
nonattainment
area
as
well
due
to
its
likely
contribution
to
the
poor
air
quality
in
this
area.

EPA
Response:
In
February
2004,
North
Carolina
recommended
that
the
entire
county
of
Davidson,
be
designated
as
nonattainment
for
the
Fine
Particulate
Matter
Standard.
In
the
June
29,
2004,
response,
EPA
recommended
Davidson
County
be
designated
nonattainment
because
it
has
a
violating
PM
2.5
monitor.
The
MSA
counties
of
Guilford,
Stokes,
Forsyth
and
Randolph
were
also
being
recommended
as
nonattainment.
EPA
agreed
that
Alamance,
Davie,
Yadkin,
Rowan,
Chatham,
Rockingham,
and
Iredell
Counties
be
designated
attainment/
unclassifiable.
Alamance
is
an
MSA
county
with
an
attaining
monitor
of
13.7
micrograms
per
cubic
meter
(
µ
g/
m3),
75
%
of
the
commuters
remain
in
Alamance
County
and
the
county
has
low
emissions.
Davie
and
Yadkin
are
MSA
counties
that
do
not
contain
PM
2.5
monitors,
have
low
populations,
and
low
commuting
into
Davidson.
There
is
significant
distance
between
the
violating
monitor
and
the
counties
of
Iredell
and
Yadkin.
Rowan
and
Iredell
are
adjacent
to
the
MSA,
do
not
contain
PM
2.5
monitors
and
are
a
part
of
the
Charlotte­
Gastonia­
Rock
Hill
nonattainment
area
for
ozone.
Rowan
and
Rockingham
both
have
small
power
plants,
and
there
are
attaining
monitors
in
Rockingham
between
the
SO2/
NOx
sources
in
Rockingham
and
the
violating
monitor.
Chatham
is
an
adjacent
county
to
the
Greensboro­
Winston­
Salem­
High
Point
MSA
with
an
attaining
monitor
of
12.2
µ
g/
m3,
has
low
population,
and
part
of
the
county
is
in
the
Raleigh­
Durham­
Chapel
Hill
nonattainment
area
for
ozone.
The
remaining
adjacent
counties
all
have
low
emissions,
low
population
and
low
VMT,
indicating
they
should
be
attainment/
unclassifiable.
EPA's
final
decisions
on
the
State's
recommendations
are
contained
in
the
TSD.

Comment:
1072­
1
Region:
4
State:
NC
Area:
Greensboro­
Winston­
Salem­
High
Point,
NC
|
Hickory­
Morganton­
Lenoir,
NC
Comment:
Commenter
is
commenting
on
behalf
of
the
Southern
Environmental
Law
Center
(
SELC)
and
the
Southern
Alliance
for
Clean
Energy.
Commenter
is
concerned
that
without
adequate
justification,
EPA
proposes
to
exclude
numerous
counties
that
lie
within
presumptive
nonattainment
boundaries
as
well
as
other
areas
that
contribute
to
monitored
violations.
Commenter
is
also
concerned
about
the
small
boundaries
that
North
Carolina
is
proposing
in
the
Piedmont
area
of
the
state.

Commenter
urges
EPA
to
expand
North
Carolina
boundaries
to
include
all
counties
in
all
MSAs
where
a
violations
is
registered
anywhere
within
the
MSA.
This
would
result
in
the
entire
MSA
of
Greensboro­
Winston
Salem­
High
Point
and
Hickory­
Morganton­
Lenoir
being
designated
nonattainment
for
PM2.5.
Commenter
also
urges
EPA
designate
all
areas
that
contribute
to
a
nonattaining
monitor.
This
would
result
in
EPA
designating
at
least
Rowan
County
as
nonattainment
within
the
Charlotte
MSA,
and
quite
likely
the
4­
39
entire
Charlotte
MSA
as
nonattainment.
Commenter
specifically
requests
a
response
from
EPA
on
their
letter
requesting
EPA
designate
the
entire
Charlotte
MSA
as
nonattainment
for
PM2.5.
Commenter
urges
installation
of
a
PM2.5
monitor
in
Rowan
County
to
ensure
that
fine
particulate
matter
levels
in
Rowan
meet
the
NAAQS.

Specific
comments
are
found
below:

1.
EPA
has
not
justified
its
proposal
to
designate
only
part
of
the
Hickory
and
Triad
areas
as
nonattainment.
EPA's
proposed
designations
are
an
improvement
over
the
state's
recommendation
but
are
still
not
nearly
sufficient
to
meet
CAA
requirements
and
ensure
good
air
quality.
EPA
should
follow
its
own
presumptive
boundaries
and
designate
as
nonattainment
all
counties
in
the
Hickory
and
Greensboro
MSAs.

2.
EPA
must
designate
Rowan
County
as
nonattainment
because
of
its
significant
contributions
to
violating
PM2.5
levels
in
Davidson
County
in
the
Greensboro
MSA.
As
EPA's
own
data
demonstrates,
Rowan
matches
or
exceeds
counties
that
have
been
recommended
for
nonattainment
designation
in
all
nine
sections
of
EPA's
9­
factor
analysis.
Furthermore,
during
the
summer
months
when
the
State
reports
that
most
PM2.5
violations
occur,
meteorological
patterns
put
the
county
upwind
of
much
of
the
Greensboro
MSA,
including
the
violating
monitor
in
Davidson
County.

3.
EPA
has
not
addressed
SELCs
recommendations
to
designate
the
Charlotte
MSA
nonattainment.
EPA
is
required
to
designate
as
nonattainment
any
areas
that
contribute
pollution
to
monitors
registering
violations.
EPA
information
has
consistently
indicated
that
sources
from
the
Charlotte
area
contribute
to
violations
of
PM2.5
in
Davidson
and
Catawba
Counties.

4.
EPA
should
designate
the
balance
of
the
Charlotte
MSA
nonattainment
because
of
its
significant
contributions
to
PM2.5
Violations
in
Davidson
County.

5.
North
Carolina's
recommendation
that
only
a
portion
of
Catawba
County
be
designated
as
nonattainment
is
inconsistent
with
EPA
guidance.
Counties
containing
violating
monitors
must
be
designated
in
their
entirety.

6.
North
Carolina's
argument
based
on
economic
considerations
is
flawed
and
inapplicable
to
health­
based
NAAQS.

7.
Trends
and
predictions
are
irrelevant
with
regard
to
nonattainment
designations.
What
North
Carolina
characterizes
as
a
trend
toward
cleaner
air
may
in
fact
simply
reflect
a
temporary
lowering
of
PM2.5
values
during
the
cooler,
wetter
years
of
2003
and
2004.

8.
Areas
that
were
designated
nonattainment
for
ozone
should
not
be
excluded
from
PM2.5
nonattainment
designation.

9.
Davidson
County
is
receiving
pollution
from
both
local
and
regional
sources.
This
supports
a
much
larger
area
for
designation
than
Davidson
County
alone.
It
is
no
surprise
4­
40
that
a
county
located
between
Greensboro,
Charlotte
and
Catawba
County
is
facing
a
serious
air
quality
problem.
It
is
essential
that
EPA
respond
by
designating
as
nonattainment
all
areas
that
contribute
to
Davidson
County's
dirty
air,
including
the
entire
Greensboro,
Hickory,
and
Charlotte
MSAs.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.
EPA
has
considered
the
Charlotte
MSA
and
based
on
our
analysis
disagrees
with
the
commenter
that
Charlotte
be
included
in
the
Greensboro
area.
It
would
be
inconsistent
with
the
Clean
Air
Act
for
EPA,
at
this
stage,
to
add
any
counties
not
previously
cited
in
its
notice
of
proposed
modifications
to
the
State's
recommendations.

Comment:
1037­
2
Region:
4
State:
NC
Area:
Hickory­
Morganton­
Lenoir,
NC
Comment:
1.
With
regard
to
the
non­
attaining
monitor
in
Hickory,
North
Carolina
continues
to
oppose
a
non­
attainment
designation
for
any
area
beyond
the
metropolitan
planning
organization
boundary
of
Catawba
County.
There
is
little
to
be
gained
by
including
the
partial
counties
of
Burke
and
Caldwell
in
the
non­
attainment
area
for
the
Hickory
region
for
several
reasons.
Catawba
County
emissions
are
significantly
higher
than
both
Burke
and
Caldwell
counties
in
the
L­
Factor
analysis.
The
bulk
of
emissions
from
these
counties
is
from
the
mobile
sector
and
therefore
will
benefit
from
state
and
federal
rules
addressing
mobile
emissions.
There
would
be
little
to
no
additional
opportunity
to
reduce
mobile
emissions
by
designating
Burke
and
Caldwell
counties
as
non­
attainment.

2.
A
non­
attainment
designation
for
PM2.5
would
place
significant
additional
burdens
on
Burke
and
Caldwell
counties
since
these
counties
are
already
participating
in
an
EAC
for
ozone.
These
counties
are
making
progressive
strides
to
reduce
emissions
as
part
of
the
EAC
effort
and
North
Carolina
feels
that
a
designation
of
non­
attainment
for
these
counties
would
do
little
to
reduce
PM2.5
in
Catawba
County.
North
Carolina
believes
the
recommendation
to
designate
only
Catawba
County
as
non­
attainment
is
appropriate,
while
Burke,
Caldwell
and
the
non­
MPO
parts
of
Catawba
counties
should
be
designated
as
attainment
for
PM2.5.

3.
Furthermore,
on
the
basis
of
air
quality
data
for
2004
gathered
to
date,
North
Carolina
believes
there
is
a
significant
probability
that
the
Hickory
monitor
will
attain
the
standard
based
on
complete
2002­
2004
data.
We
expect
that
it
will
be
possible
to
maintain
this
attainment
status
as
more
emissions
reductions
are
expected
due
to
implementation
of
the
Clean
Smokestacks
Act,
NOx
SIP
call
rules,
federal
heavy­
duty
engine
standards
and
new
fuel
standards.
We
are
also
anticipating
needed
reductions
from
upwind
out­
of­
state
sources
from
the
proposed
Clean
Air
Interstate
Rule,
North
Carolina's
section
126
petition
and
other
initiatives,
which
will
help
Davidson
County
as
well.
EPA
already
has
4­
41
concluded
that
these
out­
of­
state
sources
contribute
significantly
to
elevated
PM2.5
in
North
Carolina.

4.
North
Carolina
therefore
suggests
that
EPA
designate
the
Hickory
area
as
"
unclassifiable",
if
the
designation
is
made
before
December
31,
2004.
The
designation
for
this
area
as
attainment
can
then
be
finalized
in
February
2004
using
the
2002­
2004
data,
assuming
that
it
in
fact
shows
what
we
anticipate.
Alternatively,
if
the
designation
is
made
after
December
31,
2004,
the
designation
should
be
based
on
the
2002­
2004
data.
This
approach
would
conserve
significant
federal,
state
and
local
resources
by
avoiding
the
need
for
the
redesignation
demonstration,
as
well
as
transportation
conformity,
in
an
area
that
is
already
attaining
the
PM2.5
standard.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM­
2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

Comment:
1013a­
35
Region:
4
State:
NC
Area:
Hickory­
Morganton­
Lenoir,
NC
Comment:
EPA
only
recommended
parts
of
Burke
and
Caldwell
Counties
for
nonattainment
and
did
not
recommend
Alexander,
Cleveland
and
Rutherford
Counties
for
nonattainment.
Cleveland
and
Rutherford
Counties,
adjacent
to
the
Hickory
MSA,
both
have
higher
emissions
and
must
be
included
in
the
nonattainment
area.
The
Cliffside
coal­
fired
power
plant,
located
in
both
of
these
counties,
emitted
over
22,000
tons
of
SO2
and
almost
4,000
tons
of
NOx
in
2002.
All
of
these
counties
must
be
included
in
the
nonattainment
area
in
their
entirety.

EPA
Response:
In
February
2004,
North
Carolina
recommended
that
the
Unifour
Metropolitan
Planning
Organization's
(
MPO)
Planning
Boundary
in
Catawba
County,
be
designated
as
nonattainment.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

Comment:
1039­
1
Region:
4
State:
SC
Area:
Greenville­
Spartanburg,
SC
Comment:
Commenter
reaffirms
South
Carolina
DHEC's
recommendation
of
the
entire
state
as
attainment
for
the
PM2.5
NAAQS.
They
disagree
with
EPA's
recommendation
of
the
Greenville­
Spartanburg
area
as
unclassifiable
until
3
years
of
data
are
collected.

1.
The
Greenville
EQC
sampler
was
placed
into
operation
in
August
2001.
This
sampler
in
addition
to
the
two
'
core'
samplers
required
for
the
MSA
demonstrate
attainment
with
the
annual
and
24­
hour
PM2.5
NAAQS.
4­
42
2.
All
of
these
areas
have
been
reviewed
and
it
has
been
determined
that
spatial
averaging
is
appropriate
for
the
planning
areas
in
South
Carolina.

3.
Apart
from
the
process
for
attainment
determination,
DHEC
is
concerned
about
the
atypical
impacts
on
air
quality
indicated
by
the
Greenville
EQC
sampler.
DHEC
has
taken
steps
to
evaluate
the
potential
sources
of
emissions
that
cause
atypical
readings
in
cold
weather.
The
nature
and
distribution
of
these
unusual
samples
indicate
impact
at
the
monitoring
site
from
a
local
particulate
source,
possibly
residential
sources
that
heat
with
wood,
fuel,
oil
and
coal.
DHEC
intends
to
work
closely
with
EPA
for
advice
and
assistance
as
they
work
with
the
community
on
this
effort.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

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.

Comment:
1040­
2
Region:
4
State:
TN
Area:
Chattanooga,
TN­
GA
Comment:
1.
Tennessee
does
not
object
to
the
naming
of
Hamilton
County,
as
it
is
consistent
with
our
most
recent
recommendation
and
the
fact
that
it
is
measuring
nonattainment
of
the
PM2.5
standard.
4­
43
2.
Tennessee
does
object
to
the
naming
of
Marion
County
as
there
are
essentially
no
point
source
emissions
and
most
of
the
county's
emission
inventory
is
mobile
source
emissions
from
through
commuters
(
heavy
duty
trucks)
along
Interstate
24.
Because
of
federal
preemptions
on
fuels
and
the
fact
that
these
trucks
are
not
stationed
in
Marion
County,
there
is
nothing
that
the
county
or
the
state
can
do
but
wait
on
the
federal
fuels
and
diesel
rules
to
take
effect.
It
makes
no
sense
to
place
a
county
in
economic
growth
jeopardy
by
declaring
them
to
be
nonattainment
contributing
when
the
facts
so
clearly
justify
otherwise.

3.
There
have
been
numerous
meetings
since
June
with
local
city
&
county
representatives,
Metropolitan
Planning
Organizations,
Economic
and
Community
Development,
environmental
groups,
industry
and
the
public.
This
has
also
provided
an
opportunity
for
additional
discussions
regarding
the
potential
PM2.5
nonattainment
areas.
Control
measures
that
are
being
implemented
to
address
ozone
nonattainment
will
also
have
positive
impacts
in
mitigation
of
PM2.5
nonattainment.
Tennessee
is
also
planning
to
implement,
in
a
number
of
areas,
including
Knoxville
and
Chattanooga,
PM2.5
forecasting
or
Air
Quality
forecasts
(
in
areas
with
existing
Ozone
forecasting
programs).
The
opportunity
to
educate
the
public
and
encourage
business
participation
and
involvement
in
reducing
PM2.5
emissions
and
precursors
will
also
provide
a
positive
benefit
toward
achieving
and
maintaining
PM2.5
attainment.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

Comment:
1073­
3
Region:
4
State:
TN
Area:
Chattanooga,
TN­
GA
Comment:
Hamilton
County
MSA
1.
Supports
EPA's
inclusion
of
Marion
County
in
the
Hamilton
County
nonattainment
area.
Marion
County
is
a
significant
contributor
of
PM2.5
in
the
Chattanooga
area
because
of
the
commuting
patterns
of
its
residents,
high
VMTs
and
the
presence
of
a
major
highway,
I­
24,
through
the
county.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.
4­
44
Comment:
1073­
1
Region:
4
State:
TN
Area:
Chattanooga,
TN­
GA
|
Knoxville,
TN
Comment:
The
commenter,
on
behalf
of
the
Southern
Alliance
for
Clean
Energy,
national
Parks
Conservation
Association,
Tennessee
Citizens
for
Wilderness
Planning,
Southern
Environmental
Law
Center,
and
Tennessee
Environmental
Council,
suggests
EPA
make
their
designations
in
a
cautious
manner.
She
notes
that
EPA's
scientists
have
suggested
that
the
current
PM2.5
standard
of
15
µ
g/
m3
is
not
protective
and
have
recommended
a
standard
as
low
as
12
µ
g/
m3
and
healthcare
experts
have
recommended
a
standard
as
low
as
10
µ
g/
m3.
She
suggests
EPA
should
keep
in
mind
that
many
counties
have
design
values
that
exceed
10­
12
µ
g/
m3
as
the
agency
designates
nonattainment
areas.
She
supports
broad
designations
that
will
lead
to
controlling
sources
outside
of
the
violating
area
that
are
likely
contributing
to
nonattainment.
In
addition
she
comments
that
the
Tennessee
DEC
recommendations
are
not
in
the
best
interest
of
citizens
and
would
result
in
people
in
Knox
and
Hamilton
Counties
breathing
unhealthy
air
far
longer
than
is
necessary.
In
general,
commenter
agrees
with
EPA's
proposal
for
nonattainment
areas
with
the
exception
of
the
exclusion
on
Campbell
and
Union
Counties
from
the
Knox
County
area.

EPA
Response:
In
a
February
12,
2004
letter,
the
State
recommended
that
Knox,
Roane,
and
McMinn
Counties
be
designated
nonattainment
based
on
2000­
2002
monitoring
data.
The
State
revised
its
recommendation
on
May
7,
2004,
to
recommend
that
McMinn
and
Roane
Counties
be
designated
attainment
due
to
2001­
2003
data.
Therefore,
the
State's
current
recommendation
for
the
Knoxville
MSA
PM2.5
nonattainment
area
only
includes
Knox
County
and
recommends
that
all
other
MSA
and
adjacent
counties
be
designated
attainment.
The
State
submitted
justification
for
this
recommendation.
Union
County
has
very
small
amounts
of
PM2.5
and
precursor
emissions,
indicating
no
contribution.
Therefore,
EPA
agrees
that
Union
County
should
be
designated
attainment/
unclassifiable.

Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations
Comment:
1040­
1
Region:
4
State:
TN
Area:
Knoxville,
TN
Comment:
Tennessee
offered
the
following
comments
regarding
the
PM2.5
nonattainment
designations
recommended
by
the
Environmental
Protection
Agency
(
EPA)
as
outlined
in
EPA's
June
29,
2004
letter.

1.
McMinn
and
Roane
Counties:

EPA
has
proposed
the
inclusion
of
McMinn
and
Roane
Counties
as
PM2.5
nonattainment
areas
primarily
because
of
a
large
source
in
each
county
despite
the
fact
that
these
two
4­
45
counties
are
not
in
a
metropolitan
statistical
area
(
MSA).
Apparently,
the
sources
of
concern
are
Bowater
Newsprint
and
the
TVA
Kingston
Steam
Plant.
The
EPA
June
29,
2004
letter
declares
that
meteorology
or
geography/
topography
are
not
factors
in
the
EPA
rationale
for
including
the
counties.

Tennessee
avers
that
the
naming
of
these
rural
counties
as
nonattainment
based
upon
a
large
source
in
that
county
is
patently
unfair
to
the
citizens
of
that
county.
The
monitors
currently
measure
PM2.5
attainment,
so
it
has
to
be
an
argument
of
contribution.
Tennessee
agrees
that
in
general,
the
larger
sources
do
have
a
potential
to
be
contributors
to
the
formation
of
PM2.5,
but
there
has
been
no
plausible
demonstration
to
show
that
these
sources
actually
impact
either
the
Chattanooga
or
Knoxville
MSAs
where
air
monitoring
measures
PM2.5
nonattainment.

Therefore,
with
respect
to
McMinn
and
Roane
counties,
Tennessee
declares
the
following:

·
Neither
county
should
be
listed
as
significantly
contributing
to
the
nonattainment
of
another
county.

·
If
a
source(
s)
in
a
county
outside
of
an
MSA
is
to
be
listed
as
significantly
contributing
to
the
nonattainment
of
another
county,
it
should
be
listed
only
after
modeling
confirms
that.

·
Ultimately,
a
state
implementation
plan
to
ensure
that
all
of
Tennessee
will
attain
the
PM2.5
standard
will
be
required.

·
In
preparing
the
PM2.5
State
Implementation
Plan,
Tennessee
commits
to
model
the
two
sources
to
ascertain
their
impact
upon
the
Knoxville
and
Chattanooga
MSAs
and
to
the
extent
necessary,
require
sufficient
control
on
the
facilities
to
attain
the
standard.

·
EPA
extends
the
invitation
to
discuss
a
partial
county
designation
to
capture
these
sources
of
concern
as
long
as
the
ultimate
nonattainment
boundary
in
that
county
captures
the
source
and
is
contiguous
to
an
MSA
nonattainment
area.
Tennessee
rejects
this
offer,
as
it
has
no
scientific
or
technical
merit.
The
counties
measure
attainment,
so
it
is
not
an
argument
over
how
large
an
area
a
nonattaining
monitor
should
represent.
This
argument
concerns
contribution
from
point,
rather
than
area
sources.
If
a
boundary
is
to
be
drawn,
it
must
be
point
limited
without
a
peninsula
connecting
it
to
a
nonattaining
MSA.

·
Upon
designation
of
nonattainment,
existing
sources
are
expected
to
meet
a
RACT
level
of
control
for
the
pollutants
causing
nonattainment.
In
the
case
of
the
TVA
Kingston
Plant,
oxides
of
nitrogen
control
in
the
form
of
Low
NOx
burners
and
Selective
Catalytic
Reduction
units
is
underway.
Lower
sulfur
fuels
are
being
used
in
the
interim
and
ultimately
scrubbers
will
be
installed.
Details
of
the
control
efficiencies
and
timeline
for
implementation
are
enclosed
as
attachments
to
this
letter.
Since
the
facility
of
concern
will
have
controls
for
SOx
and
NOx
that
far
exceed
the
requirements
of
RACT,
it
seems
4­
46
useless
to
name
a
county
or
a
well­
controlled
facility
as
being
nonattainment
contributing
without
a
specific
modeling
study
done
at
the
controlled
level
making
a
demonstration
of
attribution.

·
The
"
urban
excess"
evaluations
conducted
by
EPA
and
proposed
as
a
method
for
"
L
factor"
ranking
of
the
counties
within
an
area
(
MSA),
according
to
their
relative
emissions
of
direct
and
indirect
PM2.5
related
air
contaminants,
also
provides
a
method
to
evaluate
potential
reductions
needed.
An
evaluation
of
the
urban
excess
data
for
Knoxville,
Tennessee
area
reveals
that
approximately
3
µ
g/
m3
total
urban
excess
is
present.
This
can
be
apportioned
based
on
the
emission
inventory.
The
approximate
amount
of
reduction
needed,
based
on
the
urban
excess
calculations
is
equal
to
about
2%
of
the
inventory.
This
is
the
projected
amount
needed
to
reduce
the
PM2.5
levels
below
the
15.0
µ
g/
m3
threshold
for
the
Knoxville
area.
When
the
entire
emission
reduction
amounts
are
actually
realized,
the
PM2.5
monitored
levels
could
be
reduced
to
approximately
14.0
µ
g/
m3
(
assuming
a
reduction
equal
to
the
total
urban
excess
amount).

·
The
existing
reductions
proposed
as
part
of
the
NOx
SIP
call
and
the
NOx
RACT
requirements
along
with
the
other
federal
program
reductions
planned
and
the
TVA
NOx
reductions
already
underway,
should
produce
reductions
that
will
achieve
these
goals.

·
It
is
unreasonable
to
include
the
Roane
and
McMinn
county
areas
that
are
monitoring
attainment
for
the
PM2.5
standard,
when
it
is
highly
likely
that
the
emission
reductions
described
above
will
alone
be
significant
enough
to
bring
the
Knoxville
area
into
attainment.
The
implementation
of
the
federal
programs
and
the
NOx
SIP/
RACT
requirements
will
also
bring
about
similar
reductions
for
the
sources
in
those
counties
as
well.
These
reductions
will
also
have
a
positive
impact
if
the
areas
are
considered
to
be
contributing
to
PM2.5
nonattainment
in
the
Knoxville
region.

2.
Tennessee
does
not
object
to
the
naming
of
Knox
County,
as
it
is
consistent
with
our
most
recent
recommendation
and
the
fact
that
it
is
measuring
nonattainment
of
the
PM2.5
standard.
The
additional
consideration
of
the
"
L"
factor
analysis
proposed
by
EPA
as
a
method
to
rank
the
emission
component
of
the
9
factors
to
be
considered
in
including
or
excluding
counties
in
a
given
area
as
contributing
to
nonattainment,
identifies
several
counties
other
than
Knox
as
significantly
contributing
to
nonattainment
in
the
Knox
County
area.
Tennessee
agrees
that
Anderson
and
Loudon
counties
have
a
significant
"
L
factor"
score.
However,
the
"
urban
excess"
contributions
should
be
further
discussed.
Blount
County
has
an
attaining
PM2.5
monitor
and
relatively
lower
emissions
than
either
Knox,
Anderson
or
Loudon
counties.
In
fact
the
reported
NOx
emissions
are
the
lowest
in
the
MSA
except
for
Sevier
County.
Carbon
and
nitrates
are
identified
as
significant
in
the
EPA
calculated
"
urban
excess"
for
the
Knoxville
region.
The
fact
that
nitrates
are
a
significant
component
of
the
"
urban
excess"
with
Blount
County
demonstrating
monitored
attainment
for
PM2.5
does
not
support
naming
Blount
county
nonattainment.
Tennessee
agrees
that
there
are
other
components
of
the
"
9"
factors
that
are
identified
as
significant
for
Blount
County
in
the
EPA
analysis.
However,
attainment
of
the
standard
is
the
true
test
for
significant
contribution.
Again,
Blount
County
has
measured
attainment
with
the
PM2.5
standard
and
should
be
given
due
credit
for
this.
4­
47
3.
The
following
control
measures
are
being
considered:
more
stringent
controls
for
open
burning,
a
NOx
RACT
rule
for
portions
of
West
Tennessee
and
for
the
Tennessee
Valley
connecting
Chattanooga
and
Knoxville.
Statewide
anti­
tampering
rules
for
vehicles
have
been
adopted
by
the
State
Air
Pollution
Control
Board
in
addition
to
a
vehicle
emission
testing
program
in
Hamilton
County.

4.
Tennessee
recommends
that
Marion,
Anderson,
Blount,
Loudon,
McMinn,
Roane
and
Sevier
be
classified
attainment
and
if
that
is
not
possible,
they
should
be
designated
as
unclassifiable.

5.
Tennessee
commits
to
examine
its
counties
in
accordance
with
PM2.5
SIP
requirements
and
further
commits
to
prepare
a
SIP
for
the
attainment
of
the
Federal
PM2.5
standards
in
accordance
with
Federal
guidance
and
regulations.
Sources
will
be
analyzed
and
if
additional
controls
are
needed,
they
will
be
imposed
in
order
to
achieve
the
PM2.5
standards
within
the
Federally
established
compliance
deadlines.

EPA
Response:
EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

In
a
February
12,
2004
letter,
the
State
recommended
that
Knox,
Roane,
and
McMinn
Counties
be
designated
nonattainment
based
on
2000­
2002
monitoring
data.
The
State
revised
its
recommendation
on
May
7,
2004,
to
recommend
that
McMinn
and
Roane
Counties
be
designated
attainment
due
to
2001­
2003
data.
Therefore,
the
State's
current
recommendation
for
the
Knoxville
MSA
PM2.5
nonattainment
area
only
includes
Knox
County
and
recommends
that
all
other
MSA
and
adjacent
counties
be
designated
attainment.
The
State
submitted
justification
for
this
recommendation.
Union
County
has
very
small
amounts
of
PM2.5
and
precursor
emissions,
indicating
no
contribution.
Therefore,
EPA
agrees
that
Union
County
should
be
designated
attainment/
unclassifiable.

Comment:
1013a­
45
Region:
4
State:
TN
Area:
Knoxville,
TN
Comment:
EPA
failed
to
include
Campbell
and
Union
Counties
(
both
part
of
the
Knoxville
CMSA)
in
its
recommended
nonattainment
area.
These
areas
must
be
included
as
part
of
the
nonattainment
area.

EPA
Response:
In
a
February
12,
2004
letter,
the
State
recommended
that
Knox,
Roane,
and
McMinn
Counties
be
designated
nonattainment
based
on
2000­
2002
monitoring
data.
The
State
revised
its
recommendation
on
May
7,
2004,
to
recommend
that
McMinn
and
Roane
Counties
be
designated
attainment
due
to
2001­
2003
data.
Therefore,
the
State's
current
recommendation
for
the
Knoxville
MSA
PM2.5
nonattainment
area
only
includes
Knox
County
and
recommends
that
all
other
MSA
and
adjacent
counties
be
designated
attainment.
The
State
submitted
justification
for
this
recommendation.
Union
County
has
4­
48
very
small
amounts
of
PM2.5
and
precursor
emissions,
indicating
no
contribution.
Therefore,
EPA
agrees
that
Union
County
should
be
designated
attainment/
unclassifiable.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

Comment:
1073­
2
Region:
4
State:
TN
Area:
Knoxville,
TN
Comment:
Knox
County
MSA:

1.
Encourages
EPA
to
include
Campbell
and
Union
Counties
although
neither
have
a
monitor.
In
order
to
base
the
designations
on
the
most
representative
data
available,
EPA
should
use
the
most
recent
(
2003)
OMB
metropolitan
boundary
lists
for
its
PM2.5
nonattainment
boundary
designations.
Using
the
most
recent
statistical
data
is
essential
in
order
to
reflect
accurately
current
populations
and
the
quantity
emissions
attributable
on
a
per
capita
basis.

2.
Supports
EPA's
inclusion
of
McMinn
and
Roane
Counties
in
their
entirety
in
the
Knox
County
MSA
nonattainment
area.
These
counties
are
home
to
major
sources
of
SO2.
She
would
not
support
a
partial
designation
of
these
counties.
Such
a
designation
would
be
inconsistent
with
EPA
guidance
and
would
create
jurisdictional
challenges.

3.
Supports
EPA's
inclusion
of
Anderson,
Blount,
Loudon,
and
Sevier
Counties
in
the
Knox
MSA
nonattainment
area.
Blount
County
has
a
design
value
of
14.4
µ
g/
m3
that
is
considered
by
many
to
be
unhealthy.
Loudon
County
monitor
has
incomplete
data,
but
the
data
available
showed
a
design
value
of
15.4
µ
g/
m3.
Sevier
and
Anderson
Counties
have
extremely
high
volumes
of
traffic
that
undoubtedly
contribute
to
air
pollution
in
the
area.

EPA
Response:
In
a
February
12,
2004
letter,
the
State
recommended
that
Knox,
Roane,
and
McMinn
Counties
be
designated
nonattainment
based
on
2000­
2002
monitoring
data.
The
State
revised
its
recommendation
on
May
7,
2004,
to
recommend
that
McMinn
and
Roane
Counties
be
designated
attainment
due
to
2001­
2003
data.
Therefore,
the
State's
current
recommendation
for
the
Knoxville
MSA
PM2.5
nonattainment
area
only
includes
Knox
County
and
recommends
that
all
other
MSA
and
adjacent
counties
be
designated
attainment.
The
State
submitted
justification
for
this
recommendation.
Union
County
has
very
small
amounts
of
PM2.5
and
precursor
emissions,
indicating
no
contribution.
Therefore,
EPA
agrees
that
Union
County
should
be
designated
attainment/
unclassifiable.
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.
4­
49
Comment:
1074­
1
Region:
4
State:
TN
Area:
Knoxville,
TN
Comment:
EPA's
9­
factor
analysis
for
the
Knoxville
area
does
not
support
including
McMinn
County.
Not
one
of
the
nine
factors
included
in
EPA's
justification
supports
designating
McMinn
County
as
nonattainment
for
PM2.5.
EPA
has
not
conducted
a
modeling
analysis
or
impact
studies
to
prove
McMinn
County
has
adverse
effects
on
the
Knox
County
MSA.
Any
designation
would
appear
unfounded
at
best.
McMinn
County
respectfully
objects
to
EPA's
designation
based
on
the
July
29,
2004
justification
and
requests
EPA
to
designate
McMinn
county
as
attainment
based
on
the
2001­
2003
design
value
of
14.6
µ
g/
m3
and
significant
opportunity
for
a
lower
design
value.

The
commenter
offers
the
following
comments
on
the
9­
factor
analysis
conducted
by
EPA.

1.
Factor
1
­
Emissions
In
the
case
of
the
Knoxville
MSA,
there
was
no
monitored
urban
excess
of
sulfate,
based
on
the
information
contained
in
the
EPA
supporting
spreadsheet
"
For
states­
PM2.5desigs­
urban
excess
data
061404.
XLS."
Therefore,
SO2
emissions
are
not
included
in
the
weighted
emission
scores
for
the
Knoxville
Area.
The
conclusion
that
McMinn
County
has
large
SO2
emissions
that
contribute
to
the
PM2.5
violations
in
Knoxville
is
not
supported
by
Factor
1.

The
weighted
emission
score
for
McMinn
County
NOx
emissions
is
4.4
out
of
a
total
emission
score
of
27.
Therefore,
the
McMinn
County
NOx
emissions
are
minor
and
cannot
justify
the
inclusion
that
large
NOx
emissions
from
McMinn
County
contribute
to
violations
in
Knoxville.

2.
Factor
2­
Air
Quality
The
2001­
2003
PM2.5
design
value
for
McMinn
County
is
14.6
µ
g/
m3
and
is
attaining
the
standard.
In
addition,
the
design
value
is
trending
downward.
Furthermore,
monitors
in
two
other
counties
also
attain
the
standard,
and
are
not
included
in
the
modified
nonattainment
recommendation
from
EPA.
Therefore,
the
conclusion
that
large
SO2
and
NOx
emissions
from
McMinn
County
are
contributing
to
violations
in
Knoxville
is
not
supported
by
Factor
2.

3.
Factor
3
 
Population
Density
The
population
and
population
density
in
a
number
of
surrounding
counties
is
similar
to
McMinn
County,
however
these
adjacent
counties
were
not
included
in
the
modified
nonattainment
recommendation
from
EPA.
Therefore,
the
conclusion
that
large
SO2
and
4­
50
NOx
emissions
from
McMinn
County
are
contributing
to
violations
in
Knoxville
is
not
supported
by
Factor
3.

4.
Factor
4­
Traffic
and
Commuting
Patterns
EPA
presented
the
2002
VMT
for
the
Knoxville
MSA
and
Roane
and
McMinn
counties.
EPA
did
not
present
the
VMT
from
some
other
adjacent
counties
that
are
contained
in
the
EPA
supporting
spreadsheet.
The
2002
VMT
in
several
counties
is
similar
to
McMinn
County;
however
these
adjacent
counties
were
not
included
in
the
modified
nonattainment
recommendation
from
EPA.
Therefore,
the
conclusion
that
large
SO2
and
NOx
emissions
from
McMinn
County
are
contributing
to
violations
in
Knoxville
is
not
supported
by
Factor
4.

5.
Factor
5
 
Expected
Growth
The
1990­
2000
population
growth
and
percent
population
growth
in
several
counties
is
similar
to
McMinn
County,
however
these
adjacent
counties
were
not
included
in
the
modified
nonattainment
recommendation
from
EPA.
Furthermore,
the
projected
2002­
2010
population
growth
for
McMinn
County
is
negative,
whereas
the
2002­
2010
projected
growth
in
a
number
of
other
counties
is
positive,
however,
these
adjacent
counties
were
not
included
in
the
recommendation
by
EPA.
Therefore,
the
conclusion
that
large
SO2
and
NOx
emissions
from
McMinn
County
are
contributing
to
violations
in
Knoxville
is
not
supported
by
Factor
5.

6.
Factor
6
­
Meteorology
In
Factor
6,
EPA
states
meteorology
did
not
play
a
significant
role
in
the
decision
making
process.
Therefore,
the
conclusion
that
large
SO2
and
NOx
emissions
from
McMinn
County
are
contributing
to
violations
in
Knoxville
is
not
supported
by
Factor
6.

7.
Factor
7
 
Geography/
Topography
In
Factor
7,
EPA
states
geography/
topography
did
not
play
a
significant
role
in
the
decision
making
process.
Therefore,
the
conclusion
that
large
SO2
and
NOx
emissions
from
McMinn
County
are
contributing
to
violations
in
Knoxville
is
not
supported
by
Factor
7.

8.
Factor
8
 
Jurisdictional
Boundaries
In
Factor
8,
EPA
states
jurisdictional
boundaries
did
not
play
a
significant
role
in
the
decision
making
process.
Therefore,
the
conclusion
that
large
SO2
and
NOx
from
McMinn
County
are
contributing
to
violations
in
Knoxville
is
not
supported
by
Factor
8.

9.
Factor
9­
Level
of
Control
of
Emission
Sources
4­
51
In
Factor
9,
EPA
states
level
of
control
of
emission
sources
did
not
play
a
significant
role
in
the
decision
making
process.
However,
EPA
did
not
consider
NOx
SIP
call
requirements
on
McMinn
County
NOx
sources.
EPA
also
did
not
consider
the
impact
of
the
NOx
SIP
call
emission
reductions
in
Factor
1.
Therefore,
the
conclusion
that
large
SO2
and
NOx
from
McMinn
County
are
contributing
to
violations
in
Knoxville
is
not
supported
by
Factor
9.

EPA
Response:
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

Comment:
1076­
1
Region:
4
State:
TN
Area:
Knoxville,
TN
Comment:
The
commenter,
representing
ThyssenKrupp
Waupaca,
Inc.,
a
facility
in
McMinn
County,
Tennessee
disagrees
with
EPA's
intended
designation
of
McMinn
County
as
nonattainment.
Waupaca
does
not
believe
that
McMinn
County
contributes
significantly
to
violations
of
the
PM2.5
NAAQS
in
the
Knoxville
MSA
and
should
not
be
designated
nonattainment
until
modeling
studies
show
that
McMinn
County
contributes
to
violations
of
the
standard.
If
McMinn
County
is
designated
nonattainment
for
PM2.5,
it
will
discourage
the
expansion
of
existing
facilities
or
relocation
of
new
facilities
to
McMinn
County,
which
will
deprive
the
county
of
economic
stimulation,
new
tax
income,
and
new
jobs.
A
nonattainment
designation
will
subject
the
county
to
transportation
conformity
requirements,
which
target
mobile
source
emission
issues.
In
addition,
mobile
sources
may
be
targeted
as
a
strategy
to
achieve
emission
reductions;
however,
EPA
has
provided
little
data
regarding
mobile
source
emissions
from
McMinn
County.
Also,
it
is
likely
that
fine
particle
emissions
due
to
mobile
sources
will
decrease
over
the
next
few
years
due
to
cleaner
fuels
and
cleaner
vehicles.
Existing
regulatory
programs
like
the
NOx
SIP
call,
the
NOx
RACT
requirements,
and
others
will
reduce
emissions
in
the
Knoxville
nonattainment
area
including
McMinn
County.
Because
Knoxville
area
emissions
in
McMinn
County
that
may
(
or
may
not)
contribute
to
Knoxville
PM2.5
violations
are
also
likely
to
decrease
in
the
next
few
years,
McMinn
County
should
not
be
designated
nonattainment.
Specific
comments
on
the
9
Factor
Analysis
are
as
follows.

1.
Factor
1
 
Emission
is
Areas
Potentially
Included
Vs.
Excluded
from
the
Nonattainment
Area
Waupaca
does
not
believe
that
EPA
has
proven
that
emissions
of
regulated
contaminants
in
McMinn
County­
at
whatever
levels­
contribute
to
PM2.5
violations
in
Knox
County.
Before
McMinn
County
is
designated
nonattainment,
modeling
should
be
undertaken
to
determine
if
emission
sources
contribute
to
Knoxville
PM2.5
violations.

2.
Factor
2
 
Air
Quality
in
Potentially
Included
Vs.
Excluded
Areas
4­
52
The
air
quality
in
McMinn
County
is
improving.
The
monitor
in
McMinn
County
is
attaining
and
the
design
value
and
monitor
value
are
trending
downward.
Knoxville
MSA
numbers
are
also
trending
downward.
Based
on
this
factor,
McMinn
County
should
be
excluded
from
the
Knoxville
MSA
nonattainment
area.

3.
Factor
3
 
Population
Density
and
Degree
Urbanization
McMinn
County
has
one
of
the
lowest
projected
growth
rates
from
2000
 
2025
of
any
of
the
counties
in
or
adjacent
to
the
Knoxville
MSA.
McMinn
County
is
not
urbanized.
Based
on
McMinn
County's
low
population
density,
low
degree
of
urbanization,
and
limited
commercial
development,
this
factor
weighs
against
inclusion
of
McMinn
County
in
the
PM2.5
nonattainment
area.

4.
Factor
4­
Traffic
and
Commuting
patterns
Waupaca
does
not
believe
the
information
provided
by
EPA
in
its
9­
Facotr
Analysis
for
the
fourth
factor
supports
EPA's
proposal
to
designate
McMinn
County
nonattainment.
EPA
fails
to
provide
the
number
of
McMinn
County
commuters
who
travel
to
Knox
County
and
does
not
discuss
what
percentage
of
McMinn
County's
VMT
are
traveled
on
I­
75
by
cars
not
registered
in
McMinn
County.

5.
Factor
5
 
Expected
Growth
With
the
exception
of
Anderson
County,
McMinn
County's
projected
twenty­
five
year
growth
rate
of
19.6%
is
the
lowest
of
the
ten
counties
either
contained
in
the
Knoxville
MSA,
designated
nonattainment
for
ozone,
or
proposed
as
nonattainment
by
EPA
for
PM2.5.

6.
Factor
6­
Meteorology
Waupaca
urges
EPA
to
accept
Tennessee
DEC's
suggestion
to
designate
McMinn
County
attainment,
yet
monitor
portions
of
the
county
to
determine
contribution.
EPA
has
cited
no
meteorological
factors
that
support
its
recommendation
to
designate
McMinn
County
nonattainment.

7.
Factor
7­
Geography/
Topography
EPA
shouldn't
ignore
the
dominant
geographic
features,
the
Great
Smoky
Mountains
and
the
Tennessee
Valley,
when
analyzing
the
impact
of
emissions
from
McMinn
County
on
the
Knoxville
MSA.

8.
Factor
8­
Jurisdictional
boundaries
McMinn
County
is
not
within
the
Knoxville
MSA.
Designating
Knox
County
alone
as
nonattainment
may
be
sufficient
to
address
Knoxville's
PM2.5
nonattainment
issues,
and
at
most,
only
the
Knoxville
MSA
or
CMSA
counties
should
be
designated.
Therefore
the
4­
53
burden
is
on
EPA
to
show
that
McMinn
County
contributes
to
Knoxville's
PM2.5
nonattainment.

9.
Factor
9­
Level
of
Control
of
Emission
Sources
EPA
should
consider
the
level
of
control
of
current
and
future
air
emission
sources
in
McMinn
County.
The
NOx
SIP
call
and
NOx
RACT
requirements
will
lead
to
further
reductions
in
PM2.5
emissions.
Also,
the
Waupaca
facility
has
recently
installed
state­
ofthe
art
BACT
emission
controls.

EPA
Response:
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.

Comment:
1075­
1
Region:
4
State:
TN
Area:
Knoxville,
TN
Comment:
The
commenter
believes
that
EPA's
analysis
of
Factor
1
for
McMinn
County
is
flawed
because
it
is
based
on
2001
emissions
that
are
much
greater
than
actual
McMinn
County
2001
emissions.
Bowater
has
reviewed
the
point
source
emissions
for
McMinn
County
that
were
used
by
EPA.
It
has
identified
seven
sources
at
the
Bowater
facility
whose
2001
actual
emissions
are
much
less
than
those
listed
in
the
National
Emission
Inventory
used
by
EPA.
Bowater
notes
that
the
McMinn
County
2001
emissions
included
in
Factor
1
are
not
representative
because
the
Bowater
2001
actual
emissions
are
overstated.
Bowater
then
recalculated
the
weighted
emissions
scores
for
each
county.
The
commenter
notes
that
the
Bowater
facility
has
recently
installed
low
NOx
burners
on
two
power
boilers
at
the
facility
to
comply
with
the
NOx
SIP
Call.
These
burners
will
reduce
NOx
emissions
by
approximately
900
additional
tons
per
year.
Therefore,
based
on
the
corrected
2001
actual
emissions
and
the
further
reductions
at
the
Bowater
facility,
the
commenter
requests
that
EPA
revise
its
proposed
designation
accordingly.

EPA
Response:
Please
refer
to
the
TSD
which
explains
EPA's
decisions
on
the
States'
recommendations.
